DOMINIC BELL
Misconduct in Public Office
That
Dominic Bell, a criminal barrister of One Inner Temple Lane (and formerly of
Charter Chambers), on dates between 01 January 2009 and 25 September 2013,
wilfully neglected to perform his duty and wilfully misconducted himself to
such a degree as to amount to an abuse of the public’s trust in the office
holder without reasonable excuse or justification.
Perverting the Course of Justice
That
Dominic Bell, a criminal barrister of One Inner Temple Lane Chambers (and
formerly of Charter Chambers), on dates between 01 January 2009 and 25
September 2013, with intent to pervert the course of public justice, did a
series of acts which had a tendency to pervert the course of public justice in
that he:
1
deliberately
ensured that a Client would be found guilty of a crime he knew his client not
to have committed, according to the Law
2
wilfully
failed to call a Witness as to Fact [Geoffrey Bacon] in a criminal trial
3
wilfully
failed to call Warwick Brown [IT Manager of Faceparty] to a criminal trial when
he knew that Mr Brown’s testimony would exonerate his Client
4
conspired
with others to collapse a trial at Woolwich Crown Court in February 2009
5
provided
false information to his Client, Brian Pead
6
conspired
with others to harass Brian Pead
7
harassed
Brian Pead between January 2009 and August 2013
8
failed to
adduce more than 125 exhibits to a criminal trial
9
misled his
Client when producing a Defence Statement of less than half a page for two
criminal trials
10
failed to report
perjury to the trial judge
11
was late
every day to the Trial and was reprimanded by the Judge for lateness
12
was guilty of
a lack of thorough preparation for the Trial
13
produced a
simple two paragraph Defence Statement and this was ridiculed by the Judge as
“…the worst Defence Statement I have ever seen…”
14
refused to
take into account the various research materials the Defendant had produced and
collated
15
refused to
apply for a delay in the Trial date, despite the Defendant informing him that
he was under orders from his doctor not to attend Trial because he was not
ready for a trial and was on two separate forms of medicine which militated
against him being fully prepared for Trial
16
refused to
act on the Defendant’s complaints that Counsel was woefully under-prepared for
Trial
17
failed to
enter into Court a significant volume of evidence [more than 125 exhibits] which
was vital to the Defendant’s case
18
failed to
cross-examine Crown Witnesses with the necessary level of skill and robustness
indicated by the Bar Standards Council
19
failed to
question the Defence Witnesses to extract the most information out of them
20
failed to
report allegations of demonstrable Perjury by police officers and Nicola Noone,
a witness for the Crown
21
failed to
report Gross Prosecutorial Misbehaviour, despite being informed of this in
writing and verbally by the Defendant, and by a previous counsel
working on the case prior to the new counsel’s appointment
22
failed to call
an important Witness As To Fact: this Witness As To Fact [Geoffrey Bacon] was
present when the Defendant sent an Instant Message to the ‘girl’ stating that
he was a fake
23
failed to
ensure that a significant volume of character statements from friends, colleagues
and neighbours were signed and ready to enter into Court as important evidence
24
failed to
address significant problems of a lack of Full Disclosure by the Crown and the
Police
25
failed to
challenge the authenticity of two search warrants
26
failed to challenge
the existence of a third search warrant
27
failed to
report the illegal disposal of vital evidence by the CPS, the Police and a
Crown Witness
28
failed to adduce
the Defendant’s beating by four police officers just months before the Trial
and how they had searched his documents bag looking for evidence of the
Defendant’s research into illegal Police online activities
29
failed to
thoroughly read evidence supplied to him by the Defendant in his Defence
30
worked alone
and failed to be supported in Court by the Defendant’s solicitor, save for one
brief period of two hours (in an 8 day trial)
31
failed to
report demonstrable police entrapment : police as Agents Provocateurs
32
failed to
request reporting restrictions
33
failed to
meet daily with his client for briefings during the Trial process
34
worked on too
many cases simultaneously and failed to devote enough care and attention to the
Defendant’s case
35 failed to report that a police informer was known to
be supplying the police with deliberately
false information
36
failed to organise
the Defence witnesses: did not write to them, but left it to the Defendant to
contact them and ask them to attend Court
37
failed to
have questions prepared for a Witness for the Crown, and instead got the Defendant to prepare the questions and email them to Counsel the night before the
Witness took the stand failed to ask the vital questions of this Witness
that would have highlighted Perjury to the Judge and Jury
38
failed to
point out to the Jury that a key Police statement was written one year after
the Defendant’s arrest, and one year after the Defendant had made his
own statement
39
failed to
point out to the Jury that this Police statement differed greatly from the
original Police statement made one year previously
40
failed to
report Police perjury regarding the website to the attention of the Judge and Jury,
despite having evidence of perjury
41
failed to
apply for Full Disclosure, especially disclosure which would have proved the
Defendant’s innocence beyond doubt
42
failed in his
Duty of Care to the Defendant by not providing more than a basic two-page argument
against Joinder on the second occasion that the Crown applied for Joinder
43
failed to
report the Bexleyheath Police for failing to investigate an allegation and relying only on the testimony of three
females of known dubious repute
44
failed to
elicit a statement from the fourth
female in the house, who refused to make a statement to the police
45
failed to
subpoena this potential Witness, as she clearly had an important bearing on
Indictment One
46 failed to communicate with the Defendant regarding
photographs in Indictment One, and therefore entered the wrong photographs into Court
47
despite
possessing knowledge and evidence to the contrary, failed to report Police
misbehaviour (breaches of PACE) on a number of counts
48
failed to
point out to the Judge and Jury that the three female witnesses in Indictment
One did not make their statements until two weeks after their allegations
so that the Police could manipulate this information and join it to the
investigation by the Paedophile Unit
49
failed to
enter into Court all the evidence which the Defendant had gathered about
illegal Police activities online –
despite having knowledge of its existence
50
despite
having evidence to the contrary, allowed false evidence to be entered
into Court by the Police and Crown
51
despite
having evidence to the contrary, failed to apply to the Crown and the Police
for the correct evidence to be brought into Court
52
failed to
apply for the Trial to be halted despite knowing that the wrong evidence
was in Court
53
stated openly
in Court that “…I am not going to bother trawling through all the DVDs
[provided by the Police]…” despite being informed by the Defendant that this
was a necessary undertaking because improper evidence had been entered into Court
by the Police, i.e. the wrong DVDs
were entered into Court and the Judge and Jury seriously misled
54
allowed the
Crown’s witnesses (including the Police) to answer questions with “I don’t know”
or “I can’t be sure” or “I can’t remember” and did not continue with his
questioning, but allowed a lack of clarity to permeate the Trial
55
failed to ask
the Police what they did to investigate the fact that the Defendant used false
mobile numbers when ‘communicating’ with the alleged ‘girl’
56
despite the
Police stating on oath that they knew the numbers to be false, failed to
cross-examine why they had brought this case to Court if they knew that
the numbers were false and thus no charge of Incitement could hold up, since
no-one with the intention of meeting with someone else would provide false
mobile numbers
57
failed to
request a copy of the website’s servers, which was necessary for a fair Trial
58
failed to
request a copy of the Defendant’s computer hard drive at work which would have
established the Defendant’s claim of innocence and provided a fair Trial
59
failed to
establish as a fact that the Defendant had been researching into Child Sexual
Abuse partly because he had been asked by his Line Manager to teach his work
colleagues during Staff Training failed to subpoena this Line Manager as a
Witness and bring him into court to establish this important fact
60 failed to challenge the Crown’s statement that this
Staff Training in Child Sexual Abuse did not take place, despite being shown considerable evidence to
the contrary
61
failed to
challenge the demonstrable fact that a Crown witness committed Perjury
62
failed to act
when informed by the Defendant that his computer at work had been illegally
tampered with
63
failed to act
when informed by the Defendant that his research materials at work had been
removed from the office servers
64
continued to
represent the Defendant after being removed from the case during the trial
65
was guilty of
over-confidence by repeatedly informing the Defendant that “…this is an easy
case to win…”
66
was guilty of
false representation to the Defendant by stating each day that “…We are in good
shape…” when, even to the Defendant’s untrained eye, it was obvious that this
was not the case
67
stated during
the Trial that “…We need more information to win this case…” despite being
given a wealth of evidence prior to the Trial by the Defendant to
support his claim of innocence – this evidence went unread and unused
68
failed to
write several letters requesting information from various sources (including
the Police and the Crown), despite stating in conferences in his office that he
would write these letters
69
failed to
inform Scotland Yard’s Professional Standards Unit that evidence in this case
had been tampered with, despite possessing knowledge that it had been tampered
with
70
failed to
adduce examples of evidence tampering into Court
71
was rebuked
by Judge on 3 separate occasions for continued lateness, for a lack of
submission of Defence Statement on time, and for a poor Defence Statement (only
two lines)
72
failed to
procure the Defendant’s medical records to postpone the Trial until the
Defendant was medically fit to stand Trial
73
used
prejudicial language against his own client during Closing Remarks
74
wrongly
advised the Defendant to withhold evidence (which the Defendant and supporters
believed to be crucial evidence in his favour)
75
failed to
provide a copy of the Crown’s Joinder argument to his Client, for consideration by his Client
76
failed to
provide a copy of Defence counsel’s argument against Joinder for his Client to
consider
77
made a threat
to his own client – the Defendant – that “...If you continue to keep saying
you’re innocent, the Judge will jail you…”
78
has
deliberately misled the Registrar in the Appeals Court – by making claims as if
they were facts, despite compelling evidence to the contrary
79
failed to
provide his client with a Trial Bundle
80
failed to
bring to the Court’s attention that the Jury was not sworn in
81
failed to
contest the Judge’s duress towards the Jury
82
failed to
bring to the Court’s attention that there was a significant breach of his
Client’s Article 6 rights in that the case took 23 months to come to court,
despite it not being a complex case
Blackmail
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 01 June 2013 and 31 July 2013, did attempt
to blackmail Brian Pead with a view to gain for himself in a series of
telephone calls made, and emails sent, to his former Client.
Harassment
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 01 January 2009 and 25 September 2013, did
pursue a course of conduct amounting to the harassment of Brian Pead and did
cause him and his daughter and grand-children alarm and distress contrary to
the Protection from Harassment Act 1997 and that in June and July 2013, he did
pursue a course of conduct by making a series of telephone calls and sending a
series of emails which amounted to a course of conduct.
Fraud by failing to disclose
information
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 15 November 2006 and 25 September 2013, did
commit fraud by deliberately failing to disclose documents to Brian Pead, to
the police, to a Crown Court, and that he failed to report child grooming,
racism, bullying, assault, false imprisonment, theft, and breaches of the
Computer Misuse Act 1990, contrary to the Fraud Act 2006.
Fraud by abuse of position
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 01 January 2009 and 25 September 2013, did
abuse his position as a Barrister and Officer of the Court in that he (and
others) perpetrated a series of crimes and human rights abuses against Brian
Pead during a corrupt trial at Southwark Crown Court in December 2009 and
pursued a course of conduct amounting to the harassment of Brian Pead which he
knew, or ought to have known, would cause him and his daughter and
grand-children alarm and distress, contrary to the Fraud Act 2006, the
Protection from Harassment Act 1997 and the Human Rights Act 1998.
Fraud by false representation
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 01 January 2009 and 25 September 2013, did
make false representations and provide false documents to the Courts in
relation to Brian Pead, contrary to the Fraud Act 2006.
Breaches of Computer Misuse Act 1990
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 01 January 2009 and 25 September 2013, failed
to report the modification of the contents of a computer used by Brian Pead by
others in that they removed the contents of that computer’s hard drive, upon
which were documents necessary for a bona
fide investigation and trial to take place contrary to section 3(1a) of the
Computer Misuse Act 1990 and Article 6 of the Human Rights Act 1998.
Misuse of Public Funds
Dominic
Bell, a criminal barrister of One Inner Temple Lane Chambers (and formerly of
Charter Chambers), on days between 01 January 2009 and 25 September 2013, did
misuse public funds in perpetrating crimes and human rights abuses against
Brian Pead and in allowing crimes to be perpetrated against Brian Pead. He
extracted monies from the public purse in the form of Legal Aid and
misappropriated those funds by running a defence which he knew to be contrary
to law and in allowing others to participate in an unlawful trial and the
cover-up of significant crimes.
