+Slater Gordon Lawyers

26 May 2016

PRIVATE AND CONFIDENTIAL The Editor Crocels News, LLC Ty Morgannwg PO Box674 Swansea SA19NN

And by email: info@crocels.info

Dear Sirs

Our Client: Constable Stuart Mann

50-52 Chancery Lane London WC2A 1HL DX 202 London Chancery Lane

Tel: 020 7657 1555 Fax: 020 7657 1557

www.slatergordon.co. uk

Your Contact: Angus Young Assistant: Karen Woolford

Direct Tel: 020 76571425 Direcl Fax: 020 76571420

Email: AJYoung@slatergordon.co.uk

Our Ref: AY001/UM1284779

NOT FOR PUBLICATION

We represent Constable Stuart Mann, of Dyfed Powys Police. Our client has consulted us in respect of defamatory articles published on the Crocels News website .

Publications complained of

On 27 June 2015 the Crocels News website published an article by Jonathan Bishop entitled Llanelli police officers deny assault and, on 16 November 2015, published an article by the same author entitled Police brutality victim in hunger strike. These articles are available here:

http://news .crocels.com/news/7177 /complaint-pc-stuart-mann -ps-mike-thomas-Jyn-carter/

http://news.crocels .com/news/7821 /yolande-rees-hopkins-hunqer-strike-aqainst-pc-stuart-man n/

Meaning

The 27 June 2015 article, Llanelli police officers deny assault, contains the following two paragraphs:

It is believed that the PC Stuart Mann and PS Mike Thomas acted inappropriately in how they approached and handled Mr Edwards. Mobile phone evidence was said to have recorded PC Stuart Mann telling Edwards to "f**king wank over your Bible ." It is understood that PC Stuart Mann then told Edwards that he had contacted his mother without his consent and that he should be "ashamed" of himself. Mr Edwards's mother is known to the police.

It is further believed that PS Mike Thomas told Mr Edwards that he would make his life 'hell." Both Officers are believed to have battered Edwards at the police station, stripping him naked and giving him a black eye. Both police officers are refusing to take responsibility for these reported actions .

Stater and Gordon (UK) LLP is a Limited Liability Partne~hip re9istered in England and Wates (OC371153). R•gist•red office : 50/52 Chancery Lane, London WC2A IHL. Slater and Gordon (UK) LLPi, authorised and regulated by the Solicito~ Regulation Authority; and authorised and regulated by the financial Conduct Authority for insurance mediation activity

The natural and ordinary meaning of these words is that our client is guilty of stripping and assaulting Mr Edwards as well as seriously unprofessional conduct, rudeness and intolerance, particularly in telling Mr Edwards to "f**king wank over [his] Bible".

Clearly the allegation of assault is by far the most serious but, in placing this allegation in the context of the other allegations the article as a whole alleges that our client is a corrupt policeman. Such a meaning also implies that he is unfit to be a police officer, and that he should be prosecuted for committing criminal offences.

The 16 November 2015 article Police brutality victim in hunger strike victory contains the following paragraph:

A woman who fell victim to the attacks of a rogue police officer has had hope of a reprieve after her MP, Nia Griffiths, took up her case after she collapsed due to taking part in a hunger strike.

Your article later identifies our client as the 'rogue' police officer mentioned.

This is a clear and unequivocal allegation that our client is guilty of attacking a woman and police brutality. In the following paragraph of your article the author underlines this allegation stating that:

Yolande Rees-Hopkins is believed to be one of a number of people subject to violence from Dyfed-Powys police officer, PC Stuart Mann 553.

The natural and ordinary meaning of this article is that our client is guilty of using unjustified violence against a number of people including Ms Rees Hopkins. As with the earlier article such a meaning also infers that he is unfit to be a police officer, and that he should be prosecuted for committing criminal offences .

Our client's position

The 27 June 2015 article refers to Graham Edwards. Mr Edwards was arrested by our client on 25 October 2013 for assaulting one Dr Lyn Carter at a medical centre in Carmarthen. When arrested he also assaulted Police Sergeant Mike Thomas . He was charged with both offences, tried, convicted and sentenced to ten weeks imprisonment. His conviction was upheld on appeal.

The 16 November 2015 article refers to Yolande Rees-Hopkins. Ms Rees-Hopkins was arrested on 21 September 2011 by Police Constable Geris Davies for assaulting a paramedic during an incident during which Ms Rees-Hopkins was reported missing by her husband. She was later found at a neighbour's house and paramedics attended as she was suspected of having taken an overdose. Our client was present with PC Davies when Ms Rees-Hopkins kicked and assaulted the paramedic and following the arrest he provided a witness account. Ms Rees­Hopkins was initially charged but the CPS withdrew the proceedings after Ms Rees-Hopkins claimed she was mentally ill.

Following these incidents our client was made aware that both of these individuals made blanket complaints to the Dyfed Powys Police Professional Standards Department ("PSD") about all of the officers and staff involved in the arrests. The PSD found in September of 2013 that our client had no case to answer in respect of the allegat ions made by Ms Rees Hopkins and, in April of 2015, they found he had no case to answer in respect of the allegations made by Mr Edwards .

Our client did not assault either Mr Edwards or Ms Rees Yolande. His contact with both of these individuals was minimal and throughout his contact with them our client conducted himself with complete professionalism. It follows that it is untrue that our client is unfit to be a police officer or that he should be prosecuted.

These allegations are untrue, they are defamatory and they have caused serious harm to our client's reputation.

The circumstances of publication

Your journalist has demonstrably made no effort whatsoever to confirm these stories. In respect of each article he has clearly relied entirely on a single, second-hand and wholly unreliable source. Given that the sources had an axe to grind, seeking some kind of independent confirmation should be the first and most basic step a responsible journalist would take.

Similarly no-one at Crocels News sought comment or explanation from our client. These are hugely serious allegations made entirely without substance or foundation and you did not give our client an opportunity to respond before publishing them. Crocels News have made no effort whatsoever to provide balance or outline our client's position.

Equally Crocels News did not contact the Dyfed Powys PSD for comment; they concluded their investigations into the incidents complained of some considerable time prior to your publications and would have informed your journalist of these conclusions.

Next Steps

You have made serious and unfounded allegations and our client cannot allow them to lie on the record. You should be under no illusions that our client is determined to restore his reputation.

Your website states that [w]e are committed to creating a better educated world, where people have information that is fair, balanced and accurate. In light of this sentiment and having considered the content of this Jetter, we trust that you will wish to resolve our client's complaint swiftly and amicably.

If so, your proposals to do so should include the following terms:

1. the removal of the offending articles; 2. the removal of related articles, tweets, facebook posts and any other relevant

publications; 3. a formal apology to our client, in terms to be agreed by us, to be prominently published

on the Crocels News website; 4. an undertaking not to repeat the same or similar allegations in the future; and 5. payment of our client's legal costs.

Our client's attitude to his additional entitlement to damages will be informed by the speed, tone and content of your response.

All our client's rights are reserved in this matter and should you fail to meet the requirements set out above our client will not hesitate to take such action as he sees fit to protect and vindicate his reputation including, if necessary, pursuing formal proceedings in libel.

We await hearing from you as a matter of urgency and in any event not later than 4:00pm on 9 June 2016.

Yours aithfully

Slater and Gordon