1996 T No . 127.

I, MELANIE PARKER, an unemployed systems analyst, of Bubble Brook Camp, Great Penn Wood,

Hampshire, DO SOLEMNLY , SINCERELY AND TRULY DECLARE AND AFFIRM as follows:-

1. I have been living at Bubble Brook Camp since 19th January 1996, when it was established.

My reason for being at this particular site is the presence of a unique chalk-stream and various rare and

endangered species, especially dormice. At the time I informed the Treasury Solicitor of our occupation

and sent hand-drawn maps and Ordnance Survey coordinates clearly defining the boundaries of the area

we were claiming possession of. This letter is exhibited as Exhibit "MP1".

2. On Wednesday 24th January, I was woken by the sound of an S.O.S. The only two people

resdiding on ground level premises - myself and Karl Gannon - were confronted by the sight of hundreds

of security guards running towards our clearly-marked perimeter fence. These guards are employed by

Reliance Security to allow preliminary clearance work to take place. The said fence was labelled with

notices explaining section 12 of the Criminal Law Act 1977; I stood next to it and quoted the relevant

sections to the guards. Despite this, they broke through the fence in a most aggressive and intimidating

manner and proceeded to physically assault me and throw me in a ditch. Karl was punched in the face

and elbowed in the ribs by one of the guards and thrown into the chalk-stream, in the process sustaining

visible injuries. At this time there were no legal observers or police officers in attendance. They formed a

cordon across and around the camp. In the meantime we had both run back into the camp to prevent our

property being damaged and what seemed to be an illegal eviction from taking place. I called for a police

officer and spoke first to Sgt Shepherd of Thames Valley Police ( Banbury), pointing out the breaches in

law to him. Two ground level premises were then torn down and illegally removed. Trees and

undergrowth were then removed in dangerous proximity to the occupant of a tree house who was clinging

to a walkway, thus placing her in a position of great danger and in breach of Health and Safety regulations

governing the use of chainsaws. I then spoke to Sgt Maughan and asked to speak to a senior police

officer. Subsequently I, and Carl Gannon, had a ,taped, conversation with Chief Inspector Webb of

Thames Valley Police, Newbury, on a number of legal matters including the assaults. We submit Exhibit

"MP2", the statements of legal observers, to support this.

3. A number of different camps have been established over a period of time in the Penn Woods -

these are commonly known as Birthday Party; Seaside; Bubble Brook; Manic-sha; Heartbreak Hotel;

Horse-shoe and Little Lhasa. I am personally not aware of the dates these other camps were established.

On 29th January the camp known as Little Lhasa, defined by a clearly-marked perimeter fence (to which

was affixed a sizeable number of the document exhibited as Exhibit "MP3") and registered with the

Treasury Solicitor, was entered by a large number of security, who formed a double cordon around the

camp. The 'kitchen bender' was unlawfully removed while the occupants of the other premises ( ground-

level 'benders') were ordered to remain inside those premises, or they would be removed from the area,

while tree-felling work continued around them, with no regard for health and safety practice. Every single

tree and bush was felled, leaving the occupiers with no clear access route to and from the camp. There is

a civil case underway with regard to this incident.

4. For the last two weeks, the contractors have been regularly coming into Penn Wood and working

on 'land clearance' and tree-felling around the camps. The usual tactic employed has been for over 500

security guards to form a cordon around the area to be 'cleared' and then continuing their work.

Anyone who attempts to cross the cordon is threatened with arrest under section 68 of the Criminal

Justice and Public Order Act ( ie. 'Aggravated Trespass'). There are now very few trees left outside the

camps, thus rendering absurd the suggestion made in Paul John Selby's first affidavit that if the protestors

are evicted from their current camps they will simply move onto this land. The guards commonly spend

their entire working day - this can be for continuous periods of up to nine hours at a time - on the land; in

some places 'portaloos' have been erected for their convenience. Their midday meal is delivered to the

site. A new practice emerged during the week commencing 19th February whereby bulldozers piled

trees and undergrowth to a height of 30 feet and set fire to it. These fires were at a distance of less than 20

feet from the boundary of the nearest camp, known as 'Horseshoe camp', with the wind on that day

blowing in the direction of the camp. This resulted in large quantities of embers, fumes and smoke being

blown into the camp. The occupants were then prevented from leaving their camp. The criminal damage

to many of the ground-level dwellings, in addition to the hospital treatment necessary for many of the

occupants, is now the subject of a civil case. Exhibit "MP4" is a collection of photographic and other

evidence showing these practices. Large areas of the land being disputed are clearly not in the sole

occupation of the protestors.

5. On the morning of 22nd February 1996 a group of Reliance Security employees entered Bubble

Brook camp at pre-dawn dressed in camouflage clothing and proceeded to criminally damage property,

cut walkways and conceal their cutting, and cut abseil lines, thereby endangering the lives of the

occupants of the tree dwellings. An assault charge is also pending as is a civil case. We produce Exhibit

"MP5", an official press release. .

6. With reference to Exhibit "ACW01" and cross-referencing with "ACW02" of Case 1996 T

No.128, which is produced as Exhibit "MP6" and the subject of a hearing in front of Master Prebble on

the 26th April 1996, we have several points about the correctness of said documents and their effect on the

validity of the order for possession and application for such.

7. Occupants of the camp known as Birthday camp, which has not been included in the application

for an order of possession, have not had the opportunity to be heard in the court proceedings. We produce

Exhibit "MP7" to support the legal registration, boundaries and existance of said camp.

8. With reference to exhibits "PJS2" and "PJS3", we dispute many of the facts stated therein and

would therefore suggest that this further substantiate our argument that all camps are entirely separate

entities, logically, legally and physically and have been treated as such throughout the period of their

existance with the sole exception of the application for possession which has been submitted to the High

Courts, without the benefit of correct service and statement of facts to support said application.

9. With regard to 2(g) of Exhibit "ACW02" which refers to the 'mitigation of adverse effects .....will

have on their surroundings', no supporting documentation has been produced with this. Additionally, the

duty of care that regional government and central government are bound by has not been considered and

as the residents of ,and visitors to, many of the individual camps consist of local residents we propose that

the Ministry of Transport's possession of the land applied for is invalidated.