Susan Jones

Year of Call: 2011
Email Address: susan.jones@3pb.co.uk
Secure Email: susan.jones@3paper.cjsm.net
Telephone: 01962 868 884

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Public and Regulatory

Susan has experience of appearing before a variety of public law and regulatory forums.

Licensing

In 2016 Susan appeared for a Local Authority in a long running case involving an appeal against refusal to renew a license under the Animal Boarding Establishments Act 1963. The licence being necessary for carrying on a business of providing accommodation at premises, including a dwelling, for other peoples cats and dogs.

Susan is regularly instructed to appear in taxi licensing appeals and will consider acting on a direct access basis.

In 2016 Susan appeared for a local authority in a number of appeals against revocation of Hackney Carriage Licences with immediate effect under the Local Government (Miscellaneous Provisions) Act 1976, when drivers breached a Traffic Regulation Order by a pedestrianised areas.

In 2017 Susan represented a Licensing Authority in a taxi licensing appeal in which the license holder was accused and acquitted of rape. Upon learning of the allegation the Licensing Authority revoked the driver’s license with immediate effect in the interests of public safety. During the course of the licensing appeal, Susan highlighted the burden of proof depends on the nature of proceedings and the purpose of criminal and licensing proceedings are very different. Susan relied on a transcript of the complainant’s ABE interview, the driver’s PACE police interview and Crown Court Transcript when questioning the officer in the case and the driver. The driver’s appeal was refused.

Susan has appeared before a taxi and private hire licensing sub-committee on behalf of a taxi conglomerate for consideration of fitness of two directors to continue holding Private Hire Operator Licences. This involved issues of natural justice and responding to a report from the Head of Transportation Services.

Before the Traffic Commission, Susan represented four Lorry companies in a multi day, multi issue inquiry arising from five reports concerning professional competence, good repute, satisfaction of fundamental licensing requirements and financial standing. The case involved a history of receipt of a large number of PG9’s including some serious roadworthiness prohibitions. Concerns were raised relating to third party trailers, inadequately of checks, driver failings and issues surrounding nominated Transport Managers. The licences of each company had previously been suspended due to failure to provide evidence of appropriate financial standing. Susan ensured the financial suspension was lifted on the first day of the inquiry. Following the evidence and submissions, all parties received Formal Warnings.

Susan has represented Duty Premises Supervisors before licensing sub-commitees and appeared in review hearings and applications for extension of opening hours. She has also represented publicans in criminal sentencing hearings involving consideration of suspension of their personal licence under the Licensing Act 2003.

Inquests

Susan has experience dealing with cases in which the determination of the cause of death are complex and involve the assessment of factual evidence and the opinions of a number of experts.

Susan has experience with inquests involving:

  • Prison death
  • Care homes death
  • Complications in cardiology and urology procedures
  • Hospital deaths
  • Emergency Services attendance
  • Neonatal deaths
  • Sudden Infant Death
  • Suicides
  • Sudden deaths
  • Article 2 inquests
  • Jury inquests
  • Multi day inquests

Susan completed a 7 month secondment in the inquest team at Capsticks solicitors during which she prepared cases from receipt of initial instructions and appeared as the advocate at the inquest. Susan continues to build on this area of work.

Recent Inquests:

Hospital Deaths
Baby D: Susan represented an NHS Trust in an inquest concerning a neonatal death with alleged antenatal and neonatal failings surrounding Haemolytic Disease of the New Born. Although the coroner was critical of care provided by the Trust, no causative failings were established.

Susan represented a family in a two day inquest following the death of a woman with placenta accrete who died post emergency caesarean section as a result of torrential haemorrhage. This inquest involved extensive obstetric evidence from clinicians, an independent obstetrics expert and a pathologist with an interest in maternal death. Evidence considered antenatal reviews, timing of the caesarean section, surgical entry and postoperative care. The coroner made neglect findings.

Re LM-B: Susan appeared on behalf of a Trust providing psychiatric care to a patient who collapsed in the street. Prior to the inquest Susan drafted instructions and questions for a toxicology expert to advise on post mortem redistribution and other factors affecting post mortem blood concentrations of anti psychic drugs and anti-depressant (clozapin and venflaxin), that according to the post mortem were present after death at toxic and fatal levels. At the inquest Susan questioned the pathologist and expert witness. The coroner returned a natural causes conclusion.

Re CMcL: inquest into the death of a member of hospital staff arising out of a rare but recognised complication during an elective investigatory angiogram. Live evidence was heard from consultant pathologist, consultant cardiologist and registrar.

Re JP: this inquest involving attendance by emergency services and delays at the scene whilst awaiting a bariatric ambulance. Questions were raised about the time taken for the ambulance service to transfer JP to hospital.

Prison Deaths
Re AH: 7 day jury inquest into the death of a prisoner who received a drugs package into HMP Pentonville, on which he subsequently choked. This inquiry included investigation into prisoner restraint.

Care Home Deaths
Re DB: 4 day inquest into the death of a dementia resident who whilst in care was struck in the face by another dementia resident. This inquest involved examination of medical records of a living person to determine if there were any missed opportunities to protect others. Susan advised on disclosure of the records of a living person who lacked capacity and made submissions to the coroner in respect of disclosure.

Re NMcL: 5 day inquest into the death of an elderly care home resident suffering with dementia after falling from a chair and sustaining a fractured neck of femur. This matter went part heard at which point Susan succeed in getting her client’s status demoted to an interested person on the basis of “sufficient interest” only.

Local Authority Deaths
Baby C: Susan represented social services in an inquest touching the death of a 3 week old baby. The inquest explored co-sleeping and whether the actions of social services and other agencies were appropriate. In evidence Susan explored the rationale behind the approach taken by social services and the frequency of their interactions with other agencies. A conclusion of Sudden Unexpected Death in Infancy (co-sleeping) was returned and in respect of prevention of further death reports, the coroner indicated that the evidence clarified the multi-agency approach was appropriate and a report was not necessary.

Susan appeared for a Local Authority in an inquests concerning drowning on a beach. The inquest explored adequacy of signage and personal rescue equipment and whether these were in accordance with Royal National Lifeboat Institute (RNLI) guidance.

Susan recently attended the following inquest seminars: 'The Coroner’s and Justice Act 2 years on' and 'The Coroner’s Inquest some current dilemmas'.

Susan appeared for a Local Authority following death arising from a tree falling onto a vehicle travelling on the highway.

Recommendations

“Speed and uptake was impressive to say the least, as was her energy and the commitment she made. Since this first encounter, we have sought to use her whenever possible. Having sat next to her I can say that she is an accomplished advocate with a compelling style of advocacy” (Partner, instructing and attending a 3 day hearing)

“Our client is very happy with the outcome and I wouldcertainly not hesitate to use Miss Susan Jones in the future or recommend her to my colleagues”. (Solicitor)

“Thank you for your advice which is both thorough and lucid of its analysis of the case” (Associate Solicitor)

“Miss Jones was extremely helpful and professional.  I do not see how we could have done any more to better present my case” (Lay Client)

 

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Academic qualifications

  • Queen’s University Belfast (LLB: First, Top in Year)
  • City University Law School (Bar Professional Training Course: Outstanding)

Scholarships

  • BPTC scholarship
  • Sweet and Maxwell Prize - most distinguished student in LLB final examinations
  • Queen’s University Belfast awards for:
    • Jurisprudence and political economics
    • Contract law
    • Trademarks and unfair competition

Professional qualifications & appointments

  • Western Circuit Area Bar Junior (Winchester)
  • Direct/Public access qualified

Professional bodies

  • Personal Injury Bar Association
  • Association of Regulatory & Disciplinary Lawyers
  • British Association for Sport and Law (BASL)
  • Bar Pro Bono Unit

Direct Access

Susan Jones is qualified to accept instructions directly from members of the public and professional clients under the Direct Public Access scheme.

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