Statement of Daniel Cho

Fictional statement for demonstration. Not a client file.

1. This statement made by me accurately sets out the evidence that I would be prepared, if necessary, to give in court as a witness. The statement is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I will be liable to prosecution if I have wilfully stated in it anything that I know to be false or do not believe to be true.

2. My full name is Daniel Cho. I am 29 years old. I work as a bar attendant at the Crown Hotel at 392 Crown Street, Surry Hills. I have worked there for three years. I was on duty on the evening of Saturday 12 September 2026. My shift started at 5:00pm.

3. At about 9:05pm a man came to the service side of the bar. I now know him as Jordan Lee. I had not met him before that night. He asked for a whiskey. His speech was slurred and he was steadying himself on the bar. I refused the drink. He argued with me about the refusal. He said I was treating him differently from other customers.

4. The argument lasted less than a minute. He then pushed me once in the chest with two open hands. I stepped back into the fridges. I was not injured. I did not fall. I did not strike him, and I did not push him back. I told him to leave. He swore at me and walked toward the Crown Street doors.

5. I did not follow him outside. I stayed behind the bar. I last saw him inside the hotel at about 9:20pm. I do not know where he went after that. I was not at Holt Street later that night, and I did not see any fight at a unit.

6. Sam Okonkwo, the supervisor, was behind the bar to my right when the push happened. He had a clear view. I do not remember any other staff member being close enough to see the push. A couple were seated at a booth, but I do not know their names and I did not see them watching.

7. There are cameras over the bar and one camera toward the Crown Street doors. I do not operate them. I have not watched the footage, and I have not been given a copy. I cannot say what the cameras recorded.

8. On 13 September 2026 I spoke to police at the hotel and gave this account. I have read it. It is correct.

Statement of Sam Okonkwo

Fictional statement for demonstration. Not a client file.

1. This statement made by me accurately sets out the evidence that I would be prepared, if necessary, to give in court as a witness. The statement is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I will be liable to prosecution if I have wilfully stated in it anything that I know to be false or do not believe to be true.

2. My full name is Sam Okonkwo. I am the supervisor at the Crown Hotel, 392 Crown Street, Surry Hills. I was on duty on Saturday 12 September 2026 from 4:00pm until closing.

3. At about 9:05pm I was standing behind the bar, to the right of Daniel Cho. I heard a man arguing about a drink Daniel had refused. I looked up. I saw the man push Daniel once in the chest with two hands. Daniel moved backward. I did not see Daniel strike the man. I did not see the man fall, and I did not see any injury on Daniel.

4. I had not met the man before. I watched him leave by the Crown Street doors at about 9:20pm. Daniel stayed behind the bar. Neither of us followed the man onto the street. I do not know what happened after he left the hotel.

5. The hotel has cameras that cover the bar, the tills, and the doors onto Crown Street. I can play them back in the office. I have not exported the footage, and I have not given police a copy. The recording for 12 September 2026 was still on the hotel recorder when I made this statement. I do not know how long the recorder keeps footage.

6. On 13 September 2026 a police officer showed me one photograph of a man and asked if he was the man who pushed Daniel. There was no folder of other photographs and no line-up. I said the photograph was the man. I had not been asked to describe him before I was shown the photograph. I do not know the man's name except that police used the name Jordan Lee.

7. I can produce the recorder if police ask. As at the date of this statement, no one has collected it.

Statement of Alex Morgan

Fictional statement for demonstration. Not a client file.

1. This statement made by me accurately sets out the evidence that I would be prepared, if necessary, to give in court as a witness. The statement is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I will be liable to prosecution if I have wilfully stated in it anything that I know to be false or do not believe to be true.

2. My full name is Alex Morgan. I live at unit 4, 18 Holt Street, Surry Hills. Jordan Lee had been staying in the spare room of that unit for about six weeks before 12 September 2026. We had been friends. He was not on the lease.

3. On Friday 28 August 2026, at about 8:10pm, I was inside unit 4. Jordan was not in the unit. He shouted from the stairwell. I did not open the door. A few minutes later a message arrived on my phone reading "I will come back tonight". I was frightened. He did not come back that night. There was no physical contact between us that night. I still have the handset the message arrived on. Police have not taken that handset, and I have not been shown a download of the message.

4. On Saturday 12 September 2026 I was in the kitchen of unit 4 with a man I know as Chris. I do not know Chris's surname or his phone number. He had come over to watch a game. Shortly before midnight Jordan came in. We argued about him staying at the unit. I say he punched me once, with a closed fist, to the left side of my face. My lip was cut and my cheek was swollen. I did not punch him.

5. After the punch he kicked the front door on his way out. The lower timber panel split. I have not obtained a quotation. I estimated the repair at $640 from a similar repair in the building last year. I do not have an invoice.

6. A black mobile phone was on the kitchen bench. It was my phone. He took it as he left. I cannot give a serial number or an IMEI. I bought it second hand and I did not keep the box. I have not seen that phone since.

7. I later attended St Vincent's Hospital because of the cut and the swelling. I was seen and I went home the same night. I was not given papers to take with me. No medical report has been given to me.

8. I cannot now say who opened the door when police arrived. I do not remember signing a consent form, and I do not remember being shown a warrant. Chris was still in the kitchen when police arrived. I do not think police spoke to him. He left while I was washing my face.

9. When I first spoke to police I said there was one punch. That was the account I gave on the night.

Further statement of Alex Morgan

Fictional statement for demonstration. Not a client file.

1. This statement made by me accurately sets out the evidence that I would be prepared, if necessary, to give in court as a witness. The statement is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I will be liable to prosecution if I have wilfully stated in it anything that I know to be false or do not believe to be true.

2. I made a statement on 13 September 2026. I have read it again. I want to correct the number of blows. There were three punches, not one. The first was to the left side of my face. The second and third were also to the left side of my face, while I was against the pantry. I do not say that I fell down. My lip was cut and my cheek was swollen, as I said before.

3. I first told police there was one punch. I said that on the night, and I said it again in the statement of 13 September 2026. I later said there were three punches. I was upset on the night and I wanted the conversation to be short. The later account is the one I now adopt. I do not say that any other part of the first statement is wrong.

4. I have still not obtained a quotation for the door. I have still not been shown photographs of the door or of my face. No medical report from St Vincent's Hospital has been given to me to read.

5. I have thought about the phone. The phone taken from the bench was mine. I cannot give a serial number. I know Jordan's sister, Helen Lee, says she lent him a black phone. I do not know the phone she means. I did not see a second phone in his hand that night.

6. I adopt the statement of 13 September 2026 except for the number of punches.

Statement of Priya Nair

Fictional statement for demonstration. Not a client file.

1. This statement made by me accurately sets out the evidence that I would be prepared, if necessary, to give in court as a witness. The statement is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I will be liable to prosecution if I have wilfully stated in it anything that I know to be false or do not believe to be true.

2. My full name is Priya Nair. I live in unit 5, 18 Holt Street, Surry Hills. Unit 5 is on the landing above unit 4. I can hear the stairwell from my lounge if the windows are open. I do not know the occupants of unit 4 well. I know one of them by sight as Alex.

3. On Saturday 12 September 2026 I was at home. At about 11:35pm I heard shouting in the stairwell, then a loud bang, like something hitting a door. I opened my front door a little. I did not go down the stairs at that moment. I did not see any person strike another person. I could not see into unit 4.

4. A short time later a man came up the stairs past my door. I now know police say that man is Jordan Lee. I had seen him on the stairs in the weeks before. As he passed me he said, "I only hit him because he came at me." He said those words to me. He was not speaking to a police officer. There was no police officer on the landing when he said it.

5. I do not know who he meant by "him". I did not see a second man on the stairs. I do not know if he was speaking about Alex or about someone else. I did not ask him. He kept walking down toward Holt Street.

6. I looked at my phone after he passed. I still had 11:35pm in my head from the shouting, but I did not look at the clock when I first heard it. I cannot reconcile that time with any later time police have mentioned to me. I did not see police arrive. I closed my door before they came up.

7. I did not see a weapon. I did not see a phone in his hand. I heard only the one bang. I have not been shown footage of the stairwell, and I do not believe the building has a camera on my landing.

Statement of Constable Amelia Reyes

Fictional statement for demonstration. Not a client file.

1. This statement made by me accurately sets out the evidence that I would be prepared, if necessary, to give in court as a witness. The statement is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I will be liable to prosecution if I have wilfully stated in it anything that I know to be false or do not believe to be true.

2. I am a constable of police attached to Surry Hills Police Area Command. I am the informant. On Saturday 12 September 2026 I was working a night shift in uniform. At about 11:40pm I went to unit 4, 18 Holt Street, Surry Hills, after a radio call about a loud argument.

3. At about 11:42pm I entered unit 4. This statement does not record a warrant. I cannot say who let police in. I do not remember an occupier signing a form. I do not remember the door being forced. Alex Morgan was in the kitchen. His lip was cut and his left cheek was swollen. I did not take a photograph of the injury. I did not call an ambulance. He said he would go to hospital himself.

4. Alex Morgan told me he had been punched once to the left side of the face. He pointed to the front door. The lower timber panel was split. I did not take a photograph of the door. I did not obtain a quotation. He said a black mobile phone had been taken from the kitchen bench. I did not see a phone on the bench.

5. A man was in the kitchen. Alex Morgan called him Chris. I asked Chris to wait. He left before I took his details. I do not have a surname, a phone number, or an address for him. He has not been interviewed. There is no statement from him in this brief.

6. I did not seize a handset from Alex Morgan. I did not ask him to show me the message from August. I made no download that night.

7. I left the unit after Alex Morgan said he would attend hospital. I then drove the length of Holt Street looking for the man he had described.

Statement of Constable Amelia Reyes (continued)

Fictional statement for demonstration. Not a client file.

8. At about 12:05am on 13 September 2026 I saw a man on the footpath of Holt Street. A black backpack was on the footpath beside him. He matched the description Alex Morgan had given. I now know him as Jordan Lee. I stopped him there.

9. My body-worn video begins at 12:11am. The earlier part of the stop, including the first words in the caged vehicle, is not on that video. The video itself has not been served with this brief. I have not watched it back for the purpose of this statement.

10. I searched the backpack on the footpath. A black mobile phone was in the front pocket. This statement does not record the power I used for that search. I did not record a serial number. I did not record an IMEI. The phone has not been examined. I cannot say from my own observation whether it is the phone Alex Morgan described or another black phone.

11. While Jordan Lee was in the caged vehicle, and before a caution was recorded, he said to me, "He swung first." I did not ask him who he meant. I did not write those words in my notebook at the time. I wrote them up after I returned to the station. I do not know whether he was speaking about Daniel Cho or about Alex Morgan.

12. At about 1:15am on 13 September 2026, at Surry Hills Police Station, I cautioned him. He declined to be interviewed. No ERISP was made. I did not put further questions to him after the caution.

13. Police bail was refused at about 2:05am. The custody manager spoke to him. I am not the custody manager. The custody management record has not been served with this brief. I know the concerns recorded on the night were the safety of Alex Morgan and the lack of a confirmed address, and that Jordan Lee was already on bail for an unrelated matter.

14. I have not served the hotel CCTV, the street CCTV, the August messages, the medical report, a quotation for the door, photographs of the door, or the criminal history. Those items are listed as not served. No apprehended violence order was sought in the court attendance notice, and I have not prepared an application.