I refer to your letter of 13 Dec 2002. Having considered the same carefully, I write to inform you that the Bar cannot accede to your request.

Yours sincerely,


Alan Leong, S.C.
Chairman

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1. I would like to request you or someone from HKBA to continue my application as an amicus in the above case to be heard on Friday 20 Dec 2002 2:00pm at Western Magistracy at Court No.1 before Mr. Allan Wyeth. The First Clerk of the Western Magistracy is Mr. K.L. Ho, who knows about the details of my application. Please see the following the papers:

(a) My written application before Mr Wyeth dated 18 Nov 2002. Mr Wyeth asked me to submitted my information to either the defence or the prosecution. I submitted to the HK Regional Crime Unit 1A SIP TANG Wai-keung/RCU1AHKI Tel: 2859 8556.

(b) CAPO reply under CAPO HKI-02001291, referring also to
[(b1)] SIP TANG Wai-keung/RCU1AHKI.

(c) My 7-page cautioned statement to RCU1AHKI, in which I identified 22+ persons who should be prosecuted with Mr LAU and Mr TO, failure to do so is a malicious prosecution against the two and an abuse of court process that their case should be dismissed.

(d) My 28 photos dated 11 May 2002 in which I identified 22+ persons who should be prosecuted with Mr LAU and Mr TO (colour photocopies). [I also gave the RCU1AHKI 2 rolls of negatives; see p.5 of my cautioned statement]

(e) Colour print of the Apple Daily dated 12 May 2002 in which I identified 22+ persons (including myself) who should be prosecuted with Mr LAU and Mr TO. [see p.5 of my cautioned statement]

(f) Two Apple Daily colour print photos (dated 3 and 4 June 2002) of the Hong Kong Federation of Students Headquarters (HKFS/Hq) unlawful June 4 rally.

(g) Three colour print photos from Sing Pao, Apple Daily and Oriental Daily dated 23 Sept 2002 of the 22 Sept 2002 unlawful rally.

(h) One colour print Apple Daily photo dated 18 Nov 2002 in which I identified the Hon. CHENG Ka-Fu and the Hon. Emily LAU in the 17 Nov 2002 unlawful rally.

(i) Copy of the "Declaration of Collective Punishment for Civil Disobedience" dated 7 Dec 2002.

(j) Copy of the standard cautioned statement under the the "Declaration of Collective Punishment for Civil Disobedience" dated 7 Dec 2002.

(k) Apple Daily 8 Dec 2002 p.A10 of the event in (i) and (j), in which I was photographed as standing in the front line. See also my own photos #23, and #34 [deleted: #37] dated 7 Dec 2002 [negative #4864].

(l) Copy of the Chief Magistrate's judgement in the first post-1997 unlawful case HKSAR v LEUNG Kwok-Hung, FUNG Ka-Keung and LO Wai-ming (KCC8456/2002).

(m) Copy of Police v Beggs [1999] 3 NZLR 615, in which the police case was dismissed.

Yours faithfully,


Anthony C.H. Chua


Encls. [only encls. b, b1, and j for Mr Wyeth, prosecution and 2 defts.]

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Your complaint of 18 Nov 2002 is now handed over to HK Region ­«®×²Õ Regional Crime Unit 1A for action.

If you have any enquiry, please phone 2859 8556 and contact the case i/c SDIP TANG Wai-keung ¾H°¶±j.

If your contact address is changed, please inform us so that we can continue to inform you the investigation results.

YU Tak-Chung
for Comissioner of Police

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I refer to the report you made to the police on 17 Nov 2002 relating to a case of Unauthorized Assembly that took place from Chater Garden to Police Headquarters on 11 May 2002. Police has noted the information you provided and it is decided not to call you as a prosecution witness. However, your statement and other materials will be treated as "Unused Materials" and according to the current practices, police is obliged to provide them to the two defendants.

May I take this opportunity to thank you for your assistance in this case. Should you have any queries, pelase feel free to contact the undersigned at 2859 8556.

Yours faithfully,


¾H°¶±j
(TANG Wai-keung)
Officer-in-charge
Regional Crime Unit 1A ­«®×²Õ
Hong Kong Island

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