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124

“I was also aware that there were a number of blockages

that started to spring up all over the Western Kingston belt

that included the area of Tivoli Gardens and at all entrances.

There were blockages also on Spanish Town Road, Marcus

Garvey Drive, Industrial Terrace and blockages were later

discovered in West Street, Pechon Street and other streets

within the West King Street area – all of that corridor there

were blockages.”

6.12.

Some of the embattlements erected at entry points to Tivoli

Gardens had new and distinctive features:

They were deeply layered or organised in depth, making

them useful as firing position or offering protection on

retreat – see the evidence of Maj. Williams.

They were higher than normal and obstructed visibility into

the community.

According to CoP Ellington and Lt. Col. Cummings, gun posts

were established within the barricade itself, making it a true

embattlement.

The explosives placed within the structure of the barricade

could have caused “mass casualties” to the security forces,

as was explained to us by Lt. Col. Cummings at para.21 of

his witness statement.

6.13.

Perhaps this excerpt from the oral evidence of Maj. Williams on

30 June 2015 best exemplifies the magnitude of the danger posed by the

embattlements – structures or objects with explosives devices embedded within

them:

“the barriers interspersed with IEDs, with fall-back firing

positions allowing gunmen to engage, detonate devices and

withdraw to fall-back position, [made] it easy to conclude

that it resembled urban warfare.”