New Zealand Private Prosecution Service Limited (Accounting and Taxation Division) 5/13 Cameron Road 01 September 2018 The Watch House Sergeant Wellington Central Police Station 41 Victoria Street PO Box 693 Wellington 6140 By Fax: 04 470 1600 Phone: 04 381 2000 Copy: Mr Mike Bush Commissioner of Police Police National Headquarters By Fax: 04 498 7400 Copy: RT Hon Lucinda Ardern Prime Minister Parliament Buildings Bowen Street, Wellington +64 4 81 7 8700 By Email: jmdem @ministersgovmz And Mail: Parliament Private Bag 18041. 6160. New Zealand Copy: Hon Meka Whaitlri Phone +64 4 817 9999 By Email: And Mail: Private Bag 18888 Parliament Buildings Wellington 6160 Copy: All Media for immediate publication craig.mcculloch@radionz.co.nz 1. Subject: Assault Complaint Section 196 of the Crimes Act 1961 2. Alleged Offender: Hon Meka Whaltiri 3. Alleged Victim: Parliamentary Press Secretary for Hon Meka Whaitiri. 4. Alleged Place of Offence: Parliament Grounds, Bowen Street Wellington 5. Date of Alleged Offence: On or about 30 August 2018 6. Facts: The alleged offender became engaged with the alleged victim and subsequently pushed the alleged victim. 7. Source of evidence: Extensive media coverage and statements by the Prime Minister. 8. Definition of Assault: “Section 2 of the Crimes Act 1961 defines assault as “assault means the act of intentionally applying or attempting to apply force to the person of another, directly or indirectly, or threatening by any act or gesture to apply such force to the person of another, if the person making the threat has, or causes the other to believe on reasonable grounds that he or she has, present ability to effect his or her purpose; and to assault has a corresponding meaning” 9. Formal Complaint “I Graham Edward McCready, Private Prosecutor, have reasonable and probable grounds to believe and do believe that on or about 30 August 2018 the alleged offender did assault the alleged victim in the grounds of Parliament at Wellington”. 10. Police Jurisdiction The Police have clear jurisdiction under Section 9(c ) of the Policing Act 2008 to enforce the criminal law. 11. Prime Minister does not have jurisdiction: Constitutionally the Prime Minister is not a Police Office and should refer the matter immediately to the Police. 12. Previous Parliamentary Precedents: 2007 “Punch up in Parliament between Hon Tau Henare and Hon Trevor Mallard in Mc Cready v Mallard, Wellington District Court November/December 2017. Mallard plead guilty to fighting in a public place and was fined $500.” 13. Reasonable Expectations I fully expect the Police to investigate these allegations of assault committee by the Hon Meka Whaitiri and if warranted prosecute her. 2 14. Notice and warning If the Police as in the Mallard case refuse to act the New Zealand Private Prosecution Service Limited gives notice that the Service will commence a private prosecution against the Hon Meka Whaitiri without further delay or notice. Graham McCready Private Prosecutor 3