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Inconsistent data created by East Sussex Children's Services

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Please identify the complete documentary and evidential basis upon which Gerard Keenan and members of the Keenan family in Northern Ireland were entered into the family records and genograms relating to Lauren and Emily.

In particular, please provide:

Every source record relied upon to establish any claimed biological, paternal, legal or familial relationship between Gerard Keenan and either child.
The name and professional role of the person who supplied that information.
The name of the social worker who entered the relationship into the records or genogram.
The date upon which each entry was created.
Details of every subsequent amendment, including who made it, when it was made and the evidence relied upon.
Any DNA evidence, declaration of parentage, court order, parental-responsibility agreement, birth record or other official document supporting the claimed relationship.
The documentary basis for inserting other members of the Keenan family into the children’s family structure.

The documents presently available disclose no documentary basis for stating that Gerard Keenan was Lauren’s father. Lauren Anne Julia Peters’ Newry birth certificate records that she was supposedly born at Daisy Hill Hospital on 30 April 2001, but the section identifying the father is blank. A later social-work genogram cannot establish or manufacture biological paternity; it records only information entered or accepted by Children’s Services.

A separate movement record states that Catherine moved to Northern Ireland with her daughter Lauren. This indicates that Lauren already existed when the recorded move occurred. That account must be reconciled with the Newry birth certificate and the chronology represented elsewhere within the social-work records.

The records therefore present three matters requiring a documented explanation:

Newry birth certificate: Lauren Anne Julia Peters recorded as born at Daisy Hill Hospital, Newry, on 30 April 2001, with no father recorded.
Movement record: Catherine recorded as moving to Northern Ireland with her daughter Lauren.
Later social-work records: Gerard Keenan and members of the Keenan family inserted into the family structure despite the birth certificate establishing no paternal connection.

If the movement record describes Catherine moving from outside Northern Ireland with Lauren as part of the same chronology, the Newry birth account and that movement account appear incompatible unless there was an earlier birth in Newry followed by a departure and later return. If that is the council’s explanation, please identify the records proving those movements.

Please do not provide an assumption, general narrative or restatement of the genogram. I require the underlying contemporaneous evidence showing how each relationship was established. If no such evidence exists, please confirm that expressly and explain what steps will now be taken to correct the records and identify how the unsupported information came to be recorded.

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