STATEMENT OF IAN LESLIE SHANAHAN

{1} My full name is IAN LESLIE SHANAHAN.

{2} I reside at 57 Yates Avenue, Dundas Valley NSW 2117.

{3} I am a highly trained classical musician and a composer of modern art-music. I hold both
undergraduate and postgraduate degrees in music, including a Doctorate of Philosophy. I have
for many years been a Lecturer and Tutor in several music subjects within various universities,
music schools and conservatoria within New South Wales, although I do not hold any such
position at the moment.

{4} I am a single man, and reside with my widowed mother at her home at the above
address.

{5} I suffer from Type II Diabetes, requiring medication twice a day; this permanent condition
was diagnosed in November 2002. I also have been diagnosed as having Bipolar II disorder,
and take daily medication for this as well.

{6} I am a member of a musical group known as The Renaissance Players. Prior to giving
public concerts, we rehearse for many weeks within the Music Department in the Seymour
Centre at the University of Sydney every Tuesday evening from 7.00 pm.

{7} On Tuesday 25 April 2006 [Anzac Day], I ate a lunch consisting of two sandwiches at
about 11.00 am (just prior to this taking my regular morning medication). Before driving my Ford
Fairlane car (NSW license WYB 577) from home at around 4.00 pm for the scheduled
Renaissance Players rehearsal at 7.00 pm, I had nothing further to eat or drink. (I left
unusually early for this rehearsal foregoing dinner in order to carry out some extra private
practice of the music, and to access a computer in the Music Department so that I could deal
with my e-mail; normally I do the latter at a local public library, but they were both closed on
account of the Anzac Day public holiday.) I arrived at Sydney University at approximately
4.45 pm, parking within the university grounds next to the western side of the Seymour Centre
building.

{8} The rehearsal began on time at 7.00 pm, ending after 10.30 pm according to the clock in
the rehearsal space (which is a fairly small, stuffy and over-heated room); by the time
everybody in the group had packed up their instruments and left the building, it was after
11.00 pm. Midway through the rehearsal there was a short break, during which I drank just a
cup of black coffee but ate nothing else.
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 {9} By the end of the rehearsal, I had developed a severe migraine so severe, in fact, that
when about to drive home, I decided that I was unfit to drive. So, with the drivers window fully
down (for fresh air), I decided to sleep in my car. (By this time, the other members of The
Renaissance Players had already gone their separate ways; those who drove to the rehearsal
had parked elsewhere.) Quite a while later I am unaware of exactly when, as I never wear a
watch, do not own a mobile phone, nor does my cars clock operate properly I awoke feeling
very cold. Although the migraine was still present, it seemed less severe, and so I set off for
home, driving along Victoria Rd towards Parramatta. I put all of the car windows up, turned my
car radio (which is always tuned in to ABC Classic FM) up loud high-volume classical music
often helps me to concentrate on the task at hand, while distracting me from the pain of a
migraine and set my cars rear-vision mirror on anti-glare (because bright light exacerbates a
migraine).

{10} By the time I reached Top Ryde approximately the intersection of Victoria Rd and
Church St I realized that I was experiencing the onset of hypoglycaemia (i.e. dangerously low
blood-glucose levels); its symptoms all of which I was feeling include: fatigue, anxiety,
physical shakiness, and a loss of concentration, in addition to my ongoing migraine. Because
this was a genuine medical emergency (hypoglycaemia can quickly lead to unconsciousness
and coma), I increased my speed above the 60 km/h speed limit in order to reach home quickly
and eat something immediately (which would rapidly raise my blood-sugar levels into a safe
zone). According to my cars digital speedometer, at no time did I exceed 90 km/h.

{11} After I had entered the right-hand turning bay at the intersection of Victoria Rd and
Marsden Rd (this being 2.2 km from home), I glanced in my rear-vision mirror and saw a
sinister-looking black (or dark-blue) sedan rapidly approaching me from behind and repeatedly
flashing its high-beam headlights at a constant rate. Given my impaired state of mind, I
immediately panicked thinking that such behaviour might well signal an impending road-rage
or violent incident (see {12} below), which I was in no physical condition to repel and, having
ascertained that there were no oncoming vehicles, proceeded to turn right through this
intersection and up Marsden Road. It then also occurred to me that this black sedan, which was
now following me, might be an unmarked police car. In any event, I was concentrating solely
upon reaching home safely, and was focussing exclusively on the road ahead.

{12} Note: I also remembered recent media reports of criminals who, during the previous
month, had impersonated police travelling in unmarked cars in order to pull over and assault
other motorists; moreover, a friend had a week or so earlier given me a copy of a document
advising readers about correct procedure whenever being followed by a purported unmarked
police vehicle. In essence, this advice was to proceed to a place of safety while acknowledging

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ones awareness of the vehicles presence. Hence, while driving up Marsden Rd, I slowed down
somewhat and carefully signalled my intention to turn into Stewart St. My reasoning was that if
the black vehicle were being driven by police officers, then I would be given an opportunity to
explain my actions and to eat something; whereas if those following me were intending me
harm, then hopefully I could quickly enter my home and telephone for emergency assistance.
(Given the time of day, my home was the only close place of safety reasonably available.)

{13} Having exercised due care, I signalled and turned left into Stewart St, travelling along
that road to the next set of traffic lights, where I signalled and turned right into King St. This was
now a 50-km/h zone, so I slowed down again to a little over 50 km/h. About 50 metres along
King St, I signalled again and turned left into Yates Ave, proceeding to Yates Aves intersection
with Alexander St where I signalled and turned right into Alexander St thence immediately
signalled and turned left into my homes carport area. (My house lies on the corner of Yates
Ave and Alexander St.) The black sedan followed all along, but did not enter my property.
However, I was aware that its headlights were shining into my carport driveway.

{14} As ever, I parked my car hard up against a tyre sitting at the far end of the carport next
to a brick wall: this is always necessary, otherwise I cannot exit from the drivers seat of my car
(the drivers door being blocked by one of the carports support posts), or the vehicles boot
protrudes from the rear of the carport. I then lowered my cars aerial electrically, turned of its
headlights, put it into park, switched off its motor, undid my seatbelt, opened the drivers door
and alighted from the vehicle.

{15} All the while facing the front of my car, I shut the drivers door and locked the vehicle
electronically from my key-ring. Just after putting my car-keys into my right trouser-pocket, I felt
a pair of hands strongly grab each of my upper arms and pull me towards the rear of my car.
Moments later, I heard a voice declare Youre under arrest!. Being somewhat mentally
confused and taken by surprise, I did not immediately reply, but silently sat down on a low brick
wall on the drivers side of my car opposite its boot. Directly adjacent to me on my left was the
carport post that also brackets a downpipe. I saw a balding man standing in front of me on my
left (hereafter LEFT) wearing what appeared to be a police uniform without any identifying
name-plate; there was also a second person on my right (hereafter RIGHT) who continued to
hold on to my right arm. At no time did I threaten these people, physically or verbally.

{16} When I had regained my composure a little, I demanded as is my right that these
persons identify themselves and their police station of origin. RIGHT did not respond at all;
LEFT just said: Eastwood Highway Patrol. I then asked why I was being arrested and LEFT
said something like: Traffic offences and failing to stop for police. I was about to try to explain
the situation when LEFT grabbed my arm again (trying to bend it back), and RIGHT started to
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bend my right thumb back towards my wrist causing considerable pain. RIGHT at the same
time also shouted Have you been drinking alcohol?, to which I replied No!; this verbal
exchange was then repeated verbatim. Throughout 25 & 26 April 2006, I had consumed no
alcoholic beverage whatsoever.

{17} I managed to wrap my left arm around the abovementioned carport post/downpipe and
to evade RIGHTs thumb-hold; RIGHT then bent my whole right hand forward beyond its normal
limit, inflicting further pain within my wrist, but I succeeded in escaping this by firmly placing my
right hand palm-down upon the brickwork. LEFT and RIGHT continued trying forcefully to bend
my arms back. (Being in a weakened state, all of my physical and mental effort was being
devoted just to preventing injury to my arms and hands.)

{18} Despite my right hand being only in contact with brickwork, RIGHT (now sitting down on
the brick wall next to me) yelled out: Get your hand away from my gun!. Although I knew I was
not touching him or any of his equipment, I promptly lifted my right hand and straightened out
my right arm, well away from his body; RIGHT continued his attempts to bend this arm.

{19} Soon afterwards, somebody on my left fired two short bursts of what I presume to be
Capsicum [OC] Spray into my left eye (only), causing me instantaneous agony and blurred
vision on top of my ongoing migraine; I did not hear any warning about OC spray, nor was I
endangering anybody. I do recall feeling absolutely exhausted, and said shortly thereafter: Im
going to relax my arms now. RIGHT put handcuffs on my right wrist behind my back with
excessive tightness; LEFT a little later did likewise with my left wrist, and I was then led
forcefully by the upper arms to near the entrance of the driveway and made to lay down on my
back upon the ground in front of the black sedan (which was parked in the driveway across the
nature strip).

{20} As I lay down, my trackpants dropped to around my ankles, and I had to arch my back
in order to avoid putting further pressure upon the handcuffs (which were already digging into
my wrists). I also noticed that a considerable number of additional police officers had arrived on
the scene. They all ignored my repeated requests to pull my pants back up. I was calling out
loudly in order to wake up my mother, who then came out and pulled my pants up. (One officer
mendaciously asserted that she doesnt want to see you.) I told my mother to go back inside
and get her camera; she returned with it and took some photographs. While my mother was
inside finding the camera, one police officer offered to remove the handcuffs, saying You wont
lash out will you? (to which I replied No); I was then rolled to one side, the handcuffs were
removed, and I was put into a seated position on the ground. Two ambulance officers then
arrived and attempted to wash the OC spray out of my eye. While this was happening I also

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informed them about my Diabetes and Bipolar II, and one of the ambulance officers took a
blood-sugar reading with a portable machine after pricking a finger on my right hand. (He also
bandaged my left wrist, which was badly lacerated and bleeding heavily.)

{21} Shortly thereafter, I was lifted to my feet. I then turned to my right and saw my wallet
lying open upon the bonnet of the black sedan, while a police officer was counting out $50
notes from it in front of my mother. Feeling that my privacy had been invaded, I straight away
grabbed my wallet and money, saying something like she [my mother] wouldnt have a clue
how much money was in there! to this officer. Another officer, who, when asked, identified
himself as MOORE, then yelled out Ive had enough of you!, and, with my mother watching
on, he aggressively shoved me off the property and towards the rear door of a paddywagon
parked on Alexander St near the carports driveway. I was plunged into it head-first, along the
rear cage floor of this vehicle. For reasons unknown to me, some police officers then, despite
my protests, reached in, grabbed my trackpants, and removed them! In my underwear, I sat on
the passenger-side bench of the paddywagon near the front cabin as it was driven away,
feeling very unwell. (This vehicles cage I recall was lit by a roof-light.)

{22} Somewhere between my home and the paddywagons destination, it stopped, the rear
door was opened, and a female police officer asked why I was trying to make myself ill (I had
been poking at something stuck between my rear molars with my left index finger). I retorted
that I was doing nothing of the sort, and that although I was unwell, I did not feel nauseous. At
no time did I vomit in the back of this vehicle, or anywhere else.

{23} The paddywagon arrived at what turned out to be Macquarie Hospital (North Ryde); I
alighted from the vehicle and was led into a room by police where I was then interviewed at
some length by a psychiatrist and psychiatric registrar. Among other things, I discussed my
hypoglycaemia with these doctors, as well as my other medical conditions. When this interview
was concluded, I was given some pills and a room to sleep in. Some time during the night, I
was woken by torchlight being shone into my eyes, and I think that another blood-sugar reading
was also taken.

{24} I was released from Macquarie Hospital on the afternoon of 27 April 2006.

Yours faithfully,

Dr Ian Shanahan.

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