It's "absolutely incorrect" to claim a swim coach did nothing to change his techniques after being warned about a complaint, a child sexual abuse trial has been told.
Kyle James Henk Daniels has pleaded not guilty to 21 charges alleging inappropriate sexual contact with young female students while working as a part-time instructor at a Mosman swim school in 2018 and 2019.
The NSW District Court jury's attention has been drawn to a memo circulated to staff of the swim school about not holding children close to the groin or chest.
That followed a complaint to management in July 2018 about Daniels' touching of a girl during a lesson.
Contrary to the Crown's submissions, Daniels became "conscious and aware" of how he was handling students during lessons in the weeks following the memo, his lawyer said.
"Where the Crown says 'look how he does nothing', that is absolutely incorrect," barrister Les Nicholls said on Thursday.
The Crown on Wednesday said it seemed "a little bit unusual" that the now-23-year-old gave evidence this week that he had no memory of the memo or changing his techniques.
But Mr Nicholls said the memo addressed concerns about an instructor's forearm being "between the legs" which the barrister said could be anywhere down to the ankles
"It was about ... generic handling, not specifically 'you touched this girl on the vagina, immediately change that hold'," the lawyer said.
Before detailing a series of inconsistencies, Mr Nicholls said Daniels wasn't asking the jury to find the children "lied, or gave false accounts or did anything wrong".
"It's about reliability or quality of evidence," he said.
The jury was also asked to consider Daniels' character, with attention drawn to a thank-you note he wrote to a police officer "for treating me like a human being" after his March 2019 arrest.
Daniels gave evidence that other officers in the police station referred to him as "a disgusting pedo" and joked about what would happen to him in jail.
The swim coach is accused of touching the genitalia of female students, then aged six to 10, on the outside of their swimming costumes on 16 occasions. He also faces five charges of sexual intercourse with a child under the age of 10, related to allegations he penetrated some girls' vaginas with his fingers.
He steadfastly denies ever intentionally touching any student inappropriately.
After a second complaint was made to the swim school in February 2019, a police investigation was launched, leading to the coach's arrest. Further children came forward after that date.
"There is a significant commonality in each of the accounts they gave which ... shows that it's no coincidence," crown prosecutor Tony McCarthy said on Thursday.
"It was intentional, that he had a sexual attraction, that he acted on it because he was presented with that (opportunity)."
The trial continues.
