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§ 114 - violation).

I am no lawyer myself and I am trying to go through the human rights act which is a very long document and
extremely difficult to understand.
You were also aware my son and I have been working from older bundles and ordered the solicitors who were
acting for my son before they were removed from record on the 21/09/2016 by your honour to pass the correct
bundles to us. Upon seeing these bundles, it has come to light that there are statements we have never seen before
this date and never have seen them before the trial of the lower court. I am not sure if these statements have been
added after the last trial when the appeal was applied for or if my son’s last solicitor has had these statements and
they were not given to us. I do know they are dated before the last trial took place. How was my son ever meant to
have a fair trial without having and seeing all the documents within the case against him?
Upon also looking at my son’s own bundle the barristers were using for this Appeal there were many documents
missing from this bundle that I have had to take time to update this bundle to the correct version with all
statements included as there were no statements in there and other documents, it was not even indexed, How was
the barrister even meant to have dealt with this Appeal with so many documents missing.
The police have targeted my son and family for many years mostly being Simon Cordell, and I believe they have
pursued a malicious prosecution against him also trying to include his brother’s name in this case, this can be
proven.
The Magistrates court hearsay rules 1999 do not apply to the crown court.

The defence do not accept that the Respondent has relied on the correct legislation to apply under the hearsay
rules. In any event the Appellant requests that the Respondent call the witnesses who made CAD entries for cross
examination.
It is neither professionally appropriate nor suitable for the Appellant to call police officers and question their
credibility, as proposed by the Respondent through their application under the Magistrates Court Hearsay Rules.
The Appellant submits that questioning the credibility of one’s own witnesses would not be permitted by the court.
The Respondent has put forward no good reason for why these witnesses cannot be called. As to say it is not in
the interests of justice to do so.

Burden of proof and standard of proof are set high in this appeal case and you must find to be satisfied beyond
reasonable doubt that the respondent case can be proven to the criminal standard in every aspect of the
prosecution.

I do not feel the Respondent application bundles could ever prove beyond reasonable doubt that the Appellant my
son was concerned in the organisation of illegal raves / provided sound equipment for illegal raves.

The Appellant my son and I is still not even sure what he is meant to be defending in this case and this has been
asked many times for this to be explained. Even the Respondent skeleton argument bundle has had the word
illegal removed from it case, but the definition of the word rave does make this illegal and this can clearly be
seen from the Respondent original application bundle.
The inaccurate data that is within the Respondent original application namely my son’s PNC and statements of
police which is relied on in the Respondent original application bundle, the large concern that the Respondent has
refused to unedited the CAD’s and intelligence reports they rely on in their original application bundle, why there
th
was a need to update original intelligence reports, why no CAD reports was included for the 6 June 2014 in the
original application, why there are so many missing CAD’s, why the police refuse to admit in the lower court that
CAD’s they had in their original application bundle clearly relates to an illegal rave in Crown Road and CAD’s
from that have been placed in the Respondent original application bundle. (Please see freedom of information
request to Enfield council in the Appellants bundle page 274 to 284 which clearly shows this) why they refuse to
disclose information held on the police public order unit Scotland Yard systems and why Steven Elsmore did not
ask DS Val Tanner from the police public order unit in Scotland Yard to write a statement after he spoke to her

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