Page 443 - tmp

From: JOSEPHINE WARD [josephinewardsolicitor@gmail.com]
Sent: 27 January 2014 11:38
To: too smooth; Lorraine Cordell
Subject: Venice chair
Dear Simon

I have checked the invoice / delivery note from Li­Lo Leisure Products and there is no reference to
Venice chairs on this invoice. There is reference to Monaco chairs. I have raised this issue with Jemi
and I have asked him what he wishes to do tactically in relation to this matter. I state this for the
following reason Mr Patel will have to give evidence in the witness box regarding his claims to the
insurance company. He will also have to give evidence in relation to the statement that he made to the
police in relation to the Venice chairs he alleged in his section 9 statement that he recognised. At
present he has not produced an invoice confirming that he was ever in possession of the Venice chair.
He will be asked about this when he is giving evidence.

We will be seeking stock movement also as the goods were delivered on 19th January 2012 and
allegedly stolen in February 2013. We will be seeking confirmation of the movement of stock from
the premises.

I will also be emailing the CPS to make arrangements for the original invoice for the purchase of the
gazebo seized from your rear garden to be examined and agreed prior to the trial. Please confirm that
you are still in possession of the original invoice in order that I can do an addendum to your defence
case statement.

I will be requesting that the CPS take a detailed statement from Mr Patel together with invoices,
delivery notes and stock movement from the premises at Unit 3 Horrisons Industrial Estate.

Regards

Josephine

421