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With regards to the section 8 application Jemi has been on notice that this has been required since
before Christmas. A detailed defence case statement was submitted and as a result of this document
and the Crown's failure to disclose the requested items that the Third Party Disclosure arise as did the
section 8 application. If the Insurance company believe Mr Patel has committed a fraud then it is their
decision whether he is prosecuted.

Nikki Diamond has to confirm her unwilllingness to disclose the file before I can apply for Third
Party Disclosure. I cannot take a statement from her as part of her statement will require her to
disclose and exhibit as part of that statement the original insurance claims and she cannot do this as
client confidentiality arises.

Re Simon's most recent request to vary bail he did not provide the information when requested. I have
dealt with this point already as I have re the Third Party Disclosure and the section 8 application.

I am not prepared to have my professional judgement or integrity called into question. Simon
threatened to blacken my name on Facebook Lorraine. I am reliant on instructions from my client re
bail variations. I am reliant on Counsel drafting applications re section 8. I drafted Simon's original
bail application and defence case statement well within the time limits. All other requests to vary bail
I have made. Due to the number of bail variations Simon is aware of the process and trying to get the
variations agreed administratively. He is also aware of the attitude if the Court to his case

The issues regarding Simon's case when I am on leave I have no control over.

Simon himself caused problems in this case by (a) his behaviour on arrest (b) his comments to police
when the police were at his house re the number of items bought as a job lot. There was no evidence
of this apart from what came from Simon himself. (c) The gazebo in his garden was easily dealt with
as he had the original receipt (d) Simon ignoring legal advice in his interviews (e) Simon's inaccurate
interpretation on the law on burglary and what squatters can and cannot do whilst squatting in a
building.

There is a risk that Simon will be convicted in this case and this is not through the fault of Michael
Carroll & Co or my representation but through his own conduct on his arrest and at the police station.
To try to blame other people for the position he finds himself in is very wrong.

Simple questions to consider:

1. Did the police know about or have any evidence re the job lot ­ answer No until Simon himself
revealed this
2. Could Simon explain his DNA in a moveable object ­ answer. Yes and he would have achieved the
same result as Naomi
3. Could police prove the Venice chair came from warehouse ­ no. Information on this again came
from Simon
4. Is Mohammed likely to be a witness as to sale of the items? No because he will have to be advised
to obtain independent legal advice as he could incriminate himself

This was better left to cross examination at trial as too late then to produce invoices but Simon
obviously does not agree. This will be an example of Simon making a further tactical mistake as he
did during the comments to police at his address and again in interview.

The Judge and prosecution will be influenced in making decisions in this case based on Simon's
conduct before arrest, in interview and his previous convictions.

The point that Simon is missing is that a prima facie case exists and this case will go to trial. Simon
should re­read his interview and his attitude in his interview where he effectively suggests it serves
the owner of the premises right for having his premises burgled.
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