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Subject: Re: Proposed letter for Commissioner of Metropolitan Polcie
From: JOSEPHINE WARD (josephinewardsolicitor@gmail.com)

To: lorraine32@blueyonder.co.uk; re_wired@ymail.com;
Date: Thursday, 8 September 2016, 16:01

Lorraine / Simon

Simon I do not believe that it is in your best interests for me to serve the suggested amendments to the letter that
I proposed sending to the Ms Sally Gilchrist. The reason for this advice is similar to the advice given to you by
Mr Morris on 4th April 2016 and you decided to ignore his advice. A lot of the matters you raise I have
previously advised you can be dealt with by cross examination. Your instructions are simply that you have not
organised, provided equipment or been concerned in the organisation of illegal raves. In relation to all events
with the exception of Millmarsh Lane you dispute providing equipment or any intention to hold any events. In
some you are visiting friends who are homeless and have a LAPSO notice up confirming they are treating the
building as their residence. The legal technicality you refer to i.e. absence of trespass does not prevent any
parties from being held at the buildings in question as amounting to anti social behaviour. You are well aware of
how anti social behaviour is defined and loud music being played over two nights would satisfy this definition
as it undoubtedly causes noise nuisance and distress to neighbours. Your defence to Progress Way is denying
being in attendance inside the premises on any occasion and you merely dropped off keys. The question as to
whether the premises were being squatted and the appropriate notice was on display to prevent trespass does not
affect whether anti social behaviour was caused. I have advised you that championing the rights of persons
squatting in a building to hold a party where a couple of hundred people attend and justifying the event as not
being a rave due to lack of trespass does not prevent the event from causing anti-social behaviour. Anti social
behaviour was clearly caused as a result of the Progress Way event. There is a significant risk that you will
alienate the Judge if you advance the argument that anyone squatting can hold a loud party. The loud parties
cause anti-social behaviour regardless of trespass / rave definition being satisfied.

I ask you to reconsider whether the attached document should be served on the Respondent. This document I
have copied and pasted from the amendments you made to the letter that I sent to you. The views you expressed
in the letter and the requests made were your requests and legal challenges so I have changed "we" to, "I, Simon
Cordell" to reflect this. My view is that this document should not be sent but if you insist then please confirm
this in writing. Type in your signature and email back to me please.

Mr Andy Locke is available for a conference on 13th September 2016 at his Chambers and following this
conference a decision will be made whether to list the case for lack of disclosure or not.

Please confirm your instructions on the service of the attached word document. I reiterate that I do not believe
that it is in your interests to serve the document.

Regards

Josephine

On Thu, Sep 8, 2016 at 2:15 PM, Lorraine Cordell <lorraine32@blueyonder.co.uk> wrote:

Josey please see letter back from Simon

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