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From: JOSEPHINE WARD [josephinewardsolicitor@gmail.com]
            Sent: 07 August 2013 22:10
            To: Lorraine Cordell
            Subject: Simon's case

            Hi Lorraine

            Winchester Crown Court

            This case is in the warned list for 29th August 2013.  I am still waiting for Simon to provide witnesses
            who can corroborate the negotiations between Simon and the "seller".

            Woolwich Crown Court

            The main problem in this case is that Simon is unhappy that he is subject to an electronic curfew.  As
            you are aware I did not request a curfew as I knew that this problem would arise.  He was initially
            given a door step curfew but the Judge changed this to an electronic curfew.  This is the preferable
            option as it is a qualifying curfew and counts half a day towards any custodial sentence, if convicted.
            The Judge did state an electronic tag as the clerk checked the tapes for what was said.  The Judge is
            within his rights to do this as he will view this as relieving a burden in terms of man power from the
            police.  I cannot challenge this as it is still a curfew.

            Bail variation:

            Simon has to be realistic in terms of what we can achieve here.  One of my obligations as a solicitor is
            to manage a client's expectations.  I will of course make an application to vary Simon's bail conditions
            but as I stated before I will require emails from Simon from clients requesting that he cover events
            with quotes given by Simon as to how much he will charge.

            The smartest way to attempt to get Simon's bail varied is to ask for certain dates as opposed to lifting
            the curfew altogether as the Judge will not do this.

            If Simon persists in stating that he is not allowed to work and earn his living then Simon will then
            have to complete a change in financial circumstances statements for both the Woolwich case and the
            Winchester case and the court will have to assess his monthly contributions for both cases. At present
            he does not have to make a contribution as he is in receipt of benefits.


            I can only properly challenge the evidence in this case when I receive the case papers and then make
            my requests for secondary disclosure.  The court would then be more amenable to an application to
            remove conditions of bail.

            I am sorry that Simon feels that his case is not being handled properly.  I sent Simon a client care
            letter at the commencement of this case outlining the complaints procedure.  I do not believe that
            Michael was aware of the calls made by Simon to the office.  I tried to deal with Simon's case
            personally and usually I do. e.g. Going to Birmingham Police Station in 2012, attending home address
            after his remand from Camberwell Green Magistrates Court to draft bail application.

            I am not sure what happened when I was on annual leave but based on your email it appears that the
            complaint should be directed against me as I am the fee earner and I am meant to supervise case
            workers.  Michael is the Principal of the Firm and not the fee earner on this case. The case workers
            knew I was contactable by email and did not contact me. Michael Carroll has had no dealings with
            this case.


            (Since returning from annual leave I have dealt with 2 complex rapes, 3 GBH and a police station
            duty to date.
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