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From: JOSEPHINE WARD [josephinewardsolicitor@gmail.com]
Sent: 19 May 2014 17:22
To: croydonkingston&woolwichcrown@cps.gsi.gov.uk; listing@woolwich.crowncourt.gsi.gov.uk;
J.B. Akin­Olugbade; Lorraine Cordell; too smooth; Del Edgeler; Mark.Tomlinson@cps.gsi.gov.uk
Subject: Regina v. Simon Cordell for mention at Woolwich Crown Court on Wednesday 21st May
2014
Dear Sir or Madam

We continue to act on behalf of Mr Simon Cordell in relation to an allegation of burglary.

As you are aware this case was in court on 8th April 2014 for a mention hearing before his Honour
Judge Shorrock. On that occasion the Learned Judge made directions as to the service of crime scene
photographs from February 2014 (as referred to in the statement of Paul Michael Whittaker dated 25th
March 2014). There are 14 photographs referred to in the statement but we have not been provided
with an album containing the pictures of indeed a photograph.

In addition we have not been served with the statement from the Council regarding the noise
abatement. We will forward under separate cover copies of a section 80 noise abatement notice and a
notice prohibiting the sale of alcohol at the planned party in Bianca Road that Mr Cordell's mother
secured from the Council under a section 35 application. It appears as though there is confusion as to
the venue address and indeed the venue referred to in the noise abatement notice (Bianca Road) and
the alleged burgled premises appear to be one and the same albeit the burglary is charged under the
address of Unit 3­4 Haymerle Road, Peckham, London, SE15 6SA as opposed to Bianca Road.

We also request that the prosecution clarify specifically what the particulars of the charge is against
Mr Cordell as in the advance information he was charged with loss of stock to the value of £8220. Mr
Patel in his statement dated 8th May 2013 refers to loss and also damage. The damage is estimated at
£8,000 ­ £10,000. In the case papers there is reference to a burglary and the items being stolen being
a gazebo and also a chair. With regards to the gazebo Mr Cordell will bring to court a copy of an
invoice that he has confirming that he purchased this item and therefore this could not have come
from any burglary. In addition the invoices provided in the case papers do not have listed the chair
seized from Mr Cordell's home address. The chair listed on the invoices provided by Mr Patel refer to
Monaco mutli position chairs whereas the chair removed from Mr Cordells' address is a Venice chair.
The photograph provided is of a Venice chair and not a Monaco chair..

We seek clarification as to the particulars of the burglary charge as if the charge is to be amended to
damage caused. There have to date been three burglaries at the premises, one in February 2013, one
in March 2013 and one in May 2013. We know from the insurance documents that Nikki Diamond
visited the site on 28th February 2013 and updated the broker on 2nd April 2013 damage being
described as access holes being knocked through in the walls to gain access and an additional two
access points were discovered. reference is made to damage to the rook also. There is also a
comment made that there is no way to differentiate which damage was caused when. We know that
there are crime scene photographs in relation to the February 2013 offence and these need to be
compared to the crime scene photographs in relation to the May 2013 offence.

We also request that the officer in the case clarify the position with regards to the invoices and the
date when they were obtained from Mr Patel. The invoices that we are specifically making reference
to are the ones dated 1st March 2013 and 29th March 2013 which itemise identical damage. The
optional extras recommended are identical also. Mr Trevor Allway from the Insurance company
confirmed that he never received the invoices / estimates from Mr Patel and he checked with Nikki
Diamond whether she had seen the invoices and she stated that they had not been provided to the
insurance company. Indeed from the insurance file there is an email from Simone Sailman requesting
repair quotations from Deven Patel (dated 24th April 2013) but the invoices provided by Mr Patel to
the police are clearly dated 1st March 2013 and 29th March 2013. Our query is why were these not

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