Page 600 - tmp

From: Josephine Ward [josie@michaelcarrollandco.com]
Sent: 08 February 2015 19:02
To: Peter.Wood@canopius.com; andrew.austin@canopius.com
Cc: lorraine32@blueyonder.co.uk
Subject: Appeal against conviction for no insurance Regina v. Simon Paul Cordell on 5th March
2015 at Kingston Upon Thames Crown Court
Dear Mr Wood
I have been instructed by Mr Simon Paul Cordell and Miss Lorraine Cordell to assist in the appeal
against conviction that is due to be heard at Kingston Upon Thames Crown Court on 5th March 2015
at 10am.
Miss Cordell has played two recordings that she received from KGM which are pertinent to the appeal
but at present as the telephone recordings have not been produced as an exhibit by KGM they will not
be admissible at court.
Can you therefore please write a section 9 statement confirming that:
(a) all recording equipment was working correctly
(b) KGM produced two recordings at the request of Ms Lorraine Cordell
(c) Confirmation that the recording of S Cordell call from police 141113 Recording was provided by
KGM from their recorded calls and is authentic
(d) Confirmation that the recording between the Car Pound and Kelly Tiller was also provided from
the KGM recorded calls and is authentic
If we are in possession of a section 9 statement producing the recordings then we will not have to
apply to the court for a Third Party Summons to compel an employee from KGM to attend to produce
the recordings. This would be a complete waste of your time when all we require is a section 9
attesting to the recordings being retrieved from the system and exhibited as two separate recordings.
If you require assistance with drafting a section 9 statement then we would be happy to draft it and
email it over. We would require the name of the person who retrieved the recordings. the dates that
the recordings were retrieved, the dates the recordings relate to, confirmation that the recordings were
sent to Lorraine Cordell by email so that she can produce CD's of the recordings so that they can be
played in court and specifically refer to the email containing the recordings so that there is continuity
in the chain of evidence. Ideally we would like KGM to produce the CD's and exhibit them but
failing this we will try to get the CPS to agree the CD's as produced from the email of Miss Cordell.
We stress that the section in relation to the search and retrieval of the KGM database is essential and
critical to ensuring that the chain of evidence is intact.
We can serve these recordings on the CPS and the Court so that they are agreed in advance of the
Appeal hearing.
We thank you in advance for your anticipated co­operation in this matter and hope that we do not
have to apply for a Third party Witness Summons to compel the attendance of a KGM employee at
the Appeal on the 5th March 2015.
We confirm that Miss Cordell is forwarding an email confirming that we are instructed and authorised
to request this information.
Yours faithfully
MICHAEL CARROLL & CO.

1578