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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.
1580

