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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.

Confidentiality Caution

The information in this e­mail and in any attachments is CONFIDENTIAL. If you are not the
intended recipient, please destroy this message and notify the sender immediately. Canopius may
monitor the content of e­mails sent and received via its network for viruses, unauthorised use or other
lawful business purposes. E­mail sent for and on behalf of a member of Canopius Group, which
includes:

Canopius Holdings UK Limited | registered number 04818520
Canopius Managing Agents Limited | registered number 01514453 | Authorised by the Prudential
Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation
Authority
Canopius Underwriting Limited | registered number 02473672 | appointed representative of Canopius
Managing Agents Limited
Canopius Services Limited | registered number 02733994
KGM Motor Insurance is a brand name for business written by Canopius Managing Agents Limited
Registered office: Gallery 9, One Lime Street, London, EC3M 7HA | Registered in England and
Wales

Confidentiality Caution

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