Page 764 - 5. 2015 New 26-05-21 No Table

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.
1965,
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.
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Agents Limited Canopius Services Limited | registered number 02733994 KGM Motor
Insurance is a brand name for business written by Canopius Managing Agents Limited
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