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I have drafted a section 9 statement as requested. Before I sign it off can you review it and
confirm it satisfies all of your requirements please? As soon as you do so I will sign it off,
scan a copy over to you and put the original in the post.
Let me know if you need anything else and of course if you need me to amend the attached in
any way.
Lorraine/Andy - FYI.
Regards
672,
Peter Wood
UK Specialty Operations Manager |
UK Specialty Division of Canopius Group
KGM House | 14 Eastwood Close | London | E18 1RZ
D +44 (0) 20 8530 9120 | www.kgminsurance.co.uk | www.canopius.com
From: Josephine Ward [mailto: Josie@michaelcarroHandco.com
Sent: 08 February 2015 19:02
To: Wood, Peter; Austin, Andrew
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:
all recording equipment was working correctly
KGM produced two recordings at the request of Ms Lorraine Cordell
Confirmation that the recording of S Cordell call from police 141113 Recording was
provided by KGM from their recorded calls and is authentic
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.