Page 1081 - Driving Ban Simulation 1
P. 1081

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.
          E.  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.
          F.  If you require assistance with drafting a section 9 statement, then we would be happy to draft it and
              email it over.
          G.  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 CDs 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.
          H.  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 CDs as produced from the email of Miss Cordell.
          I.  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.
          J.  We can serve these recordings on the CPS and the Court so that they are agreed in advance of the
              Appeal hearing.
          K.  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 of March 2015.
        1965,
          L.  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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        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
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        Holdings UK Limited | registered number 04818520 Canopius Managing Agents Limited | registered number
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        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 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
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