Page 835 - Driving Ban Simulation 1

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.
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.

2
The Enfield Gov / Email’s Issue:
452. Lorraine Cordell _Fwd._ Appeal against conviction for no insurance Regina v
/ Page Numbers: 1579,1580,
From: Lorraine Cordell [lorraine32@blueyonder.co.uk]
Sent: 08 February 2015 19:46
To: 'Wood, Peter'
Subject: FW: Appeal against conviction for no insurance Regina v. Simon Paul Cordell on 5th March 2015
at Kingston Upon Thames Crown Court
Dear Peter
➢ We have had to have a meeting today with a solicitor re the appeal case for my son.
➢ The reason for this is due to something about chain of evidence and submitting the tapes as exhibits to the
court I think that was why the CPS and judge said to us last time we were in court we would need a
section 9 witness statement.
➢ please can you address the email from Josephine Ward from MICHAEL CARROLL & CO that has
been sent to you I have forwarded it below.
➢ This court appeal is a lot harder than I had ever dreamed.
Regards
Lorraine

From: Josephine Ward
Mail To:josie@michaelcarrollandco.com
Sent: 08 February 2015 19:02
To: Peter.Wood@canopius.com
andrew.austin@canopius.com
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.