Page 838 - Driving Ban Simulation 1

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:
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 separates
511,
F. recordings.
G. If you require assistance with drafting a section 9 statement, then we would be happy to draft it and
email it over.
H. 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.
I. 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.
J. 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.
K. We can serve these recordings on the CPS and the Court so that they are agreed in advance of the
Appeal hearing.
L. 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.
M. 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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