Page 26 - 3. 2014 1st half New 26-05-21 No Table
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Sent: 02 February 2014 23:58
               To: Lorraine Cordell
               Subject: RE: Simon Cordell application
               to transfer legal representation
               Hi Lorraine
               It is 10.47pm. I do not have Simon's file at home with me. I will ask Jemi to respond to the
               allegations made by Simon re his conference on
               13th December 2013
               At the same time, I will ask him and his clerks to respond to why the Christmas bail variation
               was not made on
               19th December 2013.
               As you are both aware, I was on annual leave until
               06th January 2014
               Simon's case is listed for trial in
               June 2014
               There is enough time to secure the information but there is a process.
               453,
               With regards to the section 8 application Jemi has been on notice that this has been required
               since before Christmas. A detailed defence case statement was submitted and as a result of
               this document and the Crown's failure to disclose the requested items that the Third-Party
               Disclosure arise as did the section 8 application. If the Insurance company believe Mr Patel
               has committed a fraud, then it is their decision whether he is prosecuted. Nikki Diamond has
               to confirm her unwillingness to disclose the file before I can apply for Third Party Disclosure.
               I cannot take a statement from her as part of her statement will require her to disclose and
               exhibit as part of that statement the original insurance claims and she cannot do this as client
               confidentiality arises. Re Simon's most recent request to vary bail he did not provide the
               information when requested. I have dealt with this point already as I have re the Third-Party
               Disclosure and the section 8 application. I am not prepared to have my professional
               judgement or integrity called into question. Simon threatened to blacken my name on
               Facebook Lorraine. I am reliant on instructions from my client re bail variations. I am reliant
               on Counsel drafting applications re section 8. I drafted Simon's original bail application and
               defence case statement well within the time limits. All other requests to vary bail I have
               made. Due to the number of bail variations Simon is aware of the process and trying to get
               the variations agreed administratively. He is also aware of the attitude if the Court to his case
               the issues regarding Simon's case when I am on leave, I have no control over. Simon himself
               caused problems in this case by
               (a) his behaviour on arrest
               (b) his comments to police when the police were at his house re the number of items bought
               as a job lot. There was no evidence of this apart from what came from Simon himself.
               (c) The gazebo in his garden was easily dealt with as he had the original receipt
               (d) Simon ignoring legal advice in his interviews
               (e) Simon's inaccurate interpretation on the law on burglary and what squatters can and
               cannot do whilst squatting in a building. There is a risk that Simon will be convicted in this
               case and this is not through the fault of Michael Carroll & Co or my representation but
               through his own conduct on his arrest and at the police station. To try to blame other people
               for the position he finds himself in is very wrong. Simple questions to consider:
               1. Did the police know about or have any evidence re the job lot answer No until Simon
               himself revealed this
               2. Could Simon explain his DNA in a moveable object answer. Yes, and he would have
               achieved the same result as Naomi
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