Page 5 - 3. 2014 1st half New 26-05-21 No Table

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. 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
3. Could police prove the Venice chair came from warehouse no. Information on this again
came from Simon
436,
4. Is Mohammed likely to be a witness as to sale of the items?
No because he will have to be advised to obtain independent legal advice as he could
incriminate himself This was better left to cross examination at trial as too late then to
produce invoices, but Simon obviously does not agree. This will be an example of Simon
making a further tactical mistake as he did during the comments to police at his address and
again in interview. The Judge and prosecution will be influenced in making decisions in this