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email it over. 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 CD's 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. 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 CD's as produced from the email of Miss Cordell. 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. We can serve these recordings on the CPS and the Court so that
they are agreed in advance of the Appeal hearing. 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
March 2015. 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. Can you therefore
please write a section 9 statement confirming that: