Page 338 - 5. 2015 New 26-05-21 No Table

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:
(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
1583,
the recordings. 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 separate
recordings. If you require assistance with drafting a section 9 statement, then we would be
happy to draft it and 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. I deally
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.
Confidentiality Caution
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Group, which includes: Canopius Holdings UK Limited | registered number 04818520
Canopius Managing Agents Limited | registered number 01514453 | Authorised by the
Prudential Regulation Authority and regulated by the Financial Conduct Authority and the
Prudential Regulation Authority Canopius Underwriting Limited | registered number
02473672 | appointed representative of Canopius Managing Agents Limited Canopius
Services Limited | registered number 02733994 KGM Motor Insurance is a brand name for