Page 340 - 5. 2015 New 26-05-21 No Table

• Confirmation that the recording of S Cordell call from police 141113 Recording was
provided by KGM from their recorded calls and is authentic
• 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. 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
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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. 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 co-operation 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
The information in this e-mail and in any attachments is CONFIDENTIAL. If you are not the
intended recipient, please destroy this message and notify the sender immediately. Canopius
may monitor the content of e-mails sent and received via its network for viruses,
unauthorised use, or other lawful business purposes. E-mail sent for and on behalf of a
member of Canopius 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 business written by Canopius Managing Agents
Limited Registered office: Gallery 9, One Lime Street, London, EC3M 7HA | Registered in
England and Wales
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