Page 240 - Pages from 8. 2017 New 26-05-21 No Table- 2nd Half

22/02/2016
Miss Ward who was dealing with this case for The
Appellant at Michael Carroll & Co, knew the response had
to be completed by the
04/04/2016 when the case was next listed in Court. Miss
Ward did not start working on the response to the Judge’s
letter until the
03/04/2016
and an email was sent to The Appellant with what Miss
Ward wanted to reply to the Judges letter also stating any
amendments needed to be done as soon as possible. Because
the Appellant knew that Miss Ward had sat on the letter
from the Judge and done nothing about it since February and
then had rushed a response on the
03/04/2016
when Miss Ward had been asked repeatedly to address the
letter from the Judge, which now had not given The
Appellant any time to go over the response Miss Ward had
written. The Appellant amended Miss Wards Letter to
include multiple points that had been missed out and sent it
back to Miss Ward via email within a few hours of getting it
but The Appellant was upset that he had to rush things as
due to the learning problems he has he does need long to be
able to go over documents, the delay in getting the letter
from the solicitors meant The Appellant had hardly any
time.
Please see attached: --
Upon attending Court on the
04/04/2016
it was seen that Mr Morris had also drafted a response to the
Judge letter this response was almost identical to Miss
Ward’s Letter except that it included one crucial section
regarding the hearsay rule that had not been included in Miss
Ward’s letter. The Appellant agreed the point about the
hearsay rule did need to be included.
But was adamant it was going to be his letter that was going
to be handed to the Judge with the oral addition of the
hearsay. This was the oral addition. The Magistrates Court
hearsay rules 1999 do not apply to the Crown Court. The
defence do not accept that the Respondent has relied on the
correct legislation to apply under the hearsay rules. In any
event The Appellant requests that the Respondent call the
witnesses who made CAD entries for cross examination. It is
neither professionally appropriate nor suitable for The
Appellant to call police officers and question their
Credibility, as proposed by the Respondent through their
application under the Magistrates Court Hearsay Rules. The
Appellant submits that questioning the credibility of one’s
own witnesses would not be permitted by the Court. The
Respondent has put forward no good reason for why these