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Faxed from Society of
Attorneys 16 Oct 2007 to Ministerio Publico in Portimao.
GERALD PATRICK MCCANN and KATE MARIE HEALY, better identified in
the documents referenced above, approach, very respectfully, to
set forth and request, Sir, the following:
1 - Since the applicants stopped being considered witnesses,
moving to suspects of the disappearance of Madeleine McCann,
witnesses central to the discovery of truth were not questioned,
or re-questioned.
2 - With the recent investigations, witness interviews and
interrogations of the applicants, new questions were raised and
doubts aroused, broadening, in this way, the object of the
investigation, as well as matters of fact considered relevant to
the investigations.
3 - Indeed, the Investigation departed from confining itself to
the disappearance of the minor, proceeding to embrace other
matters, allegedly connected with her.
4 - It is therefore essential to hear these witnesses who can
explain facts now very relevant, such as the way the couple
treated their children, their personality and routine and, even,
the reactions manifested by them after the disappearance and the
consequent psychological and emotional state.
5 - So, and because it is believed essential and indispensable
for the establishment of the facts and consequent discovery of
the truth, they come to request the hearing of the following
groups of witnesses, all present and with direct knowledge of
the facts:
Group 1 (persons with whom the couple dined every night during
the holidays)
David Payne, with address at ...> (Leicester) (0,774,884 ####)
Fiona Payne to address in ...> (Leicester) (0,779,627 ####)
Diane Webster, with address at ...> (Renhold, Bedford)
(0,123,477 ####)
Russell O'Brien, with address at ...> (Exeter) 0,771,325 ####)
Jane Tanner, with address at ...> (Exeter) (6,780,858 #####)
Rachael Oldfield, with address at ...> (London) (0,777,159
####)
Matthew Oldfield, with address at ...> (London) (0,777,159
####)
Group 2 (independent customers and employees of the Ocean Club
who saw the behavior of Kate and Gerry on the day of the
disappearance):
Dan Smith, with address at ...> (Ocean Club, c / o Mark
Warner)
Steve Carpenter, with address at ...> (Ware, Herts) (0,781,577
####)
Carolyn Carpenter, with address at ...> (Ware, Herts)
Jeremy Wilkins, with address at ...> (London)
Catriona Baker, with address at ...> (Surrey) (0,785,823 ####)
Group 3 (people who saw and/or spoke with Kate and Gerry at the
time they noticed Madeleine's disappearance):
Patricia Cameron, with address at ...> (Dumbarton) (079,122
####)
Paul Seddon, with address at ...> (Salford) (079,262 #####)
Michelle Thompson, with address at ...> (Liverpool) (0,151,280
####)
Emma Kinghts, with address at ...> (Ocean Club, c / o Mark
Warner) (3,519,614 ####)
Alan Pike, with address at ...> (Skipton) (0,781,212 ####)
Group 4 (people who knew the daily routine of Kate and Gerry and
their relationship with their children before coming to
Portugal):
Janet Kennedy, with address at ...> (Rothley, Leics)
(0,118,230 ####)
Amanda Coxon, with address at ...> (Leicestershire) (0,794,042
####)
Karen McCalman, with address at ...> (Leicesterhire)
(0,116,269 ####)
Patricia Cameron, with address at ...> (Dumbarton) (0791 202
####)
Sharon Lewin, with address at ...> (Leicester) (0,788,780
####)
Hayley Plummer, with address at ...> (Syston) (0,778,987 ####)
Group 5 (persons closely involved in the routine of Kate and
Gerry in Portugal after the disappearance of Madeleine and their
emotional state)
Sandy Cameron, with address at ...> (Dumbarton) (0,793,399
####)
Michael Wright, with address at ...> (Skipton) (0,777,556
####)
Clarence Mitchell, with address at ...> (Bath) (0,779,628
####)
Linda McQueen, with address at ...> (Merseyside) (0,780,956
####)
Nicky Gill, with address at ...> (Liverpool) (079,004 ####)
Justine McGuiness, with address at ...> (Dorchester)
(0,780,109 ####)
Group 6 (Professionals who can confirm that there was no
abnormality in the way Kate and Gerry treated their children):
Dr. Phil Hussey, with address at ...> (Leics) (0,116,260 ####)
Dr Ian Schofield, with address at ...> (Mountsorrel)
(0,116,230 ####)
6 - It is certain that some of these witnesses have already been
heard, at least once, in the investigation.
7 - But, at that time, the direction of the investigation was
apparently different, [that being] the reason why some of these
witnesses were not heard on the matters mentioned above,
currently considered relevant to the prosecution of the
investigation and who already were, furthermore, the object of
actual proceedings, namely the questioning and the
interrogations of the applicants.
We submit that, their testimony [being] essential to the
discovery of the truth, and given that the witnesses designated
above actually live in the United Kingdom, where they will be
found, (except Dan Smith and Emma Knights who will be found in
Portugal), it is requested further, under Arts. 229 and
following of CPP, 145 and following of Law 14-4/99 of 31 August
(Law of International Legal Assistance in Criminal Matters) and
3 and following of the European Convention on Mutual Legal
Support in Criminal Matters, that a Rogatory Letter be expedited
for them to be heard in the United Kingdom.
They ask that the request be granted
The Advocates
CARLOS PINTO DE ABREU
ROGERIO ALVES |