Precedent - Crown Letter re Admissions

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Letter

Letter/email to defence counsel

With a view to streamlining the case pursuant to the Crown's Jordan duties, I’m proposing the following defence admissions:

  • The following records as business records within the meaning of s. 30 of the Evidence Act:
    • Record #1 ...
  • The Mohan requirements necessary to qualify the expert as identified in the notice dated [date] have been made out
  • The authenticity and reliability of the following electronic records captured by s. 31.1 of the Evidence Act:
    • Record #1...
  • The authenticity and continuity of the following items seized as listed in the exhibit sheet (attached) that constitute real evidence:
    • item #1...
  • The authenticity and reliability of the following videos and/or photographs:
    • image #1...
    • video #1...
  • The voluntariness of the utterances given by the accused to a person in authority on [date] when [circumstances]
  • The voluntariness of the audio/video recorded cautioned statement given by the accused to a person in authority on [date] when [circumstances]

Please advise whether you are prepared to agree to any of the above admissions.