Crown Letter re Admissions (Precedent)

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]