We confirm our success before the Bond Street Court with our client Frankly Chisolom in December 2012 based on similar analysis that follows here. Mr. Leaf Steveens, Assistant Crown Attorney Orange County Prosecutor's Office Fax: 905-743-2538 Dear Mr. Steveens, Re: Ferrel Chisolom-Returning on 18/10/18 The intention to lead the witness to say and suggest to the Court a contrary and false set of facts is to pervert the court of Justice. The file is to be withdrawn as no one saw him driving the vehicle and he was not driving the Vehicle. It is to be withdrawn also on a section 11B. Click here.

 To

: Mr. Leaf Steveens, Assistant Crown Attorney
Orange County  Prosecutor's Office 
Dear Mr. Steveens,
Re: Ferrel  Chisolom-Returning on 18/10/18

The intention to lead the witness to say and suggest to the Court a contrary and false set of facts is to pervert the court of Justice. The file is to be withdrawn as no one saw him driving the vehicle and he was not driving the Vehicle.   It is to be withdrawn also on a section 11B. 
 
Thank you for contacting Angel Ronan Consulting.   This is to confirm that you attended and conducted a pre-trial on your own behalf October 4th, 2018.  You asked us afterward to review your situation and you have provided some information so that we could understand what you are looking for as a book or book excerpt.   What follows is our book page analysis on this type of situation  as downloaded from our existing volumes.

__________________Book Excerpt Appears Below___________________________________

   I confirm the following issues at pre-trial. The first issue is the identity of the driver.   You do no have a driver according to the evidence although the charge is Driving while Intoxicated.  The second issue is whether the individual was seen in the vehicle. The notes do not confirm the writer's name or other ID. The accused confirmed he was not in the vehicle when the officers arrived. The information suggests a sergeant was first on the scene but the notes do not assist in identifying the witness. The next issue is s.8 charter rights as to approach any van in a parking lot without reasonable and probable grounds and violate charter rights protecting against unreasonable search or seizure. The description of the van was vague with no mention of the lettering on the side by the civilian witness.
The last issue is that there are two sets of alcohol readings but you claim it is only one reading with the numbers rounded down to the last round number. For instance 130 over is rounded down to 123 over 80. This causes doubt with equivocal information evidently.  How can we be sure of what the technician recorded?   Why would he write down anything other than what the machine recorded? The machine should tell us whether the sample proves intoxication such that continuity/proof of the reading is at issue as a person can be arrested for a certain offence at 80 mg but not 79 mg. The Crown/Mr. Stevens claims this is a procedure of the officers or breath technician. There are triable issues and while it is a workable resolution on an early plea, the entire file raises the issue of  the charges being thrown out for want of evidence.   I say this based on the S.8 charter issue primarily. While there are other offences, the offer provided by the Prosecutor for early resolution involve a fine of $1200.00 with a plea to impaired driving and a one year driving suspension. There is no jail time as discussed.   Mr. Chisolom has two prior convictions.  The other two charges are to be withdrawn. The key weaknesses in this case are as I have indicated but specifically the s.8 charter issue as there are many white vans on the highway or on the main roads. Mr. Chisolom did not admit to driving the vehicle. He did not provide any written or videoed statements. To assist conclusively in resolving this, I am suggesting a plea to an HTA (Highway Traffic Act) offence of driving while under suspension or careless driving.   If this is not amenable to your office, please advise and I will communicate the offer as already discussed with these observations in mind to Mr. Chisolom. Thank you for communicating the resolution offer without delay.



Thank you.
It is a pleasure being of service to you.
Yours very truly,


Warren Lyon.

Angel Ronan S.L.R.P.-Law Firm
___________________end of Book Excerpt____________________________________


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