PETER L. HILL, B.A., LL.B.

Barrister and Solicitor

25 Poyntz Street Tel: (416) 555-9876 Toronto, Ontario Fax: (416) 555-6789 M3B 3V3

July 2, 2019

Municipal Prosecutor

City of Toronto

101 Avenue Road Toronto, ON M5M 234

Dear Sir/Madam:

RE: Steven Scott

______Charge: Drive Left of Centre - Section 149(1)(a) HTA

As you may be aware, I am counsel on record for Steven Scott with respect to the above noted charge.

I am in receipt of initial disclosure on this matter, and I am writing to request the following additional disclosure:

1. Video recording from the bus;
2. All witness statements including names, address, and phone numbers;
3. All witness statements from the passengers on the bus, including their names, addresses, and phone numbers;
4. Any and all photos taken at the scene;
5. Damage estimate for vehicle #1;
6. Damage estimate for vehicle #2;
7. Name, address, and telephone number of the driver of the vehicle that turned northbound that caused driver #1 to take evasive action;
8. Address and telephone number for driver #2;
9. If there was another officer at the scene in addition to the primary officer, the name, address, and phone number of the second officer;

I look forward to receiving the above noted information.

Regards,

Peter L. Hill

PLH/nab

Digital audio file or Memo to police officer (student)

"The prosecutor's office has received a letter from the lawyer for Steven Scott.This is a charge that you laid back on June 30^thfrom a motor vehicle collision involving a city transit bus and a civilian motor vehicle.

The prosecutor's office has forwarded this letter to our detachment for follow-up on possible outstanding disclosure. Initial disclosure was provided in full on the first appearance date.

Please draft and fax a letter to the lawyer in response to his inquiries. I have looked into each item requested and can advise as follows:

• No bus video in police possession. This is considered 3^rd party records and counsel will have to make a court application to obtain from 3^rd party.
• Only one witness - already provided statement in disclosure.
• Damage estimates for both vehicles are 3^rd party records and counsel will have to make a court application to obtain from 3^rd party.
• No notes or any information in police possession regarding any northbound vehicle. Cannot provide.
• Driver 2 has advised he is not agreeable to his personal information being released.
• No second officer.

Please generate responding correspondence to counsel.

1. Review the letter from counsel setting out certain requests for information on a case you have been working on.
2. Review the memo which sets out the responding position provided in point form from your sergeant who has asked you to respond via letter.
3. Using the full block style with open punctuation format, draft a proper letter responding to the lawyer's letter.
4. Ensure the content of your letter is properly formatted and structured in accordance with the samples and examples provided in the lesson content, including spacing and paragraph format.
5. Ensure the content of your letter is free of spelling errors and meets all punctuation and grammar rules as set out in lessons one through three.
6. Letter should be one to two pages in length while maintaining proper format and single spacing.