| The Dream Solution
- Documents |
08/06/93
- RESPONSE TO GROUNDS OF APPLICATION FOR LEAVE TO APPEAL
ENCLOSURE 3
THE CASE AGAINST LISA TAYLOR
RESPONSE TO GROUNDS OF APPLICATION FOR LEAVE TO APPEAL ENCLOSURE
3
A In the submission of the Respondent the learned Judge
was entitled to leave the case to the jury at the close
of the prosecution case and the jury were entitled to convict
this Appellant.
B At the trial the Crown submitted against this Appellant:-
(1) The frenzied nature of the attack indicated the likelihood
that it was Michelle Tayior who Killed Alison and not this
Appellant, It was not suggested that this Appellant had
any motive to kill (summing up p 44A-B).
(2) That any consideration of the case against this Appellant
should be postponed until after consideration of the case
against Michelle Taylor.
(3) That the jury could conclude that Michelle Tayior had
committed the murder for the reasons canvassed in Enclosure
1 and 2.
(4) That this Appellant left the clinic at 4.05pm with her
sister in her sister's car.
(5) That Michelle Taylor went to the address with a knife
in her possession and that lisa Tayior accompanied her.
(6) That Alison Shaughnessy was attacked with the knife
at the top of a small staircase within the flat before she
had had opportunity to open her mail or to dispose of her
handbag or jacket.
(7) That the evidence indicated an intention to carry out
the attack at an early opportunity above ground floor level
where Mr Casey lived.
(8) That in the circumstances it was not sensibly possible
that Michelle Taylor would have gone to the flat with a
companion unless she had taken that companion into her confidence
about her intention in advance.
(9) That thereafter the two Appellants left 41 Vardens Road
together and returned to the clinic.
(10) That this Appellant was the first of the two Appellants
to tell a lie to JJ Tapp (when JJ Tapp returned to her room
at 7.15pm) that she had been in JJ Tapp's room since about
5.00pm having spent the afternoon shopping in Lewisham/Bromley.
(11) That this account was part of an agreed false story
invented by the Appellants to account for their movements
between 3.00-6.00pm.
(12) That this Appellant thereafter encouraged JJ Tapp to
provide an alibi for her and her sister for the period 5.00-6.00pm.
(13) That she subsequently told lies to police about her
whereabouts between 3.00-6.00pm by claiming to have been
in Bromley.
(14) That if the two Appellants had not gone to Bromley,
Tessa Jordan's evidence that they had all three planned
to go there that afternoon was untrue.
(15) That if there had been no plan to go to Bromley there
was no reason why the two Appellants should not, as alleged,
have planned to kill Alison (summing up p 62C-E).
(16) That she had told police that she had never been to
the flat at 41 Vardens Road,
(17) That the presence of her finger and thumb print on
the inner door of the Oat established:-
(a) that she had been present recently at the flat
(b) she had lied to police in claiming never to have visited
the flat.
(18) That it was probably that her finger and thumb print
became affixed to the door of the flat between 1 and 4 June.
(19) That there was no circumstance canvassed in evidence
to explain a visit by her to the premises during that period
unless it was at the time of the murder of Alison.
(20) That in all the circumstances of the case this Appellant
accompanied her sister to the flat and was present at the
time of Alison's murder.
(21) That she knew of her sister's intentions and intended
to assist her if necessary, in the killing of Alison Shaughnessy.
|
| Contact : bernard.omahoney@bernardomahoney.com |
|
|
|
