#13551 - Cross Examination Bott

REAL ASSESSMENT - XX

ALFIE BOTT

PREVIOUS CONVICTIONS

Mr Bott you said a few minutes ago that you ____________
(I’d like to take you back to something you said in your evidence a few minutes ago – previous convictions)

You stole jewellery.
And you pleaded not guilty.
But the jury didn’t believe you did they?
And the offence we are concerned today is because it alleged that you stole jewellery and cash.
And there was another incident wasn’t there on the 19^th October 2010?
And that incident concerned burglary as well.
And you again pleaded not guilty.
And the jury again didn’t believe you.
You stole a watch.
From 78 year old man.
You approached his house didn’t you?
And you said to him that you were collecting property.

(continued) PREVIOUS CONVICTIONS

When in fact you didn’t.
That man let you in didn’t he?
So because he let you in, you saw an opportunity.
So you like to take advantage of situations where people are more likely to let you in.
And you think it is justified to lie to the elderly.
And you think it is justified to steal items when vulnerable people let you in.
So if you find yourself in a situation where vulnerable people let you in there is a real risk of stealing from them.

And on the 2nd of April 2011, you were convicted of 3 further distraction burglaries of dwellings.

On the incident we are concerned today, you approached Mrs O’Grady’s house.
That is a 73 year old woman.
And you said to her that you were supervising the visits by the younger members.
And she let you in.
And you stole from her a ring and cash.

POSTERS

IDENTIFICATION

RELATIONSHIP WITH SARAH + brought back card

(continued)RELATIONSHIP WITH SARAH)

- On the 15th of September , you went to her house uninvited.

12 September

(continued) 12 September

She was in the kitchen with Sara Holt.
And the hatch between the kitchen and the sitting room was open.
And you were in the sitting room.
And while in the sitting room, you overheard Emma and Sarah talking.
You overheard them talking about one of the visits Sarah made to an old lady.
You overheard her saying that the old lady wanted to pass on her engagement ring to her granddaughter.

INCIDENT

Mr Bott it is true isn’t it that you don’t work on Mondays and Sundays.
On Monday the 15th of September you were not working.
You visited Mrs O’Grady’s house.
And you were wearing a suit.
You said to her that you were from the council.
You showed her Emma’s ID.
And you said to her that you were supervising the visits by younger members of staff from the council.
And Mrs O’Grady let you in.
You talked for a while.
She told you that she was going to give her engagement ring to her granddaughter.
You told her, it was a well-known fact that old people hide things under the bed.
You told her that because you wanted to find out where she kept the ring.
You went to use the toilet.
You went into Mrs O’Grady’s bedroom.
You went there to look for the engagement ring.
You found it in her bedside table drawer.
You also found 3,000 in cash.
You then took the ring and the cash.
You went to the bathroom.
You flushed the toilet.

(continued) INCIDENT

And went back to the kitchen.
The 3,000 that were stolen from Mrs O’Grady were in denominations of 50.
And it is true isn’t it that when you were arrested you were found in possession of cash.
And the cash you had in your possession were in denominations of 50.

INTERVIEW (adds something to his XIC)

Mr Bott while at interview you had a solicitor present.
You were cautioned.
And you understood the caution.
You knew that you needed to be clear and accurate in what you were saying.
You understood that it may harm your defence if you failed to mention anything that you later rely on it in court.

NO COMMENT – END

While at the police interview, you answered to most of the questions by the police officer.
But towards the end, you went no comment.
You refused to answer the remaining questions.
You refused to answer because you became tired.
You became tired because you were lying.
And you didn’t have a consistent story.
What you said in interview was not the truth.
And what you are saying today is not the truth.

PREVIOUS INCONSISTENT STATEMENT – DEFENCE STATEMENT

Mr. Bott you earlier told the court that ________________
Are you sure about that?
You provided a Defence Statement in this case didn’t you?
That document was drawn up by your solicitors?
And based on your instructions?
You would have been given an opportunity to check that document for accuracy?
You would have been told that it should reflect your defence as completely and as accurately as possible?
And you have signed that document haven’t you on that basis?

PLEASE may the witness be shown a copy of his defence statement.
That is your signature isn’t it at the bottom of page 3.
And it is dated 6th January 2015.
May I ask you to look at the __________ page at...

#13551 - Cross Examination Bott - BPC Criminal Advocacy