Edited to replace Google. Translated by Albym:

Processos Vol XI
Pages 3030 -3034


Faxed from Society of Attorneys 16 Oct 2007 to Ministerio Publico in Portimao.

GERALD PATRICK MCCANN and KATE MARIE HEALY, better identified in the documents referenced above, approach, very respectfully, to set forth and request, Sir, the following:

1 - Since the applicants stopped being considered witnesses, moving to suspects of the disappearance of Madeleine McCann, witnesses central to the discovery of truth were not questioned, or re-questioned.

2 - With the recent investigations, witness interviews and interrogations of the applicants, new questions were raised and doubts aroused, broadening, in this way, the object of the investigation, as well as matters of fact considered relevant to the investigations.

3 - Indeed, the Investigation departed from confining itself to the disappearance of the minor, proceeding to embrace other matters, allegedly connected with her.

4 - It is therefore essential to hear these witnesses who can explain facts now very relevant, such as the way the couple treated their children, their personality and routine and, even, the reactions manifested by them after the disappearance and the consequent psychological and emotional state.

5 - So, and because it is believed essential and indispensable for the establishment of the facts and consequent discovery of the truth, they come to request the hearing of the following groups of witnesses, all present and with direct knowledge of the facts:

Group 1 (persons with whom the couple dined every night during the holidays)
• David Payne, with address at ...> (Leicester) (0,774,884 ####)
• Fiona Payne to address in ...> (Leicester) (0,779,627 ####)
• Diane Webster, with address at ...> (Renhold, Bedford) (0,123,477 ####)
• Russell O'Brien, with address at ...> (Exeter) 0,771,325 ####)
• Jane Tanner, with address at ...> (Exeter) (6,780,858 #####)
• Rachael Oldfield, with address at ...> (London) (0,777,159 ####)
• Matthew Oldfield, with address at ...> (London) (0,777,159 ####)

Group 2 (independent customers and employees of the Ocean Club who saw the behaviour of Kate and Gerry on the day of the disappearance):
• Dan Smith, with address at ...> (Ocean Club, c / o Mark Warner)
• Steve Carpenter, with address at ...> (Ware, Herts) (0,781,577 ####)
• Carolyn Carpenter, with address at ...> (Ware, Herts)
• Jeremy Wilkins, with address at ...> (London)
• Catriona Baker, with address at ...> (Surrey) (0,785,823 ####)

Group 3 (people who saw and/or spoke with Kate and Gerry at the time they noticed Madeleine's disappearance):
• Patricia Cameron, with address at ...> (Dumbarton) (079,122 ####)
• Paul Seddon, with address at ...> (Salford) (079,262 #####)
• Michelle Thompson, with address at ...> (Liverpool) (0,151,280 ####)
• Emma Knights, with address at ...> (Ocean Club, c / o Mark Warner) (3,519,614 ####)
• Alan Pike, with address at ...> (Skipton) (0,781,212 ####)

Group 4 (people who knew the daily routine of Kate and Gerry and their relationship with their children before coming to Portugal):
• Janet Kennedy, with address at ...> (Rothley, Leics) (0,118,230 ####)
• Amanda Coxon, with address at ...> (Leicestershire) (0,794,042 ####)
• Karen McCalman, with address at ...> (Leicesterhire) (0,116,269 ####)
• Patricia Cameron, with address at ...> (Dumbarton) (0791 202 ####)
• Sharon Lewin, with address at ...> (Leicester) (0,788,780 ####)
• Hayley Plummer, with address at ...> (Syston) (0,778,987 ####)

Group 5 (persons closely involved in the routine of Kate and Gerry in Portugal after the disappearance of Madeleine and their emotional state)
• Sandy Cameron, with address at ...> (Dumbarton) (0,793,399 ####)
• Michael Wright, with address at ...> (Skipton) (0,777,556 ####)
• Clarence Mitchell, with address at ...> (Bath) (0,779,628 ####)
• Linda McQueen, with address at ...> (Merseyside) (0,780,956 ####)
• Nicky Gill, with address at ...> (Liverpool) (079,004 ####)
• Justine McGuinness, with address at ...> (Dorchester) (0,780,109 ####)

Group 6 (Professionals who can confirm that there was no abnormality in the way Kate and Gerry treated their children):
• Dr. Phil Hussey, with address at ...> (Leics) (0,116,260 ####)
• Dr Ian Schofield, with address at ...> (Mountsorrel) (0,116,230 ####)

6 - It is certain that some of these witnesses have already been heard, at least once, in the investigation.

7 - But, at that time, the direction of the investigation was apparently different, [that being] the reason why some of these witnesses were not heard on the matters mentioned above, currently considered relevant to the prosecution of the investigation and who already were, furthermore, the object of actual proceedings, namely the questioning and the interrogations of the applicants.

We submit that, their testimony [being] essential to the discovery of the truth, and given that the witnesses designated above actually live in the United Kingdom, where they will be found, (except Dan Smith and Emma Knights who will be found in Portugal), it is requested further, under Arts. 229 and following of CPP, 145 and following of Law 14-4/99 of 31 August (Law of International Legal Assistance in Criminal Matters) and 3 and following of the European Convention on Mutual Legal Support in Criminal Matters, that a Rogatory Letter be expedited for them to be heard in the United Kingdom.

They ask that the request be granted

The Advocates
CARLOS PINTO DE ABREU
ROGÉRIO ALVES