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

Processo a pdf11 page27

Quote:
Autos de Inquerito; (Received by Ministério Público de Portimão: 16 Out 2007 – rubberstamp)

Exmo Senhor
Magistrado do Ministerio Publico
Servicos do Ministerio Publico de Portimao

GERALD PATRICK MCCANN e KATE HEALY, melhor identificados no autos supra referenciados, vêm, muito respeitosamente, expor e requerer a V. Exa. o seguinte:

1- Desde que os ora requerentes deixaram de ser considerados testemunhas, passando a suspeitos do desaparecimento de Madeleine McCann, não foram inquiridas, ou reinquiridas, testemunhas fulcrais para a descoberta da verdade.

2- Com as recentes investigações, inquiriçao e interrogatórios aes ora requerentes, novas questões foram levantadas e dúvidas suscitadas, alargandao-se,deste modo, o objecto da investigação, bem como a matéria de facto considerada relvante para as investigaçóes.

3- Com efeito, a investigação deixou de se cingir ao desaparecimento da menor, passando a abarcar outras matérias alegadamente, com ela conexas.

4- Assim, torna-se imprescindível ouvir estas testemunhas que podem esclarecer factos por ora muita relevatnes, tais como a forma o casal tratava os filhos, a sua peronalidade e rotina e, até, as reacções manifestadas por estes após o desaparecimento e o eonsequente estado psicológo e emocional.

5- Assim,. e porque se entende essencial e indispensável para o apuramento dos factos e consequente descoberta da verdade, vem requerer-se a audiência dos saguintes grupos de temunhas, todas presenciais i com conhecimento directo dos factos:

Grupo 1 (pessoas com quem o casal jantou todas as noites durante as férias)
• David Payne, com morada em …> (Leicester) (0774884####)
• Fiona Payne com morada em …> (Leicester) (0779627####)
• Diane Webster, com morada em …> (Renhold, Bedford) (0123477####)
• Russel O’Brien, com morada em …> (Exeter) 0771325####)
• Jane Tanner, com morada em …> (Exeter) (6780858#####)
• Rachael Oldfield, com morada em …> (London) (0777159####)
• Matthew Oldfield, com morada em …> (London) (0777159####)

Grupo 2 (clientes e funcionários independentes do Ocean Club que viram o comportamento de Kate e Gerry no dia do desaparecimento):
• Dan Smith, com morada em …> (Ocean Club, c/o Mark Warner)
• Steve Carpenter, com morada em …> (Ware, Herts) (0781577####)
• Carolyn Carpenter, com morada em …> (Ware, Herts)
• Jeremy Wilkins, com morada em …> (London)
• Catriona Baker, com morada em …> (Surrey) (0785823####)

Grupo 3 (pessoas que viram e/ ou falaram com Kate e Gerry no momento em que estes constataram o desapareciment de Madeleine):
• Patricia Cameron, com morada em …> (Dumbarton) (079122####)
• Paul Seddon, com morada em …> (Greater Manchester) (079262#####)
• Michelle Thompson, com morada em …> (Liverpool) (0151280####)
• Emma Kinghts, com morada em …> (Ocean Club, c/o Mark Warner) (3519614####)
• Alan Pike, com morada em …> (Skipton) (0781212####)

Grupo 4 (pessoas que conechem a rotina diária de Kate e Gerry e a sua relação com os seus filhos antes da vinda para Portugal):
• Janet Kennedy, com morada em …> (Rothley, Leics) (0118230####)
• Amanda Coxon, com morada em …> (Leicestershire) (0794042####)
• Karen McCalman, com morada em …> (Leicesterhire) (0116269####)
• Patricia Cameron, com morada em …> (Dumbarton) (0791 202####)
• Sharon Lewin, com morada em …> (Leicester) (0788780####)
• Hayley Plummer, com morada em …> (Syston) (0778987####)

Grupo 5 (pessoas que acompanharam de perto a rotina de Kate e Gerry em Portugal após o desaparecimento de Madeleine e o estado emocional destes)
• Sandy Cameron, com morada em …> (Dumbarton) (0793399####)
• Michael Wright, com morada em …> (Skipton) (0777556####)
• Clarence Mitchell, com morada em …> (Bath) (0779628####)
• Linda McQueen, com morada em …> (Merseyside) (0780956####)
• Nicky Gill, com morada em …> (Liverpool) (079004####)
• Justine McGuiness, com morada em …> (Dorchester) (0780109####)

Grupo 6 (Profissionais que podem confirmar que não havia qualquer anormalidade na forma como Kate e Gerry tratavam os fihlos):
• Dr Phil Hussey, com morada em …> (Leics) (0116260####)
• Dr Ian Schofield, com morada em …> (Mountsorrel) (0116230####)

6- É certo que algumas destas testemunhas já foram ouvidas, pelo menos uma vez, em sede de inquérito.

7- Porém, nesse momento, o rumo da investigação era aparentemente outro, motivo pelo qual estas testemunhas não foram ouvidas sobre as matérias supro referidas, presentemente consideradas relevantes para a processução da investigação e que já foram, alias, objecto de diligências processuais concretas, designadamente a inquirição e o interrogatories dos ora requerentes.

Temos em que, sendo o sue depoimento essencial para a descoberta da verdade, e uma vez que as testemunhas acima designadas reidem efectivamente no Reino Unido, onde se encontram em Portugal), requer-se ainda, ao abrigo dos arts. 229 e ss do CPP, 145 e ss da Lei 14-4/99 de 31 de Agosto (Lei da Cooperação Judiciária Internacional em Matéria Penal) que seja expedida Carta Rogatória para serem ouvidas no Reino Unido.

Pedem deferimento

Os Advogados
CARLOS PINTO DE ABREU
ROGÉRIO ALVES

Processo pdf12 page84

Request from the McCanns (via Rogerio Alves) received by the Public Ministry in Portimao on 7 Nov 2007

Peter Neil Patterson (Leicester).


Quote:
"Se apos o desaparecimento da filha do arguida a testemunha ofereceu a esta um bibliba.

Se essa biblia estava assinalada em algum local especial pela testemunha, e, em caso afirmativo, porque razao a testemunha assinalou esse(s) trecho(s)."

"If after the disappearance of the daughter of the defendant the witness gave this a Bible.

If the Bible was marked in particular by some local control, and, if so, why the witness pointed out that (s) sentence (s). "

Processos Vol XII
Pages 3085 – 3089

(In Portuguese and English)


Case number 201.070 GALGS

TO:
The Magistrate of the Public Ministry
Public Ministry Services
Portimao



Gerald Patrick McCann, arguido identified in the case mentioned above, subsequent to the notification made on 25th October 2007, respectfully proposes these questions (prepared in English to facilitate purposes) for the following witnesses:

Questions for Group 1:

How long have you known Gerald McCann and Kate Healy and in what capacity?

Have you seen Gerald and Kate with their children? How often?

Have you been on holiday with them before? If yes, can you describe how they looked after the children of an evening/night?

How often did you see Gerald and Kate during your holiday 28 April – 03 May?

How often did you see their children: Madeleine, Sean and Amelie?

Did you have any concerns about the children in any way?

When was the last time you saw Madeleine?

On Thursday 3rd May when did you see Kate and Gerald?

At what time did you arrive at the Tapas restaurant on May 3rd? Who was already there?

What were Kate and Gerry doing when you arrived?

Did you speak with Kate and Gerald?

How were they behaving?

Who left the table during the meal and to do what?

Did you see Gerald leave the table during the meal? At what time? How long was he away? What did he say when he came back? Was his behaviour or attitude different when he returned?

Did you see Jane leave the table during the meal? At what time? How long was she away? What did she say when she came back? Was her behaviour or attitude different when she returned?

Did you see Matthew leave the table during the meal? At what time? How long was he away? What did he say when he came back? Was his behaviour or attitude different when he returned?

Did you see Russell Leave the table? At what time? How long was he away? What did he say when he returned?

Did you see Kate leave the table during the meal? At what time? How long was she away? What did she say when she came back? How did she look and behave? Were you shocked at what she said? What did you do?

Did you go into the McCann apartment? Did you go into the bedroom where the children were sleeping? Can you describe what you saw? Did you see the twins? Did you notice anything unusual about them?

What did you do next? Did you take part in any further searches? Who were you with?

How did Kate react when Madeleine was not found after the first ten minutes?

How did Gerry react when Madeleine was not found after the first ten minutes?

How did you think they were behaving considering that the (sic) Madeleine was gone?

What did you do between 22.30 and 10.00 am the next morning? Who did you see?

Who did you speak to?

When did you leave Portugal? How often did you see Kate and Gerry? How do you think Kate and Gerald were behaving for parents who had lost a child?

Did you see Kate and Gerald speaking to anyone during your holiday that you did not know?

Did you see either Kate or Gerry in a car during the holiday?

Processos Vol XII
Pages 3089 – 3091

Questions for group 2:

When did you meet Gerald McCann and Kate Healy during the week 28th April – 03rd may?

How often did you see them between 29 April and 03 May?

Did you see them with Madeleine and their other children? How did the children behave?

Did you see either of them in a car?

Did you see Kate or Gerald on Thursday 3rd May? When and at what time? How were they behaving?

When did you hear that Madeleine was missing? Did you take part in the search? Did you see Kate or Gerald after Madeleine was discovered missing? When?

How did they behave?


Questions for Steve and Carolyn Carpenter:

At what time did you arrive at the Tapas restaurant on Thursday 03 May?

At what time did Kate and Gerry arrive?

What did you talk about? Who else was in the Tapas restaurant?

Did you see Kate or Gerald or anyone else at their table leave the table before you left?

At what time did you leave the Tapas restaurant?

Was anyone with you?

Where did you go before going to your apartment?

Did you see anyone outside the Tapas bar or apartments?

At what time did you go to bed?


Questions for Catriona Baker:


Did you feel Madeleine was unhappy or upset during her holiday?

Did Madeleine mention anything to you about crying and her parents not being there?

Did Madeleine mention seeing any adults around the apartments?

How do you (describe) Kate or Gerald’s behaviour was when dropping off Madeleine or picking her up from the kids club?

How do you think the interaction between Madeleine and her parents was?


Questions for Jeremy Wilkins:

When did you meet Gerald McCann on Thursday 03 May?

Where exactly were you standing? Did you see where Gerald had been?

Did you see him come out of his apartment?

Did you notice anything unusual?

What did you talk about? Did he mention anything about checking the children?

How long did you speak for? Are you sure about the time?

Did you see anyone else whilst you were talking? If so who and where?

Did you see Jane Tanner?

From where you were standing, talking to Gerald, was it possible to see the road at the top of the hill – Rua Dr Francisco Gentil?

Could someone have walked across this junction travelling west to east carrying a child without you seeing him?

Processos Vol XII
Pages 3092 –

Questions for Group 3:


How long have you known Gerald McCann and Kate Healy and in what capacity?

When did you first speak to Gerald or Kate after Madeleine was discovered missing?

What did they say had happened?

Describe what they sounded/acted like?

How do you think they were acting emotionally to Madeleine being discovered missing?


Questions for Alan Pike:


For how long have you worked for the Centre for Crisis Psychology?

What was your profession before working for the Centre for Crisis Psychology?

How many times have you helped people deal with tragedies whilst abroad?

How do you think Kate and Gerald were reacting as parents who had lost a child?

How did you help them cope with the situation mentally?

What specific advice did you give them?

Processos Vol XII
Pages 3093 – 3094

Questions for Group 4:

How long have you known Gerald McCann and Kate Healy and in what capacity?

How often have you seen Kate and Gerald with their children?

Are you aware of their home routine?

At what time do the children usually go to bed?

How often would the children wake up in the evening?

How often would the children wake up overnight?

What would happen when a child wakes up?

Have you ever seen the children being given medicine? Have you known Kate and Gerry ever giving the children medication to help them sleep?

Have you ever seen sleeping tablets in their house?

Did you ever see Kate or Gerald punish the children? Have you ever seen them hit the children?

Why did Madeleine have a star chart?

How do you think Kate coped looking after three children?

Have you seen Kate or Gerald using medicine to help them cope?

Was Madeleine’s behaviour a problem?

Did she ever tell you she was unhappy?

Have you got any concerns about Kate or Gerald’s relationship with Madeleine?

Processos Vol XII
Pages 3094 – 3095

Questions for Group 5:

How long have you known Gerald McCann and Kate Healy and in what capacity?

On what dates did you come to Portugal?

Where did you stay in Portugal? Did you notice anything unusual in the accommodation?

How much time did you spend with Kate and Gerry?

How do you think they were behaving given the circumstances?

Where (sic) you in the Renault Scenic hire car they had? How many times? Did you notice anything abnormal? Did you notice any bad or strong smells in the car?

Do you think Kate or Gerry could have hidden Madeleine somewhere and moved her body in the car?


Questions for Group 6:


How long have you known Gerald McCann and Kate Healy and in what capacity?

Have you ever had any concerns about their mental health?

Have you ever prescribed any sedatives or mood altering drugs for Kate or Gerald?

Have you ever had any concerns for the well-being of their children?


Signed

The Lawyer


Carlos Pinto de Abreu

(Docs linked in TOC)