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1. IN THE SUPREME COURT
DPP (NSW)
- v -
Tara Elizabeth Follett
_____________________________________________________
SUBMISSIONS ON BEHALF OF THE APPLICANT
_____________________________________________________
Introduction
1. A release Application is being made by the applicant.
2. 27 May 2020 - The accused was arrested.
3. 27 May 2019 - A release application for bail was made to Dubbo Local Court.
Application was refused.
s 18 factors
1. This application attracts the provisions of the s 18 of the Bail Act. And the
show cause provisions don’t apply
The indictment
The applicant has been charged with one sequence of Participate in criminal group
contribute to criminal activity as per Section 93(T)(1) Crimes Act 1900.
The crown will have issues in relations to sequence 1

2. 2
i. On page 2 of the police facts sheet they assert that the accused is
responsible for the management of telecommunication of Thompson
police provide no detailed explanation as to how they came to this
basis.
ii. Police also assert that the accused was responsible for conducting
surveillance for the criminal group and managing proceeds of crime
again no basis or evidence has been given to support this assertion.
iii. Upon the search of the accused property the police state that
instructions for the self destruction of Thompson phone and icloud,
icloud accounts were located. Police again do not provide evidence as to
why they are of the view that the instructions were firstly from
Thompson/the criminal group or why they equated to self
destruction/s.
Section 18 factors
2. The following section 18 factors are relevant;
i. The applicant has close community ties. She was born in Australia. She
is an Australian citizen.
ii. The applicants Grand Mother, mother Karon Horan and her sister
Rachelle Patricia Follett is a persons of excellent repute.
iii. The applicants sister and mother give an undertaking that they will
assist the accused in complying with her bail conditions.
iv. The applicants sister and mother give an undertaking that they will
report the applicant to the police if she fails to comply with any of her
bail conditions.
v. The applicant will have no communication with any of the co accused
vi. The age of the applicant is a significant consideration. She was 35years
of age at the time of the offence.

3. 3
vii. The applicant also has no history of non-compliance with any bail
conditions or failures to appear.
viii. The applicant cannot be described as someone who has committed
serious offences whilst on bail.
ix. The applicant does not possess a passport and he would comply with
any condition that he is not to apply for any travel documents.
x. The applicant is prepared to be the subject of a condition that confines
her to what is often referred to as ‘house arrest’. The applicant would be
residing with her Mother,
xi. The applicant is also able to reside with her Grand Mother if the court
finds it suitable, and is prepared to be released subjected to a ‘house
arrest’.
xii. The applicant and her family are willing to comply with an enforcement
condition.
xiii. The applicant will be providing $5000 cash assurity.
3. In all the circumstances of the case, it is submitted that the relevant factors, when
combined, show cause why detention is not justified, and bail should be granted
on strict conditions.
Javid Faiz
Solicitor
Sydney Criminal Law Specialists
2/247 Church Street Parramatta NSW 2150
More Information: -
https://www.sydneycriminallawspecialists.com.au/