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29/01/2025

3127BEGOVIC

RE: Brief for Forensic Expert | The King v Milan Begovic

Dear Nikola,

I refer to our previous correspondence.

I confirm that we act for Mr. Begovic who has been charged with importing a
commercial quantity of a border-controlled drug into Australia, namely cocaine.

For context, we enclose a copy of the Statement of Material Facts as alleged by the
Commonwealth against Mr. Begovic.

Relevantly:
a) on 23 May 2024, a Signal chat named 'BOATS' was used between multiple
parties to facilitate the offloading of illicit drugs from the MV St Pinot to be
picked up by a smaller fishing vessel, "No Fixed Address";
b) one of the participants in the chat operated the anonymous handle 'Timur';
c) 'Timur' is alleged to have been on the MV St Pinot and organizing the
rendezvous with No Fixed Address;
d) 'Timur' sent one photo at 4:33pm and another at 5:14pm of the MV St Pinot's
navigational instruments into the Signal chat. This was purportedly to advise
No Fixed Address of the MV St Pinot's positioning and course;

At 9/4 Adelaide Street

P: (08) 6319 2388 E:
Fremantle WA 6160
[email protected]
www.thedefencelawyers.com.au
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e) the prosecution alleges that the reflection of the navigational instruments shows Mr. Begovic taking the
photos on a mobile device; f) the prosecution are alleging that Mr. Begovic
sent those photos into the Signal chat for the purpose of coordinating a rendezvous with No Fixed Address
to offload the drugs; g) this Signal chat and the corresponding photos were found on an iPhone 11 Pro
Max that was located
aboard No Fixed Address when it was seized by the police; h) Mr. Begovic's phone was seized by the police
at a later time, but no evidence of these photos or the Signal chat were found on his phone; i) Mr
Begovic's mobile phone while on the MV St Pinot at the relevant time was an iPhone 14 Pro.

We are seeking your opinion on: 1.

whether Mr Begovic is holding an item in his hand only in one or both of the
photos;
2. what are the visible dimensions/measurements of the item in his hand; 3. whether it can be
determined what that item is; 4. whether the dimensions of that item
exclude the possibility of it being an
iPhone 14 Pro;
5. whether the dimensions of that item exclude the possibility of it being a mobile phone device in general; 6.
whether the item could be one
of the two in-board radio handsets situated to the left of the navigation instrument; 7. whether there is a

camera lens visible on that item; 8. whether there

is someone else visible in the photos; 9. if it is possible to estimate, how
far away Mr. Begovic is standing or sitting from

the navigation instrument;

10. if it is possible that someone other than Mr. Begovic has taken the photos but cannot be seen in the
reflection; and 11. any other matters that you
may see as relevant.

To assist you, we have provided the following materials:

[1] Phone download of the iPhone 11 Pro Max on which the Signal chat was found; [2] The extracted data of
the Signal chat; [3] The relevant extracted image files
of the Signal chat; [4] A series of photos taken of Mr. Begovic's glasses;
[5] Photos taken by the AFP of the navigation instrument; and [6]
Photo and dimensions of JRC NQW-261 VHF handsets next to the navigation
instrument.

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If there is anything I can assist you with, please feel free to contact me by email
[email protected] or phone 0468 416 884.

Kind regards,

Oliver Heath

Lawyer
The Defense Lawyers