Triad Group Plc:
Electronic Handling of Data Subject to Privacy and Copyright:
Supplemental Authority:
[2006] EAT 0513_06_18.10 -18 Oct 2006-Makar v TRD
Law: Public Interest Disclosure Act 1998 - Privacy - Confidential Information - Privilege - Insider Information - Insider Dealing - Civil Procedure Rules (Consent) - Applications to Strike Out Evidence - Bullying (including Abandonment) - Harassment - Intimidation - Defamation- FSMA 2006 (uncertainty notifiable) (third party financial dependence notifiable) - Contamination of Evidence - Identity Theft - Surrogacy - Cyber Crime including Interception (e-mail ; corporate servers ; mobile phone records -external platforms including LSE RNS; BAILII; MoJ; Jersey court; Bloomberg; subscription services; Williams Lea (Deutsche Poste DHL), trading as "Gazette" (TNA); uncorrected Investor Chat (Social Media) fuelling Insider Dealing; Libel; Reputation Damage- Cyber Crime re Manufacture and Sale of Phantom Electronic Shares - Malicious Falsehood.
Protection from Harassment Act 1998 Section 3 Injunctive Relief (heard 10 August 2012 Haddon-Cave LJ, HQ06XO1803, QBD)
Civil Restraint Orders by the court of its own motion (30 July 2007, heard 19 November 2012, 2012 Folio 336, Andrew Smith J
Section 2 Notices Criminal Justice Act 1987 (Director of the SFO)
Statutory Voids
EU Directive 1984 (member states to have a register of auditors)
Companies Act 1985 section 309 (Duty to act in Interests of Employees) - Duty of Mutual Confidence and Trust (common law extension) - Enduring Obligations - section 389 (B) (Duty to provide Information relevant to Auditor's Discharge of their own Duties) - Auditor Independence - Auditor Resignation - Duty to Notify at the time Decision is made (see also: [2011] EWHC 3950 (Comm) 11 July 2011 Mira Makar v PriceWaterhouseCoopers LLP) - Incorporation by Share Capital - Proxy Poll Voting - Disenfranchisement of Members - Prejudice of Minorities - Companies Act 1985 section 459 Petition - Indemnity under Articles of Association - Indemnity Invoked: Expenditure Automatically that of the Company - Indemnifiers of Sponsor on IPO - Deed of Counter Indemnity - Duty to Maintain Members' Register - Duty to Safeguard the Assets of the Enterprise - Duty to Safeguard Members' Records including Proxy Poll Voting Preferences - Certificate of Registration of Shares as Record of Registration (as opposed to being an instrument negotiable by transfer) - Payments on Account of Dividends (before approval by members, reflected in RNS with true proxy poll voting results- Dividends due but not paid (ie decision taken to pay) at Balance Sheet Date reportable - Annual Report and Accounts; Adoption of Accounts by Members; Officers Appointments including Auditor; Remuneration Report; Share Option Schemes; Shadow Directors - Capacity.
Court: Dis application of Privilege from Self Incrimination - Notice of Funding (filed on date agreement concluded) - Solicitor signing Claim Form ("the Claimant believes") recording Duty to Witness Proof - Notice of Change (Address for Service) - Application on Notice with Reasons and Evidence to Vacate or Adjourn - CRO by court of its own motion after strike out of claim or two applications devoid of substance (heard 12.2.19 and listed before Master Eastman Jan 2020 - TRD RNS March 2019 "default judgment" and "costs" meaning disbursements of £95k, being first and last two before CRO automatic. TRD RNS March 2019 reflects the Disenfranchisement of Members and Interference in the Register. This randomly names one member who had been the Target of Vilification and Hate Speech on Investor Chat and Supporting that Campaign by reducing their stated holding to accommodate phantom shares manufactured and sold by Chris Hardie, Arden, on unrecorded mobile calls outside any known licence).
2012 Folio 336 (protection from prejudice) Rider 6 (part)
Explanation:
- Riders 1, 3, 4, 5 are identity of defendants / changes of service address or legal form / pre service additions of defendants
- Rider 2 (2 pages) part of issued claim form 5 March 2012: damage mitigation re 6.3.06 ET1, together with wrong decision in EAT 18 October 2006 endorsing obstruction, a statutory offence. This was already in judicial system in Companies Court 6530-2005, 29 September 2005, at a time members were disenfranchised.
IMH retired by rotation in 2006. He told members in the presence of AMF, JR and JR's female valet, who picked up JR's jacket after the members meeting in 2006, that his (IMH's) money was locked into paying private school fees.
IMH omitted to mention that his true investment was in Vujou Limited (Nr 5655097) from 2005 with CJD and Marcus Gibbons. This was the man from whom AMF took instructions from the morning of 3 February 2005 in Milton Keynes. AMF's decision to knowingly forfeit any remnants of self-respect that remained, after "visiting" PwC on 20 January 2005 in secret, is unexplained. AMF's records of this event have been hidden by AMF for sixteen years.
This visit by AMF to PwC on 20 January 2005 was not revealed to his Board at the time and emerged only in October 2006, after four sets of live proceedings were issued, including HQ06XO1803, Herbert Smith, in June 2006. This secret meeting triggered PwC's exit from TRD. They had been in deadlock as a result of his refusal to meet them, particularly junior Fiona Kelsey who had stated, combatively, that she had wanted to "eyeball" AMF. AMF's reposte was: (gist) "no, what value do they add? I want this answered before I meet."
This rebuff of PwC made their exit inevitable, despite the alignment achieved by MM by 28 January 2005, not knowing that AMF was working against TRD in the background. MM instructions accepted by A&O were: "why are these guys competing with me?"
The secret activity undermined TRD, ended the relationship with Tony Bartlett ("I am never speaking to them again"), shareholder and director Arden and representative of Sponsor. He proceeded to give his own evidence to PwC of which he is an alumni, including Tim Pope head of PwC risk and legal who refused to see AMF or hear from him.
In addition, AMF's attitude to PwC broke the goodwill of each of the Sponsor and Abacus (C&L). As float Indemnifier to the Sponsor ("market"), AMF's indemnity was engaged. Unlike MM, AMF is not beneficiary of any Deed of Counter Indemnity. I 2005 AMF bought a letter from A&O addressed to PwC, stating that officers expenditure on behalf of TRD was indemnified under the articles. It went on to state that MM's expenditure did not qualify. A&O were not instructed by MM or TRD in creating this evidence to PwC, to support TRD expenditure funded by MM being excluded from the accounts, a pattern continuing until 2021, with unpaid dividends of £115k not accrued or reported.
In 2006, IMH's explanation to members was true: he had no "skin in the game" to speak of, and was not investing in TRD. The market likes to see leaders putting their hand into their pocket to buy shares, and strengthen the company as MM did in November 2002, spending £430k out of taxed income to buy out Dill Faulkes. This was to enable TRD severing from him, his divorce, his ex, their shares in onerous leases, terms of which they falsified on IPO, together with history of predatory sexual activity in the boardroom, that AMF ("semi detached" SSR) had done nothing about.
Since IMH retired by rotation in 2006, whether he invested in TRD or not, was of no interest. His investment in Vujou, with Dixie and others, however was. AMF was at a 2006 members' meeting but stayed mum about this dissipation of TRD goodwill which happened "under his watch" further to consulting with, and being influenced by, Gibbons 3.2.05.
IMH needed to save up whatever he had. This was to pay the Rule 9 mandatory triggered by trading after preliminary results for full year to 31.3.05 in July 2005, as member of the concert party that was created in January 2005. This was when AMF ordered IMH not to handover the information MM required of him, with the result the 2005 interim audit could not start. He continued to be used by AMF from January 2005.
IMH was protected by MM/TRD under TRD duty to act in interest of employees at all times CA 1985 s309 and mutual duty of confidence and trust.
- Rider 6 added 3 July 2012, served 4 July 2012
Below the start of Rider 6 applicable to each D
CLAIM UPDATE July 2012
EACH DEFENDANT (D): ALLEGATION AND REQUIRED ADMISSION
There are no separate particulars.
There are specific allegations against specific defendants alone or together with others and in any event part of collective action, triggering the requirement
Ds = Defendants severally, collectively and/or any combination
Headings part of the Claim
Claim drafted by C, someone known to Ds to be in person with no legal training, or qualifications;
BREACH OF IPR etc and/or ALIENATION FROM PROPERTY including contingent and/or intangible assets and/or access to civil relief and/or MONIES held (or which ought properly to be held) on Client Monies Account and which have not been returned (RJW) and/or INSURANCE MONIES under a contract of insurance that have not been paid and/or all interactions and consequential
1. Being in possession of statutorily confidential data, personal data, legally privileged data, litigation privileged data, data provided subject to purpose trust, implicit or explicit, without prejudice data, knowledge of all or any of these or any combination, that is properly owned by C and/or those entitled to file for judgment on admission and/or deemed admission and/or that was in the possession or knowledge of C* for a purpose and/or over which others have rights and/or interests and/or which C and/or which those entitled require in order to secure access to efficient civil relief from start of December 2004;
* should be Ds severally
2. Alienation of C and/or those entitled from the above and/or coming into the possession, control or knowledge of the above for purpose demonstrably authorised by C for one purpose on trust but used for another demonstrable to the financial interest of D, alone or together with other defendants, and against C and/or those entitled to file on admission or deemed admission;
3. Distortion of above data and information and malicious and/or vexatious transmission of such to other defendants and/or improper use of such used in the civil courts to secure relief for matters for which the civil courts cannot grant relief in particular the reputational damage that Ds have brought on themselves for which the civil courts cannot grant proper relief at the expense of C and those for whom C is executor and/or those who are Allen & Overy clients introduced by C and/or those whose estate is witnessed by Allen & Overy and/or partners/members of Allen & Overy, current or former
ONGOING DEFAMATION and attacks on C’s INTEGRITY
4. Defamation within one year of claim and/or on the same facts and included by subsequent amendment including but not limited to formal notice given to David Wootton, engagement lead at A&O, and Guy Wilkes (A&O) by Simon Bushell, Anthony Macauley, Andrew Brown, all Herbert Smith, that C’s integrity could not be bought at any price (24 November 2005) and/or all attacks on C’s integrity and/or attempts to compromise C including but not limited to C’s communication to Cameron Scott, FRC, dated 24 May 2007, on the FRC website, and/or actions, omissions and or representations including in the civil courts, and outside, together or singly or in subgroups, in continuous acts, omissions, distorted representations, unbroken since December 2004 and which have not yet ended triggering the start of the clock for the purposes of the one year time limit rule for defamation claims and or which have been frozen before C could secure relief while other pre-emptive attacks have started which form part of the same continuum and with the same purpose such that the trigger for the start of the one year clock for defamation claims has not yet been reached and or which are consequences of ALLIANZ LEGAL PROTECTION confirming legal expenses cover in June 2006 (contingent asset in C’s estate) and failing to provide it and or the Mayor and Commonality of London having a statutory obligation to provide a citizens advice bureau that can be relied on, in this case February 2007 to January 2011, and then closing it and issuing proceedings against C instead, undermining the reputational benefit that C had secured through RNS November 2006 and in the National Press 2005, and 2006, and creating a cause of action by C against David Wootton and the Commonality of London, that ought properly not to exist on the grounds that a statutory duty to provide a service is insufficient to give rise to a right of action in itself, but does once a civil claim is made, and consequential reputational damage to C with the City of London, landlord since 1983 and continuing and consequences; and/or similarly defamation by interference in relationships with family, fellow investors, investee companies including Headway Consultancy Ltd (directly or beneficially), A&O, PwC, counsel and leading counsel, knowledge and goodwill with A&O partners now trading as Maurice Turner Gardner LLP and members in other firms as Nabarro, without access whom any attempt to access own capital and assets including contingent assets, is bound to be futile (those of C and those entitled on admission or deemed admission), regulators and enforcers, the City and the market and acting to frustrate the work of the Financial Ombudsman Service, the FSA, DTI, now BIS prosecution of LLPs, the SFO/DPP prosecution of LLPs and members under the Bribery Act, enforceable from 1 July 2011, on their own irrefutable evidence; the SFO the SFO in issuing s2 notices on the date PwC decided to resign and the letter commissioned by PwC from A&O, both records of events for which C is responsible personally for maintaining properly, that were required to be delivered up in proceedings issued in the Companies Court in September 2005, and the further delivery up orders on 9 October 2006, and that RJW failed to secure by the end of March 2006 or at all, and the records of which attempts it has waited to 2012 to say it has not retained; default and/or on the return date to Master Leslie of 21 April 2011, proceedings live and default continuing;
5. Acting together or severally or in subgroups in protection (or enhance including by incorporating on a tax free basis, and “litigating away” contingent liabilities to C and those entitled, including by unlicensed risk transfer arrangements in defiance of POCA, licence terms of perpetrators, and in abuse of court, using C’s own assets and contingent assets) of the reputation of PwC, Allen & Overy LLP, Herbert Smith LLP, Barlowe Lyde Gilbert LLP, Clyde & Co LLP, Slater & Gordon (UK)LLP, formerly Russell Jones Walker, Wragge & Co LPP, Blandy & Blandy LLP, Fladgate LLP; Reynolds Porter Chamberlain LLP, Boodle Hatfield LLP, Mourant Ozannes (UK partnership); Mourant Ozannes LP (Jersey); Foot Anstey LLP; including consequent on Jack Naylor communications (PwC) via Barlowe Lyde Gilbert LLP/now Clyde & Co LLP that PwC with BLG would continue to alienate C from her personal property unless she gave an undertaking through lawyers not to use in a claim against PwC or to discredit them, December 06, blocking unfettered enjoyment of what belongs to C, including its use to protect the market and the integrity of the Companies House register, and her own reputation; through to threats of defamation claims by Naylor in April 2011, without specifics or quantification of purported damages; protection of PwC through illegitimate scuppering of other civil reliefs to which C is entitled including interim payment orders of £1.7m from PwC on 14 January 2011 and delivery up of personal records and data and damages to be assessed by the court further to Default Judgment for C against PwC (22 December 2010) and A&O (15 April 2011), the first served by C on PwC on 22 December 2010 and the second taken illegitimately from the Liverpool Court by Tom White Clyde & Co, ex BLG, to block notice on A&O, in the knowledge that this has made the Default Judgment a public document, contrary to the interests of A&O, and C’s requirement for private Hearings or dealings ex court with her own lawyers, in furtherance also of the co-operation between the Defendants to circumvent the return to Master Leslie due on 21 April 2011, and to make the embargo’ed judgment (the private thoughts of LJ Leveson, LJ Hughes and Sir Andrew Morritt), that was set to reverse before hand down to make lawful (and an approved judgment or order) and not a reversal of findings of fact and reasoning at first instance, referring to C as having a scatter gun approach to PwC and A&O, in circumstances that C was compelled to issue on the six year dead line by way of damage mitigation and defence against Herbert Smith LLP that sued C in June 2006 for circa £1/2m pounds that C did not have, and was run up contrary to instructions in a planned “outwalleting” exercise, and in an act of abuse of process as being properly a defence of proceedings C issued on 29 September 2005, in another court, Herbert Smith instructed and delaying from 7 February 2005 to 29 September 2005 in breach of contract on grounds of commercial alignment with PwC and facilitating their exit without challenge, and refusal to secure injunctive relief against named A&O partners, including for acting in own interest and in conflict, for fear of upsetting Guy Beringer, until told they were wrong by leading counsel in December 2005, when too late, including the fact that they had served on A&O and not the Company, thus deflecting service; accepting A&O acknowledging without instructions and indicating an impossible defence to alienation of C from her property; and proceeding to vacate a Hearing on 11 November 05 on grounds of saving counsel fees, until C could be made to no longer be a director, adding a further expensive hurdle of no real substance, that could only be relieved in the court.
COMPELLING C TO UNDERTAKE DAMAGE MITIGATION FOR LIMITATION REASONS, TO PRESERVE REPUTATIONAL BENEFIT TO C OF PRESS AND RNS, 2005-6, TO DEFEND ONGOING ALIENATION FROM ASSETS AND CONTINGENT ASSETS AND INTANGIBLES including GOODWILL and MONIES PROPERLY HELD ON CLIENT MONIES ACCOUNT, INCLUDING TO DEFEND PRE-EMPTIVE AND COLLATERAL ATTACKS IN THE COURT INCLUDING FROM SHAM LITIGATIONS (7EX00719, 7MY03183; 2IR75828); PROCEEDINGS and/or APPLICATIONS including requests for declarations, ISSUED as a response to an improper request, and no more than MISCHIEF; SWAPPING BY DEFLECTION POTENTIAL APPROVED JUDGMENTS FROM BECOMING ORDERS, and MANUFACTURING REPLACEMENTS hoping for BURDEN and RISK SHIFT, but in any event STALLING due process to hit TIME LIMITS, and REPRESENTING C WITHOUT C’s AUTHORISATION OR DIRECT ACCESS LICENCE USING C’S PRIVILEGED DATA AND OTHER PERSONAL ASSETS AND CONTINGENT ASSETS, INCLUDING PURPORTED CONSENTS BY C THAT C NEVER GAVE AND COULD NOT IN ANY CIRCUMSTANCES GIVE SINCE IT PROPERLY WAS NOT HERS ALONE
6. Causing C (and family) to have to defend the above unbroken 2005 to 2012; and obstruction of FIRST payment on account of £1.7m due on 14 January 2011, from PwC, that would have protected the elderly from the worse ravages of this unwanton attack on human beings, that would have permitted a modicum of respect and break from 14 hours a day defence work in addressing shams including in SCCO from May 2011 onwards and artificial hurdles as compelling each 6 minute time unit to be analysed on a purported bill of £78k plus £465k plus VAT to secure a nil assessment rather than strike out, triggering an underwriting agreement secured on C’s property by arrangement with Simon Rylatt, Boodle Hatfield, who signed a CONSENT Order in January 2009 in C’s name, agreeing her property could be taken, without her knowledge or authority, culminating in vexacious and malicious proceedings by Cogher and Saunders purportedly in the name of the City of London and David Wootton, Mayor of the City of London, an opportunistic abuse, to allow City to do forfeiture proceedings, grab the properties and defeat the theft by those seeking to deliver up the properties to the underwriter as the asset backing promised, for the off balance sheet transactions to keep contingent liabilities away from LLPs incorporating, including not limited to Baker Tilly and Fladgate LLP, suing C in June 2009 on the basis of a retainer successfully completed in 2006 by Burges Salmon and leading counsel from 4 New Square Chambers, that Fladgate said was with them, starting in April 07. Incorporation 1 April 2008, instructions to agree out of court return of capital advances with Edward Cooper, RJW, solicitor accepted by ALLIANZ in June 2006, and sacked by them on 17 October 2006 for failing to do any work or keep any records, including CLIENT MONIES, without C’s knowledge, discovered by FOS in 2011, with recommendation to issue proceedings.
7. Copies of PwC and A&O Default Judgments are PART of this Claim and not appended as EXHIBIT. Relief is in the default by Ds that caused the Claims to have to be issued. Loss of opportunity never to set foot in a court of law and for C to protect herself from public humiliation and comment as Mr Justice Teare, 15 July 2011, (gist) “you face a bill of £90k from Wragge & Co and David Mumford because you filed” six months after C was entitled to enforcement orders; and Mr Justice Simon, sealed 22 June 2012, (gist) “anything from you to the court will be filed and not looked at” an achievement of Ms Annelisse Day barrister, in reliance on representing C, through the improper and unauthorised use of C’s legally privileged data, while purporting to represent A&O, in both cases without direct access licence, and making public a rift between A&O partners that otherwise would not have got out publicly, depriving C of mitigating reputational damage to A&O her supplier regardless of the fact that they may have brought it on themselves;
LOSS OF OPPORTUNITY FROM THE ABOVE AND FROM CLAIM FORM 5 MARCH 2012
8. Includes but not limited to ADMISSION REQUIRED BY ANDREW CLARK that A&O assessed damages on loss of opportunity by frustrating the Company turn around post share buy back (RNS November 2006) in November 2003, through David Wootton, as £200m, cash exit value offered when Company was trading at £178m, loss of opportunity opportunity to complete the turnaround extrapolation forward to accommodate contracts length and client quality at 2004, industry consolidation at that time, resilience of engineering service revenues to financial shocks and turbulence, opportunities created by the vacuum from industry consolidation in Europe, Channel Isles, Hong Kong, and other locations of the clients and goodwill of the business, and move to shared back office services in the public sector, a key market;
9. Includes but not limited to loss of opportunity to achieve the predictable financial results and outcome in regard PwC Default Judgment and A&O default Judgment plus proper treatment under CPR that each are now treated as having Admitted the Allegations in the Claim Form and P particulars by 29 September 2005 (first proceedings issued by Herbert Smith) ; mitigate the damage by Herbert Smith issuing on 29 September 2005 instead of 7 February 2005, for a short wholly uncontested Claim for delivery up to C of her own property and data; mitigate the damage caused by A&O accepting instructions on 13 January 2005 on matters confirmed by PwC on 25 July 2005; mitigate damage by PwC omitting to decide to resign citing loss of independence on 13 January 2005; mitigate damage by PwC removing Chris Maidment as partner in early 2003, and allowing Bill Brown to retire on 30 June 2004 in both cases without parallel running by a replacement for two financial years, no notice, in the second case date provided January 2011, immediately after a share repurchase in 2002, and incorporation in 2003, to LLP, leaving Alistair Rose stated to be the partner responsible, remote and providing an audit certificate to A&O, in exchange for A&O assuming the auditor’s risk and undoubted reputational damage, and A&O using control of C’s estate and representations made to third parties in her name as well as distorted privileged data, to eliminate the risk for PwC, ward off the FSA for PwC (8 September 2005); mitigate damage by Andrew Clark who told Lord Justice Goldring in the C of A (2009/1711/B) in a letter to secure a STAY on C’s home being taken, that C’s files from pre 1990 had gone in a fire in July 2006, which could not have been true as A&O were delivering them up to C in a process started in September 2005 in their own offices (Clark) but omitting to say that Clark had ordered the Royal Bank of Canada in September 2008 to “close the files” without authorisation, permanently alienating the family from its bankers, and preventing A&O reconstructing the files from the evidence held by the bank in its vaults; mitigate damage from the stalling of executing transfer of legal title to assets beneficially owned by C, and others with interests in her estate, a notarization task stalled from December 2004, and treated as admitted in the A&O Default Judgment; mitigate damage from the loss of opportunity in regard Headway Consultancy Limited, that was following the Generic trajectory with investment through Abacus/RBC from 1995, flotation 1995 £34m of which Generic was 20% reaching 20% of £178m by 1998/9, and further loss of opportunity by Headway losing its access to the client base in the Company that could not have been won without Headway, as well as Headay as a platform to replace the Company from 2004, on its own goodwill and engineering skill and track record; culminating in staff being made redundant in December 2008, without recompense to anyone concerned, a disastrous result for an engineering company supplying ground control and space and defence industries, co founded by entrepreneur who was awarded with an OBE for export services in space on the back of this work .
10. Loss of opportunity deriving from multiple breached of Human Rights act, details above and in Claim Form 5 March 2012, not yet served.
BREACH OF CONTRACT AND CAUSE CONTRACT TO BE BROKEN – written and by conduct, including in regard all licensed legal persons with duties to someone in person in which they have defaulted
11. Direct written contracts or documented by instructions for which there is default by Ds apply at least to ALP; DWF; RPC/Boodle Hatfield/Baker Tilly through Pinsent Mason, Mediator; Russell Jones Walker (now Slater & Gordon (UK) LLP; Fleet Solicitors; Mayor and City of London (NOT INCLUDED); and indirect, including by representing C without her consent or using her data and or other property tangible or otherwise with or without her agreement apply to the rest.
BREACH OF STATUTORY DUTY
12. Alienation of C from records that must be provided to her to maintain properly and/or causing or permitting those with a direct statutory to deliver these up to C to fail, in particular BLG/Clyde & Co re PwC.
13. Reporting as statutory auditor without properly agreeing estimates and information in LLP accounts to underlying records including letters to the auditor and insurer and VAT and CGT potential liabilities on a timely basis or at all (A Rose PwC re A&O) (D Blancher re Reynolds Porter Chamberlain LLP) (Kingston Smith re Baker Tilly LLPs and Holdings Ltd), such default enabling the customers to trade profitable enjoying preservation of reputation, whilst attacking C, using her own assets and contingent and intangible assets, and destroying her investments and reputation of integrity, as well as enjoy personal freedom and autonomy including to enjoy her estate and life unfettered by the humiliation of 2005 to date.
ABUSE OF COURT including Ds acting together in SHAM PROCEEDINGS for a purpose
14. Default by extortion, blackmail and abuse of court to steal assets including money property reputation in the courts and assets of human rights; Jamie Smith Ben Wood, apprentice in 2005, Angus McNicol, Foot Anstey, Blandy & Blandy, Jonathan Gater Boodle Hatfield Tim Manning Sophie Hoffman Simon Rylatt, proceedings started on A RECEIPT FOR CASH from C/Royal Bank of Canada, presented as a purported UNPAID bill by Jamie Smith when the true position was that court told on 23 July 2007 that RJW had NO BILLS and NO RECORDS and held this was for the SCCO (January 2009) proceedings blocked by Simon Rylatt that would have caused the return of £640k, gifted earlier to Angus McNicol and others by Sophie Hoffman, and in the Appeal Court where it was said C’s counsel was instructed by Foot Anstey (untrue), RJW issued bills and a complaint was not made in time (referral to SCCO), Jamie Smith’s pupil in attendance, whereas the true position was that RJW was the responsibility of ALP that accepted cover by 30 June 2006, and had there been bills they would have been for ALP’s account.
15. Support for McNicol and Wood by Jonathan Gater and Blandy & Blandy in fake orders and bailiff’s warrants and circumventing relief by Application from C in Reading court, providing a distorted account to Master Fontaine, Wood citing “abuse” to strike out relief; further Wood falsely telling court that C gave undertaking to pay him money, such that C was at risk of custodial sentence by way of penalty, if it was not paid, leaving C and elderly widowed mother in extreme despair and further seeking court order that C’s front door would be broken down by bailiffs; terror campaign from April 2008 to April 2009 for the sole purpose of averting SCCO hearing and acceptance by the court there are no bills or records from RJW and if there were they would be paid by ALP, who had sacked RJW, who lied saying C had gone elsewhere of her own motion (October 2006 exchange, hidden by RJW from them to July 2012).
16. Untruth by Carl Trouman to Master Leslie (17 June 2009 onwards) that C had a contract governed by privilege with the former Baker Tilly partners ie NOT an INDEPENDENT Opinion, working as labour resource to Burges Salmon, when the true position was that the court order 1 August 06 entitled C to the benefit of an INDEPENDENT Opinion, and the contract was between C and her choice of INDEPENDENT expert, and C appointed Baker Tilly in August 06 with a delivery date post delivery up of C’s records and data of 13 October 2006, when RJW was the solicitor on the record. Mr Trouman did not tell Master Lesley his account was a nonsense not least because Baker Tilly did not have control over the privileged data, and could not get it from court records as the court deletes one year after last record, January 2008. He omitted to say that parties working together (Cumberland Ellis, RPC, Baker Tilly, Boodle Hatfield, others) had told C that they would not withdraw sham proceedings unless C agreed to sign an UNDERTAKING that Burges Salmon LLP were at fault for Baker Tilly’s defaults and received some payment to indicate being let off, continuing to hound BS that C had consented to waiver of privilege when she had not until Travellers, BS insurer compelled BS to freeze acting, BS having been instructed in securing the Opinion and the sham litigation.
17. Abuse of court by members and staff of Reynolds Porter Chamberlain LLP against C, with Boodle Hatfield, and those required to make a return by 21 April 2011, before the Court of Appeal and SCCO (VOLUME A B C) and included in time records appended, Christopher Semken and Carl Trouman included.
18. Abuse of purpose trusts including in pre emptive and collateral attacks, including holders of data and client monies/information, particularly Andrew Clark and RJW
Facts true to the best of my knowledge and belief, Claim issued 5 March and reissued July 2012, before service.
Mira Makar MA FCA 3 July 2012
19.
Facts true to the best of my knowledge and belief, Claim issued 5 March and reissued July 2012, before service.
MIRA MAKAR MA FCA – 3 JULY 2012
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