BLUFF JUSTICE. Yafa Partner & Paddy Gormley

Transcription

1 BLUFF JUSTICE is the story of one victim's ill-fated attempt to fight back: the desperate pleadings of a desperate, impoverished, vulnerable woman, now in her late sixties and suffering from deeply debilitating illnesses arising from this scandal. Her story is told under Privilege in a series of sensational court documents. Her shocking account of the conspiracy, involving not only Ealing Borough Council, but also Thames Water, HSBC and the Metropolitan Police, was submitted to the Central London County Court, but judged to be irrelevant, and the evidence of her non-lawyer representative was deemed inadmissible. She is now under threat of imminent eviction from her home. BLUFF JUSTICE For nearly 30 years, the London Borough of Ealing has facilitated criminality at 353 Uxbridge Road by condoning breaches of restrictive covenants, abuses of planning permissions and blatant industrial pollution. Neighbours' lives have been blighted, their land contaminated and their property values undermined. BLUFF JUSTICE Is this justice? Judge for yourself as you read these pages. Yafa Partner & Paddy Gormley Yafa Partner & Paddy Gormley

2 BLUFF JUSTICE is the story of one victim's ill-fated attempt to fight back: the desperate pleadings of a desperate, impoverished, vulnerable woman, now in her late sixties and suffering from deeply debilitating illnesses arising from this scandal. Her story is told under Privilege in a series of sensational court documents. Her shocking account of the conspiracy, involving not only Ealing Borough Council, but also Thames Water, HSBC and the Metropolitan Police, was submitted to the Central London County Court, but judged to be irrelevant, and the evidence of her non-lawyer representative was deemed inadmissible. She is now under threat of imminent eviction from her home. BLUFF JUSTICE For nearly 30 years, the London Borough of Ealing has facilitated criminality at 353 Uxbridge Road by condoning breaches of restrictive covenants, abuses of planning permissions and blatant industrial pollution. Neighbours' lives have been blighted, their land contaminated and their property values undermined. BLUFF JUSTICE Is this justice? Judge for yourself as you read these pages. Yafa Partner & Paddy Gormley Yafa Partner & Paddy Gormley

3 Contents Introduction by Paddy Gormley 2 1. Yafa Partner s Witness Statement 6 2. What happened next Paddy Gormley s Witness Statement Paddy Gormley s Case Notes Part 1 78 Part Concluding Remarks by Paddy Gormley 192

4 Introduction by Paddy Gormley In 2012, the London Borough of Ealing (LBE) petitioned for the bankruptcy of Yafa Partner on the pretext of council tax arrears. The bankruptcy order was made in the Central London County Court on 1st October 2012 (case 2385 of 2012). Mrs Partner had been in dispute with LBE for about thirty years because her life, her daughter s life and their home, at 351 Uxbridge Road, were ruined by serious environmental pollution emanating from the industrial premises next door at 353. Along the way, there were breaches of restrictive covenants governing 353, blatant abuses of planning permissions, shocking instances of industrial filth, and more. LBE turned a blind eye to every one of them. The industrial works at 353 were demolished in 2005, ancient oil tanks under the ground were dug up, incinerated on site (see cover photograph), re-interred and covered up. Work began immediately to build the residential apartment block that now stands on the site and on a strip of land grabbed for 353 from Yafa Partner s driveway. Ealing Council steadfastly ignored the protests of Yafa Partner and her neighbours and supporters, including the local press, and rebutted all suggestions that the land was contaminated (see back cover). To this day, LBE still maintains that there was no contamination at 2

5 353 and ignores the plain truth that ancient trees in all the gardens touching on 353 have died horrible black deaths. A local tree surgeon suffered major respiratory problems after cutting down one of the dead trees in a neighbouring garden in Most of the victims have either died, gone away in anger and frustration, or given up the fight. Only Yafa Partner remains, in extremely poor health, her crumbling house standing as a testament to the lies and corruption of the London Borough of Ealing and its corrupt associates. Yafa Partner has sought to plead her case in court on several occasions, despite the fact that she has been unable to meet the costs of legal representation. LBE has used its superior forces of money and legal knowledge, with the help of a series of devious and sly tactics outside the courts, to ensure that the bankruptcy was ordered and upheld. Her final attempt to have the bankruptcy annulled was dismissed by the court on 17th April She has been given notice that she is to be evicted from her home on 12th May. Is this equality under the law? Is this justice? Judge for yourself as you read these pages. Each of the chapters of this book is taken from the court papers. The first chapter, Yafa s main witness statement, makes hardhitting allegations against LBE and others. The court ruled that the statement was largely irrelevant to the matter of her bankruptcy. The statement remains in the public record, however. Mrs Partner is therefore entitled to publish it in its entirety 3

6 under Privilege and without fear of reprisal not that she has much to fear from anyone after what she has already suffered. I enter the story in the second chapter of this book. Yafa had asked me, in 2011, a year before the court action began, to help write her autobiography,. So began my work of research and analysis that has made this book possible, including the drafting of Yafa s main witness statement (often referred to in this book as the Big Statement ), which she could never have done without my help. I subsequently offered to represent her in court to the best of my ability, since she could not possibly afford the costs of proper legal representation. I m no lawyer. I had to pick things up as I went along, and I made many mistakes. There were several fallingsout between Yafa and me along the way, and these too have their part to play in the saga that is about to unfold to you. And, insofar as the bankruptcy order still stands, and eviction looms large, we failed miserably. I constructed a case for her and presented my credentials by way of the witness statement that forms the third chapter of this book. When it came to the final hearing, my case notes were deemed inadmissible: it appeared to the court that I was trying to conduct Mrs Partner s case for her, but I had no rights of audience in the Central London County Court. Accordingly, none of the case notes that you will read in the fourth chapter of this book have been taken 4

7 seriously in court. I don t take the rejection personally. But I am appalled for Yafa s sake. LBE has enjoyed every possible advantage in this case, and yet the Court chose to compound Yafa s countless disadvantages by ignoring her desperate pleadings in the Big Statement. The ruling that I could not represent her in the Court was tantamount to saying that her case would never be heard in court, and so, Yafa was denied her only hope of justice. Irrelevant as my case notes may have been in the eyes of the Central London County Court, I stand by every word of them. Do not be put off, gentle reader, by the dry-as-dust, analytical style of the early notes, whereby I hoped to undermine the witness statement of LBE s solicitor by finding fault with every aspect of his analysis. Read on, and, I promise you, before long you will be laughing aloud. The parties to this case have lied and cheated their way at every step of these proceedings. As far as the Central London County Court is concerned, these villains are innocent people all. Let us see how they fare in the court of public opinion. 5

8 Chapter 1 Witness Statement dated 6th June 2013, including corrections and clarifications dated 13th June 2013 by Yafa Partner 1. I shall argue, in the course of this statement, that the petition that gave rise to this bankruptcy order is unprincipled, unnecessary, devious, draconian, an abuse of the insolvency legislation, and therefore fundamentally unjust, and that the petition should never have been brought to the court. POSTPONEMENT OF THE CREDITORS MEETING 2. Accordingly, I beg the court to order the postponement of the meeting of creditors currently scheduled to take place on 14th June 2013 pending the outcome of this matter, so that the parties to that meeting may be prevented from taking any precipitate action prior to the court ruling. 3. As a precaution against the eventuality that the court may be unable to order the postponement of the meeting of creditors, I am taking steps to ensure that each of the principal parties to that meeting, whom I understand to be The Official Receiver, the Trustee in Bankruptcy and the Chief Executive of the London Borough of Ealing ( LBE ), will receive a copy of this statement by way of Royal Mail s tracked delivery 6

9 service at least three working days before the proposed meeting. Whilst I claim no knowledge of the law, I only hope that the court may deem any subsequent prejudicial action by any party to the creditors meeting prior to the court s ruling in this matter to be tantamount to a contempt of court. LBE S FAILURE TO COLLECT COUNCIL TAX PROMPTLY AND EFFICIENTLY 4. LBE knows perfectly well that, prior to the bankruptcy order, my assets were far in excess of the sum demanded of me and, accordingly, that LBE s bailiffs could easily have recovered, in the course of the last few years, the council tax allegedly owed by the time of the bankruptcy petition. Such enforcement of LBE s liability orders would better have satisfied LBE s statutory duty to collect council tax more promptly and efficiently than this bankruptcy order, while avoiding the cruel extremity of causing me to forfeit my home, all my possessions and all hope of ever again being able to live in peace and dignity. 5. Instead, LBE has desisted from all enforcement action for the last six years, for the sole purpose, as far as I can tell, of compounding my council tax liability to the point at which LBE might credibly instigate bankruptcy proceedings against me. From this I conclude that LBE has repeatedly failed its principal obligation to the Crown, which is to collect council tax promptly and efficiently without fear or favour. 7

10 LBE S UNSCRUPULOUS ATTEMPT TO FORECLOSE A THIRTY YEAR DISPUTE WITH ME 6. This bankruptcy order is a draconian contrivance by LBE to foreclose a decades-long dispute with me by impoverishing me, discrediting me and rendering me homeless, so that I might never again be able to call LBE to account for its unremitting abuse of the powers vested in LBE by the Crown. I shall give further details of that dispute in the course of this statement, but the summary point is that my refusal to comply with LBE s demands is wholly motivated by my determination to achieve a just resolution to the said dispute. My refusal to comply with LBE s demands has nothing at all to do with my ability to pay, nor have I ever disputed my liability to council tax. LBE is perfectly well aware of these facts, and has chosen to mislead the court by pretending that this bankruptcy order is a legitimate course of last resort. 7. This bankruptcy order is an abuse of the insolvency legislation by LBE, insofar as LBE s petition for my bankruptcy, far from aiming to bring relief to a distressed creditor in keeping with the spirit of the insolvency legislation, was intended to ruin me once and for all. THE UNSALEABILITY OF MY HOUSE 8. There is no need to sell my house. It is manifestly unsaleable anyway, as LBE also knows, following a series of incidents for which LBE is partly responsible, and which began no later than I shall return to these incidents later in this statement but, for now, I need only say that the foundations of my house 8

11 suffered a major flood because of an illegal water supply to 353 Uxbridge Road, the property next door to my house ( 353 ), which supply took water from my supply and at my expense. As a result of the flood, my various attempts to sell my house have been consistently thwarted by intractable issues concerning the stability of the house and the fact that it appears to be uninsurable. LBE S FAILURE TO RENDER A TRUE ACCOUNT OF MY COUNCIL TAX LIABILITIES 9. For many years, LBE has manifestly failed to render a true account of my liability to council tax despite repeated demands for such true account. I have made many payments of council tax over many years, which payments have never been acknowledged or taken into account by LBE. These include a single payment, in May 2007, of approximately 3,500 to a council official, during a well documented incident that was witnessed by three people, including my then solicitor. I have made vigorous and sustained efforts to call LBE to account for this and other incidents, sometimes with professional help, incurring huge solicitors fees that amount to nearly as much as the sum demanded by LBE in the petition that gave rise to this bankruptcy order. Despite these efforts, LBE has consistently and stubbornly failed to explain its conduct. THE QUESTIONABLE QUALITY OF LBE S RECORD-KEEPING 10. I would like to draw the court s attention to two other pieces of evidence that directly call into question the quality of LBE s record keeping. 9

12 10.1 In June 2012, I took the opportunity, at a magistrates court hearing in respect of a liability order against me by LBE, to protest that LBE s statement of my council tax did not include a payment of 1,442 made to a bailiff in LBE, stung, no doubt, by my allegation of fraud, was uncharacteristically quick to respond. LBE very cleverly succeeded in altering one of the figures in the statement so that it now said 1,442 while, magically, the total sum demanded of me was unchanged. This was obviously instrumental in sparing LBE the trouble and embarrassment of having to reissue the bankruptcy petition, which was served upon me on the very day of the magistrates hearing, but it demonstrates LBE s creative approach to council tax accounting The list of liability orders in the bankruptcy petition itself is erroneous, insofar as the liability period is duplicated. Whilst I cannot tell whether this error is material in terms of the integrity of the petition, I suggest that the reliability of any organisation that can make such a serious error in an extremely serious legal document should be open to question. MY EFFORTS TO INVESTIGATE SUSPICIOUS TRANSACTIONS 11. My bank statements reveal that HSBC has made a series of payments on my behalf to a Morrison Card (a VISA card scheme devised and controlled by HSBC for customers of Morrisons Supermarkets), despite the fact that I have never been in possession of any such card. The first of these payments was at the time of the aforementioned incident in May 2007, 10

13 and in the sum of 3, The timing of the sum of this transaction and the suspicious nature of both transactions suggested a coincidence too striking to be ignored. The payments to Morrison Card continued until June Suspecting that some or all of these payments might correspond to occasions when I had thought I was paying council tax, only to discover much later that LBE had not taken account of the transactions, I proceeded to make vigorous and sustained efforts to enlist the help of the Metropolitan Police, and of my bankers, HSBC, in pursuit of the plain truth about these transactions and about other highly suspicious transactions on my accounts with HSBC. All these efforts have proved fruitless, despite the fact that I have provided copious documentary evidence in support of my assertions, and despite the fact that I have persevered with my enquiries, elevating them respectively via the IPCC to New Scotland Yard, and to the Group Chairman of HSBC. HSBC S ABUSE OF MORRISONS NAME 13. I greatly fear that Morrisons may be the innocent victim of a fraud by HSBC employees. Morrisons has confirmed that the proceeds from the Morrison Card scheme were entirely garnered and controlled by HSBC, and that Morrisons would have no hesitation in assisting with police enquiries. But the fact remains that HSBC appears to have abused Morrisons good name by associating it with extremely dubious dealings without Morrisons knowledge and beyond Morrisons control. 11

14 LBE S PREVENTION OF A PRIVATE SALE OF MY HOUSE 14. In September 2012, I made a final attempt to preempt the bankruptcy order by arranging a private sale of my house for redevelopment. LBE thwarted the sale by ignoring an attempt by the potential buyer to make discovery of any information held by LBE concerning the state of the foundations of my house and its water supply. If LBE had been serious about collecting council tax, it would surely have made rapid disclosure of the salient facts for the information and reassurance of the intended buyer of my house, so that the sale might proceed and my debt of council tax might be promptly discharged. LBE s conduct of this matter suggests that it does not come to this court with clean hands. LBE S HIDDEN MOTIVES FOR BANKRUPTING ME 15. I believe that LBE was and is determined to take control of the site on which my house is built, in order that LBE may at long last be at liberty to eradicate all residual evidence of its role in the thirty year scandal concerning environmental pollution, contaminated land and development irregularities at 353, 355 and 363 Uxbridge Road. 16. I further believe that LBE is exploiting every opportunity to acquire properties in the block where I live, in view of the strategic development potential of such properties. One local estate agent describes the block on which my house stands as a prominent main road location which could be of interest to professional users. I would go further. It is evident to me that the 12

15 properties in my block, when considered collectively, would form a vast, potentially hugely lucrative site that would be of enormous value, far beyond the combined value of the existing residential properties, to commercial property developers. Insofar as my house stands close to the mid-point of the block, it is an essential target for any such portfolio. 17. In short, I consider that this bankruptcy order has been largely motivated by LBE s intention to grab my property under the guise of an arrangement designed to look like the logical outcome of a tragic bankruptcy order, when it is in fact an unscrupulous land-grab: a covert sharing of the spoils between LBE and the Trustee in Bankruptcy, guaranteed to deliver handsome profits to these two parties alone, while ensuring that no other potential buyer of my house may stand in the way of LBE s hidden agenda. GROSS MISCONDUCT BY THE OFFICIAL RECEIVER 18. I wish to raise the strongest possible complaint against the Official Receiver for his conduct of the matter of this bankruptcy. At a meeting in October 2012, shortly after the bankruptcy order, and in the presence of my daughter and of one of my supporters, he told three blatant lies My supporter offered to pay my outstanding council tax for financial year , to which the Official Receiver replied but she s paid it already. I had done no such thing The Official Receiver went on to assert before all present that, apart from the payment, I 13

16 had not paid any council tax for ten years. This was patently untrue, as even LBE could affirm He also said that my erstwhile business venture, Holistica Biotech, was still trading, despite the fact that it had been dormant for several years, and that Companies House had already published the strikingoff notice in The London Gazette. 19. My daughter was utterly shocked and horrified by the Official Receiver s defamatory remarks, which branded me as a liar in her eyes, and so it was that my previously amicable relationship with her was utterly shattered, and has never properly recovered. 20. The Official Receiver s mendacious behaviour continued after the meeting, when he returned my court papers in a state of disarray. 10 of the 31 pages were missing, and other pages had been jumbled together in what I can only imagine to have been a further attempt to make it seem as if I were a slovenly and hopelessly disorganised person, with a view to discrediting me in the eyes of the court and of anyone else who might bear witness to my demise. 21. I imagine that the Official Receiver s role in such meetings is rather like that of a prison officer who strips the convict of all possessions and dignity before consigning him to the cell. I can see how some people might take sadistic pleasure in the privilege of being at liberty to defame and discredit their victims with impunity, safe in the knowledge that there is no further hope of access to justice for the utterly defamed and discredited. But do the courts routinely turn a blind eye to defamation and mendacity by their appointed officers? I sincerely hope not. 14

17 22. In February 2013, my daughter informed the Official Receiver that sufficient money had actually been raised to discharge the bankruptcy. The Official Receiver demanded the sum of 31, I had already been warned before the bankruptcy that the very biggest players in the insolvency industry would be desperate to win the trusteeship, ostensibly because of the complexity of the case, but really because of the richness of the pickings. After all, any high street solicitor and estate agent could competently carry out the work of selling my house and paying off the creditors for a few thousand pounds. 24. I could not help noticing that the sum demanded of me in February was nearly half as much again as the sum of the bankruptcy order. I was shocked to think that these people had already conjured up ten thousand pounds worth of expenses. What value had the Crown derived from such costs? The Trustee hadn t even done me the courtesy of returning my telephone calls, so what was he actually doing? I dare say I will never know the answers to these questions but, if I was going to discharge the bankruptcy now, I was determined to know who was pocketing the money so generously raised on my behalf. 25. I told the Official Receiver that I would make the payment on condition that he first provided me with a detailed account of the sum demanded. He never did so. Like LBE before him, the Official Receiver was now manifestly failing his obligations to the court and to the Crown by wilfully refusing to exploit an opportunity to discharge the bankruptcy. 15

18 26. I can only conclude that the Official Receiver is primarily interested in oiling the wheels of the bankruptcy business and not remotely interested in justice. This man has made a mockery of his office, and of the court. MY FINAL OPPORTUNITY TO PUT MY CASE IN COURT 27. I am acutely aware that, if the court rejects this application for an annulment of my bankruptcy, this witness statement may well be my last word in an English court of law. In the paragraphs below, therefore, I exercise my right to catalogue my grievances in the public record. 28. My grievances against the above mentioned wrongdoers in the context of this case are palpable enough, and I shall return to them before this statement is concluded. But first, I must expose for public scrutiny the roots of the many-canopied tree of injustices that have given sap to the crowning injustice of this bankruptcy order. 29. LBE is but one of many villains in this piece and, if I seem to digress at this point, it is only because the true extent of LBE s villainy can only be seen in the context of the bigger picture. And it is no accident that the bankruptcy petition came from LBE alone, rather than others acting in concert: whereas most organisations could not possibly hope to bankrupt me (since my equity in my house is many times greater than the sum of all my debts), LBE s legal obligation to collect council tax offered the perfect cloak for a bankruptcy order whereby I might be silenced once and for all. 16

19 30. I should add that I have been assiduous in the collection of documentary evidence since the earliest days of this dispute, and that I have now catalogued virtually all of it in a remarkably comprehensive, computerised, fully indexed archive. Accordingly, I am readily able to bring evidence, in support of almost every fact in this statement, as I shall demonstrate in a small way in the paragraphs below. THREE DECADES OF VICTIMISATION BY LBE 31. My troubles with LBE began in the early 1980s, when my husband and I separated, leaving me as a single parent to bring up our young daughter. At almost precisely the same time, the rarely visited Ewin s Radio warehouse at 353, adjoining my property along its western edge, was replaced by a busy car repair workshop. 353 has given rise to countless problems for me ever since then, including, but not exclusively: 31.1 emanation of toxic substances, 31.2 contamination of my land, 31.3 serious contamination of and disruption to my water supply and drainage facilities, 31.4 serious environmental pollution arising from the unsafe removal of a huge asbestos roof by two teenage men using blow-torches but working unsupervised and without facial protection (as illustrated here in Exhibits 1 & 2: these photographs were taken from an upstairs window of my house) under instruction from demolition company Frank Valori Demolition Ltd, which demolition company was subcontracted to 17

20 Kewmoor Limited, and of which demolition company Timothy John Burke, a director of Kewmoor Limited and Managing Director of Kewmoor (Construction) Limited, of 72 Fielding Road, London, falsely declared to the Brentford County Court in Paragraph 5 of Timothy John Burke s statement dated 25th April 2005 in response to claim number SBF01966, which claim was an Application for an Injunction by me against Timothy John Burke s companies Kewmoor Limited and Kewmoor (Construction) Limited, although Kewmoor (Construction) Limited was not named as a party in the action, from continuing to demolish a garage workshop at 353 Uxbridge Road, from excavating and constructing foundations for a new building and from encroaching on my property at No. 351, as follows: The demolition work is being undertaken by our specialist subcontractor, Frank Valori Demolition Ltd in a professional manner in accordance with all current Health and Safety legislation and best working practices ; 31.5 and, most recently, a land-grab, in the sense that the eastern wall of the residential apartment block subsequently constructed at 353 Uxbridge Road encroaches on my land in by more than a metre along the full length of the said eastern wall. Exhibit 3 (April 2005) shows the workmen from 353 trespassing on my land and preparing to destroy shrubs in my garden. 32. The responsibility for such problems obviously does not rest solely with LBE. However, LBE has inevitably been one of my first, and one of my neighbours first ports of call in our protests against the many dubious goings-on at 353 Uxbridge Road. In the face of such protests, LBE has consistently and 18

21 unfailingly sided with the freeholders, leaseholders and tenants of 353 Uxbridge Road. It is for this reason that I hold LBE answerable for the environmental pollution scandal at 353 Uxbridge Road in the 1980s and for everything that has flowed from it, including, in addition to the items already listed: 32.1 my near fatal illness; 32.2 my daughter s illnesses, incapacitation and inability to abide in her childhood home; 32.3 the unexplained death of a near neighbour, who died in her thirties of a mysterious cancer (vociferous calls for a full enquiry were dismissed by all parties with something to hide); 32.4 the ruination of my house; 32.5 the collapse of my erstwhile bed & breakfast business; 32.6 my need to live elsewhere for extended periods because of the health risks of living in my own house; 32.7 my inability to insure my house; 32.8 the alienation of the tenants in my upstairs flats; 32.9 and more. LBE S DARK SECRETS ABOUT THE SITES AT 353 & 355 UXBRIDGE ROAD 33. At this point, it seems appropriate to add a further narrative in support of my earlier hypothesis that LBE s interest in my house is strategic. The narrative concerns the ownership of 353. This has been a matter 19

22 of abiding interest to me, of course, in view of the many conflicts arising from my proximity to 353, and I have made frequent attempts to discover the truth. 34. I am in possession of a letter from LBE confirming that Tesco (which owns the site at 363) was a one-time freeholder of the site at 353. In fact, LBE s planning department lists at least one planning application in 1998 (TPAP 07392/18, dated 23rd June) confirming that Tesco owned all the freeholds from 353 to 363 at the time. I am also in possession of a written denial from Tesco that Tesco ever owned 353, so either LBE or Tesco must be telling a lie remains a potential source of major embarrassment to LBE because it is built on contaminated land, though LBE has consistently denied this. Exhibit 4, again taken from an upstairs window of my house, shows old oil tanks, just dug out of the ground at 353, being burned on site. These tanks were badly rusted and incontinent even before the burning began, and it was evident that they must have leaked considerable toxic waste under the ground at 353. The remaining vestiges were crushed and buried and, as Exhibit 5 shows, the site was levelled so that work could begin immediately to construct the apartment block now standing at I am alarmed to see that another large apartment block has recently been constructed, by the same company that appears to manage 353, on the site of the former bus station near Acton police station. I am acquainted with some of the traders there, and they tell me that their cellars are still subjected to pollution from the contaminated land under the former bus station. 20

23 37. There is clearly a problem concerning the title of 353. A demonstrable marketing campaign to sell the apartments there failed badly despite the buoyant property market conditions prevailing at the time. Most of the apartments at 353 are still rented, and I suspect that the few sales may have been fraudulent, insofar as the property company may have taken the buyers money without ever transferring title to them. 38. I have made strenuous efforts to persuade LBE to reveal the truth about the ownership of 353. When I last tried to obtain the information, by visiting LBE s offices in January 2012, LBE employees lied to me by telling me that there was no apartment block at 353, and sought to have me ejected from the building. A sympathetic security guard helped me to raise a formal complaint which LBE, true to form, has never answered. 39. In short, I would not be at all surprised to hear that LBE and others have a secret plan to consolidate all the sites from 339 Uxbridge Road to 363 Uxbridge Road, because it would enable them to destroy potentially damning evidence not only of the wrongs done against me, but also of the no less embarrassing scandals concerning land contamination, title and planning irregularities. THE PATTERN OF LBE S CONDUCT TOWARDS ME 40. My dispute with LBE has never abated since these troubles began, and my efforts to hold LBE to account have been unremitting. In all this time, LBE has adhered to a consistent pattern of conduct towards me that may be characterised in the following terms: 21

24 40.1 In any matter requiring a judgment by LBE as to any potential conflict between my rights as a householder and the rights of any organisation, including utility companies, commercial freeholders, commercial leaseholders, property companies and LBE itself, LBE invariably maintains that the organisation is in the right, and that I am in the wrong LBE never offers any proposals or suggestions that might help me in any way. For example, in the interests of ensuring that I was treated fairly in matters of council tax liability, and in view of our unending correspondence concerning council tax, LBE should surely in all fairness have informed me of its council tax discount policy to the effect that I was eligible for a reduction of 25% in my council tax bill at times when I was the only adult living in the property and that I was eligible for a 10% discount when the house was unoccupied because I was living elsewhere. In fact, I have only recently learned, from another source, of LBE s council tax discount policies LBE invariably ignores or else finds reason to dismiss summarily any applications for grants or other assistance that might be awarded to me at LBE s discretion LBE offers little or no response to communications by me and by others acting on my behalf, replying only to decline or rebut suggestions and proposals, and ignoring or denying the existence of communications that do not accord with LBE s motivations and fixations. One of LBE s favourite ploys in the case of my letters sent by Royal Mail s tracked delivery service (which letters existence cannot 22

25 be denied) is to reply promptly, saying that so-and-so will be dealing with this matter; that is the last I ever hear of it. 41. In short, LBE has actively exploited every opportunity to infuriate and exhaust me, and to weaken my financial position, while contriving to inflate and conflate my liabilities for unpaid council tax in readiness for the long-planned bankruptcy petition. THE METROPOLITAN POLICE S CONSISTENT REFUSAL TO HELP 42. In view of the allegations of criminality that underpin this witness statement, the court will not be surprised to hear that I have often looked to the Metropolitan Police for help. I am sorry to have to say that my every appeal to them in the last thirty or so years has fallen on deaf ears. 43. The Metropolitan Police have consistently maintained that all matters raised by me are civil matters. I thought I had made a breakthrough in March last year when I managed to persuade Ealing Police to issue a crime number ( /12 ) that held out the prospect of a robust investigation of some of the financial irregularities detailed above. However it transpired that the police are determined not to investigate the compelling evidence that I was able to provide to them. 44. The refusal by the Metropolitan Police to investigate any of the compelling evidence presented to them in connection with this crime number occasioned my complaint in 2012 to the Independent Police Complaints Commission. The IPCC declined 23

26 to compel the Metropolitan Police to record any crime. I have subsequently elevated my complaint to New Scotland Yard. 45. Whilst my complaint about police inaction might seem, at first sight, to be peripheral to the present context, I have to say that the Metropolitan Police s refusal to investigate the misappropriation of my payments of council tax has been a crucial factor in facilitating this bankruptcy order. 46. The decision by my husband and me to move to London nearly half a century ago was motivated by the perception that England was a thoroughly decent country, wherein we might put behind us the horrors that had befallen our respective families in the prevailing anti-semitic climate of the World War II years in particular, which climate persists in many countries to the present day. 47. In England, we thought, we would be free to bring up our daughter with the dignity and respect that must surely adhere to all honest, industrious souls. The English police, we believed, were Dixons of Dock Green all: high-minded, principled, unarmed, scrupulously fair protectors of the public interest. I even remember hearing (rightly or wrongly) that English judges were receptive to petitions from anyone with a serious grievance, and that a judge would have no hesitation in summoning the other side if he thought there was a case to answer. In short, we imagined England to be a latter-day Shangri La. 48. Now I am disabused of such naive perceptions. Whatever the agenda of the Metropolitan Police, it is certainly not to protect the interests of this citizen. The 24

27 crime reporting system is long-winded, bureaucratic and, above all, excessively rigid. The system is such that I must deal exclusively with my local police force. Even if the IPCC had upheld my recent appeal, my case would still be in the hands of my local police, with all their prejudices intact, and their hatred of me all the more virulent. 49. None of this would matter if my local police force treated me even-handedly, but they do not. For example, last year I was the victim of an assault in my own home. A young police officer attended the scene promptly, conducted an impressive initial review of the material evidence in the presence of my daughter, took a lengthy statement from me, arrested the suspect and assured me that the matter would not end there. The following morning, I received a call from a belligerent police officer who refused to give his name, telling me that the suspect had been released and that that was the end of the matter. 50. I cannot help thinking that the local police s prejudice against me is unalterable, and that the young officer s work must have been immediately sidelined when he filed his report and his superiors saw the name and address of the alleged victim. 51. Now that my home, my possessions and, indeed, my very ability to live any sort of a life at all, are subject to the tender mercies of the Trustee in Bankruptcy, I curse the police for their refusal to help me in my darkest hours. Having listened to endless news reports of police corruption, and in view of the other facts of my case, I cannot help thinking that the police must surely be party to a conspiracy against me. 25

28 52. Whilst I cannot fathom the depths of the Metropolitan Police s relationship with LBE, I take some cold comfort from my conspiracy theory that these parties have worked in concert to bankrupt me. LBE is well aware that its statutory powers hold fast only insofar as the Metropolitan Police do not interfere in LBE s affairs. My local police force, meanwhile, has reasons of its own for wanting to be rid of this nuisance resident (as LBE described me to one of my tenants during an infamous incident in 2001). From the news reports I have heard about the problems of rooting out institutional racism in the police force, I would not be at all surprised to find that they hate me just because I am a foreigner and, worse, Jewish. I fear that, unless New Scotland Yard succeeds in performing the miracle of overturning years of local police prejudice against me, my only hope for justice lies either in the Crown Prosecution Service or, ultimately, the European Court of Human Rights. CALLING HSBC TO ACCOUNT 53. I am also increasingly convinced that HSBC Bank plc is part of the conspiracy. One of the main tricks used by the Metropolitan Police to fob me off when I raised the matter of the Morrison Card scam, under crime number /12, was to say that HSBC had assured them that everything was in order. Is it standard police procedure to make decisions based on cosy chats with rich and powerful people? In the light of recent media coverage, that is a serious question indeed. The upshot was that the Metropolitan Police deemed HSBC s conduct of my accounts to be unworthy of police investigation (even though I subsequently offered categorical evidence of an instance 26

29 of cheque tampering on my account by a named HSBC employee). The Metropolitan Police told me that it was up to me to deal with these matters for myself. 54. And so I set about the task of trying to call HSBC to account. When my first letters to HSBC failed to elicit any meaningful response, I quickly escalated the matter to HSBC s head office and, finally, to the office of HSBC s Group Chairman, Mr Douglas Flint. Mr Flint did not reply in person. Instead I received letters from HSBC employees deputed to respond on behalf of Mr Flint. Such employees, speaking with the full authority of HSBC insofar as they were replying on behalf of the Group Chairman, refused to answer my perfectly reasonable questions, which questions were exclusively concerned with HSBC s conduct of my accounts with HSBC. Furthermore, HSBC s letters to me contradict one another. 55. My archive of documentary evidence includes numerous letters that demonstrate the robustness and persistence of my questioning and the resoluteness of HSBC s determination not to be held to account by me. I have put eighteen mordant, searching questions about HSBC s conduct of my accounts. HSBC has refused to answer any of them. I have identified large, patently fraudulent payments from my account to several mysterious accounts referenced only by their respective account numbers. HSBC has never answered my demand to know the truth about these payments and these accounts. One of my last letters to HSBC s Group Chairman, written in February 2013, includes the following text: Specifically, I have presented you personally, by way of tracked Royal Mail, with documentary evidence of various serious 27

30 irregularities in HSBC s handling of my accounts, including mortgage mis-selling, misappropriation of many thousands of pounds of my money, and cheque tampering. I have also alerted you to the fact that HSBC employee [named in the letter but redacted here] has been party to a conspiracy whose aim was to rob me by forcing me to make payments in the course of telephone calls to a private telephone number operated by persons falsely purporting to be acting on behalf of HSBC. You have failed to provide any remotely satisfactory response to any of these concerns. Such negligence might be considered reasonable in the context of a civil action, where a simple see you in court will generally suffice. You are on far more dangerous ground, however, in the event of a criminal prosecution, insofar as you, Mr Chairman, may be held personally responsible for allowing known criminal actions by HSBC minions to go unchecked, and for failing to deliver up such employees to justice. Not long afterwards, I received a letter from another HSBC underling, telling me that the matter was now closed, and that I must address all further communications to their solicitors. LARGE ORGANISATIONS FREEDOM TO FLOUT THE LAW WITHOUT FEAR 56. Whilst my experience of trying to call HSBC to account might at first seem irrelevant in the present context, it is not. Such experience is further evidence of the impossible situation in which I found myself when confronted by LBE s bankruptcy petition. In the absence of police help, the correspondence with HSBC was my only hope of obtaining justice. 28

31 57. From this I conclude that, insofar as large organisations, such as HSBC, can all too easily evade customers efforts to hold such organisations to account, safe in the knowledge that very few retail customers could possibly afford to bear the costs and risks of instigating legal action against large organisations such as HSBC. Fewer still could hope to fight more than a battle or two in the war of attrition that would certainly be waged by the organisation until the customer yielded to the inevitable defeat. In short, large organisations are at liberty to flout civil laws without fear. Worse still, insofar as police corruption persists, such organisations are no less at liberty to flout criminal laws. THAMES WATER 58. There is one further chapter of this sorry saga that must be told here. It concerns the incidents that gave rise to the unsaleability of my house, with the consequences previously described in terms of this bankruptcy order. Again, it may appear at first sight to be a digression, but its relevance in the present context will soon become apparent. 59. The problems with the water supply to my house date from the time of the demolition of the industrial buildings at 355 Uxbridge Road in the late 1990s. This was not the demolition of 353 mentioned above, which occurred several years later. When 355 was demolished, a car repair workshop was still trading at Prior to the demolition of 355, there had been a single industrial site spanning the respective sites of 353 and 355. In 1984, LBE had given conditional approval 29

32 to a planning application, jointly for 353 and 355, thereby providing for alteration to vehicular access and erection of three storey building comprising basement car park, ground floor showroom, car rental and service counter, first floor storage of parts and second floor ancillary offices. 61. The water supply for the composite site must have been connected to 355 because, as I later discovered, 353 was deprived of any water supply when 355 was demolished. 62. In the early autumn of 1998, I received an unsolicited notice from Thames Water (TW), offering to install a water meter at my house, free of charge. I had always believed that water is humankind s most essential and precious resource of all and, accordingly, that water should be metered and, in common with all other utilities, priced according to actual usage. And so I accepted TW s invitation. Plumbers soon appeared at my house, and spent several days working underground at the front of the house. 63. Soon afterwards, the quality of the water delivered by TW to my house began to deteriorate dramatically, with filthy water coming through my kitchen taps. And so began a major chapter in the deterioration of my health, and my daughter s health, and the fight for our very lives but that is another story for another time. Needless to say, I complained loud and long to both LBE and TW, but to no avail. 64. I soon began to receive huge water bills, based on water usage at about four times the average for a house such as mine (according to TW). I would have been affronted to abuse water in this way and, since the 30

33 water supply to my house was utterly contaminated, I was strongly disinclined to use TW s water at all. 65. This grossly unsatisfactory situation persisted for nearly two years until October 2000, when TW wrote to say that the excessive usage had been due to a leak, that the leak had now been repaired, and that a leakage allowance had been credited to my TW account to offset the excessive charges. My account with TW has been in dispute ever since. 66. TW s protestations of innocence in this matter should not be taken at face value. The truth did not become apparent to me until several years later, in 2006, when the industrial usage of 353 had long ceased and the residential block was already built. It transpired that the new apartments were not ready for occupation because 353 was not connected to the sewage system. One lane of Uxbridge Road had to be closed for several weeks while the connection was established. I have many photographs of this work. 67. Then, about six months after the completion of the construction work at 353, I noticed a TW engineer at work in front of the building at six o clock in the morning. He accepted my neighbourly offer of a cup of tea, and told me that there had never been any water supply to 353, and that he was acting under instructions to open a mains supply to the new apartment block. He also allowed me to photograph his work, but asked me not to photograph his face, because he had been told to carry out the work in secret. 68. Exhibit 6 is one of the pictures I took on that occasion. It is significant because it shows that the 31

34 engineer was installing a new connection component, which he would not have done if 353 had previously enjoyed a mains water supply. This adds weight to the body of evidence that TW facilitated the theft of water from my supply in The old pipes in the foreground of the photograph in Exhibit 7 appear to run from 353 to the front of my house. My guess is that these pipes are remnants of the parasitical connection to my water supply and drainage facilities, established by TW in 1998, under the guise of installing my water meter. Perhaps most tellingly of all, the evidence for that assertion probably remains in place: to the best of my knowledge, there has been no significant digging in front of my house, or of 353, since the photograph in Exhibit 6 was taken. 70. I am mindful of the possibility that a forensic examination of these pipes, their respective end points and any residual water or waste within the pipes might yield crucial evidence, not only in support of a charge of theft of water by TW, but also in support of a further criminal charge of unlawful collusion between TW and the then freeholder of 353 to facilitate the theft of water. 71. Nor should I omit to add that, if the pipes are found to have conveyed sewage from 353 to my drainage system, this would expose TW and the then freeholder of 353 to further criminal charges of damage not only to me and my property, but also to the local environment (in the sense of contamination of land). To my way of thinking at least, this adds weight to the evidence in support of my emerging conspiracy theory. Whether or not LBE was directly involved in 32

35 this scandal, it seems to me that LBE manifestly failed in its public duty to prevent serious abuses of planning regulations. 72. There is further evidence of TW s mendacity in the Local Government Ombudsman s report into this matter in July The LGO states that TW denied having anything to do with installing the meter. Any such denial is indefensible. TW s bills based on meter readings began at the time of the installation of the meter, and TW s letters to me claim that TW has no records of previous usage. 73. I remain sceptical about TW s bills to this day. My builder, who has served me faithfully down all the years of this terrible story, has observed on many occasions that my water meter behaves most strangely. The face of the meter has long been buried under a light topsoil, suggesting that TW never looks at it. Furthermore, as my builder has proved by repeated experiment, the meter continues to indicate that water is being channelled into the house even when he deliberately disconnects all water systems in the house. This suggests that TW s meter is an abandoned syllable of a forgotten charade, and that TW s meter readings are a work of fiction. 74. These facts lead me to think that TW must also have worked in concert with LBE to undermine me. When I first complained to LBE about the contamination of my water supply, they played their usual game of telling me it was no responsibility of theirs. I do not pretend to know what a borough council s obligations are in such matters, but I find it impossible to believe that any borough council should 33

36 be permitted to let the wilful contamination of a resident s water supply go unchecked and unpunished. 75. My conspiracy theory goes further. I believe that LBE was instrumental in ordering the contamination of my water supply. It seems clear to me that it would have been a very simple matter to connect a water meter to 353 when its connection with 355 was severed. And so, I ask myself, what possible reason could there be for the freeholder to do anything other than instruct TW to install a meter? 76. After many years of thinking about this question, I can think of one answer only: that the installation of the parasitical connection to 353 in 1998 was the brainchild of the conspirators who wanted to do me serious harm. At the time, TW had no reason to harm me, but LBE had every reason to want to be rid of me. From this I conclude that LBE instigated the plot. TESCO 77. Nor can Tesco claim to have been ignorant of this crime. Tesco was demonstrably the freeholder of 353 at the time of this scandal, despite its attempts to deny the fact. If Tesco s intentions for 353 had been honourable, it would have insisted that a proper water supply be established at the outset. Furthermore, I and others vigorously demanded disclosure of Tesco s water bills for 353 during the period under question. Tesco promised to provide these, but has never fulfilled its promise. This is no surprise since I dare say no such bills exist. 78. No wonder Tesco hastily abandoned its grand designs for the redevelopment of the composite site 34

37 from 353 [to] 363 and retreated to 363 alone, putting, it hoped, a safe distance between itself and the scandals surrounding 353. The conspiracy theorist in me would not be surprised to discover that 353 continues to lurk in some shadowy corner of Tesco s property portfolio even now, carefully concealed beneath the cloak of the behemoth s labyrinthine company structure, and patiently awaiting its transformational renaissance. Nor would I be surprised that find that the plan to demolish and combine the entire strip from 339 to 363 is the brainchild of the mighty Tesco. I shall return to this subject in due course. OTHER POSSIBLE CONSPIRATORS 79. I cannot fathom the depths of the conspiracy against me, but I suspect that it involves many organisations and individuals beyond those named above. Since this statement may be my last opportunity to articulate my fears in the public record, I would like to include a brief mention of other possible conspirators now, so that the court may know that I have evidence against them, such as may lead to convictions in the future. I have been advised not to name names here, or to present any information such as might compromise future criminal proceedings, but what I can say is as follows At the heart of my story, there is one private individual who has lied and cheated his way into my story and charted a mendacious course through it, leaving widespread destruction in his wake, and whose corrupt double dealings have demonstrably sown the seeds of my demise. I believe that questioning by police officers (but certainly not my local police, who 35

38 are themselves implicated in all this) would soon cause him to reveal the identities and motives of the main conspirators In the mid 1980s, I was the victim of an international fraudster in an series of incidents so visceral and disturbing that I can never get them out of mind. Significantly in the present context, the case involved overseas police authorities and senior officers from Scotland Yard in addition to my local police. Their enquiries continued until the mid 1990s. I fear that the prejudice against me by local police may be rooted in these incidents. I cannot help thinking that the voice of the aforementioned belligerent police officer (who called me and refused to give his name, as described in paragraph 49 above) was that of one of the officers who called on me in my own house on a notorious occasion in 1994, and told me in extremely threatening terms that I must desist from any further enquiries or mention of the fraud, for fear of my very life. I think I know his name, written for me in his own hand, and his badge number British Gas, which has been only marginally connected with the bigger story already told, installed, or appears to have instructed its agents to install, a meter at my house in extremely suspicious circumstances, knowing that my builder was away at the time. My builder subsequently informed me that the meter was booby-trapped, and that anyone touching it incautiously might have been electrocuted, even killed. Incidentally, British Gas marginal involvement with my story was concerned with some irregularities on my HSBC account. I have raised the matter of these irregularities with HSBC but, having received 36

39 no answers from HSBC, I am unable to determine whether the installation of the booby-trapped meter was motivated by the financial irregularities or by some other aspect of the wider conspiracy. A new development arose only the other day, when my brother, who lives in the USA, sent me a copy of a bill he had just received from British Gas, addressed to me and claiming money from me, but at his address. This seems to draw British Gas into the net of my conspiracy theory. My brother s address is known to only one or two players in this saga, so the fact of British Gas latest bill means that I can now make intelligent guesses as to who is conspiring with whom A freelance residential property agent tricked me last year into accepting two tenants who, it subsequently transpired, had no rights of residence in the UK. The agent failed to provide me with any of the requisite due diligence documentation or any valid tenancy agreement. It was one of these tenants that assaulted me during the incident referred to in paragraph 49 above. My complaints to the agent went unanswered, and the Property Ombudsman told me that the matter fell outside the Property Ombudsman s terms of reference. I suspect that the police and the agent may have conspired against me in this matter. I cannot help thinking that, at the very least, the incident played into the hands of the police, insofar as my permanent incapacitation or death would suit them very well. I would like to take this matter further but, as ever in my present situation, I cannot hope to afford the legal costs that would be incurred For many months in recent years, I have been bombarded by calls from debt collection agencies 37

40 demanding arbitrary sums of money from a range of different organisations. Often, two agencies have simultaneously claimed to be acting on behalf of the same supplier, while asking for different sums that bear no relation to the sums demanded, if any, by the organisations themselves. Whilst I cannot claim to know why these agencies have been harassing me, I have noticed that they move with the pack, as it were. For example, the calls became more frequent and insistent in the run-up to LBE s issuance of the bankruptcy petition. The calls stopped abruptly soon after I raised the aforementioned crime number, but started again as soon as the Metropolitan Police dismissed my case. I know that the Metropolitan Police must have discussed my complaint with both LBE and HSBC at the time, but I also suspect that the police went further, by informing LBE and HSBC of their intention not to proceed with further enquiries, and that either LBE or HSBC, or both, proceeded to inform their co-conspirators that another victory over me had been achieved, and that the coast was now clear for their henchmen to resume the efforts to break my spirits At least one medical doctor, at least one senior politician and two or more solicitors have serious questions to answer about their respective roles in my affairs and in the scandals concerning 353. ACCESS TO JUSTICE 80. I greatly regret the fact that I have been driven to the extremity of making this lengthy statement to the court. I do so because of the present lamentable limitations of access to English justice. This is not the 38

41 England I thought I was coming to, half a century ago. This is an increasingly barbarous country whose base currency is corruption, where money matters more than morality, where ordinary citizens are routinely treated with contempt or worse. No one without extremely deep pockets can any more afford to bring an action at law in England, let alone sustain such an action to its conclusion, and especially in confrontation with any powerful, cash-rich organisation such as LBE, or HSBC, or TW, or Tesco. 81. We are told that all parties are equal under the law, but it is a half truth at best. Organisations or exceptional individuals with vast sums of money at their disposal can afford to count themselves equal to other similarly deep-pocketed parties under the law. Most people, however, having little or no money, have no access to justice other than the access of the defendant who must nurse her or his grievances in dignified silence until she or he is called to account by a plaintiff of substance. THE DESPERATE PLEADING OF A DESPERATE WOMAN 82. I am such an aggrieved defendant, and the only comfort I can take from this bankruptcy order is that LBE has at long last elected to fly its true colours in full view of the court. This statement is more than a routine request for the routine annulment of a routine bankruptcy order. It is the desperate pleading of a desperate woman, bowed by decades of psychological and sometimes physical abuse at the hands of unscrupulous power players a desperate pleading to be given a real chance of justice not the justice that 39

42 money can buy, but the justice that, regrettably, money can NOT buy in 21st century England. 83. I hope the court will not think it unduly melodramatic of me to say that my treatment at the hands of my torturers, LBE et al, is on a par with illegal imprisonment, torture and rape. I have been the prisoner of my intractable plight for years now and, were it not for the fulsome generosity of the few faithful friends and supporters I am lucky enough to have, I would have been unable to meet so much as my basic costs of living. My torturers have harassed and abused me repeatedly and unremittingly with their lies, their pretence and their cruel tricks. Their attacks on my home, my health and my person, from industrial pollution, to bullying threats, to this bankruptcy order and much else besides, have been so sadistic, vicious and painful that I can identify closely with the women recently in the news who were held (we were told) in a basement dungeon and gang-raped for years. 84. Is this equality under the law? Is this justice? I don t think so. This is bluff justice, whereby overwhelmingly powerful organisations pretend to be in the right, while behaving dishonourably or worse. LBE is bluffing its council tax payers by pretending that it values honesty and fairness, while concealing from public view the parasite of corruption that gorges itself on the tainted blood of LBE s anaemic moral authority. LBE is bluffing this court by holding forth a false image of an impeccable public servant, exploiting the moral authority of the court while concealing the moral bankruptcy of LBE. The time has come for the Crown to call LBE s bluff, and with it the bluffs of all the 40

43 parties to this disgraceful conspiracy, whose conduct is an affront to the once great name of once great Britain. 85. I heard on the news that those poor, incarcerated women only escaped because one of them exploited a rare opportunity to speak to a neighbour, and because the neighbour courageously chose to break the story. I beg you, Mr or Madam Judge: please be that neighbour for me now, and I will honour your name forever. Please don t send me back to my dungeon by simply annulling the bankruptcy order and dismissing the case. If you do that, my torture will be worse than before, and I will be weaker than ever; I m in my late sixties now, and in far from good health; my life will never again be worth living. MY WISH LIST 86. Of course I know that your powers to help me are fenced in by countless constraints, procedures, formalities, checks and balances, and in truth I have not got a clue about legal matters, or about what you can do to ensure that I get a fair hearing, or if there is anything at all that you can do to help me obtain fulsome justice. But I beg you to look kindly on the remaining paragraphs of this statement, which are nothing more or less than my wish list. The wishes may be naive and hedged around with so many hypotheses as to be fanciful, but I hope they will serve to demonstrate to you something of the depth of the injustice I suffer, the intensity of the hurt it has caused me, and the scope of the actions that must be taken to put these wrongs to rights. 87. If you are obliged for whatever reason to condemn me to the fate that LBE has contrived for me, I shall at 41

44 the very least have had my say in this statement; in a small way, I shall have had my day in court. 88. But if you can see the blazing light of truth that shines through every syllable of this statement, and if you feel the warmth of my heartfelt sincerity in this pleading, and if you are moved by the appalling injustice of my plight, and if you believe my claim that I can bring a vast body of evidence in support of this statement, and if, out of all this, you can find it in your remit and in your heart to make it possible for me to have a fresh start and a fair chance, then I implore you to do what justice surely demands of you, and to do it quickly, so that I may have some hope of enjoying the few remaining years of life left to me, and of recovering some remnant of the joy that I have not known in all the decades since this story began. 89. Insofar as my wishes extend beyond the jurisdiction of this court to embrace investigations and judgments such as the court might consider appropriate in the light of these proceedings, then I hope that you may see fit to put my case into the hands of other courts of appropriate jurisdiction. For example, I am mindful that criminality may be imputed in the case of certain actions by LBE and others, regardless of whether the court may deem my conspiracy theories to be worthy of further investigation, and that criminal matters obviously lie beyond the jurisdiction of the civil courts. THE ANNULMENT ITSELF 90. My first hope is that the annulment may be made, and justified in terms of my assertion, in the very opening paragraph of this statement (reiterated here 42

45 for ease of reference), that the petition that gave rise to this bankruptcy order is unprincipled, unnecessary, devious, draconian, an abuse of the insolvency legislation, and therefore fundamentally unjust, and that the petition should never have been brought to the court. 91. This immediately raises the issue of costs. I note from the Insolvency Service publication Can my Bankruptcy Be Cancelled? that the fees and expenses of the bankruptcy will have to be paid, and that the court will take account of my application when deciding who should pay them. I hope that this statement will leave no room for doubt that, insofar as the court may conclude that LBE s petition for my bankruptcy should never have been brought to the court, LBE must in my opinion be held liable for all such fees and expenses. I certainly have no wish to be required to pay any of the costs of a wrongful matter that was not of my making. 92. I specifically ask the court to consider ordering LBE to meet the substantial legal costs (of approximately seventeen thousand pounds) that I incurred circa 2007 as part of my ongoing efforts to bring about a fair resolution to my already long-running dispute with LBE concerning LBE s calculation of my council tax liabilities. THE HIDDEN COSTS OF THE ANNULMENT 93. But there are hidden costs too. I have worked slavishly for at least eighteen months to prevent LBE s bankruptcy petition, to have the petition set aside, to garner evidence (notably from HSBC) in support of my claims, to report to the police my suspicions of fraud, 43

46 to put my case against the bankruptcy petition to LBE and to anyone else who would listen and, most recently, to make the case for the annulment of the bankruptcy order. I think I should be fully compensated for that expense of time. 94. I could not have done more than a fraction of this work for myself, of course, nor I could have afforded more than a fraction of the expense of time that a team of appropriately qualified lawyers would have incurred in the preparation of a statement with all the depth and analytical rigour of this statement. I estimate that the costs of producing this statement alone would have amounted to as much as two hundred thousand pounds, even without taking into account the years of painstaking record-keeping, research and analysis that necessarily preceded the drafting of this statement, and that underpin the contents of this statement. 95. In fact, most of the work to fight the bankruptcy petition has been undertaken at the personal expense of a few loyal supporters, impecunious people all, and mostly non-lawyers, who were so incensed at the injustice of LBE s bankruptcy threat and everything that gave rise to it, and who feel so strongly about justice, and about the absolute injustice of the present lack of access to English justice, that they undertook the tasks of research, writing and advocacy for little or no money. Insofar as these were and are impecunious people, and insofar as their collective efforts amount, in effect, to several years of full-time employment, the court may rest assured that my rescue from this bankruptcy, if rescue comes, will have been achieved at enormous cost to these few incomparable souls and, 44

47 (especially in the periods when they worked full-time on my case for little or no money) their families and family relationships. 96. The conduct of this stalwart few stands in stark contrast to that of the many legal professionals I have encountered down all the years, who merely feign interest in justice, and even then only if and when the client has been persuaded to part with a substantial sum of money. I shudder to think that, if the annulment hearing goes against me, there will soon follow a feeding frenzy, in which the assets that my true helpers have fought so selflessly to preserve are instead divided among the vultures that now circle around me, clawing at the proverbial carcass of my estate even before the breath has gone out of this victim. 97. Even if the bankruptcy is annulled, as I fervently hope it may be, I am no less fearful that the undeserving and uncaring rich will profit from their respective roles in this disgraceful, abortive action, while the deserving poor go unthanked and unnoticed. It may be that court rules deem my stalwarts unworthy of proper remuneration for their expense of time on account of their lack of professional qualifications, and yet, ironically, the qualities of their holistic thinking, their analytical approach, their rigour, their written communications and their advocacy skills, are far and away the most impressive I have ever seen. Faced with a choice between a world class team of lawyers, on the one hand, and on the other my rag-tag coterie of stalwart truth-seekers, duly armed with the requisite advice as to legal processes and technicalities, I would choose my stalwarts every time. 45

48 98. I therefore beg the court, when awarding costs, to ensure that the costs of this bankruptcy are viewed within a holistic context, and apportioned in a manner that is not only just, but that also reflects the extraordinary nature of this case, and the years of painful self-sacrifice that my stalwarts have endured on my behalf in the deadly tentacles of this Medusa. 99. I should add a few words about the cost to me. I have suffered incalculably greatly from the stress of this case and from the abuses inflicted on me on an almost daily basis, not only since the instigation of these bankruptcy proceedings but also for many years before. My erstwhile reputation for truth and integrity has been shattered by the final indignity of this bankruptcy. The abuse is perhaps all the greater because of the fact of the chronic illnesses inflicted on me and my daughter years ago by LBE and others I will not go so far as to allege that LBE tried to kill me, but I firmly believe that LBE and my other tormentors made deliberate and concerted efforts to reduce me to a complete wreck, so that I might be in no fit state to fight back, and so that I might never again be in any fit state to assert myself in the face of their efforts to impoverish, defame and discredit me. I hope the court will not think it improper of me to suggest that I, and my daughter, whose life has also been ruined by the same evil powers, deserve to be compensated liberally for the loss of what should have been the best years of our lives, and that we deserve to have our reputations restored, and with them our dignity. 46

49 ARRIVING AT A TRUE ACCOUNT OF MY OUTSTANDING COUNCIL TAX 101. Of course the annulment, if granted, will not alter the fact of my arrears of council tax. However, if the court upholds my assertion that the sum petitioned by LBE does not precisely correspond with my true debt of council tax, and insofar as LBE s continuing failure to produce a true account is tantamount to LBE s depriving the Crown of council tax long owed to the Crown, I hope the court will see fit to order LBE to publish to the court, as a matter of urgency, a true account of my council tax liability Some of the inconsistencies in LBE s account should be relatively simple to investigate. For example, LBE needs to come clean about the infamous incident of the council tax payment of about three and a half thousand pounds that was never properly accounted by LBE. I know the name of the council official involved and I am in possession of other correspondence from him, stating his job title and linking his name to the incident. He deserves to be cross-examined under oath. Two of the witnesses are still alive (including my then solicitor), and both have recently confirmed that they have vivid memories of this extraordinary incident and are happy to bear witness to it I have always doubted LBE s assertion that I was liable to pay council tax even at times when my house was uninhabitable as a consequence of the events outlined in this statement. Indeed, I had to live elsewhere at times for extended periods, exclusively because of the horrors inflicted on my home. And I suspect that there have been other times when I have 47

50 been eligible for reliefs of council tax such as LBE has never acknowledged or advised I dare say that some further assistance may be required from me and from my helpers in researching the circumstances and revising the financial calculations. In this, and in all further suggestions hereinunder, I suggest that the court should order LBE to meet my costs and my helpers costs in full I ask the court to order a discovery of my accounts with HSBC, again at LBE s expense, for the purpose of explaining the aforesaid Morrison Card payments and other transactions that may have arisen from my belief that I was paying council tax when I was doing no such thing. I cannot see how any further account of council tax arising from this matter can be trusted unless and until the irregularities on my bank accounts have been fully explained. THE OFFICIAL RECEIVER S MENDACIOUS DEFAMATION 106. I would like to instigate a legal action against the Official Receiver on account of his blatant lies and defamation of my character, as outlined above. I am, of course, unable to do so in my present, bankrupted, impecunious state. Anyway, insofar as my complaint against the Official Receiver, if upheld, would be indicative of corruption at the very heart of the legal system, his conduct is a matter of considerable public interest Specifically, if it can be demonstrated that the Official Receiver s mendacity and refusal to discharge the bankruptcy, even when the discharge was 48

51 unquestionably within the Official Receiver s grasp, was a deliberate act for the purpose of preventing the rightful discharge of the bankruptcy, such a conclusion would prove that the Official Receiver had put the financial interests of the Trustee in Bankruptcy (who stood to profit hugely from the disposal of my assets) before the interests of the Crown. Any such conclusion would be inalienable evidence of corruption at the heart of the insolvency system In the event that the court considers the Official Receiver s conduct of this matter to have been questionable, I would like to suggest that the court should order LBE (being the party that occasioned this alleged abuse of the insolvency system) to underwrite the costs of my action for defamation against the Official Receiver within the period of limitation for actions for defamation, which period I understand to be extremely short. In the light of such an action for defamation, the court would be able to make a fully informed decision as to whether or not the Official Receiver should remain in post, and as to whether or not any further action must be taken against the Official Receiver in the interests of protecting the integrity of the insolvency system. LBE S EXPLANATION OF ITS CONDUCT 109. I hope that the court will go further still beyond the demand for a truthful account of my council tax, and demand in addition an explanation of the many other improprieties outlined in this statement. LBE has long asserted that council tax is inalienably distinct from all other council matters and, until now, I have always reluctantly accepted the truth of that assertion. 49

52 Now that my version of the truth has been articulated to the court, however, I would like to test the hypothesis that LBE has abused its position by acting negligently, even criminally, while pretending to be an honest agent of the Crown It is surely axiomatic that if this case, rooted in environmental concerns, and with such terrible consequences, should never have been brought to the court, then something must surely be done to try to prevent the occurrence of similar injustices in the future. In short, I hope that the court will demand from LBE a full written response to this statement, point for point, including the points that do not have any direct bearing on the issue of my council tax liability, and specifically that LBE be ordered to: investigate and explain to the court any improprieties by LBE and by agents acting under instruction from LBE and by third parties whose conduct should have been prevented or ameliorated by LBE; identify the individuals responsible for the injustices against me and set in train an inalienable process such as may be publicly verified, whereby the wrongdoers, be they employees of LBE, or the principals or employees of LBE s agents, or the confederates of employees of LBE, or the confederates of principals or employees of agents of LBE in whatsoever capacity, will be brought to justice; set in train an inalienable process such as may be publicly verified, whereby the history of LBE s relationship with me since circa 1980, when 50

53 the erstwhile Ewins Radio warehouse at 353 was replaced by a car repair workshop, will be subjected to a comprehensive, critical review, at LBE s expense, by a demonstrably disinterested and objective third party; make to me such redress as the court may considerable reasonable in token of the financial hardship caused to me, the damage caused to my mental and physical well-being, and the affront to my human rights resulting either directly or indirectly from LBE s catalogue of injustices against me since the 1980s; acknowledge to the court the fact that LBE s misconduct is not only a wilful abuse of its statutory powers and the trust placed in it by Her Majesty the Queen and Her Majesty s Government, but also a scandalous affront to the integrity of the local government sector as a whole; put in place demonstrable mechanisms for ensuring that LBE can never repeat such abuses as those outlined in this statement, and that LBE must give a public undertaking to that effect. THE VALUE OF MY HOUSE 111. I have no hesitation in maintaining that the dilapidated state of my house and the land-grab described in paragraph 31.5 are upshots of the wrongful actions and inactions of LBE and others as outlined in this statement and, accordingly, that LBE should be ordered either to meet the costs of restoring my house to the state, and to the market value, that would now apply if 51

54 none of the aforesaid wrongful actions or inactions had occurred, or else to buy my house at a price no less than the full market value that would apply if my property were in its rightful state and if the land-grab had not occurred Frankly, I would like to go further. I strongly suspect that LBE has a hidden agenda for the site of my house, and I would like to ask the court to order LBE to confirm or deny, point for point, my hypothetical account of this possible hidden agenda, for reasons that I shall presently explain Specifically, my hypotheses are as follows: LBE has already acquired the freeholds of 339, 341 and 343 Uxbridge Road. If LBE confirms this hypothesis to be true, the court may wish to note that the acquisition of any further freehold, whether 345, 347, 349 or (my house) 351, would result in LBE owning more half the freeholds in the strip (further references below to the strip denote a putative composite site combining all sites from 339 to 351 inclusive). If it transpires that LBE does not already own any of the freeholds of 339, 341 and 343, the following hypotheses concerning LBE s alleged hidden agenda may be considerably weakened. Even so, I urge the court to persevere with my analysis for the sake of the inductive conclusions that arise from it (I hypothesise that) the properties at 339, 341 and 343 have been converted or are being converted into smaller apartments for use as social housing. Such use cannot be justified in purely economic terms, since each of the houses in the strip has a present market 52

55 value of up to two million pounds, and since social housing could easily be provided more cost effectively elsewhere. In other words, LBE s acquisitions of properties on the strip are not consistent with the best value principles governing the provision of social housing, and are not justified by any otherwise insoluble demand for social housing (I hypothesise that) LBE intends to acquire any further freeholds from 345 to 351 inclusive, at the first available opportunity, in pursuit of the goal of having absolute discretion in all planning applications and planning decisions concerning the strip. My bankruptcy presents a golden opportunity for LBE to acquire the freehold that has long presented the greatest challenge of all to the fulfilment of LBE s grand plan to exploit to the full the strip s profit potential LBE stands to profit hugely by converting the strip from residential to commercial use, thereby creating, in effect, an eye-wateringly attractive brown field site on a prime arterial route, with excellent tube and railway connections, and even a nice little park opposite, all within a mile of Acton town centre. Acton town centre is the subject of a major regeneration scheme devised and proposed by LBE itself. The regeneration scheme is more than likely to occasion further increases in the value of all properties in the vicinity, both residential and commercial, to the extent that Acton town may soon be transformed from a lacklustre suburb into one of West London s most vibrant economic hubs LBE would stand to make a far greater profit from commercial use of the strip than from the 53

56 ongoing residential use of the strip. LBE s profits may be all the greater if LBE succeeds in doing a further deal with the freeholder or freeholders of the adjoining strip from 353 to 363, thereby creating an even more lucrative composite site ( the super-strip ) for the benefit of all remaining freeholders at the time of the consolidation LBE would stand to make a greater profit from the acquisition of the properties in the strip for potential commercial use than the profit that any commercial property developer could hope to make from such acquisitions. My logic for this assertion is based on the premise that any commercial developer needs to factor into the price paid to residential freeholders the usually significant costs of obtaining planning permission and the risk that all planning applications may be declined. Insofar as LBE s willingness to grant itself permission for one of its own schemes is a foregone conclusion, and insofar as there is, therefore, no risk of failure, LBE enjoys significant strategic and financial advantages over rival commercial developers in the market for the commercial redevelopment of properties such as those in the strip I further hypothesise that the increased profit potential for LBE, whether from the strip or the superstrip, is so far out of proportion with the present value of the residential properties in the strip that LBE could easily afford to persuade the current freeholders to sell out by offering them a sum far above the present value of their properties (I further hypothesise that) the conversion of 339, 341 and 343 for use as social housing is a charade 54

57 whereby LBE could, if called upon to justify its actions, play the hypocrite by tearfully trumpeting LBE s concern to help people in need (and that, surely, is a joke worth savouring in the present context) by playing its part in countering social exclusion. In other words, this little social housing project could be presented as what one former Prime Minister might have termed The People s Borough Council, doing its bit to ensure that The People s Poor are not, after all, driven out of inner city areas by housing benefit cuts and forced to dwell in ghastly ghettos out of sight of proper human beings LBE is wilfully obscuring the real purpose of its plan, which is to ensure that, when the change to commercial use is finally achieved for the entire strip and the redevelopment plan is in place, the remaining occupants of LBE s properties can easily be removed at will because their inferior social status ensures that LBE has every right to rehouse them elsewhere at will Having cleared the site and changed its use, LBE would then be in a position to close a highly lucrative deal with the freeholder or freeholders of 353 to 363, thereby creating the super-strip The conspiracy theorist in me cries out in jubilation at this point. I have already spoken at length about LBE s reluctance to divulge the truth about 353. What, then, if my earlier hypothesis re Tesco s possible covert ownership of the site (paragraph 78) should also prove to be true? If it is so, then my conspiracy theory is fully wound up, and I will confess (since I am advised that the courtroom context for this statement confers upon me the ordinary citizen s equivalent of 55

58 Parliamentary Privilege), that I LOVE the idea of little me playing Daniel to such a prestigious Goliath. To think that my little stones might be enough to cause a veritable super-strip of Goliaths to fall to ground, contaminated as that ground may be at 353! Finally in this context, and in conclusion of the above logic, I hypothesise that, insofar as the above logic is correct, LBE s desire to acquire the freehold of my house has been one of the principal reasons for LBE s decision to try to bankrupt me. I dare say LBE calculated (correctly) that I would probably be the freeholder least likely to acquiesce to any further devious conduct by LBE such as the exploitative acquisition of my property for covert purposes. Accordingly, LBE has chosen to acquire the freehold by the characteristically devious means of this bankruptcy order I am suggesting nothing more or less than that the court should consider the issue of LBE s willingness to speak truth in this matter to be a mark of LBE s veracity and even-handedness. If any of my hypotheses are correct, then I modestly suggest that LBE should be compelled to tell the other freeholders frankly about its plans and to negotiate with them openly and on equal terms, so that they may make informed decisions as to whether to acquiesce to LBE s plan or else to demand their cut of the ultimate proceeds If LBE comes clean about its true intentions as I am suggesting, I may be willing to sell the freehold of 351 to LBE for four million pounds, which I estimate to be its present full market value as defined in paragraph above plus a one hundred percent 56

59 premium as my cut of the proceeds resulting from LBE s grand plan. I make no promise, though. If, by contrast, LBE prefers to continue in the same pattern of mendacity that has characterised its relationship with me for these last thirty years, LBE can rest assured that I will do everything in my power to prevent LBE from ever acquiring the freehold of 351 AT ANY PRICE, and that I will do my best to thwart any petitions by LBE for a compulsory purchase order for 351 which petitions do not include full disclosure of this witness statement Returning, then, to the issue of the present value of my house and, specifically, to the matter of reparation for its present dilapidation and the landgrab, I recognise that LBE cannot be expected to bear exclusive responsibility for the costs of the dilapidation and the land-grab. However, insofar as LBE is the principal player in this matter, LBE should, in my opinion, be forced at least temporarily to bear the costs of making just reparations. Specifically, I imagine that the attribution of blame for the dilapidation and the land-grab will be an enormously complex business, involving endless lawsuits between LBE and others, incurring legal costs far in excess of the full market value of my house I only hope the court will understand my concern that LBE must not be allowed to commit the further injustice of forcing me to spend the rest of my life waiting in vain for the outcome of an interminable series of legal actions that it is not my business to undertake. I therefore ask the court to order LBE either to make reparation to me promptly for the dilapidation, and to be directly answerable to the 57

60 court for the timing, the manner and the outcome of its actions, and all the while as if LBE were solely responsible for the dilapidation, or else to accede to my terms for the sale of 351 to LBE as previously suggested, which sale would be deemed to relieve LBE of any further obligations to me concerning the dilapidation of 351, without in any way diminishing my rights in terms of my other complaints against LBE. If the court acts accordingly, I will get the justice I need and deserve, while LBE will be free to choose for itself whether and how best to sort out any questions of contingent liabilities. THE FUTURE OF The matter of the dilapidation is further complicated by the issue of the true source of the damage to my house. My archive includes much correspondence about the flood damage to the foundations in 1998, but I know that the damage began much earlier, when asbestos sludge from the erstwhile roof of 353 was running down my garden wall, my trees and shrubs were being killed by pollution from above and below ground, and the fabric of my house began to suffer cracks and other weaknesses. This scandal was particularly well documented, including newspaper coverage (an Ealing Times article in March 2004, headlined Resident worries over polluted land, quotes Jenny Jones, then Deputy Mayor of London, as saying There should be a proper independent investigation to assess the extent of any land contamination and this should include the adjoining land. There is also asbestos present and this is another worry. Residents should not be expected to pay for the investigation themselves. ) and a video recording of a public meeting 58

61 in December 2004 at which local residents and traders discussed the issues under the chairmanship of Professor John Whitelegg, an internationally renowned specialist in environmental issues (to which meeting LBE, TW, Tesco, other organisations connected with 353, and local police were cordially invited, but none of them chose to attend), because everyone whose property bordered directly on 353 (or 355) was affected. LBE stood famously and publicly in favour of the owners of 353, whoever they were. The victims of the scandal moved away one by one. This, I believe, was the real beginning of it all, with the unexplained death of a neighbour at the dark heart of the story. It is a story of major public interest, and it deserves to be told. I only hope that the court may force LBE, at long last, to speak the truth I cannot possibly end without making one further mention of the scandal at 353. It seems perfectly clear to me that LBE s claim, to the effect that the land under the residential block at 353 is free from contamination, is a deliberate lie. There are other lies too, about the title of 353, and secrets so dark that LBE, rather than revealing them, has had this questioner ejected from its offices on more than one occasion And why, I would like to know, did LBE not intervene to prevent the land-grabs at my property and at 355, whereby the residential block now standing at 353 overreaches its registered allotment of space both eastwards and westwards. I think we should be told, and I look forward to the day when the building at 353 is torn down at the expense of LBE and the other thieves and liars who put it there in the first 59

62 place. That can be the only just solution for the unfortunate leaseholders of 353 who think they own their apartments, but do not, and for the sake of all the residents who live there, atop a pit of poisonous industrial filth, and for the people whose lives were needlessly destroyed, or prematurely ended, for no reason other than that a gang of faceless villains might save their faces. THE ANNULMENT HEARING 121. I have no idea what form the annulment hearing may take. I fear greatly for my health in the event that I might be required to confront my tormentors at the hearing. When I delivered a statement along similar lines to this at the aforementioned hearing by Ealing Magistrates last year, I was in such a bad way that it was almost impossible for the presiding magistrate to complete the proceedings. It did not matter much in the great scheme of things, since I had been told that the outcome of the proceedings was a foregone conclusion. The annulment hearing is a different matter, though, and I am acutely aware that, without wishing to seem too melodramatic for a second time, my very life will be hanging in the balance at that hearing English is not my first language, and my powers of oral communication are anyway not nearly so magnificent as this eloquent statement might suggest. I therefore beg the court to grant me leave to bring with me to the hearing one of my trusted helpers, a person who has no legal qualifications whatsoever, but who is well aware of my case, of the contents of this statement and of my wishes in this matter, and that 60

63 the court may permit this person to advocate for me in the event that I am asked to make any contribution to the hearing beyond oath-taking and the affirmation of simple questions of truth. If only I may receive such an assurance from the court, I know that I will approach the hearing in a positive frame of mind and in readiness to do whatever the court may require of me on and after the occasion of the hearing. THE URGENT NEED FOR SOME REPARATION 123. The length of this wish list surprises even me, and inspires an important afterthought. It occurs to me that the court might perfectly reasonably order LBE to provide a point-for-point response to this statement, and postpone the annulment hearing pending such a response. Whilst I must say that I greatly relish the prospect of reading LBE s response, I suspect that it may take LBE many months to produce a response that fully satisfies the court. My problems, meanwhile, are somewhat more pressing If, as I have hypothesised, the only immediate results of this statement are an indefinite postponement of the meeting of creditors and a court order for further, detailed submissions by LBE, I will accordingly be consigned to the further injustice of further penurious imprisonment in my own home for howsoever long it may take LBE to provide the requisite answers. The plain truth of it is that I urgently need money NOW to live. And so, Mr or Madam Judge, if you accept that this bankruptcy order was wrong, and if you agree with my assertion that LBE has a case to answer, I beg you to make an immediate (perhaps interim) award of costs in favour of me and my helpers, 61

64 so that we may begin to pick up and mend the broken threads of our lives, and renew our energies for the further actions that we will soon be required to take. ANCILLARY BUT IMPORTANT MATTERS 125. Whether or not the court considers my allegations arising from the pipe work under the pavement at 353 to be directly relevant here, I suggest that the court should ensure that all utility companies should be prevented from exercising their public highway digging rights for the purpose of accidentally destroying such potentially valuable evidence of criminality on behalf of LBE or TW or any party to the alleged conspiracy. I would be much obliged if the court would consider referring this matter directly to the Director of Public Prosecutions, so that a proper forensic examination of the site may be carried out in the near future. I would be only to happy to co-operate with the DPP in any such survey I would also like to suggest that the court should order the discovery of LBE s council tax account for 353 and TW s water and sewage account for 353 during the periods in question. I have pressed both parties to provide this information but to no avail and, since the Data Protection Act, they can fob me off all too easily with the handy client confidentiality excuse anyway. A similar logic applies to the various transfers of title of 353 over the years. I have tried to research this, but my lack of knowledge of the technicalities of land registration has prevented me from ever making significant progress. In short, whereas these discoveries may not add significantly to the weight of evidence in support of my case, they may greatly inform the court 62

65 as to the extent of LBE s and TW s respective capacities for truth-telling. This is a revised version of my witness statement dated 6th June 2013, which revised version incorporates the amendments specified in the schedule annexed hereto, and incorporates no other amendments. 63

66 Concluding Remarks by Paddy Gormley So it has come to pass that Yafa Partner, having spent so many years as a prisoner in her own home, is shortly to be rendered homeless and deprived not only of all her possessions but also of her reputation. Her final application for annulment has been dismissed, and she is to have no further right of appeal. Meanwhile, the wicked repossession order brought about by HSBC and the Trustee will have the effect of conveying the freehold so long coveted by Bad Enterprises into the hands of LBE, when Mrs Partner is evicted from her home on the morning of 12th May Perhaps you can help her in some small way? Not by knocking on her door, certainly, for she is still under constant siege by bailliffs and dares not answer to anyone: Bad Enterprises is determined to continue its spiteful harassment until the last possible moment. You might complain to your MP about this affront to the integrity of local government, or join the Twitter Or if you happen to be passing 351 Uxbridge Road, why not sound your car horn to indicate your support for Yafa? Or if you happen to be passing LBE s offices, why not take the opportunity to tell them what you think of them? 192