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Note
27
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2005
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Note
27
April
2005
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False date on letter - written and sent on 27 April 2005 - dated 22 April 2005
Page 2 of 2
Not true. Form N244 allows for determinations to be without a hearing and by telephone.
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1 Pares Land Walk
Rochdale OL16 5SX
29 April 2005
Claim No. HQ05X00419
Listing Number 05/TLQ/0318
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Sirs
Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mill & Partners v Moore
I refer to your response to my 26 April 2005 letter. This appears to be your letter dated 22 April 2005, which arrived here on 28 April 2005, in an envelope postmarked 27 April 2005.
Would you be good enough to put my letters, and your response, before a Judge, with my request that this matter, if not dismissed, is transferred to another Court? Please remind the Judge, that I remain unable to secure proper replies to my letters to the Court, as the Judge will see, on reading my letters, and your brief response.
Would you please remind the Judge that the Court has decided I am somehow at risk of attacking Claimant Barrister Miss Sarah Branson? Please point out to the Judge that this is despite the agreed fact that Miss Branson and I have never met, she is ten years younger than me, I am unable to breathe properly, and I have never attacked anyone in my life?
You will, I hope, remind the Judge, that Barrister Miss Sarah Branson, and the Court, formed this belief, and then demanded that I repeatedly travel the 200 or so miles from Rochdale to Miss Branson’s place of work and residence, London.
Would you please remind the Court that this Claim, under the Protection from Harassment Act, arises solely from an Internet web site, http://www.sarahbranson.com/, which the Claimants say contains remarks they believe to be untrue? The Judge might form the opinion, that an alleged lack of truth is not, of itself, harassment, and that on the face of it, this Claim appears to be an abuse of the Court.
Yours faithfully
T Moore
Page 1 of 2
1 Pares Land Walk
Rochdale OL16 5SX
26 April 2005
Claim No. HQ05X00419
Listing Number 05/TLQ/0318
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Sirs
Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mills & Partners v Moore
Would the Court please find the decency to reply, properly please, to my letters of 17, 13 and 11 April 2005? The Court received my 11 April 2005 letter at 0812 on 11 April 2005 letter, and my 13 April 2005 letter, at 1551 on 13 April 2005.
I attach copies of these letters. May I please, now, have a proper reply?
Yours faithfully
T Moore
Page 1 of 10
1 Pares Land Walk
Rochdale OL16 5SX
17 April 2005
Claim No. HQ05X00419
Listing Number 05/TLQ/0318
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Sirs
Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mills & Partners v Moore
Would the Court please find the decency to reply, properly please, to my letters of 11 April 2005 and 13 April 2005? The Court received my 11 April 2005 letter at 0812 on 11 April 2005 letter, and my 13 April 2005 letter, at 1551 on 13 April 2005.
I attach copies of these letters. May I please, now, have a proper reply?
Yours faithfully
T Moore
Page 2 of 10
1 Pares Land Walk
Rochdale OL16 5SX
13 April 2005
Claim No. HQ05X00419
Listing Number 05/TLQ/0318
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Sirs
Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mill & Partners v Moore
This morning, 13 April 2005, I received a letter from the Claimants representative, insisting that I meet them at 9.00 am tomorrow, to receive the documents they presumably should have served before 4.00 pm on 11 April 2005.
Would the Court please order that these papers are served on the solicitors the Court appoints to represent me, subject to the availability of funding? The time table for this, and therefore this letter in respect of it, was set at The Claimants request.
May I remind the Court that the Claimants had over two weeks to serve their documents. Instead of serving their documents, the Claimants have continued harassing me, this time, including persuading a journalist from the UK national newspaper The Mail on Sunday to obtain a telephone call from me, so he could obtain information for the Claimants.
By using The Mail on Sunday as a proxy, the Claimants have acted in a sub judicial manner, obtaining information from me by deceit while litigation is in progress, and evaded my request for no telephone calls.
The Claimants could have resolved any problems they may have experienced with service, by writing to me. In their Claim, the Claimants complain about my personal web site. This has pictures of bricks thrown through my windows, written descriptions of the problems I experience and pictures of the additional security measures I was forced to take.
The Claimants had no excuse. They still left service for two days after their own deadline.
Those two days are highly relevant. Miss Sarah Branson presumably intended that I
Page 3 of 10
receive her letter dated 7 February 2005, when she sent it using electronic mail, during the evening of 8 February 2005.
This would have given me, were those letters received when Miss Sarah Branson claims, two days to meet her demand, that I remove everything “offensive” from a web site, the only demand her letter makes. On 12 March 2005 I received a letter from Mills and Partners demanding that I remove almost everything from a web site, without any explanation, again within two days.
Yet, when the Claimants, at their own insistence, take for themselves the task of giving me their documents within two weeks, and the first I hear from them, about serving these documents, is two days after the close of the deadline the Claimants set for themselves.
The Claimants recognise I was subjected to harassment at the time they say they wanted me to reply to Miss Sarah Branson’s 7/8 February 2005 letter, and at the time they say they wanted me to respond to their 12 March 2005 letter.
This means I did not have the chance the Claimants say I should have had, to respond to Miss Branson’s letter dated 7 February 2005, sent first on 8 February 2005. The Claimants are also saying I did not have the chance they say they believe I should have had, to respond to their letter dated 10 March 2005, which I received on 12 March 2005.
Yet the Claimants have not made any effort to put right the injustice that caused. The Claimants have not pursued the perpetrators of this harassment, which, if the Claimants account is correct, was harassment of the Claimants, as well as me, for it was a campaign intended to prevent me meeting the Claimants demands.
Clearly, I am not in any doubt that the Claimants are either part of, or intended, this harassment. One of the harassing letters I received was from Rochdale Metropolitan Borough Council, which monitors the web site about which the Claimants complain.
The Claimants solicitors Mills and Partners say Rochdale Metropolitan Borough Council was monitoring that web site without their consent. If Rochdale Metropolitan Borough Council was doing that, then that local authority has done so unlawfully.
At the very least, since the site makes no mention of Rochdale Metropolitan Borough Council, the site has nothing to do with Rochdale Metropolitan Borough Council, and Rochdale Metropolitan Borough Council was abusing public funds.
So I ask that this action be dismissed, amongst other reasons including those in this letter and my other communications to the Court, because the Claimants criticise me for not meeting, with far fewer resources, their own two day deadlines, while the Claimants extend their service of papers deadline by three days, having not achieved the easier task of service, with the far greater resources available to the Claimants, within some fourteen to eighteen days.
Would the Court please set a fresh time-table, because the late document service, even if achieved tomorrow, will have cut between 20 and 25% of the time available to me for compiling my response?
Page 4 of 10
My original statement omits the harassing letter from the local newspaper, Essex Chronicle, although I mention it, and clearly thought I was including it. Bullying me with decreasing time for meeting already difficult targets, makes errors more common, and justice even less likely than it already is.
May I please have solicitors appointed by the Court? This is now a criminal matter, in which I face imprisonment, and solicitors are still refusing to represent me, as has been the case, for what has been at least eleven years of harassment by Broomleigh Housing Association.
As matters appear to me, at the current time, I am not being allowed any chance. This litigation is more complex than anything I have seen before, and I do not understand its stated intention. I am being harassed, as the Claimants agree, but without legal help, I can do nothing.
I have no legal qualification of any kind. The Claimants include one highly effective, and experienced barrister, and they have several barristers and at least one solicitor working for them. No one is helping me in any way at all.
Please excuse me if you think this is rude, but, if the Court allows this to continue, without my having any opportunity to instruct solicitors, subject to the limitations of funding, and proper legal advice, then this is clearly intentional injustice. Law Centres and Citizens Advice Bureaux are also unable to help me. I have asked.
I still need a reply to my 11 April 2005 letter to the Court. I am not suggesting the Court should have replied so quickly, although the Claimants expect me to meet their demands within two days. I simply want to make clear that this letter does not replace my 11 April 2005 letter.
Yours faithfully
T Moore
Page 5 of 10
1 Pares Land Walk
Rochdale OL16 5SX
11 April 2005
Claim No. HQ05X00419
Listing Number 05/TLQ/0318
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Sirs
Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mill & Partners v Moore
I refer to your Notice of Date for Returning Pre-Trial Checklist and Notice of Trial, both dated 6 April 2005, and both quoting Listing Number 05/TLQ/0318. I have not received a reply to my letter to the Court of 28 February 2005. Would the Court be good enough to expedite sending me a response to that short letter?
The two 6 April 2005 forms sent to me by the Court are addressed to the “Defendant’s Solicitor.” My 28 February 2005 applications to the Court include a request that “the Court appoints solicitors to represent The Defendant, subject to the availability of funding.”
Would the Court please expedite a determination of that application? Most of the documents I have received from the Court are addressed to solicitors acting for Defendant, and those that are not, tell me to obtain legal advice.
I have asked Geraint Davies MP, Barrister Sarah Branson and their solicitors Mill & Partners, to lift the ban on my access to legal services, subject to the availability of funding. To the extent that any have responded to that request at all, they have all refused. I have asked solicitors to represent me and all of those that replied refused.
May I please remind the Court that many English Court Service forms are not addressed exclusively to solicitors? Parliament, with the Ministers and Judges responsible for those forms, clearly intended that parties subject to Claims of this type, should have, and need to have, legally qualified representatives, subject to the availability of funding.
The Claimants say they require the Court to issue an order for my imprisonment. This Court has granted the Claimants every Order they have hitherto sought, even when the Claimants have said they had no need or reason to seek the Order.
The threat of imprisonment is compelling grounds for the appointment of solicitors to act
Page 6 of 10
for me, and so I ask that the Court is mindful of the gravity of imprisonment, in its consideration of my application that “the Court appoints solicitors to represent The Defendant, subject to the availability of funding.” May I also please remind the Court that the highly qualified, experienced and professional Barrister, Miss Sarah Branson, has appointed solicitors to represent her in this matter.
As I am not qualified, not experienced, not proficient and not competent in these matters, by need is much greater than Miss Sarah Branson’s need. May I also point out that any observation that Geraint Davies MP and Barrister Sarah Branson are proxies for the unending cycle of abusive litigation brought against me on the orders of Broomleigh Housing Association and their solicitors Cook & Partners, is additional reason for my need of legal representation, and no grounds for denying my application.
Amongst other reasons, the appointment of solicitors by Miss Sarah Branson, and Geraint Davies MP, who normally has his legal position protected by Miss Sarah Branson, suggests their solicitors are receiving instructions direct from Cook & Partners, solicitors to Broomleigh Housing Association. I am not asking the Court to accept this as true, but I would appreciate it if I were not subject to the insinuations I normally receive from the judiciary and other officers of Courts, when I mention the difficulties presented to me by these proxy Claims for Broomleigh Housing Association.
I will retain the Court’s forms until I receive a reply to this letter. I hope the Court will not put me to the indignity of completing those forms, which say unqualified, and inexperienced litigants in person, such as me, are not competent to complete them.
Would the Court please transfer the hearing of this matter to a venue nearer to my home? The Queen’s Bench Division, apparently hearing this matter, does hear applications in Birmingham.
The Court has ordered me not to contact Miss Sarah Branson, accepted claims by Miss Sarah Branson that she has never met me, but that the thought of my presence somehow creates a feeling of fear in Miss Sarah Branson. The Court can protect Miss Sarah Branson from this alleged fear, if it exists, by moving the hearing of this Claim at least as far north as Birmingham.
Would the Court be good enough to ask Mills and Partners, solicitors to Geraint Davies MP and Barrister Sarah Branson, to reply properly to my letters to them of 29 and 14 March 2005, copies of which I attach to this letter? I would like to avoid this litigation, but to reach any agreement with the Claimants, I do need information from the Claimants.
Yours faithfully
T Moore
Page 7 of 10
1 Pares Land Walk
Rochdale OL16 5SX
29 March 2005
Mills & Partners
88-90 Middlesex Street
London E1 7EZ
Sirs
I refer to your letters dated 7 and 10 March 2005. I attach a copy of my letter of 14 March 2005, which your office received at 1852 on 14 March 2005.
May I please have a full and proper response to my 14 March 2005 letter? I do need a response to my letters, so that agreement of some kind is at least in some way possible.
I am sending this letter to the facsimile number you gave on your Application Notice, 020 7797 7700, and the facsimile number you give on your letters, 020 7425 0100. Would you please tell me which I should use?
Yours faithfully
T Moore
Page 8 of 10
1 Pares Land Walk
Rochdale OL16 5SX
14 March 2005
Mills & Partners
88-90 Middlesex Street
London E1 7EZ
Sirs
I refer to your letters dated 7 and 10 March 2005.
I ask you to stop harassing me. When your official client wrote to me in her name, she waited a day before sending me her letter, in order to make its receipt coincidental with the closure of one of my web sites, an attack on an Internet account of mine, and a bogus enquiry from a newspaper.
Your 10 March 2005 letter arrived on 12 March 2005, the day after a bogus enquiry from Rochdale Metropolitan District Council. The letter you caused to be sent to me by Rochdale Metropolitan District Council asks me a question that not only had I repeatedly answered, but its signatory had also answered repeatedly answered. This letter also asks for a utility bill with my full name, date of birth and signature.
Will you please refrain from harassing me in any way at all?
The notice sent to me by your Court tells me to obtain legal advice. Please will you remove the block on my access to legal services, and ensure, by reference to the Courts if need arises, that I am allowed to access legal services on the same basis as other British citizens?
Should you permit me to access to legal services, which with a barrister and a Member of Parliament as your clients, is well within your abilities, then I am confident of a speedy resolution. However, I cannot see how even the best of solicitors, can resolve this within the one working hour you have allowed me to meet your demands.
Any legal representative of mine, will need to explain to me the problem your official clients have, if any, with statements such as, “Richard Ottaway, the Croydon South Conservative MP, was more helpful, insisting that Broomleigh Housing Association tell me where they had hidden my breathing ventilator machine. Richard Ottaway is a solicitor, but Sarah Branson is a barrister,” and “I ask you, whoever you are, simply that I be allowed to live the remainder of my life in peace, instead of being put to death by denial of service from every quarter.”
Would you please help by, amongst other things, ensuring I can access legal services, ensuring you and your clients comply with the terms and conditions for accessing my web
Page 9 of 10
sites, and by making your demands reasonable?
Yours faithfully
T Moore
Page 10 of 10
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