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3 Pares Land Walk
Rochdale OL16 5SX
28 February 2005
Claim No. HQ05X00419
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Dear Sirs
Please will you acknowledge safe receipt of the attached Acknowledgment
of Service for a Part 8 Claim, and witness statement.
Yours faithfully
T Moore
Acknowledgment of Service
(Part 8 claim)
You should read the ‘notes for
defendant’ attached to the claim form which will tell you how to
complete this form, and when and where to send it. |
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In the High Court of Justice
Queen’s Bench Division
Claim No. HQ05X00419
Claimants Sarah Branson
BA (1)
(including ref) Geraint Davies MP (2)
Defendant Thomas
Moore
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Section A
I do intend to contest this claim.
Section B
I intend to contest this claim
Give brief details of any different remedy you are seeking.
Damages and punitive damages limited to
£200 000.
This is my estimate of the cost of hiding from the Claimants, and those
who's instructions they obey, in a foreign country, so that I am able
to access to services, including medical services, without the
Claimants, and those who's instructions they obey, blocking my access
to that service.
The Court appoints solicitors to represent The Defendant,
subject to the availability of funding.
I appeal the Orders apparently granted to The Claimants on 21 February
2005. These are permanent injunctions, which should not be granted, and
I do not understand them. As far as I can see, for example, the Orders
prevent me from publishing The Claimants own words, which, as far I can
tell, say that the Claimants have behaved unethically and dishonestly.
I understand that these Orders are governed by the limits of being
reasonable, but I cannot see the limits on what I may say and publish.
There are substantial disagreements on facts. For example, The
Claimants say the Second Claimant's home address is not in the public
domain, and The Second Claimant even accuses me of following him to his
home. The Second Claimant's home address is in The Electoral Register,
a document available in Public Libraries and Post Offices.
I now invite visitors to my web site to compare the Electoral Register
with The Second Claimant's affidavit, and The Claimants have thanked me
for the amendment in which I published both those documents. Yet this
does suggest that The Claimants have, by stating The Second Claimants
address is not in the public domain, have acted unethically,
dishonestly and committed an offence.
As far as I can tell, there is no question that this application seeks
to resolve, and my attention is not drawn to legislation that allows
for a Part 8 application in the circumstances outlined by the Claimants.
In most cases, The Claimants have not presented any evidence at all, to
justify their need for the Injunctions, or that they have a right to
the relief sought in any event.
Section C
I do intend to dispute the Court’s jurisdiction.
The court office at
is open between 10 am and
4 pm Monday to Friday. When corresponding with the court, please
address forms or letters to the Court Manager and quote the claim
number.
N210 Acknowledgment of Service (CPR Part 8) (3.01)
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Section
D Claim No.
HQ05X00419
I do object to the claimant issuing under this
procedure
My reasons for objecting are:
Mentioned in section C. In addition, The Claimants have made no effort
to resolve matters before litigating. I did not received The Second
Claimant's letter until after the deadline she set. Even if I had
received it when she claims, that would not give me sufficient time to
obtain legal advice, better details of what the Claimant meant by
"offensive material" and the connection between that the Claimant's
rights. As far as I know, The Claimants had no right to the removal of
anything simply because it was offensive.
There are substantial disagreements on facts (some mentioned in section
B).
As far as I can tell, since the application does not raise a question,
and I am not directed to legislation that facilitates the use of Part 8
in this matter, this should not be a Part 8 application.
I am entitled to suggest The Second Claimant is dishonest, but these
Orders say I may not make such a suggestion. He is a politician and
many in society, including Members of The House of Commons, do
associate politicians with dishonesty. The Second Claimant is not
entitled to have The Court protect him from legitimate campaigning,
which frequently includes allegations of dishonesty.
I am entitled to suggest The Second Claimant is not competent to do his
job, although the Orders forbid me from doing so. If I am not entitled
to suggest The Second Claimant is incompetent in his profession, that
is an effectively an order that, should I vote in national elections, I
must vote to retain the current government of which The Second Claimant
is a member.
The First Claimant is not entitled to protection from comment upon her
ability to do her job. I was refused an opportunity to consider
additional submissions by The Claimants in advance of the hearing.
In their skeleton argument, the Claimants say "in summary, the
Respondent has posted false, abusive, offensive and defamatory material
on his web site at http://www.tommoore.co.uk."
As far as I know, this refers to one proposition the Claimants insist
is wrong. That was not a summary, but dissembling language.
Section E
I hope to rely on solicitors to file my evidence. However, as this may
be my only chance to submit written documentary evidence, I attach my
statement of 28 February 2005.
Section F
| Full name of defendant filing this application |
Thomas Moore |
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Section G
Signed
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I believe that the facts
stated in this form are true.
Date 28
February 2005
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Address to which notices about
this case can be sent to me:
1 Pares Land Walk
Rochdale OL16 5SX
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Telephone
number:
no more telephone calls please. |
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