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This statement is lengthy, so every five paragraphs there is a box with paragraph numbers, for navigation. The exhibits follow the paragrpahs in which they are mentioned, but in the original they were, as appears to be normal, attached at the end in an appendix. You can see an example of this at the foot of the page.
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IN THE HIGH COURT OF JUSTICE CASE NO: HQ05X00419
QUEEN’S BENCH DIVISION
In the matter of The Protection from Harassment Act 1997
BETWEEN
(1) SARAH BRANSON BA BARRISTER
(2) GERAINT DAVIES MP Applicants
and
Thomas Moore Defendant
WITNESS STATEMENT OF THOMAS MOORE, DEFENDANT
- I am the Defendant in this, the most recent example of harassing litigation by and at the request of Broomleigh Housing Association. Broomleigh Housing Association’s solicitors, Cook & Partners of the Second Applicants constituency, are particularly keen on abusing injunctions.
- Since leaving London, the Judges hearing these claims have refused me an opportunity to give an undertaking, presumably because an undertaking carries no finding of fact.
- The fact determine by The Honourable Mr Justice Sullivan was that I was not “nothing to do with this,” and therefore, he said, he was granting the Applicants absolutely everything they sought.
- I did try to persuade the Second Claimant to help me, while subject to the same harassment in his constituency, and close to his home, but I was unable to secure any help from the Second Claimant at all. In fact the Second Claimant told me I should obtain all the medical aids breathing aids I need, from London Borough of Croydon’s psychiatric social services department. I fear the Second Claimant did not listen to the question, such was his enthusiasm for obeying orders.
- Since I did write to the Second Claimant in 1999, I cannot truthfully say I am “nothing to do with this,” but I deny the Claimants are entitled to the relief sought as alleged or at all.
- The only Member of Parliament to have ever been able to give me any help at all with the harassment campaign of Broomleigh Housing Association is Richard Ottaway.
- I am, and am known to be, non violent.
- In the recording I play on my web site, the First Claimant is heard to say to me, on 29 June 2000, that she wants me to tell her if I cannot attend on 29 June 2000, “so we can put someone else into your slot.”
- In her witness statement, paragraph number 5, the First Claimant says, “no other constituents had requested a surgery appointment that day.” The Second Claimant holds open surgeries where an appointment is not needed.
- On 29 June 2000, the First Claimant told me, “we’re looking forward to seeing you,” but she was not, and neither was the Second Claimant. They had arranged for a plain clothed police officer to attend.
- I do recall the interview. The Claimants’ statements suggest to me that they do not and are guessing.
- I did not snatch anything from the Second Claimant.
- We did have further exchanges of correspondence after 29 June 2000, but the Second Claimant still refused to help me in any way at all.
- In paragraph number seven of her witness statement, the First Claimant notes Croydon Social Services intended to subject me to a false arrest. I am disappointed that the Claimants did not tell me, and act to stop this criminal act.
- As far as I know, none of my web sites say anything untrue about the Claimants.
- The allegation of lying is a question left to the visitor to my web site.
- I changed my web site, in breech of Injunctions obtained by the Claimants, so that it now states clearly that the Claimants deny having an affair. The Claimants have thanked me for breeching their Injunctions in that manner.
- Google can remove web addresses from their search engine. I should be very surprised if Google did tell the First Claimant they cannot.
- Exhibit TM 1 is a copy of the public ownership record for the Domain Name the First Claimant calls www.sarahbranson.com. This clearly associates me at my address with that Domain Name.
- I purchased that Domain Name with United States Dollars, and it is held for me in the United States. The First Claimant clearly has no claim to that Domain Name, and she has no interest in it. The First Claimant has not asked me for that Domain Name, but she followed the normal Broomleigh Housing Association route of trying to take it from me.
- Should the Claimants continue to deny an affair, I have nothing, at present, to say on the matter. Had either of the Claimants told me they deny an affair, and asked me to remove mention of their apparently non existing affair, I am sure I would have done so. I have no interest in their love life.
- The web site www.sarahbranson.com is not ostensibly the First Claimant’s web site. The Second Claimant’s work related public Internet web site has an address of http://www.geraintdavies.org.uk and http://www.geraintdavies.labour.co.uk/. The Second Claimant’s web site says it is “promoted by Matt Carter, General Secretary, on behalf of The Labour Party, both at 16 Old Queen Street, London SW1H 9HP.”
- My second exhibit, TM2, is a copy of web site http://www.tonyblairmp.org/. This complains that, inter alia, http://www.michaelhowardmp.net/ is registered to The Labour Party, at 16 Old Queen Street, London SW1H 9HP. If I may say so, my web site is about Sarah Branson, and it includes her speaking, and her writing, reproduced with 100% accuracy.
- My third exhibit, TM3, is the ownership record for http://www.tonyblairmp.org/, which gives a UK address, which the Claimants could use to launch a claim for damages, if this claim had any merit.
- My fourth exhibit is the web site http://www.tonyblair.org/ which has a young woman showing the camera her naked chest.
- My fifth exhibit is the ownership record for http://www.tonyblair.org which gives an owner in England, from whom the Claimants could recover that Domain Name, particularly as the Claimants say it associates the Prime Minister Tony Blair, a prospective and practising Roman Catholic, with pornography, but only if this claim has any merit.
- Clearly, these web sites are not ostensibly those of Prime Minister Tony Blair. Otherwise, they would give rise to a claim the Cabinet Office is more that able to pursue, and it has pursued Claims for other Prime Ministers.
- Mr Tony Blair says he likes modern technology and gadgets. Mr Blair is a non practising Barrister and his wife is a leading Barrister. Mr Blair has the interest and ability to pursue, or have pursued on his behalf, Claims in respect of both both both http://www.tonyblair.org and http://www.tonyblairmp.org and if this claim has any merit.
- In fact, rather than pursue the owners of those web sites, Mr Blair’s party, and those who run the Second Claimant’s web site, have taken ownership of domain names the Claimants say, in respect of me only, belong to someone else.
- Frankly, if the Court does not recognise as bullying the Claimants dragging a sick person 200 miles in an over night journey in respect of claim that if true would make the cause of one’s employment liable for more, then the Court does not use the term bullying in the same way as native English speakers.
- The Claimants, and the incessant bullying of which they are part, is putting me to death. They could, and I ask them to, help me with campaign that is now over ten years old, if they wanted. The Claimants have decided not to help me, but to help someone who was never their constituent, in criminal activities. I cannot obtain, privately at my own expense, or from the National Health Service, a dental device I need to breathe at night. The Claimants dismiss this bodily defect, with which I was born, as mental illness.
- In her tenth paragraph the First Claimant accuses me of saying she has defrauded the Student Loans Company. I have no idea how she draws that conclusion, but the allegations her side claims I make about them are invariably true and I now suspect the First Claimant has defrauded the Student Loans Company. I cannot see where, apart from her own memories of her own activities, she finds the allegation that she defrauded the Student Loans Company.
- I note that from the First Claimants statement, paragraph number 12, that the statement “I don’t give a hoot about Arabs, the more of them that are dead, the better off the world will be,” EH5A, is attributed to someone calling themselves John Evleth.
- In the same paragraph, the First Claimant claims the post she reproduces in part as EH5B, and I reproduce in full as my Exhibit TM6, associates her with racist and homophobic sentiment. The post is headed “inside the mind of Jessie Helms (e.g. ‘Homosexuals are weak, morally sick wretches.’).”
- I would have thought the allegedly socialist Geraint Davies MP, and his staff, would be happy to be associated with exposing the words, but perhaps I am wrong, about the socialism, or even social-ism, of Labour MP Geraint Davies.
- This is another example of Broomleigh Housing Association, and its representatives, being so keen to be unkind to me, that they complain about quotes. They wrote to my web hosts on 6 October 2003 complaining an article called “True Christian Child Spanking” advocated beating children, but it the article is copied from people about whom the Claimants and their associates do not complain.
- The same is true of Miss Sarah Branson and her paragraph 12 claim of being associated with homophobic and racist sentiment. The entire article is copied from a web site that campaigns for the more liberal beliefs Miss Sarah Branson says she shares and upon which she claims her professional reputation depends.
- Had Miss Sarah Branson reproduced in full the article about which she complains with her Exhibit EH5B, the Court would see Miss Sarah Branson is complaining that I have enhanced her professional reputation. I do not believe Miss Branson is any need of my assistance, although if she asked, I would my best for her. For the sake of clarity, that is an offer.
- I do not understand the First Claimants complaints in her paragraph thirteen about her safety. Miss Branson complains I said she lives in Croydon and says she lives in Brixton. No one is going to follow her home to Croydon are they?
- With regard to the professional address of the First Claimant, her Chambers puts this in the public domain, and I have noticed English Chambers afford their members considerable protection against members of the public attempting to instruct them direct, but if the First Claimant has a real complaint, she need only tell me. As Miss Branson says, we have never met, and I could be wrong.
- The First Claimant has no grounds for saying “the Respondent appears to be signing all his Internet posts with my full name and professional address,” and I deny that claim.
- I notice in the First Claimant’s paragraph 14, Miss Branson lays claim to computer skills she denies having in her paragraph number 9.
- With regard to the First Claimant’s paragraph number 15, I do not understand her claim about Internet Chat Rooms, for which she produces no evidence.
- The First Claimant then accuses me of signing things “Geraint Davies and Sarah Branson, 3 Mulgrave Road, Croydon,” contradicting her claim in her paragraph number 14 where she accuses me of using her professional address alone.
- The First Claimant is a very able person. I wonder who compiled the First Claimant’s statement.
- The First Claimant then claims the home address of the First Claimant is not in the Public Domain, but it is on the Electoral Register, available in Public Libraries and Post Offices, as the First Claimant knows, having worked closely with an elected Member of Parliament. The Legal Profession, of which the First Claimant is a member, the most politically active of professions, claiming amongst its members, the current Prime Minister, his wife who was politically active, and the Leader of Her Majesty’s Loyal Opposition.
- I do not share the low esteem in which the public in general seem to hold politicians, solicitors, barristers and journalists, as my web site says.
- The Exhibit EH8 the First Claimant mentions in her paragraph number 16 shows examples of posts are “re: Jews killing gentiles, okay for money” and “re: !! The idolizing of Hitler by Muslims.” It means, as it says, “referencing” a previous post with that name.
- In her paragraph number 17, the First Claimant says Royal Mail confirmed delivery of her letter ZU 440 5215 7GB. The First Claimant can use the Internet when it suits her, but when it does, she appears to be using telephone calls, real or perhaps imaginary.
- My exhibit TM7 is the Royal Mail’s account of that item on 27 February 2005, stating it was yet, on that date, to be delivered.
- In her paragraph number 17, the First Claimant also says “I was informed by the operators of the Google web site that web service providers cannot generally scrutinise the contents of material set to or hosted by them.”
- My exhibit TM8 is Yahoo’s account of their electronic mail services, which offers a service that will “filter out unsolicited email” and a service that will “send a custom, automatic message response when you are away.”
- I do not believe Miss Branson has been given this wrong information by Royal Mail and Google.
- I would like to know how many unlikely conversations bullies like Miss Sarah Branson have to lay claim, before the Courts will stop as a legal principle, the use of the telephone in evidence owing to the risk and likelihood of mendacity.
- These people are doing this all the time. Last year I received correspondence from Hildegard Schakel, Consultant Clinical Psychologist, Laurence E Burns Unit, Department of Clinical Psychology, Birch Hill Hospital, Rochdale. Mrs Shakel offered to help me, owing to a request from Rochdale Social Services, and I responded by asking her to help me. She repeatedly offered meetings, which I declined in favour of her achieving something for me, and she never did anything. Meeting Mrs Schakel will not provide me with the dental device I need before she could practice her profession, to professional standards, upon me.
- The Second Claimant says, in her paragraph number 17, that she believes I typed and manually sent to her the electronic mail response she reproduces in her exhibit EH9. Even if the Second Claimant had all the conversations to which she lays claims, she would have to believe that response was typed and sent to her within 91 seconds. The document the Second Claimant reproduces in her exhibit EH9, says her electronic mail was received by Yahoo at 17:22:38, and the response received between 17:23:00 and 17:23:59.
- The First Claimant calls me a liar. My web site compares the words and documents of the Claimants and asks the visitor to the site to decide if the Claimants are liars.
- I believe I have no need at all to call the Claimants liars.
- I received the First Claimants electronic mail at 1040 on Friday 11 February 2005, owing to a computer fault. I intended to respond, but my response could not have been much more than asking her to identify the material she believed she had a right to be removed. As far as I know, something being offensive, does not, of itself, give the offended party a claim over the offender.
- Even if Miss Branson were correct about the delivery of her letter, she would then only have given me two working days to obtain legal advice, and act upon it.
- In her paragraph number 18, the First Claimant, having reviewed notes to which she has no lawful access under Data Protection Legislation, claims “that there is a real possibility that he [meaning me, the Defendant] might attempt to hurt me physically.” May I please remind the reader, that were that true, Miss Branson would have made greater effort to avoid dragging me the 200 odd miles to London where she lives and works. For what purpose does Miss Sarah Branson want me in London?
- On Wednesday 9 February 2005, I received the letter from the main local newspaper in Essex, Essex Chronicle, exhibit TM8. As far as I know, there are only two web pages that mention Chelmsford Baptist Church, and the town Chelmsford has no Chelmsford Baptist Church. The author of that letter, who wrote to me on the day the Second Claimant sent her electronic mail to me, must know that.
- That is the only letter I have received from a newspaper in the last ten years. Clearly someone working with the Claimants asked Essex Chronicle to send me that letter.
- Again, on Wednesday 9 February 2005, I was exhibit TM9, a note of an attempt to gain fraudulent entry to an Internet account of mine. This attempt was made, not by a member of the public, but Fiberpipe Inc., 10215 West Emerald Street, Suite 160. Boise, Indiana, USA. Fiberpipe Inc provides its customers with Internet access, domain name registration and web site hosting. The automated email clearly assumes the party making the attempt is an individual acting alone.
- I have never received a communication like exhibit TM9 before. These are not issued when someone makes a mistake with their password. I have made erroneous password entry for that account in succession, without, as I say, receiving any note of the incident.
- Clearly, the Claimants are responsible for the letter from Essex Chronicle and the attempt to break into an Internet service account of mine.
- This is again normal Broomleigh Housing Association practice. By the time I received their 6 October 2003 letter, Broomleigh Housing Association had already arranged for my hosting to be terminated, and my domain names handed over to them.
- I was able to rescue my domain names from Broomleigh Housing Association. I now display Broomleigh Housing Association letters, intended to furnish service providers with an excuse for terminating my service and handing my property to Broomleigh Housing Association.
- My exhibit TM10 is a 14 October 2003 threat by Broomleigh Housing Association to obtain a High Court injunction, if I do not stop activities I restored before the end of October 2003, “insofar as they have not ceased.” Broomleigh Housing Association did not give me a chance to stop the activities, and neither have the Claimants in this action. Broomleigh Housing Association has not honoured the threat in exhibit TM10, as I would surely know.
- As with this Claim, Broomleigh Housing Association always makes urgent claims for injunctions. There is no difference.
- Broomleigh Housing Association has people claiming to be frightened of me. When I was asking the Claimant for help, South London Family Housing Association was claiming it had tenants frightened of me, and then took almost a year to apply for possession, after, as with Broomleigh Housing Association, obtaining injunctions.
- The same solicitors, Cook & Partners, who’s office is now in the Second Claimant’s constituency acted for South London Housing Association, obtaining injunctions and Costs in an interlocutory hearing, from District Judge Fink, who as Sarah Fink is a former solicitor of mine in Orpington. I did remind her in the hearing.
- On 10 April 2003, a young man approached me from behind in the porch to my home, smashed my right spectacle and rubbed the shattered glass into my right eye socket.
- My current landlord, Rochdale Metropolitan Borough Council, refused to reply to copious letters asking for a transfer, even after multiple burglaries caused the Authority to fit a metal security door over a front door frame young people had smashed.
- As my web site now says, all these people and organisations, including the Claimants and London Borough Croydon, accuse me of being violent without any solid evidence, and CCTV cameras always break down coincidental with their allegations. Yet, when I am assaulted and subjected to multiple burglaries, they pretend not to notice, and the Police, always keen to help those acting against me, have not arrested one person.
- At Oldham County Court, when I have asked for solicitors subject to the availability of funding, District Judge Simpson gave me the same excuse as The Honourable Mr Justice Sullivan. Both transliterated my request into a complaint about some alleged unavailability of funding, and referred me to the Legal Services Commission.
- I make clear again, I ask the Court to appoint solicitors to act for me, subject to the availability of funding.
- Hence, and for other reasons, I cannot believe these incidents are unrelated, or that most of the Judges before whom I appear are acting independently. Some have admitted they are not directly to me, another fired insults at me, used by Mr Dick Foot in helping Broomleigh Housing Association obtain possession the first time in Bromley County Court under Circuit Judge Cryan (for whom I have a high regard, shared with other litigants in person) in 1997, case BR6 10124.
- In that time, I knew far less about my medical condition, and allowed others to dictate actions to me, and accept although not quite believe, their allegations of mental illness. Eventually, I stopped blaming myself, and faced the reality that I could not be responsible for something like a personal holocaust.
- I deny the Second Claimant’s account of our 30 June 2000 meeting.
- With regard to the meeting and my web site, I complain the Claimants were not telling the truth. The Claimants seem to be changing the question into whether their actions were justified.
- The Second Claimant says his home address is not in public domain. Exhibit TM11 is a copy of the electoral register for the people called Davies living in Mulgrave Road Croydon, close to Friends’ Road where I used to live.
- The Second Claimant is a twice elected Member of Parliament, former local authority councillor, and former leader of London Borough of Croydon council. Having been active in politics myself, I have no idea how the Second Claimant can claim he is ignorant of the Electoral Register.
- The Claimants have thanked me for replacing mention of a relationship they deny, with the Affidavit of Mr Geraint Davies and exhibit TM11.
- I therefore humbly ask the Court to discharge the Orders obtained against me by the Claimants, reject their Claim, and grant me the relief I seek.
Statement of Truth
I believe that the contents of this witness statement are true.
Signed Thomas Moore
Dated 28 February 2005
IN THE HIGH COURT OF JUSTICE CASE NO: HQ05X00419
QUEEN’S BENCH DIVISION
In the matter of The Protection from Harassment Act 1997
BETWEEN (1) SARAH BRANSON BA BARRISTER
(2) GERAINT DAVIES MP Applicants
and
Thomas Moore Defendant
EXHIBIT TM2
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