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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 Mill & 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
Geraint Davies MP
T Moore

Page 1 of 9


Geraint Davies MP

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 2 of 9


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?

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

Geraint Davies MP
T Moore

Page 3 of 9



1 Pares Land Walk
Rochdale OL16 5SX
13 April 2005

Oracle Investigations
Post Office Box 139
Rochdale OL16 4GZ




Sirs

Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mill & Partners v Moore

Please do not push me around at one day’s notice. I am a human being and I ask you to start treating me as if I were human.

I have written to the Court about your letter. Please can we wait until I have the Court’s response?

I am not evading service. Your side, or those who instruct you, appear to have waited over two weeks before attempting service.

Normally, Court determinations are available to your side, or those who instruct you, days before they are sent to me. However, if you would like me to write to you when I have the Court’s response, I will. Please use normal Royal Mail post.

I have responded to your letter within hours of receiving it. I hope you and your side will have the grace to thank me for that, and make sure, as best one can, that this is the last time they, including those working for them, subject me to demands at short notice.

Yours faithfully
Geraint Davies MP
T Moore

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