I am interested in the vacancy on the Taunton and District Council

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IN THE COUNTY COURT AT BRISTOL 

                                                                                                                                                                                                                                                                 Claim No. G00TA220                        

1^st Defendant G4S Care and custodial Services Ltd 

2^nd Defendant HM Governor of Cardiff Prison (application pending)

 Claimant’s Application for HM Governor of Cardiff Prison to be 2^nd Defendant is currently stayed by the Bristol court making further difficulties to complete a revised Particulars of Claim, as ordered Without a mandatory disclosure order by the presiding judge on G4S who is blaming the South Wales Police and HMP Cardiff for having the Claimant unlawfully in prison for years

REVISED PARTICULARS OF CLAIM

PURSUANT TO   THE COURT’S ORDER DATED 22^ND JANUARY 2021

_______­________________________________________________

1. This is a claim pursuant to section 7(1)(a) of the Human Rights Act 1998 in addition to remedies already simultaneously existing in domestic statute and common law.
2. Further, the Defendant is deemed to be a public authority for the purposes of the Human Rights Act 1998 as it is acting under contract to the Ministry of Justice to run HMP Parc on its behalf.
3. The Defendant is and was at all material times a PLC incorporated under the Companies Act 1985 and is vicariously liable for the torts committed by its employees against the Claimant.
4. The Defendant at all material times was under a contract to the Ministry of Justice for the running of HMP Parc, Heol Hopcyn John, Coity, Bridgend, Mid Glamorgan, CF35 6AP and the Claimant was detained under the custody and control of servants and/or agents of the Defendant whilst serving a vindictive 2 year prison sentence imposed by the Crown Court at Cardiff from Dec 2017 until his release on licence on or about 15^th December 2018 and following February 2019 re-arrest for re-release on 1^st Nov 2019.
5. The Claimant pleads the present case without the benefit of full disclosure herein and as a result is presently unable to fully and accurately plead all of the relevant facts to support his claim until after full Disclosure herein.
6. The Claimant is and was at all material times the owner and entitled to possession of these stopped letters that he had written to HM Royal Courts of Justice, other courts, potential witnesses, friends and family during the course of his prison at HMP Parc.
7. Further, the Claimant is and was at all material times the owner and entitled to possession of his wheelchair, a large number of Caswell Clinic, Glanrhyd Hospital and prison medical records and legal papers in connection with his 40 odd failed malicious criminal prosecutions claim (BS614159),“Trading in Machine Guns” (1CF03361) civil claim and others ongoing against the Chief Constable of South Wales Police that he needed during ‘on licence’ and prison sentences at HMPs Parc, Cardiff and Exeter.
8. On 1^st November 2019 at HMP Parc, Heol Hopcyn John, Coity, Bridgend, Mid Glamorgan, CF35 6AP, the Claimant was released on licence from his prison sentence but servants and/or agents of the Defendant wrongfully and unlawfully seized from the Claimant’s cell, a large number of medical records, legal papers in connection with his civil claims against the Chief Constable of South Wales Police, his clothes and shoes. 

Defendant’s paragraph 8 is false. The Claimant only lent his new wheel chair to an officer due to an urgent hospital visit of a prisoner and for the wheelchair to be returned soon afterwards.

• On 1^st November 2019 South Wales Police, G4S staff and/or other agents for the Defendant confiscated the Claimant’s letter-log and copies of his letters mostly generated whilst in custody and in particular copies of his letters to J Graham Esq, HM Secretary of State for Wales, The Rt Honourable Alun Cairns MP and other MPs.
• Defendant’s paragraph 13a is false. The Defendant knows perfectly well the investigation to the Claimant purportedly sending heroin and /or anthrax to Members of Parliament and John Graham. Esq and is deliberately withholding the data from the Avon & Somerset Constabulary for fear certain people in Wales will be charged for ‘perverting the course of justice’.
• Defendant’s paragraph 13b, in that the Claimant was subject to a number of restraining orders and that in accordance with subsection PSI 04/2016, identified even in part c of paragraph 13 ‘letters sent by the Claimant were intercepted and monitored’.
• As with Defendant’s paragraph 17c the Claimant cannot particularise the facts either without return of his stolen property by G4S and disclosure of relevant Parc prison evidence including the CCTV to complete these particulars of claim.

vi)       Defendant’s paragraph 17e ‘He left with his property’ contradicts the Defendant’s submission in that his property could not returned as ‘the Claimant has not provided a forwarding address’!

vii)      But the Claimant was only released on parole to reside under curfew at night at a specific Taunton address verified by the area Avon & Somerset Constabulary

viii)     Defendant’s paragraph 10 totally contradicts the parole officer’s admission that G4S had seized the Claimant’s property in his prison cell and seen stacked up on a trolley in a prison corridor.

ix)       Defendant’s paragraph 21 c is false. The Defendant has never released to the Claimant his Caswell Clinic medical cords despite specifically sent to the prison on or about 6^th November 2018 .          by Dr Gaynor Jones .

x)       Defendant’s paragraph 22d ‘the letters were presumably in the custody or control of the police or HMP Cardiff ‘indicates another reason as to why the stages of this £500,000 damages claim require strict CPR disclosure by the Defendant, the latter needing to be HMP Cardiff as Ministry of Justice, as the 2^nd Defendant or HM Prison Governor of HMP Cardiff, as the 2^nd Defendant but. the matter as to which is purely academic.

xi)      Academic as the level of criminal conduct currently disclosed in these court proceedings means it is a very real risk that it will not be the Claimant going to prison, this year but those ringleaders in South Wales who hatched yet another fabrication of a serious criminal allegation against him in order to stop the Claimant’s 1CF03361 ‘trading in machine-guns 2009  T20097445 Cardiff Crown Court fiasco with an acquittal when having not tendered any defence except his 64 page witness statement as a defence statement. The current CPS (Wales) refuses to disclose that Claimant’s BS614159 witness statement to the CPS (England) as it caused his unconditional release from custody and eventual acquittal for being in possession of a prohibited weapon contrary to the Section 5 of the 1968 Firearms Act.

xii)     Today, both Defendants are already aware there never has been a Claimant ‘risk’ to the general public or his family, never had the two Cardiff restraining orders correctly served on him and was never in possession of a prohibited weapon so described by the CPS, on the opening day of the Cardiff jury trial  T20097445, all knowing  or should of known the ‘trading in machine guns’ criminal allegation had been a complete fabrication by the south wales Police. The South Wales Police, despite having painted the film prop from off the Claimant’s Farnborough Airshow replica WW1 biplane, had unblocked the pipe, mimicking a barrel of a Lewis machine-gun to try and fool the jury for late disclosure in 2020 revealed the relevant South Wales Police expert evidence was maliciously withheld from the Claimant before trial facing a mandatory 10-year prison term.

xiii)   That said this did not give licence to both Defendants immune to any criminal prosecution, to ‘step down into the gutter’ and join the culpable senior officers  within the South Wales Police to support yet another Abuse of Process against their same victim.

1. Thereafter, servants and/or agents of the Defendant wrongfully and unlawfully failed to return the said medical records, legal papers, his clothes, shoes and wheelchair to the Claimant on his release and have wrongfully and unlawfully detained them and continue to wrongfully and unlawfully detain them in the custody and control of the Defendant at HMP Parc or elsewhere or further or alternatively have wrongfully and unlawfully destroyed and/or disposed of them without consent of the Claimant.
2. The Claimant on 1^st July 2020, caused the Head of Offender Management (HMP Exeter) to request from HMP Parc the current location of the Claimant’s, in particular, medical records as his Taunton GP had requested them and had also been refused.
3. The Claimant caused his new MP to also write to HMP Parc for the return of his property but failed even to obtain her constituent’s medical records urgently needed.
4. The Claimant reported the 2019 G4S robbery and thefts to the South Wales Police, Avon and Somerset and Devon and Cornwall Constabularies without success either.
5. On or about 11^th February 2020 The Claimant continued his extreme, unusual and very expensive decision to implement one of his routine PLAN E or F manoeuvres when local remedies have been exhausted. The Claimant, therefore, served on the Defendant, on this occasion, his re-drafted October 2019, from prison, CO/3982/2019 Judicial Review Application. It was an application setting down, in detail, the nefarious conduct of MAPPA agents in South Wales by simply requesting court intervention for the return, by HMP Parc Prison, of his 6^th September 2018 Caswell Clinic supplied medical records and 1CF03361 ‘trading in machine guns’ civil claim records, the reason behind South Wales agents conspiring to further pervert the course of Justice.
6. Mr Justice Julian Lambert ‘s most helpful remarks, upon receipt of the Claimant’s JR application, included reference to the Claimant’s 1CF03361 ‘trading in machine-guns’ civil claim and in particular, some of his 2010/11 police confiscated witness statements as they are for imminent ‘exchange of them (Oct 2020) to be first returned to him.
7. The Claimant contacted the HM Parole Board and Prison Service HQ, with no success, requesting the return of his property and promised copy tape of 2019 parole hearing.
8. The Claimant contacted Taunton’s Citizens Advice Bureau for help in recovery before filing with the High Court his ‘unlimited damages’ civil claim against those ultimately responsible, ie the South Wales Police. The ten-year running police delayed 1CF03361 claim, (Claimant’s ‘trading in machine guns’ acquittal), was, at last, at ‘exchange of witnesses statements’ stage and the reason for prison for ‘in-house’ South Wales Police staff & their agents to confiscate his letters to his Taunton MP, Ms Rebecca Pow.
9. The Claimant visited the prisoner’s charity, Easyjail of www.easyjail.co.uk in Northumberland to no avail.
10. The Defendants subsequently confiscated the Claimant’s 2019 letters to Rebecca Pow MP covering important points. Could this lady help recover the G4S/ South Wales Police stolen property of the Claimant and assist in his restoring his membership, from prison, of the Conservative Party in order to vote in the scheduled July 2019 premiership election.
11. With no positive response to his recovery PLANS A, B, C & D or E and The Claimant sent a pre-action protocol letter before claim to the Defendant in which he specifically requested the return of the said medical records, legal papers, clothes and a wheelchair but received no response to his letter. His previous MP had also written to HMP Parc for his possessions to be returned but without success with the Avon and Somerset Constabulary informing him the MP did not even receive a reply!
12. On 31^st Dec 2019 and 15^th Nov 2017, the Claimant wrote to HM Cardiff Crown Court with regards to two purportedly ‘served’ restraining orders on him that, in fact, was not true. Again, the Claimant’s applications to ‘vary’ them were ignored with the presiding district judge, in 2013, admitting to the Claimant’s barrister, in open court, the case file was now ‘missing’. The prosecution barrister even confirmed to the Claimant, during the 2017 T20170239 ‘Breach of  ‘Varied Restraining Order’ trial that he was unable to trace the origins to ‘services’ of either restraining order!
13. In June/July/August/September/October and November 2019 at HMP Parc, Heol Hopcyn John, Coity, Bridgend, Mid Glamorgan, CF35 6AP, servants and/or agents of the Defendant wrongfully and unlawfully maintained the Claimant’s custody and stopped in excess of his thirty letters, without his authority or knowledge and written by the Claimant including those sent to HM Royal Courts of Justice appeal against his then current two-year T20170239 prison sentence.
14. The Defendant also stopped or unreasonably delayed the Claimant’s letters, in or out of prisons, to other courts, witnesses, family and friends without lawful authority and or had been reasonably or unreasonably delayed due to South Wales Police interference.
15. The Claimant, during imprisonment and ever since, filed numerous complaints against HMP Cardiff and HMP Parc, Bridgend, G4S custody staff for their seriously inflicting injuries, harassment, false imprisonment and robbery for the current civil claims legal papers Chief Constable of the South Wales Police is currently defending.
16.  G4S knew its own orchestrated 1^st November 2019 robbery of the Claimant would seriously prejudice the Claimant’s position in certain other ongoing court proceedings, irrespective of verdict, leaving their victim with severe loss having already suffered, under almost three decades of South Wales Police criminality, to almost loss of his life, loss of his wife, loss of his health, loss of his wealth and damned near loss of his sanity.
17.  

Serious Assaults and Denial of previously GP supplied Medications

• After Claimant’s Feb 2019 unlawful ‘recall’ to prison from a Cardiff parole hostel, he was assaulted on at least three occasions by staff in Parc prison with the first reported over the ‘floor buffer’ incident on A2 wing. All required medical attention and all captured on CCTV & body cameras but the Claimant was refused any record of each incident.
• The 2^nd filmed assault incident was in June 2019 when the Claimant was forcibly removed from his wheel chair by unnecessary force using seven officers to carry him to B block.
• The 3^rd incident was on 1st Nov 2019 when the Claimant was violently snatched from his cell by unprovoked excessive force using no less than eight G4S officers using handcuffs on Claimant’s wrists behind his back. This deliberate pain was inflicted continued from B wing to the main gate where the Claimant was half carried to an awaiting car for release for Bristol Royal Infirmary attention. This included x-rays for trauma due to his prosthetic hip having suffered partial subluxation during the manner in which the Claimant was ejected from prison.
• The Claimant still suffers the pain due to iliac trauma whilst in Parc prison, with the denial of Omeprazole medication daily for his advanced carcinogenic Barrett’s Oesophagus syndrome,

resulting from an old hang-gliding incident. The Claimant had to barter, for months with prisoners, to obtain Omeprazole, Paracetamol and other essential medications denied him by G4S.

• The incidents have left Claimant feeling severely intimidated, vulnerable and in constant pain.
• Withholding medical treatment is normally regarded as a breach of the Human Right Act Article 8 right to respect for private and family life.
•  

Deliberate False Forensic History to prejudice Claimant’s release for prison (Breach of Article 3)

•  The Claimant’s Oct 2019 HM Parole Board hearing, held in HMP Parc and witnessed by Claimant’s sister Celia Jeune, a retired magistrate, further revealed dubious and disproportionate reasons for the unlawfully protracted prison term and need for such violent constraints. This was tendered by both G4S and South Wales Police, in writing, copies of which were denied for either the Claimant or sister observer. In order to make sure no such dubious evidence the police relied on as to the Claimant’s purported ’risk’ to the general public and his own family could heard by the Claimant or his sister both parole officer and prison police liaison officer, facing examination by Mr Kevin Green, The Chairman of the Board and cross examination by the Claimant, remained absolutely silent. This clearly portrayed to all in the room the fact there was no ‘risk’ in releasing the Claimant nor were the two officers aware of ant ‘risk’.
•  And yet, in advance, the Claimant’s parole officer & prison supervisor had both indicated that he was ‘violent, extremely dangerous and liable to try and escape’. Both officers were relianton falsely manufactured medical reports, due to South Wales Police blackmail, to obtain medical reports, stating the Claimant had ‘significant and irreversible brain damage’and PDD (Paranoid Delusional Disorder) in the misconceived belief that he was suffering South Wales Police harassment, contrary to 1997 Prevention of Harassment Act.
• Dr ………….. and Professor Rodger Wood, in Caswell Clinic Glanrhyd Hospital Bridgend, in 2009, knowingly falsified the Claimant’s medical records for their clandestine 2^nd December 2009 Cardiff Crown Court recommendation that their victim be incarcerated, indefinitely, in Ashworth’s high security psychiatric hospital.
• The records for 8^th June 2009 MAPPA level 3 category 3 Barry police station meeting, now within Claimant’s civil claim 1CF03361 ‘machine-gun trading’ claim, continues to be refused him.
• The Defendant throughout the Claimant’s custody periods in HMP Parc, from a date in 2014/15, when refusing him more than three nights residence due to above fabricated MAPPA data supplied by the South Wales Police, continues not to disclose to the Claimant relevant custody records contrary to MG6D, PII, FTAC, OASys, CPR, parole and prison legislation.
• The Claimant’s applications for CCTV and witness evidence have been requested for the above G4S assaults and for his withheld medical treatment but it is also denied by the Defendant.
• The Claimant’s false now corrected forensic history released to prisoners then encouraged them to attack the Claimant with both physical and considerable psychological abuse while, in full view of Defendant’s staff, prisoners spread faeces and urine about his cell and bedding, walls and floor in a tirade of foul abuse late into the nights.
• The Defendants and its Multi Agency partners generated have used a false criminal history and a false risk assessment which they knew were not true and which were false in many ways but included wrongly asserting fictitious ‘child abuse’, ‘narcotics’ (cultivating supply and use), ABH (Actual Bodily Harm) and ‘firearms’ convictions and future level of ‘risk’.   
• Creating this specific kind of false ‘risk’ assessment of the Claimant who is locked inside a prison wing with staff and prisoners who seek harm (and substantial harm that goes with this type of problem) is both mentally and physically threatening so that the Claimant had sound reason to believe that serious harm may occur to him. It therefore reached the high threshold of Article 3 cruel and degrading treatment tantamount to torture.
•  The Claimant also understands that all data laws and rules have come from ECHR Article 8 right to respect for private and family life and that a European Human Rights defamatory type of attack on a person using false risk assessment that is unreasonably exaggerated is a breach of ECHR/Human Rights Act 19988 Article 8 right to respect to private and family life.  
•  On 6^th Sept and 4^th Dec 2018 G4S had inadvertently released the Claimant’s forensic records containing substantially false medical data and similarly fabricated criminal convictions including ‘child abuse’, ‘firearms’, ‘narcotics’, ‘acts of violence’ and ‘failure to attend court’.
• The only one ‘at risk’ of Claimant, within our community, is current Chief Constable of the South Wales Constabulary as he or she is Defendant in current and historical damages claims.

Alleged ‘Heroin’ to Alun Cairns MP & alleged ‘Anthrax Spores’ to ,,,,, ,,,,,,MP

• The Claimant was due for February 2019 release but more allegations were concocted by both Defendants (re CPS case 52SGO22221) in order to stop his mail in and out of Cardiff & Parc prisons and to protract his time in prison as confirmed by his MP in her witness statement to the Somerset and Avon police.
• The ‘white powder’ found in the MP letters had simply been remaining traces of toothpaste used for gluing enclosed court exhibits from the Claimant’s prison cell wall. Stolen transcripts from off the Claimant’s own cell wall, in 2029, by his own prison ‘liaison officer’ may be the same as purportedly sent to Alun Cairns MP, ……… M P and John Graham Esq.
• The Celia Jeune obtained notorious 2^nd Dec 09 Cardiff Crown Court’s T20097445 extract without Claimant but with Dr ………. there to brief the CPS present, as was for police application that the Claimant be gaoled in Ashworth’s high security psychiatric prison, for life, is the real reason for the current continuing insulting police prosecution.
• Thereafter, the servants and/or agents of the Defendant wrongfully and unlawfully failed to return the said documents to the Claimant or post them to the recipients and have wrongfully and unlawfully detained them and continue to wrongfully and unlawfully detain them in the custody and control of the Defendant at HMP Parc or elsewhere, or further or alternatively have wrongfully and unlawfully destroyed and/or disposed of the same without the consent of the Claimant.
• The Claimant sent a letter before claim to the Defendant in which he specifically requested the return of the said letters to him. The Claimant has not received a reply.
• The Claimant alleges and avers that there were no lawful grounds for the stoppage of the said letters under rule 34(3)(a)-(h) and rule 35A(4)(a)-(f) of the Prison Rules 1999, and none were notified to the Claimant at the various times when the said letters were stopped by the servants and/or agents of the Defendant, nor were any reasons given either at the time of the said stoppages or subsequently.
• Furthermore, the Defendant by its servants and/or agents failed to inform the Claimant of any reasons for stopping the said letters, or to give any reasons for the said stoppage to the Claimant under rule 34(3)(a)-(h) and rule 35A(4)(a)-(f) of the Prison Rules 1999 or any other statutory or lawful provision entitling them to stop the said letters.
• The Claimant alleges and avers therefore that the said letters were converted and unlawfully trespassed thereby in breach of the Torts (Interference with Goods) Act 1977.
• Further, the Claimant alleges and avers that his “correspondence” was interfered with when this was not “in accordance with the law” in breach of article 8(1) ECHR, as incorporated in the Human Rights Act 1998.
• Further or in the alternative, the Claimant alleges and avers that his “right of freedom of expression” was interfered with when this was not “prescribed by law” in breach of article 10(1) ECHR, as incorporated in the Human Rights Act 1998.
• The said servants and agents of the Defendant were subject to the Human Rights Act 1998, as they were carrying out public functions under contract from the Ministry of Justice thereby in the running of the privatised prison at HMP Parc.
• In the premises the servants and/or agents of the Defendant converted and/or wrongfully interfered with the said medical records, legal papers, wheelchairs and the 33+ letters to their own use and control to the detriment of the Claimant.
• Further, the said servants and/or agents of the Defendant’s conduct amounted to harassment of the Claimant, contrary to sections 1 and 3 of the Protection from Harassment Act 1997, there being more than 2 incidents of unlawful conduct having been perpetrated against the Claimant, as the said servants and/or agents had at all material times known or ought to have known, and they have thereby caused the Claimant anxiety and distress by sustained unreasonable conduct.
• Further the Claimant alleges and avers that his Convention rights have been infringed.

PARTICULARS

• The Claimant was entitled to the “peaceful enjoyment of his possessions” under schedule 1, protocol 1 ECHR of the Human Rights Act 1998.
• The Claimant was entitled to the right to his “correspondence” under schedule 1, article 8(1) ECHR of the Human Rights Act 1998 in respect of the 33+ stopped letters.
• The Claimant was entitled to the right to “freedom of expression” under schedule 1, article 10(1) ECHR of the Human Rights Act 1998 in respect of the 33+ stopped letters.
• The servants and/or agents of Defendant failed to respect the Claimant’s right to “peaceful enjoyment of his possessions” under schedule 1, protocol 1 ECHR of the Human Rights Act 1998 in respect of the stopped letters and their continued detention and the seizure and continued detention of the said medical records, legal papers and wheelchair for the reasons set out in paragraphs 4 to 8 herein.
• The servants and/or agents of the Defendant failed to respect the Claimant’s right to his “correspondence” under schedule 1, article 8(1) ECHR of the Human Rights Act 1998 in respect of the stopped letters for the reasons set out in paragraphs 4 to 8 herein.
• The servants and/or agents of the Defendant failed to respect the Claimant’s right to “freedom of expression” under schedule 1, article 10(1) ECHR of the Human Rights Act 1998 in respect of the stopped letters to cause irreparable damage to Claimant’s other ongoing claims and trial including T200200177, 1CF03361 (Machine-gun conspiracy) and BS614159 (40 odd failed malicious prosecutions).
• By reason of the matters aforesaid, the Claimant has suffered significant damage as a result of the actions of the servants and/or agents of the Defendant.
• The Claimant has been very greatly distressed by the stoppage and continued detention of his correspondence and seizure and continued detention of the said medical records, legal papers, clothes, shoes and wheelchair without reasonable and probable cause or lawful excuse and has suffered severe shock and mental anguish thereby. The mental harm caused by the Defendant was deliberate.
• Further, in the premises the said conduct by the servants and/or agents of the Defendant was arbitrary, oppressive and/or unconstitutional and the Claimant claims aggravated and/or exemplary damages
• The Claimant repeats the facts and matters set out in paragraphs 4 to 8 herein.
• The servants and/or agents would have known full well that the letters written by the Claimant were lawful and that they should not have stopped them and should have posted them to the recipients and should not have seized the said medical records, legal papers, clothes, shoes and wheelchair and should have permitted the Claimant to have taken them with him upon his release from HMP Parc.
• Further, pursuant to section 35A of the Senior Courts Act 1981, the Claimant is entitled to and claims interest on the amount found due to him at such rate and for such period as this Honourable Court may think fit.
• And the Claimant claims against the Defendant an Order for the delivery up of the stopped correspondence to the Claimant under section 3(2)(a) of the Torts (Interference with Goods) Act 1977.

(a)     A Declaration that there were no lawful criteria that were applicable to the stoppage of the Claimant’s correspondence under rule 34(3)(a)-(h) and rule 35A(4)(a)-(f) of the Prison Rules 1999 that justified the said documents being stopped by the servants and/or agents of the Defendant.

(b)     An Order for the delivery up of the said medical records, legal papers, clothes and shoes and wheelchairs to the Claimant under section 3(2)(a) of the Torts (Interference with Goods) Act 1977.

(c)     Damages for conversion and/or wrongful interference with goods under section 3(2)(c) of the Torts (Interference with Goods) Act 1977 and/or harassment under section 3(2) of the Protection from Harassment Act 1997 on the footing of aggravated and/or exemplary damages.

PARTICULARS OF SPECIAL DAMAGES

  Further or in the alternative:

(e)     An Order for Replevin for the return to the Claimant of his correspondence.

(f)     An Order for Replevin for the return to the Claimant of the said medical records, legal papers, clothes, shoes and wheelchair to the Claimant.

(g)     Damages under section 3 of the Human Rights Act 1998 (Torture).

(h)     Damages under section 8(1) of the Human Rights Act 1998 for wrongful interference with “the peaceful enjoyment of his possessions” in breach of schedule 1, Part II, The First Protocol, article 1 ECHR of the said Act.

(i)      Damages under section 8(1) of the Human Rights Act 1998 for breach of the Claimant’s right to his “correspondence” under schedule 1, article 8(1) ECHR of the said Act in respect of the yet to be disclosed letters held by the Defendant.

(j)      Damages under section 8(1) of the Human Rights Act 1998 for breach of the Claimant’s right to “freedom of expression” under schedule 1, article 10(1) ECHR of the said Act in respect of the Claimant’s correspondence.

(k)     Interest pursuant to section 35A of the Senior Courts Act 1981, the Claimant is entitled to and claims interest on the amount found due to him at such rate and for such period as this Honourable Court may think fit.

The Claimant believes that the facts stated in these Particulars of Claim are true.  The Claimant understands that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

[As it appears to be an irregular, if not an unusual court order to identify loss before CPR disclosure by parties, for an ordered revised Particulars of Claim, the Claimant will, unless the court orders to the contrary what is needed.

Losses include: Torture (contrary to Article 3 of the Human Rights Act 19978), medical negligence, robbery deliberate to prejudice ongoing civil claims including BS614159, ICF03361 etc,

Evidence is included, despite my humble submission it is not required at this point in time but owing to the high level od nefarious activity in the South Wales court system  in many arch lever files and yesterday’s random supply of 29 copies of documents to the Claimant’ sister , Ms Celia Jeune

Signed                                              —————————————-

Re-Dated 15th February 2021         MAURICE JOHN KIRK BVSc

[Signed and delivered by the Claimant on 16^th February 2021at Taunton County Court]

CPS

good morning,

The Taunton courts still enjoy giving me the ‘run around’

https://youtu.be/rDZM6mUSAQs

If I need CPS Crown Court contact I get told to walk up or down to the other court buildings only to be told to go back to to the original!

all very funnystate

Robert Buckland MP

This ‘run around’ went on last year as well

Today, trying to deliver a hand signed letter to our HM Justice Secretary for a receipt.– refused

In the welsh courts  my critical court documents invariably disappear.

The court refuses to take my letter  despite a trial going on?

Do I post it to you or publish on website for police to notify you of your master’s needed fact?

Thankyou

PS I still patiently waiting for the disclosure of evidence, under your control, that will allow my case to proceed to Taunton County Court this Summer