Noëlle Rawé, victim of leasehold fraud andcorruption at Jefferson House, Basil Street,London - to generate a £7m(?) (US$12m)jackpot for Andrew Ladsky et.al. - with thehelp of surveyors, lawyers, accountants,tribunal, courts and police |
I view Mr Jeremy Hershkorn, Mr Ahmet Jaffer and Mr Daniel Broughton as evil, corrupt, morally depraved, sociopathic individuals - conduct endorsed by the Law Society, West London County Court, the Supreme Court Costs Office - and ultimately by the Ministry of 'Justice'
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portner / portner and jaskel LLP and law society
Introduction(SEE BELOW KEY POINTS OF NOTE , BREACH OF LEGISLATION AND SECTIONS LIST) Question: If you are solicitors who have had their malpractice exposed in the public domain (because your 'regulator', the Law Society, turns a 'blind eye and a deaf ear' to ALL malpractice) (points # 4 and # 5 , below ; My Diary 6 May 08): how do you attempt to hide what you have done and ensure you cannot be individually exposed in future - allowing you to continue in your fraudulent ways? Answer: (1) Modify the name of the firm; (2) Remove all possibilities of identifying the individuals by (i) having no name on your stationary; (ii) use only the individuals' initials in their email address; (3) state that "a list of members' names is open to inspection" at your office. How is this approach described? "Tradition with a modern edge" This is what 'Portner', a firm of solicitors located at 63/65 Marylebone Lane, London W1U 2RA has done in June/July 2008: contrast its 1 August 2008 and 6 June 2008 letters. It will cut down the costs of what appears to be high turnaround of staff: I count five reprints in the last 17 months (see list of names in the top, right hand corner): 10 February 2006 ; 3 May 2006 ; 16 February 2007 ; 12 July 2007 ; 7 February 2008 Since June/July 2008 Portner and Jaskel LLP "trades" under 'Portner' Client and contactsPortner and Jaskel has confirmed in its 3 October 2006 letter to my then website host that its client is Andrew Ladsky. (See also My Diary 3 Oct 06 ; Advisors to Jefferson House ; Directorships ; Owners identity ; Headlessors ) In spite of having Cawdery Kaye Fireman & Taylor (CKFT) r (CKFT) as the nominated solicitors for 'Steel Services' on the Land Registry ( NGL 373 333 ) ( at 22 February 2006), Portner is also acting for 'Steel Services' - at least, in relation to me. Portner and Jaskel is another firm of solicitors, used by Ladsky, I can only describe as evil, corrupt, morally depraved and extremely vicious (I hold the same view about Ladsky's other 'puppets', Cawdery Kaye Fireman & Taylor (CKFT) , Martin Russell Jones (MRJ) - and the rest). I first came across this firm and its bullying and intimidation tactics in 2002 when it viciously 'attacked' the then Elderly Resident at Jefferson House. Individuals who have approached me from this firm are: Mr Daniel Broughton - in relation to the 10 February 2006 so-called "Notice of first refusal" - see summary below, and for more detail, My Diary - 18 Feb 06 Mr Jeremy Hershkorn who threatened me with "bankruptcy proceedings, forfeiture and costs" (point # 3 below) and proceeded with filing the 27 February 2007 FRAUDULENT claim against me in West London County Court - see events below. (A public announcement indicates that, around mid-May 2007, Jeremy Hershkorn joined another firm of solicitors, Magrath & Co, 66/67 Newman St, London W1T 3EQ) Mr Ahmet Jaffer who took over from Jeremy Hershkorn and remained the main contact. As in the case of their client, Andrew Ladsky, I view Jeremy Hershkorn, Ahmet Jaffer and Daniel Broughton as evil, corrupt, morally depraved, sadistic, sociopathic individuals... but, as demonstrated in this section (points # 4 and # 5, below): they evidently have the blessings of their 'professional' association, the Law Society, to act as they do. (= Same as Lanny Silverstone and Ayesha Salim, CKFT, as well as Richard Twyman and Lisa McLean, Piper Smith Watton). Well, unlike the Law Society I view ALL as having VERY SERIOUSLY FAILED to discharge their professional duties (outcome of my 'cries for help' and complaints)
Sections(The documents referred to in this section are also listed under the 'Document library': Year 2006 and Year 2007+ )
I view this so-called "notice" as BOGUS and believe that it was done purely for my 'benefit' as a means of 'having fun' / taking revenge (as with e.g. the invoices sent to me three months after the exchange of the Consent Order - for which Cawdery Kaye Fireman & Taylor (CKFT) ensured endorsement by the court ). The following is a reduced version of what is contained under My Diary - 18 Feb 06. The "notice of first refusal" states:
Needless to say that a 'notice' of this type is an important legal document as it commits the 'landlord' to deliver on the offer made in the document (L&T Act 1987 - section 4 ). • The " notice" sent by Portner is, in terms of the description of the property, a carbon copy of, for example, the "notice" of 13 December 2000 sent by Laytons solicitors (Notices by landlord # 2 ) - at the time when 'Steel Services (SS)' i.e. 'my landlord', was the headlessor for the whole of Jefferson House • On two subsequent occasions (3 March 2006 and 11 March 2006), I asked Daniel Broughton to confirm the detail of the property being offered for disposal, stating :
In each instance, Broughton, confirmed that this was the case (6 March 2006 and 14 March 2006). • In actual fact, his client, SS i.e. Ladsky et. al. had, two / seven weeks previously, become a "lessee" of Lavagna Enterprises Ltd (Headlessors) to which it had also disposed of its headlease interest on the last floor of Jefferson House i.e. the "airspace" which includes the title for the penthouse flat and associated car parking space. • As you would expect, legislation ( Section 5(2) of the L&T Act 1987) requires supplying particulars of the property offered for disposal. As can be seen from the 10 February 2006 'notice', the corrupt Daniel Broughton 'did this' by supplying the Land Registry title for SS - minus the first page - hence, minus pages one and two. What page one states (at 22 February 2006 ) : “(20.10.2004)...the Air Space abutting and above the level of the surface of the roof of Jefferson House has been removed from this title” Having determined that the so-called "notice" was FRAUDULENT, I opted to catch Daniel Broughton and Ladsky at their game, by stating the following in my 30 March 2006 letter to Broughton:
This was the reply from Daniel Broughton, dated 3 April 2006 :
As I pointed out in my 30 April 2006 reply, "Therefore [the offer] is not "as per the content of the notice"" As to his comment "not any interest in the property that may be held by Lavagna Enterprises Ltd", I asked whether he was "suggesting that the information held on the Land Registry is false?"
In the same letter of 30 April 2006, I wrote :
In his 3 April 2006 reply Broughton stated that he had "deliberately omitted" to include the first page of the title, giving as reason "our client is not required to provide this information" In the same reply of 30 April 2006 I argued that:
My non-lawyer assessment, captured in my 30 April 2006 letter is that Portner and Jaskel has committed breaches of statutes, as well as rules comprised under the Solicitors Code of Conduct of the Law Society for England and Wales: Property Misdescriptions Act 1991 which "prohibits the making of false or misleading statements about property matters" - section 5(a) "false" means false to a material degree". I draw your attention to section 1(3) of the Act "A person guilty of an offence under this section shall be liable (b) on conviction on indictment, to a fine" I also stated to Daniel Broughton : “considering that I, a member of the public, was able to uncover the information about the ownership of the block; wrote you on two occasions asking you to confirm that the “notice” refers to the building, as it stands now, in its entirety i.e. the whole of Jefferson House”, he would not be able to use Section (5)2 of the Property Misdescriptions Act 1991 – 'Due diligence defence' Landlord & Tenant Act 1987 section 5, as well as section 4 (Amendment 89– (1) ) which states :
Solicitors Code of Conduct • Rule 26.01 - Solicitors selling property • Rule 18.01 – Definition of undertaking and Rule 18.09 – Undertaking on behalf of clients, stating that these rules “might be relevant” • Principle (a) – Independence and integrity • Principle (d) – Repute of solicitors’ profession • Principle (e) – Standard of work • Rule 12.02 – “A solicitor must not act where the instructions would involve the solicitor in a breach of the law…” As to SS, that it committed a criminal offence in relation to Section 10A (1) of the L&T Act 1987 by not "offering me first refusal" when it disposed of its assets to Lavagna Enterprises. Also, that the disposal of the assets has led to SS, my landlord, being unable to perform major covenants in my lease. The reply I received from Daniel Broughton is dated 3 May 2006. (It is also included at the back of my 30 April 2006 letter). It states:
(For additional detail see Notices by landlord # 3 , # 3.1 , # 3.2 ; My Diary 18 Feb 06) Throughout this website I have stated that I am not a lawyer. However, I believe that anybody of moderate intelligence would, when considering the above evidence, arrive at the same conclusions: Portner and Jaskel and its client Andrew Ladsky "deliberately" set out to mislead me and, in the process, committed serious breaches of legislation - as well as breaches of the Law Society Code of Conduct. (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (NB: On the upside, responding to this BOGUS "notice" gave me the opportunity to 'pay back' the evil , sociopathic scums at Portner and Jaskel for what they did to the Elderly Resident - see My Diary 18 Feb 06 ; 29 Apr 06 ; Elderly Resident )
Desperate to stop me from exposing the detail of my case - on behalf of Andrew Ladsky - Jeremy Hershkorn - faxed a malicious 3 October 2006 letter to my first website host, threatening my host with "proceedings for defamation and for substantial damages and costs" if it did not close down my website, making highly libellous, scurrilous - TOTALLY unsupported - claims against me that "[my website] contains suggestions that our client [Ladsky] is guilty of criminal activities and fraud all of which are totally unsubstantiated, outrageous and false... Our client's reputation has been severely damaged..." (I can't stop laughing at that). Hershkorn concluded the letter by stating "We will of course, take all appropriate steps to enforce any judgement obtained in the UK against you" (My Diary 3 Oct 06 ) The threat of "proceedings and costs and damages" had the desired effect with my first website host - as it closed down my website (My Diary - 3 Oct 06) Trying his luck again, over a period of several weeks, Jeremy Hershkorn, sent a massive amount of emails to my current website Host, threatening my Host with legal "proceedings and costs and damages" unless my Host closed down my website, by - yet again - making highly libellous, scurrilous - TOTALLY unsupported - claims against me, stating "all of the allegations on [my] website are clearly untrue and therefore defamatory" (My Diary 5 Feb 07 ) As can be seen by the fact that my website is still live, my (very courageous) Host did not cave in to the empty threats from Hershkorn - 'empty' because he would not have been able to justify his accusations - as VERY AMPLY DEMONSTRATED BY SUBSEQUENT EVENTS - which culminated in the 6 June 2008 Notice of Discontinuance of "ALL of the 27 February 2007 claim" against me (point # 31) Doesn't that substantiate my position?(See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
On 24 February 2007 I took delivery of a malicious 16 February 2007 letter from Jeremy Hershkorn headed: "Rootstock Overseas Corp - Outstanding arrears £8,937.28" (US$15,800) At the time, I had NEVER heard of this company. Proof that I had not can be seen in the 12 July 2007 letter from Ahmet Jaffer (in reply to mine of 30 June 2007): "We notified you by our letter of 27th February 2007 that the title to the premises was transferred from Steel Services Limited to our clients, Rootstock Overseas Corp on the 24th May 2006" In my 12 August 2007 reply, I asked Jaffer to supply me with a copy of the correspondence he claimed had been sent to me. He totally ignored my request = this is, yet again, another lie by Portner and Jaskel. Consider that Jeremy Hershkorn expected me to pay £8,937 (US$15,800) to a company I had NEVER heard of - and was threatening me with bankruptcy, forfeiture and costs if I did not pay immediately! It is particularly important to note this point in relation to Hershkorn's follow-up action - as he filed the 27 February 2007 claim against me - see below # 6 . Hershkorn states in his malicious 16 February 2007 letter: "We have been instructed by Rootstock Overseas Corp in connection with outstanding arrears of service charge due and which relate to the above premises, details of which you are fully aware of " My reaction was: as I have never heard of this company, it follows that I have never had any dealings with it - and consequently cannot have "outstanding arrears" - which was my reply on 25 February 2007. Hershkorn then states that, as of now, correspondence to / from Martin Russell Jones (MRJ) "in relation to arrears" is through Portner and Jaskel. (As the saying goes : "Birds of a feather flock together") The second paragraph starts with "We enclose a copy of a statement dated 13th February 2007 which indicates how the sum of £8,937.28 (US$15,800) has been calculated" NOTHING was enclosed with the letter - as I pointed out in my 25 February 2007 reply. The rest of the letter :
Note that Hershkorn had claimed very comprehensive knowledge of the details of my case - as he wrote to my website Host that "all the allegations contained in [my] website are not true" (point # 2, above) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (4) For the third time the Law Society of England and Wales provides undeniable evidence that it is a FERTILISER FOR MALPRACTICE...While I found the conduct of Portner and Jaskel in relation to the 10 February 2006 so-called "notice" absolutely outrageous (point # 1, above), considering my very extensive first-hand experience with the Law Society (i.e. my complaint against Cawdery Kaye & Taylor and Piper Smith Basham, and follow-up involving the Legal Services Ombudsman ) (summary in My Diary 6 May 08), I saw no point filing a complaint against Portner and Jaskel. Well, the 16 February 2007 letter from Jeremy Hershkorn (point # 3, above), combined his ongoing harassment and intimidation of my US website Host to get it to close down my website (point # 2, above), led me to change my mind. Also, I hoped that since my 2004 complaints a 'new regime' might have been implemented at the Law Society. This turned out to be 'in my dreams'. I headed my 28 February 2007 letter to Mrs Fiona Woolf, President of the Law Society of England and Wales:
and provided 14 enclosures as supporting evidence. I conclude by asking Mrs Woolf "to take appropriate actions against your member in relation to the matters raised in this letter" It led to the 2 March 2007 reply that the handling of complaints against solicitors is now with the Legal Complaints Service, and that it operates "independently of the Law Society". I had my doubts about this claim - and I was, yet again, proven to be right. This was followed by a 12 March 2007 letter from the Legal Complaints Service (LCS), as well as guidance leaflet (also attached). The letter states that it will determine whether it "can help with your concerns". (NB: I noted that the LCS is at the same address as the Law Society's previous "Consumer Complaints Service" to which I addressed, for example, my complaint of 20 December 2004 against Cawdery Kaye Fireman & Taylor (CKFT) - as can be seen in my covering letter of the same date. The "Consumer Complaints Service" was a renaming from "Office for the Supervision of Solicitors" (which was also at the same address) - as can be seen when I filed my 16 March 2004 complaint against Piper Smith Basham: # 4, # 5 and # 6 (i.e. nine months previously) ) As can be seen from the LCS's letterhead and booklet, its proposition is defined as"Resolving complaints about solicitors". I thought: Makes a change from its predecessors I came to view - based on my very comprehensive first-hand experience - as "Obstructing complaints". (5) ...as the Law Society rejected my complaint against Portner and Jaskel - in the process demonstrating approval of solicitors: (1) threatening members of the public with bankruptcy and of taking their property away for non-payment of monies to a company they have NEVER heard of; (2) issuing FRAUDULENT documents; (3) making FALSE accusations to a third party against a member of the publicI received a 30 March 2007 letter from the Solicitors Regulation Authority. I had no idea that this was a follow-up to the 12 March 2007 acknowledgement from the Legal Complaints Service - and the 30 March 2007 does not provide any explanation, other than state:
The pre-printed text at the bottom of the page reads "The independent (NB!!!) regulatory body of the Law Society of England & Wales" This 'information sheet' was enclosed with the letter. It states: "How we deal with concerns in the Conduct Assessment and Investigation Unit (from people who are not clients)". It continues:
What are all these names? What happened to the Legal Complaints Service? Vanished into thin air? Other extracts from the 'information sheet' - on page 1:
Doesn't that sound reassuring to the public?
Oh dear! What does the 30 March 2007 letter say?
Who does if you, as a member of the public, have been the victim of misconduct from a solicitor? (5.1) Re. my complaint that Portner and Jaskel sent me a malicious, ILLEGAL 16 February 2007 letter threatening me with "bankruptcy proceedings, forfeiture and costs" - if I failed to immediately pay £8,937 (US$15,800) to a company I had NEVER of (point # 3, above)
"Acting on the instructions of their client". (Which it also repeated in relation to the ongoing harassment of my website Host by Jeremy Hershkorn - see point # 5.3, below) This is a repeat of the reply I had from the Law Society following my 20 December 2004 complaint against CKFT. Indeed, in its 8 February 2005 letter, it stated, in relation to:
(A) 'Funny' how the Law Society did not hold this view in relation to my 16 March 2004 complaint against my then solicitors, Piper Smith & Basham. Why the 'double standard'? Why is it that Ladsky's advisors have 'carte blanche' to do exactly as they please in answering his diktats - while I have evidently NO RIGHT to expect 'my' legal 'advisors' to deal with me as per the Solicitors Code of Conduct? My 19 February 2005 reply to the Law Society was (point 2 - and ditto under points 14 and 18)
The same reply applies to the comment from the Solicitors Regulation Authority.
The 30 March 2007 letter from the Solicitors Regulation Authority continues with:
In other words: The "independent from the Law Society" Solicitors Regulation Authority approves of solicitors threatening members of the public with bankruptcy proceedings and with taking their flat away for non-payment of monies to a company they have NEVER heard of. UNBELIEVABLE! From which cave have these people crawled out of? HOORAY FOR SELF-REGULATION!In relation to the comment "... I do not consider that the letter is either threatening or that it amounts to harassment ": I wish the caseworker at the Solicitors Regulation Authority to, one day, find himself at the receiving end of a letter unlawfully threatening him with bankruptcy and of taking his property away. Let him see whether or not it feels "threatening". My message to him: if finding yourself in this situation causes you so much stress that you end-up fainting, I can - from my personal experience on 19 June 2005 - recommend St Thomas hospital. I am sure it will come to you as a surprise but: YES, going through, since 2002, the relentless mental torture from the ongoing sadistic, barbaric treatment IS AFFECTING MY HEALTH. (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (5.2) Re. my complaint that Portner and Jaskel sent me the FRAUDULENT 10 February 2006 so-called "Notice of first refusal" (point # 1, above)In its 30 March 2007 letter, the Solicitors Regulation Authority replied:
Here we go again: the game of being sent from 'pillar to post'
Ho! Am I the Law Society's "regulatory body" - meant to police the conduct of solicitors - as I was apparently meant to under its previous name? Just as well the 'Solicitors Regulation Authority' started its 30 March 2007 letter with: "Our objective is to regulate solicitors in the interests of the public and users of legal services" ! (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (5.3) Re. my complaint that Portner and Jaskel has been harassing my US Website Host for several weeks (point # 2, above)The 30 March 2007 conclusion from the Solicitors Regulation Authority is:
Here we go again (see point # 5.1, above): "on instructions from their client"! (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (5.4) Overall conclusion by the Law Society: "NO MISCONDUCT BY PORTNER AND JASKEL"And the overall conclusion from the Solicitors Regulation Authority in its 30 March 2007 letter? OF COURSE:
=THE LAW SOCIETY AND ITS "INDEPENDENT" ARM, THE SOLICITORS REGULATION AUTHORITY APPROVE OF PORTNER AND JASKEL:
...and therefore approve of the conduct of Jeremy Hershkorn and Daniel Broughton, and of, 'of course', being above the law of the land. Well, unlike the Law Society, I hold the view that they have VERY SERIOUSLY FAILED to discharge their professional duties. (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
HOORAY FOR SELF-REGULATION!(NB: Given the reply, I opted to do some research on the Solicitors Regulation Authority, as well as on the Legal Complaints Service. See My Diary 12 Apr 07)
Other examples of malpractice / injustice suffered at the hands of the legal sector: • Solicitors From Hell (http://www.solicitorsfromhell.co.uk) • Legal Bullies - http://www.legalbullies.co.uk And, unfortunately, it's not any better in Scotland: 'Scotland Against Crooked Lawyers' (SACL) (http://www.sacl.info) ; About SACL (http://www.sacl.org.uk) ; Latest News (http://www.sacl.info/about.htm) ; SACL links (http://www.sacl.info/links.htm) (In My Diary 3 Mar 07 I also refer to the case of a Scottish lawyer who ended being ostracised by the Scottish Law Society, apparently, for taking on cases of injustice) And this website relates to Ireland: Crooked Lawyers - http://www.crookedlawyers.com The SACL website also provides links to other sites e.g. Dunblane Unburied - http://www.dunblaneunburied.tk - referred to in My Diary 3 Mar 07. This website concludes involvement by the Freemasons. Another website, Stand Your Ground - http://www.standyourground.co.uk, also warns of Freemasons involvement. I believe that Freemasonry is involved in my case. With this attitude from so-called 'regulatory' bodies, it is no surprise to see what took place subsequently with Portner and Jaskel - as detailed in the remainder of this section.In My Diary 12 Apr 07, at the end of the entry I quoted a comment from a Reader of The Times, 16 April 2007: ""My father used to say that the mafia never got a foothold in this country because our legal system was more corrupt than they were. Now I know what he meant!" SO DO I !
(6.2) ‘Very conveniently’ for “Roostock (sic) Overseas Corp” and "Steel Services" - in breach of CPR PD 16 – para 7.3, WLCC also accepted the claim WITHOUT having my lease, i.e. my ‘contractual obligation’, supplied with the claimSee WLCC # 1.1
Civil Procedure Rules - Part 22 - Statements of Truth - Practice Direction (*) states :
(*) Sourced from the website of the then Department for Constitutional Affairs, on 14 March 2007 'Obviously' Jeremy Hershkorn had familiarised himself with the details of my case in considerable depth as, in the process of harassing my website Host over a six-week period (point # 2, above), from mid-January 2007, to get my Host to close down my site, he wrote:
Hence, Jeremy Hershkorn cannot claim that he did not have very comprehensive knowledge of my case at the time he filed the 27 February 2007 claim against me.Consider also the outcome of the claim (after a 16-month battle): a 6 June 2008 Notice of Discontinuance of "ALL of the claim" against me (point # 31)(See My Diary 13 Jul 10 for the THIRD MAJOR FRAUDULENT demand 'from' MRJ since 2002) (7) Two days after the claim was filed, Martin Russell Jones (MRJ) drew-up a 1 March 2007 invoice in the name of "Steel Services, represented by CKFT" - that is £249 (US$440) LESS than the claim from "Steel Services" - and, as came to light FIVE months AFTER the claim was filed against me - did this in spite of this entity having apparently disposed of its title to "Rootstock Overseas Corp", 10 months PREVIOUSLYThe 1 March 2007 invoice from MRJ, stating "Landlord: Steel Services", states a "Brought forward balance" of £8,688 (US$15,300) v. the Particulars of Claim - also supplied by MRJ - that state £8,937 (US$15,760). Hence, in the space of 48 hours, the amount I am 'deemed' to owe to "Steel Services" was inexplicably reduced by £249 (US$440) Nothing else was supplied, other than this document in relation to the electricity charge of £23.80. (This amount is not included on the 27 February 2007 claim). Of particular note: according to Ahmet Jaffer and the Land Registry title he supplied me with in his 12 July 2007 correspondence, SS had disposed of its title to Rootstock Overseas Corp on 24 May 2006 i.e. 10 months PREVIOUSLY (see also below point # 15) (See My Diary 13 Jul 10 for the THIRD MAJOR FRAUDULENT demand 'from' MRJ since 2002) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (8) On 4 April 2007, I sent WLCC my Evidence in support of my Application Contesting the Court's Jurisdiction, requesting - as per my rights under Schedule 12 Section 3 of the Commonhold and Leasehold Reform Act 2002 - the transfer of the case to the Leasehold ValuationSee WLCC # 3 (9) In the same, 4 April 2007 document, I also made a second Application: "An extended Civil Restraint Order against the Landlord"See WLCC # 4 (10) On 3 May 2007 I filed my Skeleton Argument in WLCCSee WLCC # 5 (11) Filing of the Skeleton Argument was in preparation for a hearing set by WLCC for 8 May 2007. With one working day to the hearing, WLCC cancelled it following communication from Jeremy Hershkorn - and rescheduled it for 24 August 2007 i.e. three-and-half months laterSee WLCC # 6 for its rescheduling of the hearing during the month of August, which is the holiday period - and the 24th of August was a Friday - before a bank holiday (!!!) (12) WLCC supplied a 3 April 2007 Notice to Portner and Jaskel - FALSELY - stating that I "intend to defend part of the claim"While, on Saturday 5 May 2007 I had not received any communication from WLCC, I had two letters from Jeremy Hershkorn waiting for me at my PO Box. The first one, dated 1 May 2007, is to copy me on what he had sent to West London County Court. It comprises of a letter dated 1 May 2007 stating that he "only just received today"` the 19 April 2007 WLCC order - which he attached, having written - himself - on it "Received 1/05/2007". Yeah, right!`I receive it on Saturday 28 April, but the solicitors that filed the claim against me, receive it two working days later!! ((As can be seen from Hershkorn's letter to WLCC, solicitors and the courts have a DX system to communicate between each other) Hershkorn continues: "We wish to bring to the Court's immediate attention that apart from receiving Notice that an Acknowledgement of Service has been filed by the Defendant dated 3'" April 2007..." GET READY FOR THIS ONE! "...(a copy of which we enclose)..." Look at what the West London County Court 3 April 2007 "Notice that acknowledgement of service has been filed" says:
How much bigger did I need to make the cross on the 22 March 2007 Acknowledgement of Service when I selected option #3 "I intend to contest jurisdiction"? In the fourth box, at the top of the form, I underlined - in red : "wish to contest the court's jurisdiction" NOBODY CAN FAIL TO SEE THIS.(See also WLCC # 2 ) (13) The advantage of this to Jeremy Hershkorn was the ability to claim that he had "not received a defence" from me - thereby providing a reason for asking that the 8 May 2007 hearing be cancelled - and prior to this - filing an Application for a judgement to be issued against meIn his 1 May 2007 letter to WLCC, Jeremy Hershkorn states:
My reply to this is: not my problem. Firstly, because it was not I who did not capture what I had written on the 22 March 2007 Acknowledgment of Service. Secondly, the guidance notes supplied with the claim by WLCC only make a passing reference to contesting the court's jurisdiction. I had to look at the CPR to determine that "an application must be supported by evidence" As I wrote to Ahmet Jaffer in my 30 June 2007 letter when I supplied him with a copy of my 4 April 2007 Evidence in support of my application for contesting the court's jurisdiction: "This lack of information led me to consult the Civil Procedure Rules, Part 11 - "Disputing the court's jurisdiction". It does not stipulate a requirement to serve a copy of the evidence on the other party". If Jeremy Hershkorn is to be believed: he had not heard anything from WLCC since the 3 April 2007 "Notice that acknowledgement of service has been filed". Some 'very interesting' points to note here:
Have I got 'S T U P I D' written on my forehead? (Having just looked in the mirror I can answer that: No!) OF COURSE PORTNER AND JASKEL HAD BEEN IN CONTACT WITH WLCC DURING THE MONTH OF APRIL: This is evidenced by the 19 April - 26 April 2007 WLCC Order - Point 2: "In view of the defendant's application the claimants request for judgment is refused" I guess that I should be 'grateful' that WLCC did not accede to Jeremy Hershkorn's demand. (14) The other reason given by Hershkorn for asking that the 8 May 2007 hearing be cancelled, is that Portner had 'received' a cheque for £1,069.31 (US$1,885) - FALSELY - claiming that it had been sent "on my behalf" - amount which is PRECISELY the amount of interest claimed by "Rootstock" - thereby implying that I owed all of the claimIn his 17 April 2007 letter, Hershkorn wrote "enclose a copy of a letter dated 6th April 2007 received from Martin Faulkner of flat 4, 13 Belsize Grove, London NW3 4UX together with a copy of a cheque for £1,069.31 dated 6th April 2007 payable to Martin Russell Jones" The person is 'Martin', 'the visitor' to my website who sent me the first comment (referred to under My Diary 12 Jan 07). I do not know this person. Having thanked him for his initial email, we then exchanged a few emails - as he stated that he "once owned a leasehold flat in a block owned by a company registered abroad and had a few of the same problems you have had". As can be seen from my email of 9 April 2007 to this person in response to his email of 5 April 2007, I had NO knowledge that he had done this:
As can also be seen from my previous email to him of 21 March 2007, I made it abundantly clear by, among others, providing various URLs to my website, that I had a £6,100 credit. I also wrote:
The 'visitor' NEVER replied to my 9 April 2007 email. This was a set-up by the psychos, as: (1) the sum offered 'happens to be' the full and PRECISE amount of interest claimed in the 27 February 2007 claim - thereby implying that I owed all of the sums claimed. (The human race!) (And many more have since been only too happy to cooperate - see My Diary 2009 - Introduction) (2) another individual - at the SAME ADDRESS - tried to trick me into wasting my time to, among others, write a witness statement - claiming that her block was connected with some of the same mob. (This is in addition to this 'payment' providing Portner and its client with the opportunity to ask for cancellation of the 8 May 2007 hearing and WLCC with 'setting-up', more than 4 months later, the 24 August 2007 hearing (WLCC # 11) I provided a reply to Ahmet Jaffer in my 30 June 2007 letter. Jeremy Hershkorn concluded his 1 May 2007 letter to West London County Court:
How about: "We are profusely grateful for your unfailing assistance to our client?" (considering also events in 2002-04) (I summarised some of the events in my 5 December 2007 letter to HMCS Customer Service - and comprehensively in my 2 January 2010 Subject Access Request to the Ministry of 'Justice' - see Legal-Home # C) As to Hershkorn's second letter, it is dated 4 May 2007, and states among others:
Oh yeah! "Upon the Courts own motion. The Court has made this order of its own initiative without a hearing" (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (15) FIVE months AFTER the 16 February 2007 threat of "bankruptcy and forfeiture" from "Rootstock Overseas Corp" ,and the 27 February 2007 claim on which, with "Steel Services", it claims to be my "landlord" - I finally received 'some' information on the identity of this paper entity - which further adds to the number of major issuesIn my 30 June 2007 letter to Ahmet Jaffer, on which I copied WLCC, I wrote: "in my 25 February 2007 letter to Mr Jeremy Hershkorn, I asked for an explanation as to the identity of "Roostock Overseas Corp" as I had never heard of it before. To date I have had no reply, or acknowledgment" It (finally) led Jaffer to reply in his 12 July 2007: We notified you by our letter of 27th February 2007 that the title to the premises was transferred from Steel Services Limited to our clients, Rootstock Overseas Corp on the 24th May 2006" Obviously, I never received this communication. In my 12 August 2007 reply, I asked Ahmet Jaffer to supply me with a copy of the correspondence he claimed had been sent to me. He totally ignored my request = this is, yet again, another LIE by Portner and Jaskel. With his letter, Jaffer attached a Land Registry title for "Rootstock Overseas Corp" describing it as having gained ownership of the title "from Steel Services", for £120,000 (US$212,000), on 24 May 2006, and to being domiciled in Panama (NB: A similar type of jurisdiction to the British Virgin Islands - see Owners identity for companies domiciled there). It is rather 'interesting' to note that the "transferor" of the title is "Steel Services" - given that Steel Services was a "lessee" of Lavagna Enterprises (Headlessors # 3, # 4 , # 5 ). My explanation: all these 'paper companies' have the same person trying to hide behind them: Andrew Ladsky (Headlessor # 5 ; # 7 ; Owners identity ; Directorships ; Freehold ownership ; BVI registration ) ('Maybe' the creation of Lavagna Enterprises as a superior headlessor was done for the purpose of borrowing money?) in my 12 August 2007 reply to Jaffer (on which I copied WLCC, including on the enclosures: (WLCC # 9), headed "URGENT AND IMMEDIATE ATTENTION", I note the fact that Jaffer has failed to supply me with the skeleton argument, and remind him that he has had mine since 4 May 2007. I also raise a number of other points / ask a number of questions in my 12 August 2007 reply:
Actually, three months into year 2007, the 1 March 2007 invoice from Martin Russell Jones (MRJ) also states: "Landlord: Steel Services" (!!!) For a detailed assessment of the issues, see my 12 September 2007 Defence ; my 3 June 2008 Witness Statement In my 12 August 2007 letter, I also took the opportunity to write: "your firm’s conduct and that of your client is of the most despicable" - which I followed by relating some of the past events. As Portner and Jaskel had positioned itself as a go-between with MRJ in its 16 February 2007 letter (admittedly, "in relation to arrears"), in the penultimate part of my letter, I reported the latest malicious leak in July 2007 - and supplied photographs. Needless to say that there was no follow-up. In the last part, I confirmed that I would be seeking "my costs on an indemnity basis" and would "reiterate my request to WLCC for a Restraining Order against your client" I confirmed this again in my 22 August 2007 letter to Jaffer to supply him with my costs - in anticipation of the 24 August 2007 hearing - and EQUALLY important: copied WLCC on this correspondence. (See WLCC # 11 for issue about this at the 24 August 2007 hearing) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
These letters are: • 30 June 2007 to Jaffer, copied to WLCC: "You have had my skeleton argument since 4 May 2007. I require that you provide me with your skeleton argument within seven days of receipt of this letter, so that I can make my own preparations for the forthcoming court hearing" • 12 August 2007 to Jaffer, copied to WLCC:" URGENT AND IMMEDIATE ATTENTION - You have failed to provide me with your Skeleton Argument. In my attached letter of 12 August, I have asked the court's assistance in ensuring you send me your Skeleton Argument by 16 August 2007. I remind you that you are in possession of my Skeleton Argument since 4 May i.e. for more than three months. Your failure to provide me with the requested information adds weight to my – amply supported position - that your client’s claim against me is dishonest and vexatious." • 12 August 2007 to WLCC, copied to Jaffer: Headed: "Your assistance in getting the skeleton argument from Portner and Jaskel". I wrote: "I wish to bring to your attention the fact that Portner and Jaskel has so far failed to supply me with its skeleton argument, and by the same token, evidence in support of its client’s claim against me. By contrast, it received my skeleton argument on 4 May 2007 i.e. more than three months ago. The hearing is scheduled for 24 August 2007. Clearly, non-provision of the skeleton argument puts me in a highly unfair and very disadvantageous position in relation to the hearing. Hence, Portner and Jaskel is in breach of its legal obligations under Section 1.3 of the CPR, “Duty of the parties: The parties are required to help the court to further the overriding objective“" • 16 August 2007 fax to WLCC, copied to Jaffer: "One week to the 24 August 2007 hearing and Portner and Jaskel has not supplied me with its skeleton argument. Yet, it has now been in possession of my skeleton argument for three and half months (since 4 May 2007) The unwillingness to date to provide the requested information - including failure to comply with your court’s order of 26 April 2007 - provide overwhelming support to my position that the claim against me is dishonest and vexatious. (Hence, a repeat of Steel Services Ltd claim filed against me in your court in November 2002). Concurrently, this conduct provides evidence that the claim is a waste of court time, as well as my time. Quite clearly, this breach of the rules of court is intended to gain an unfair advantage and calculated to inhibit your court from furthering the overriding objective" Eventually, sometime on Wednesday 22 August 2007, a two-page “Skeleton argument on behalf of the Claimant for hearing on 24 August 2007” produced by Mr Greg Williams of 2 Gray’s Inn Square Chambers, and attached covering letter from Ahmet Jaffer were delivered by courier to my PO Box address. Hence, LESS THAN 48 hours before the hearing (on 24 August 2007) - and three-and-half months after it had received mine As I was not living near my PO Box at the time, I tended to make relatively infrequent visits. Considering the timing of the delivery, it is my guess that Ahmet Jaffer and his client were relying on my not going to my PO Box, so close to the hearing - considering, among others, the lack of response to my above letters. But, I listened to my 'internal radar'. As one of my friends said: "that's the kind of trick you would expect from them" Indeed! YES, "Rootstock Overseas Corp" and its solicitors, Portner and Jaskel, decided to employ a barrister to face me... a non-lawyer! :-) (I have obviously progressed since 2002-04 when the opponent was' just' a solicitor) (Cawdery Kaye Fireman & Taylor, CKFT) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
Point 5 of Rootstock Skeleton argument states “The Claimant has not received a copy of the Defendant’s skeleton argument in support of her application. The Defendant asserts in correspondence that the Claimant has had her skeleton argument since 4 May” Damn right it had received it - as I proved in my 22 August 2007 fax to WLCC by attaching a copy of the printscreen of the Royal Mail website confirming that my document had been delivered. I tried to also send the fax to Portner and Jaskel but, as its fax machine 'appeared' to not work, I ended-up having it biked over. Consider as well: 'if' it were true that Portner and Jaskel had not received my Skeleton Argument, why wait until 22 August to say so? As evidenced by my four letters detailed under the previous point, since 30th June I had been writing to Ahmet Jaffer that he had been in possession of my Skeleton Argument since 4 May 2007. At the 24 August 2007 WLCC hearing, Mr Greg Williams, barrister, 2 Gray's Inn Square Chambers, asked me to show him the original post office receipts - which, of course, I had - knowing the evil, morally depraved mob I am dealing with. Their lie provides overwhelming support to my position that the claim against me is FRAUDULENT, and the lack of supporting evidence further endorses my position - see point # 24 (Note at June 2008: I was proven right! (point # 31)) Fair minded, reasonable visitor to the site: do you see the unbelievably traumatic experience I have been suffering at the hands of Jeremy Hershkorn, Ahmet Jaffer and their client - Andrew Ladsky - since the beginning of the year - added to the experience with the BOGUS "notice" of first refusal in February 2006? (point # 1 above) ... among a mountain of other events instigated by him. (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
See WLCC # 11 for detail.
...(1) my 3 May 2007 Skeleton Argument, which was used at the 24 August 2007 hearing (points 1 and 4.9, and numerous other points); (2) my 12 September 2007 "Defence & Counterclaim" (header 8.64 , 5.4 - 5.10 , 5.12 and numerous other points). I therefore opted to title my 12 September 2007 document by reproducing WLCC's wording: "Defence & Counterclaim" (and it made sense to me, as I am making ‘counterclaims’ in my document ‘in defence’ of the claims against me) IT WAS A TRAP! (see WLCC # 13) As Portner and Jaskel and its client had lied by saying that they had not received my 3 May 2007 Skeleton Argument, the following day I captured a printscreen of the Royal Mail website confirming that my "Defence & Counterclaim" had been delivered. On that day, 13 September 2007, I sent the printscreen to WLCC, copying Mr Ahmet Jaffer on my letter. (20) When, on Monday 1 October 2007, I phoned WLCC to ask why, after more than one month, my nominated company had still not received the tape of the hearing for transcription, instead of getting a reply to my question, I was immediately told that I had "to pay £1,700 (US$3,000) to file your counterclaim"See WLCC # 13 for detail.
See WLCC # 14 for detail. (22) Portner and Jaskel had sent WLCC a 26 September 2007 "Defence to Counterclaim" produced by Mr Greg Williams, 2 Gray's Inn Square Chambers - arguing that my 12 September 2007 "Defence & Counterclaim" is not a "Counterclaim". I replied to WLCC on 2 October 2007As you can see from his 26 September 2007 "Defence to Counterclaim", Mr Greg Williams argues that my 12 September 2007 "Defence & Counterclaim" is not a 'counterclaim'. In my 2 October 2007 letter to WLCC, cc'd Ahmet Jaffer - which is a reply to this 26 September document and to what I had been told when I phoned WLCC on 1 October, I explain how I had interpreted WLCC's wording in its 24 August 2007 Order i.e. "Defence & Counterclaim" - and emphasise that it was an impossibility for me to file a counterclaim stating, among other:
(See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
On 14 October 2007 and 28 October 2007 I sent chaser letters to WLCC asking for a reply to my 2 October 2007 letter. In each instance, I copied Mr Ahmet Jaffer on my letters. At mid-December, I have not heard anything from Portner and Jaskel since the 26 September 2007 "Defence to Counterclaim" And NOR have I heard from WLCC since the 27 September 2007 communication - MASQUERADING as an Order - 'from' "Mr Joseph, Courts Section" - See WLCC # 16 for detail I WONDER WHY? ...considering that the level of conviction that I owe the sum demanded is such that it led Mr Jeremy Hershkorn to write in his 16 February 2007 letter (discussed under point 3, above):
Please, recall also that, prior to sending me the above 16 February 2007 letter and filing the 27 February 2007 claim against me, Jeremy Hershkorn had positioned himself as having very comprehensive knowledge of the details of my case as he wrote to my website Host: "all the allegations contained in [my] website are not true" (point # 2, above) Hum! Has Portner and Jaskel's client run out of "instructions"? (Picking-up the 'standard reply' from the Law Society - see points # 5.1 and # 5.3, above) End of December 2007: STILL no communication from Portner AND WLCC = a three-month silence. Oh! dear! Oh! dear! the 'mafia' does not like my 2 October 2007 letter. It's spoilt their plan. However, I have had communication from Portner's client: no heating and no hot water in my flat for three days - starting on Christmas day. It reminds me of what took place during the Easter break in 2003 Portner having, like WLCC, gone into 'silent mode' since the end of September 2007 - prompted me (in addition to other factors) to head my 27 December 2007 response to the 20 December 2007 'reply' 'from' the 'Customer Service' department of Her Majesty Court Service with "CONFIRMATION OF COLLUSION" (WLCC # 22 ) (The 20 December 2007 letter was a follow-up to my 13 November 2007 complaint to HMCS 'Customer Service' - WLCC # 18 ) Notes at end January 2008 (1) Since then, the 10 January 2008 reply the Customer Service department has led me to change my header to "ABSOLUTE CONFIRMATION OF COLLUSION" (see WLCC # 23 ) (2) In spite of WLCC sending an Allocation Questionnaire on 11 January 2008, I have not heard anything from Portner and Jaskel = four-month silence. Instead of returning the questionnaire, I have asked for the case to be transferred to another court (see WLCC # 24 ) See next point which further proves that the claim against me is FRAUDULENT. (24) Further proving the collusion, with a covering letter dated 7 February 2008, Ahmet Jaffer sent me a 'List of documents: Standard disclosure ' - BEFORE the case management directions were issued, and BEFORE I served my Allocation Questionnaire. It is clear from the list of 10 items that it does NOT address the issuesWith a covering letter dated 7 February 2008, Mr Ahmet Jaffer has sent me a 'List of Documents: Standard Disclosure', dated 4 February 2008, which is 'fascinating' on a number of counts: 1. Ahmet Jaffer did not send me his client's Allocation questionnaire. The deadline set by WLCC was 28 January 2008. While I did not return the one I was sent, opting instead to send the 26 January 2008 letter c/o WLCC (WLCC point # 24 ) – on which I copied Jaffer - my correspondence was delivered to both on 28 January 2008. 2. Issuing a 'List of documents' implies that there has been a case management hearing, following which the court issues directions on submitting the document. I have not received any communication to this effect. 'If' these events took place, it means that: (1) WLCC opted to totally disregard my 26 January 2008 letter; (2) set the case management hearing without informing me; (3) issued the directions without likewise informing me. This sequence of events 'appears' highly unlikely - not least because it would have taken place in the space of four working days (the deadline for returning the Allocation questionnaire was 28 January 2008. Portner and Jaskel dated its document 4 February) - and let's not forget that WLCC "only has one judge" :-) (WLCC # 6.1 ) 3. Barrie Martin FRICS, Martin Russell Jones (MRJ), ‘managing' agent, is now acting on behalf “of the claimant” – defined on the claim as “Roostock Overseas Corp, the Lessor of the premises known as Flat 3 Jefferson House” (i.e. my flat) v. the Particulars of claim, on MRJ's headed paper which state “Landlord: Steel Services Ltd, c/o Cawdery Kaye Fireman & Taylor” (As I wrote in my 18 February 2008 letter to Jack Straw, 'Justice' Secretary, "Like Portner and Jaskel, Cawdery Kaye Fireman & Taylor, Mr Brian Gale MRICS, Mr Barrie Martin – in tandem with his ‘double act’, Ms Joan Hathaway MRICS, has no qualms lying to anybody e.g. LVT (NB: MRJ # 43 ), Kensington & Chelsea housing department (NB: Kensington & Chelsea Housing point # 2.1 ). I have considerable ‘black on white’ evidence to support my claim" In my letter, I also stated "Not surprisingly, Mr Martin repeats the ‘winning formula’ in other blocks – as evidenced in the 2006 LVT case “Nearart Homes Investments Ltd v. Mr B Martin FRICS IRRV” (LON/00AQ/LSC/2005/0258) which highlights: (1) claiming large amounts of expenditure unsupported by invoices, as well as overcharging for services; (2) failing to produce year-end accounts; (3) failing to issue a section 20 notice; (4) the use of solicitors to enforce payment of service charges (point 12) )" (Royal Institution of Chartered Surveyors - point # 8 )) 4. Comparing the list of documents in the 4 February 2008 'List of Documents' with the counterclaims / issues I have raised in my 12 September 2007 "Defence & Counterclaim" - not to mention my 22 March 2007 Acknowledgment of Service ; my 4 April 2007 Application to contest jurisdiction ; my 3 May 2007 Skeleton Argument - it is blatantly obvious that they do NOT address them. (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (25) See WLCC for (1) the 7 March 2008 threat to "strike out [my] defence" unless I immediately filed an Allocation Questionnaire; (2) the 9 April 2008 so-called 'case management directions' issued by District Judge Ryan which breached numerous CPR rules ; (3) my 30 April 2008 Application to WLCC to vary the directions, and the refusal by District Judge Nicholson
The above is my introduction to the 'standard disclosure' list of documents I sent to Portner and Jaskel today - as per the directions contained in the 9 April 2008 so-called 'case management directions' (WLCC # 27) My list includes 243 documents – as the claim covers 4 years (given the state of the Particulars of claim, I produced an easy to understand version) - during which many events have taken place. Without a request from Portner – which I viewed as a sign of more intended dirty tricks - on 21 May 2008, I hand-delivered to Portner ’s office an integral copy of the 243 documents comprised in my 6 May 2008 Standard Disclosure - contained in two arch lever files. I did this because I viewed Jaffer’s silence as being caused by a plan for more dirty tricks, as the 9 April 2008 so-called ‘case management directions’:
Another event that reinforced my anticipation of more dirty tricks was my experience with a doctor on 7 May 2008 i.e. in the SAME month - See My Diary 2009 - Introduction-Medical # 2. (See My Diary - 6 May 08 and, for further detail, 15 May 08 ; Home page-Overview) (27) Demonstrating the evilness, perversion, deviousness and warped mentality of Andrew Ladsky and his corrupt lackeys, Portner and Jaskel, is the fact that the airspace of Jefferson House was "transferred from Steel Services to Rootstock" (for "£1") seven weeks BEFORE filing the claim against meIn the context of the 9 April 2008 so-called 'case management directions' issued by District Judge Ryan (WLCC # 27), on 16 May 2008, I asked Portner to supply me with documents from its 4 February 2008 standard disclosure (point # 24, above). One turned out to be a registered transaction for Jefferson House's airspace. It states:
As I wrote in my 3 June 2008 Witness Statement, point 51:
Rather 'interesting' to note that the "transferor" of the title for the airspace is "Steel Services" - considering that it was the "lessee" of Lavagna Enterprises (Headlessor # 2 ) (And ditto in relation to the 24 May 2006 transfer "by Steel Services" of its title "to Rootstock Overseas Corp" - given that SS was a "lessee" of Lavagna Enterprises (point # 15 above ; Headlessors # 3, # 4 , # 5 ) Prior transactions about the 'airspace' also indicate 'internal shuffling of papers' (Headlessors # 4). As I wrote under points 52 to 56 of my 3 June 2008 Witness Statement, the 8 January 2007 transaction still leaves many questions unanswered...(Headlessor # 5 ) My explanation: all these 'paper companies' have the same person trying to hide behind them: Andrew Ladsky (Headlessor # 5 ; # 7 ; Owners identity ; Directorships ; Freehold ownership ; BVI registration ) ('Maybe' the creation of Lavagna Enterprises as a superior headlessor was done for the purpose of borrowing money?) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (28) As I predicted in my 14 May 2008 reply to District Judge Nicholson's 9 May 2008 refusal of my 30 April 2008 application, I was left with having to write my Witness Statement - WITHOUT - the necessary evidence to which I am legally entitled - as Ahmet Jaffer did NOT reply to my 19 May 2008 Part 18 RequestSee WLCC # 29 ; My Diary - 3 Jun 08 That's the game the WLCC judges, their friend Andrew Ladsky, and his mob wanted to play: I had only one round. I would fight for a 'knockout'. (29) As per the 9 April 2008 so-called 'case management directions' issued by District Judge Ryan, I sent my 'knockout' 3 June 2008 (74 pg) Witness Statement (4 pg - Main Points) only to Portner and Jaskel... but I am sure that it quickly found its way to individuals connected with the court - and beyond. Another of my predictions materialised: I did NOT received a witness statement from the 'claimants' i.e. Ladsky et.al.The 9 April 2008 so-called 'case management directions' by District Judge Ryan (WLCC # 27) state “Both parties shall, by 4pm on Wednesday, 4th June 2008, serve on each other the witness statements of themselves and of all witnesses (other than expert witnesses) on whom they intend to rely” Under point 2 of my 3 June 2008 Witness Statement I wrote: "Considering the (well documented) conduct of the Claimant, i.e. Mr Andrew Ladsky (et.al.?), the requirement “serving on themselves” leads me to anticipate that I will not receive the Claimant’s Witness Statement as directed – allowing Mr Ladsky and supporters at large to see my Witness Statement first – in the knowledge that there will be no sanction for not complying with the WLLC Order (as happened with the 19 April 2007 WLCC Order in relation to the skeleton arguments) (points # 16 and # 17, above ). I hope to be proven wrong" I KNEW I would NOT be proven wrong: I did NOT receive the witness statement from "Roostock (sic) Overseas Corp / Steel Services Ltd" nor, indeed, from "Sloan Development" (point # 6.1, above) i.e. Andrew Ladsky et.al. = a REPEAT of what took place with the previous FRAUDULENT claim of 29 November 2002, filed against me, also in WLCC (My 19 October 2003 Witness Statement) - see also point # 31, below (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (30) On 5 June 2008, I replied to Ahmet Jaffer's letter of 23 May 2008 - on which he copied WLCC - and in which he suggested that the case be moved "from fast-track to multi-track" - asking him, among others, why he had FAILED to send me a witness statementKnowing that (as with the previous FRAUDULENT claim of 29 November 2002 - My 19 October 2003 Witness Statement), I would NOT receive a witness statement from "Roostock (sic) Overseas Corp / Steel Services Ltd" nor, indeed, from "Sloan Development" (point # 6.1, above)... ... I opted to wait until the day after the (4 June) deadline for the exchange of witness statements (point # 29, above) to send my 5 June 2008 reply to the typically patronizing, condescending, under-handed and ironic letter of 23 May 2008 (posted on 27 May) from Ahmet Jaffer - in which he suggested that the claim should be moved from 'fast-track' to 'multi-track'...
The ‘very convenient’ benefit to Ladsky and his mob of “suggesting” this 11th hour switch was that they avoided the CPR pre-hearing requirements that are more demanding than for ‘fast-track’ As I wrote in my 5 June 2008 letter to Jaffer:
I also wrote to WLCC on the same day, i.e. 5 June 2008, reporting the fact that, in breach of the 9 April 2008 so-called 'case management directions' issued by District Judge Ryan (WLCC # 27), the "claimant" had not submitted a witness statement and that it clearly had implications on the management of the case. The case management directions state
NB: In relation to Jaffer's comment in his 23 May 2008 letter “We received your letter of 21st May 2008 enclosing two lever arch files of copy documents you wish to rely upon at the hearing of this claim. The majority of the documents provided (without any request from us)…”: I followed my 'sixth sense' opting to hand-deliver (21 May 2008 covering letter) an integral copy of ALL of 243 documents listed in my 6 May 2008 Standard Disclosure (point # 26, above) - as I explained in my 5 June 2008 letter. (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
...threaten my then ISP with "proceedings for defamation and for substantial damages and costs" because "[my website] contains suggestions that our client [Mr Ladsky] is guilty of criminal activities and fraud all of which are totally unsubstantiated, outrageous and false... Our client's reputation has been severely damaged..." (I can't stop laughing at that) (point # 2 ) (My Diary - 3 Oct 06 ) ... repeatedly threaten my current website Host with "proceedings and damages and costs" unless my Host closed down my website, claiming that "all of the allegations on [my] website are clearly untrue and therefore defamatory" (point # 2 ; My Diary - 5 Feb 07 ) ...and 10 days before the date for serving witness statements - suggested moving the case to "multi-track"! (point # 30) Considering that, since the 27 February 2007 claim was filed against me (point # 6 above) ALL my documents to WLCC and Portner and Jaskel are based ENTIRELY on the contents of my website: If the claims on my website are "false", "outrageous", "unsubstantiated" and "defamatory" of 'the good character' of Mr Ladsky (I can't stop laughing at that): why has he dropped "ALL" of his (second) FRAUDULENT claim against me? (The first fraudulent claim was in November 2002 - CKFT ; WLCC, Martin Russell Jones, LVT, etc.) Considering that - just one week previously - Ahmet Jaffer was asking for the case to be moved to a multi-track (point # 30 above), why drop the claim now? Knocked out by my Witness Statement (point # 29 above) + somebody got 'cold feet'? Remember what I have said all along - including in numerous communications to Portner and Jaskel and WLCC over the past 15 months? This claim is FRAUDULENT. BUT, this time, I was NOT ‘represented’ in relation to the claim. Hence, the 'mafia' could not repeat the same trick: arriving at 'an arrangement' with 'my' legal advisers - as happened with the - equally FRAUDULENT 29 November 2002 WLCC claim, ref. WL203537, filed against me, also in WLCC (My 19 October 2003 Witness Statement ; home # 4.12 , # 4.13 ; Cawdery Kaye Fireman & Taylor ( CKFT) # 6.8 ; Piper Smith Basham/Watton # 7.13.2 , # 7.13.3 , # 7.14 , # 7.15 , # 7.17 , # 7.12.1 ; Stan Gallagher # 15). Furthermore, unlike in 2003-04 (Home # 4.14 ; My Diary 11 Mar 07 ; CKFT ; WLCC ; Lord Falconer), the ploys and 'games' in 2007-08, and the cruel, highly vicious, perverse, sadistic, barbaric treatment - BY ALL - FAILED to make me cave in - including FAILED to lead me to appoint legal 'advisers' (WLCC # 9 , # 11) = second time round: the FEAR tactics had NO hold on me - very clearly leading – ALL - to suffer immense frustration and anger.
'Unfortunately', in 2002-04, it worked with the majority of my fellow leaseholders as evidenced by the fact that 9 out of the 14 flats listed on the claim (Particulars of claim and list) ended-up paying the FULL amount of the service charge, and a further 16 flats also paid the full amount (CKFT # 6.3 , # 6.6 ; WLCC # 2 , # 5 , # 6 , # 8 , # 9 , # 12, # 14 ; Pridie Brewster # 2 , # 3 , # 18). (NB: Considering what has happened to me for 'daring' to fight back against the scam: being persecuted (e.g. Home-Overview ; My Diary 15 May 08 ; being under surveillance) I should say 'fortunately', instead of 'unfortunately').
Of course, I forgot, silly me: Portner and Jaskel, like, Lanny Silverstone and Ayesha Salim, Cawdery Kaye Fireman & Taylor (CKFT), and Richard Twyman and Lisa McLean, Piper Smith Basham/Watton, is evidently viewed by the Law Society as having "discharged its professional duties with [no]thing less than complete integrity and probity" - and consequently has no need to worry about "severe sanctions" (outcome of my complaints). (And ditto from the Bar Council in the case of Stan Gallagher : # 16 , # 17 and # 18) Is this going to be the end of this claim? Civil Procedure Rule 38.7 states " A claimant who discontinues a claim needs the permission of the court to make another claim against the same defendant if – (a) he discontinued the claim after the defendant filed a defence (I did: 12 September 2007); and (b) the other claim arises out of facts which are the same or substantially the same as those relating to the discontinued claim" Looking at what happened with WLCC since 2007, and in 2002-2004 with the previous FRAUDULENT claim: only time will tell. (See also My Diary - 7 Jun 08) (See My Diary 13 Jul 10 for the THIRD MAJOR FRAUDULENT demand 'from' MRJ since 2002) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (32) As per CPR 38.1, on 26 June 2008 I sent Portner and Jaskel my Statement of Costs - a total of £7,756 (US$13,676). The lack of response led me to send, on 22 July 2008, a 'Notice of Commencement of Assessment of Bill of Costs' - and a draft 'Statement of Case'Civil Procedure Rules 38(6) states "...a claimant who discontinues is liable for the costs which a defendant against whom he discontinues incurred on or before the date on which notice of discontinuance was served on him" In my 26 June 2008 Statement of Costs, spanning the last 16 months, I gave Portner until 4 July to reply, stating that if my costs are disputed, I will file an application for an order for costs. As expected, more than two weeks past the deadline: no response. So, on 22 July 2008, I sent Portner a 'Notice of Commencement of Assessment of Bill of Costs' (outcome of more 'cramming in' of the CPR), and of researching other sources of information. The deadline for reply is 13 August. With the notice "for information purposes", I also sent my 22 July 2008 draft 'Statement of Case' in support of my position - should the matter proceed to an assessment hearing. In his 1 August 2008 reply "AJ" i.e. Ahmet Jaffer states that my bill of costs has been sent to "Costs Draft men to settle points of dispute..." Subsequent note: On 11 November 2008, I sent Portner my Amended Bill of Costs - see My Diary 11 November 2008 for detail (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
On 13 August 2008, Portner sent the 11 August 2008 reply to my 22 July 2008 notice, giving, under paragraph 1.4, an absolutely outrageous, preposterous explanation for dropping the claim: that
No reason was given on the 6 June 2008 Notice of Discontinuance, evidently thinking that it would be the end of it, leaving Ladsky et.al. and their aides free to promote this preposterous reason, in the knowledge (based on past experience) that they would be highly unlikely to be challenged. Fascinating to see how the situation is dealt with when - unlike with the equally FRAUDULENT 29 November 2002 claim, ref. WL203537, filed against me, also in WLCC - there has not been the option of arriving at 'an arrangement' with members of the fraternity (My 19 October 2003 Witness Statement ; home # 4.12 , # 4.13 ; CKFT # 6.8 ; Piper Smith Basham/Watton # 7.13.2 , # 7.13.3 , # 7.14 , # 7.15 , # 7.17 , # 7.12.1 ; Stan Gallagher # 15) Furthermore, unlike in 2003-04 (Home # 4.14 ; My Diary 11 Mar 07 ; CKFT ; WLCC ; Lord Falconer), the ploys and 'games' in 2007-08, and the cruel, highly vicious, perverse, sadistic, barbaric treatment - BY ALL - FAILED to make me cave in - including FAILED to lead me to appoint legal 'advisers' (WLCC # 9 , # 11) = second time round: the FEAR tactics had NO hold on me - very clearly leading – ALL - to suffer immense frustration and anger.
'Unfortunately', in 2002-04, it worked with the majority of my fellow leaseholders as evidenced by the fact that 9 out of the 14 flats listed on the claim (Particulars of claim and list) ended-up paying the FULL amount of the service charge, and a further 16 flats also paid the full amount (CKFT # 6.3 , # 6.6 ; WLCC # 2 , # 5 , # 6 , # 8 , # 9 , # 12, # 14 ; Pridie Brewster # 2 , # 3 , # 18). (NB: Considering what has happened to me for 'daring' to fight back against the scam: being persecuted (e.g. Home-Overview ; My Diary 15 May 08 ; being under surveillance) I should say 'fortunately', instead of 'unfortunately'). The worst part of it is that this kind of conduct is widely endorsed (My Diary 6 May 08) - resulting in my being treated as 'the criminal' instead of the victim - while the criminals are treated as though they are the victims (e.g. RICS # 12 ; Kensington & Chelsea police # 2 , # 3 ; outcome of my complaints) - and laughing their head off Of course, I forgot, silly me: Portner and Jaskel, like, Lanny Silverstone and Ayesha Salim, Cawdery Kaye Fireman & Taylor (CKFT), and Richard Twyman and Lisa McLean, Piper Smith Basham/Watton ALL have the approval of the the Law Society for their misconduct.- and consequently has no need to worry about "severe sanctions" (quote from the SRA Chairman) (outcome of my complaints). (And ditto from the Bar Council in the case of Stan Gallagher : # 16 , # 17 and # 18) My response to the preposterous, laughable excuse for dropping the claim is on page 5, under point 2.2 of my 26 August 2008 reply and application for an assessment hearing. In summary:
(*) Actually, over the 16-month period, I did this a TOTAL of 11 TIMES:
Obviously, as in the case of my 8 communications to the courts and Cawdery Kaye Fireman & Taylor (CKFT) in relation to the previous, 29 November 2002 equally FRAUDULENT claim filed against me - also in West London County Court - the ink 'mysteriously' disappears from my documents before they arrive, or shortly afterwards. The Detailed Assessment hearing is 'due' to take place on 4 November 2008 (See My Diary 13 Jul 10 for the THIRD MAJOR FRAUDULENT demand 'from' MRJ since 2002) (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) (34) More LIES by Ahmet Jaffer and games - in tandem with District Judge Nicholson - and a transfer of the Detailed Assessment proceedings to the Supreme Court Costs Office - providing the opportunity to amend my documentsIn the above entry I wrote 'due' in inverted brackets because I had my suspicion that the 4 November 2008 Detailed Assessment hearing would not take place. I was right. Ahmet Jaffer faxed a 3 November 2008 letter to WLCC, claiming that my 31 October 2008 fax to him was the first he had heard of the hearing. Consequently "In the circumstances we would ask that the hearing be adjourned..." - See My Diary 11 Nov 08 for detail. On 4 November 2008, District Judge Nicholson told me that "At 10h00 this morning", he had issued an order for the case to be transferred to the Supreme Court Costs Office "because it's a detailed assessment". In light of this, I am taking the opportunity to review my submissions - starting with the Bill of Cost I sent Portner on 26 June 2008 as, in its 11 August 2008 Points of Dispute, under point # 1.11, it wrote "unfortunately the Defendant's Bill of Costs fails to comply with the requirements of CPR Part 43 and therefore this hampers the Claimant's ability to consider the reasonableness of each and every individual claim for costs made". (My reply of 26 August 2008). I sent Portner my 11 November 2008 Amended Bill of Costs with a covering letter explaining the amendments. See My Diary 11 Nov 08 for detail. The hearing is 'due' to take place on 30 January 2009 - see My Diary 19 Dec 08 (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.)
In my 19 January 2009 reply, I turned down the "offer" describing it as "derisory" as, from the time the FRAUDULENT claim was filed against me on 27 February 2007, WLCC and its ‘partner’, Portner, cost me (in addition to horrendous torment, anguish and distress over a period of 21 months):
See My Diary 30 Jan 09 for detail (See breaches of statutes by Portner and Jaskel and its client, Andrew Ladsky et.al.) |
