34. The Third Born child finished his exams in May 1993 and the Second Plaintiff returned to the Matrimonial Home and the child stayed in Cyprus for another month; the Second Born child joined him there (as referred to in paragraph .....). The Third Born child returned to the United Kingdom in July the First Defendant encouraged (used) him to enrol at a private college in South Kensington. And the Third Born child with the acquiescence of the First Defendant found expensive accommodation in South Kensington; he was also encouraged to look for an expensive car after passing his driving test. In the course of conversations in the presence of the child the First Defendant proposed transferring the two properties in Hornsey North London to the Second and Third Born children; he asserted that the children would be afforded the opportunities to use the income from the two properties in order to proceed with their intended studies; in effect the First Defendant was asserting that the properties he had proclaimed to be source of continuous problems, which he himself could not handle and or cope with, two young and inexperienced and unqualified children could.

35. Before the Second Born child returned to London in September 1993, the First Defendant took her and the Third Born child to the solicitor handling legal problems with tenants; he took them there on the pretext that he needed to 'instruct' the solicitor on matters arising in the divorce proceedings of his brother Haris. The solicitor told the First Defendant that he had written to the other side as they had discussed (evincing no need to be there) and the First Defendant told the solicitor that since they were there he wished to proceed with the transfer of the two properties in Hornsey, North London; the solicitor produced two blank forms and requested of the Second Plaintiff to sign the papers where he indicated to her but she refused to do as asked; the Third Born intervened and informed the solicitor that the aims spoken of at home were as not arose there.

36. On the occasion of the child's 18th birthday the Second Plaintiff took the child along to Curries in order for the child to select something of his choice; as with the other two children The Second Plaintiff had promised the child something special for the occasion; there was a sale at Curries at Newbury Park and the child selected a CD player; the Second Plaintiff paid a deposit and the purchase was to proceed through the "Buy Now Pay Later" sales promotion; full details were given to the sales man and the appropriate forms were completed; the Second Plaintiff was going back to Cyprus for the arrangements of the First Born child's wedding due to take place in London later on in the year; she informed the salesman that upon her return she would pay for the balance as per sales promotion. A few days later, the Third Born child telephoned the First Plaintiff to 'complain' that Curries refused to give him the CD but gave him no reasons why that was so; the child was asked to pass on all relevant information to the First Plaintiff who then undertook to telephone Curries in order to clarify the situation; upon telephoning the office staff about the matter the y informed that First Defendant that on seeking references from the hairdressing salon in Seven Kings they were informed that they knew not of a Mrs. D Englezakis at the salon; also that on seeking references from the National Westminster Bank at Seven Kings they were similarly informed and in the circumstances they could not release any goods to the young man under the sales promotion even though a substantial deposit had been paid towards the purchase. The First Plaintiff was placed in a very difficult position; he had not known of the financial stronghold and domination that the First Defendant had imposed on the Second Plaintiff; he was not in any position to question what was stated by the staff at Curries; any approach to the First Defendant would be but interference in the 'family's affairs'; the child could not possibly be told of the information imparted to the First Plaintiff who simply telephoned the child and told him that because his mother was not in London to clarify and qualify matters with Curries there was nothing the First Plaintiff could do for him. The First Plaintiff was informed nearly a year later that the child collected the deposit his mother had paid towards that intended purchase.

37. Following the attempt to secure under false pretences and through deceptions signatures on blank papers, at his solicitor's office, the First Defendant became very aggressive and was verbally abusive; in the circumstances the Second Plaintiff booked a flight after making the arrangements at Curries for the CD player birthday present (as referred to in paragraph......). This was before the Second Born child returned to the United Kingdom. In the meantime in July it had been agreed that the wedding of the First Born child should take place in the United Kingdom where she was born and most of her cousins and friends she grew up with lived. The Second Plaintiff concentrated her efforts in attending to the necessary arrangements and preparations for the First Born child's big day and event.

38. The Second Born child arrived back in the United Kingdom in September 1993 after the Second Plaintiff walked out of the Matrimonial Home because of relentless verbal abuses from the First Defendant. The Matrimonial Home had as yet to benefit from furniture the Second Defendant over which the First Defendant over the preceding months had given plenty a cause of aggravation, just as he had done, with the Second Plaintiff; he would often take them to various stores with a view to selecting and placing orders for a dining room table and chairs; that issue had as yet to be resolved and there were only weeks to the wedding with guests to arrive from overseas. The Second Born child was delegated the responsibilities of the wedding arrangements, such as invitations to post, lists, and sitting arrangements. The pressures arising out of the compounded problems that arose through the catering contract gone wrong as attached to other feelings about the 'big day' for the First Born child and words that were exchanged prior to the big day between family members were spoken of and repeated later among family members and those concerned with the decision of the Second Born child to take her own life. However 'well intending' family members withheld facts and events from the Coroner's Inquest as they arranged without disclosing that event to others. The father and mother of the child did not attend the inquest because of the arrangements the First Defendant made to bury the child in Cyprus; that event kept the mother (Second Plaintiff) there so as to attend the 40 day memorial service.

39. In accordance with the First Defendant's established practices the Matrimonial Home had undergone extensions and other building improvements; the last started in December 1990 and carried on and off well into 1991; these in the best part were executed during the winter months because of lower bids. The Second Plaintiff was concerned at the futility of it all because the children were all leaving home and she could not understand why; she was not given any viable reasons; why the efforts, the additions, the extensions etc. The property had not been a home proper to the children for years; with the children gone the additions were meant to turn it into a home to live in and to be proud of. The Matrimonial Home was without any carpets until well into late Summer of 1992; as with the kitchen range and units the Second Plaintiff had to resort to calling on family members to cause the First Defendant to do something; she called upon a cousin to visit the Matrimonial Home especially after the First Born child telephoned from Cyprus to tell the Second Plaintiff that her aunt Maroulla had been advising the First Defendant to ignore such things because of The Company's 'financial' needs. The children, family and friends were made aware of such issues.

40. The Second Plaintiff arrived in the United Kingdom with the First Born child on 11 November 1993; other family members were to start arriving soon. In the meantime the Third Born child had left and returned to Cyprus because of big arguments arising out of a telephone bill that arrived in October; apparently the First Defendant was blaming the children for the high cost of telephone calls; the children admitted making telephone calls to their sister in Cyprus and in particular the Third Born admitted making telephone calls to a girl friend in Cyprus BUT it was pointed out by both children that the First Defendant had made most of the telephone calls himself, as usual the First Defendant had determined others had no rights.

41. The wishes of the children and the demands from the Second Plaintiff for higher education and Professional qualifications for the children were of no interest and or concern to the First Defendant. The First Defendant had been handing over large amounts of moneys to his nephew which the nephew as his own children knew of; meeting college fees and the cost of residence halls for other children while the First Defendant's own children were ignored and abandoned to make their own arrangements; he had in the past assisted financially other members of his paternal family and in the studies of his nieces. The children were also aware of the fact the First Defendant had been assisting his brothers and sisters over the years using the joint funds under his control as the Second Born child got to know of in the course of work experience at the National Westminster Bank, the branch where the First Defendant banked.

42. (As referred to in paragraph .....) the First Born was married at the Registry office at Barkingside on 2nd December 1993; the Second Born child took her own life in the morning of 3rd December 1993. On 4th December 1993 there was a telephone call at the First Plaintiff's residence; he had been out of hospital for a week awaiting for his turn to be taken to St Bartholomew's Hospital for an angiogram. The caller was his elder sister; she spoke to his estranged wife; the news were bad; the Second Born child had taken her own life. The First Plaintiff was told something terrible happened to his younger sister; he telephoned the Matrimonial Home and the First Born answered the telephone; she answered bluntly "She is gone" when asked "how is Rita?", the Second Born child. He telephoned Junior and asked to see him; they had to stand by and support their sister (the Second Plaintiff) in her hours of need; more than ever at that point in time; junior called round with others and the young solicitor who had been engaged to the departed; what the young solicitor stated was most disturbing; apparently he and the Second Born had been on good talking terms and were planning getting back together again.

43. The following day Junior took the First Plaintiff to the Matrimonial Home; there he was most concerned at the attitude of two members from the paternal family of the First Defendant; what they spoke of was out of place and most disrespectful of the departed. The Second Plaintiff was heavily sedated but she was able to demand and insist the burial be held in the United Kingdom and the Second Born child be buried at the City of London cemetery; the Second Plaintiff had bought a plot there following her mastectomy operation. The First Defendant and members of his paternal family decreed otherwise; they begun immediate arrangements for a burial in Cyprus at their village cemetery. During the visit the First Plaintiff was informed the Second Born child committed suicide the previous day; evidently she used the cord from the First Defendant’s dressing gown to hang herself in her bedroom.

44. Junior made the necessary travel arrangements for members who wished to attend the funeral in Cyprus. The First Plaintiff telephoned his doctors to enquire if they would advise and or sanction such travel; he was told that if he could walk up and own the stairs at home without excessive chest pains, with his medication and avoiding physical and emotional stress he could travel provided he could take the emotional strain; the First Plaintiff after careful consideration determined that all being well failure to attend the funeral and be with his sister in her hour of need the emotional stress of not going would be greater than if he attended; his estranged wife wished him dead and buried with his niece as her parting words; the First Plaintiff attended everything except the actual burial in the cemetery because he felt he would be unable to 'accept' that final act, having had a number of severe Angina attacks during the church service. The same day the First Plaintiff travelled to Nicosia with relations in order to make contact with persons he had introductions to related to possible publication of a book he had been working on. The following day in the afternoon part of the maternal family group went to Larnaca Airport for the flight back to London. In the duty free shopping hall at the airport Monday evening the First Plaintiff begun to a severe chest pain was getting the better of him which by the time he had climbed the steps into the aeroplane had developed into a full blown Angina attack; junior was asked to call the stewardess for oxygen just as the First Plaintiff lost consciousness. When the he came round he was being attended to by the cabin crew who informed him that they had called for the airport doctor as soon as junior informed them of the First Plaintiff's heart condition; a passenger, an Arab doctor, was attending to him as the airport doctor arrived and determined that the condition of the heart beat was cause for concern, an ambulance was called and the First Plaintiff was taken to Larnaca General Hospital and transferred to the Intensive Care Unit. Awake, late Wednesday night, he overheard one of the night nurses talking to the other night staff; she was speaking of a girl who committed suicide in England but her parents lied and said that she had fallen down the stairs; the nurse went on to speak of vile name callings and adjectives for the girl by family such as her own grandfather, known within their village. Early in the morning before change of shifts he spoke to the nurse, as she was attending to him in the partitioned room, told her that he was from London himself but he had not heard or read in the Greek papers of either the accident or the suicide she had spoken of; it transpired that the nurse hailed from a village not far from the First Defendant's village and that she actually speaking of the First Born child, his niece; he did not disclose to the nurse that he was related to the person she had so graphically been speaking about to the other night staff on the Intensive Care Ward. The First Plaintiff was in hospital for 11 days before he asked the doctors to release him so that he could fly back to London with his sister and his brother-in-law; he never spoke to anyone about the overheard gossip. The day before flying to London he took a taxi to visit relatives in Nicosia ; a couple of friends from London, living in Cyprus at the time, called to see him and in the course of ensuing conversations all raised questions of and as to and why the Second Born child had taken her own life; everybody by then knew of that fact. In responding and offering explanations to the four persons present the First Plaintiff among other issues stated that somehow he also was partly to blame for not recognising the girl had no one to turn to when she said to him some three months earlier "I do not know what to do now" and he explained that because he had been told by the Second Defendant the girl had been on good talking terms with her ex-fiancée and that they were seeing one another again (before the Second Plaintiff left to go to Cyprus in September) somehow he felt the girl was in the family way and needed to talk to a woman (attempts to cause the girl to speak to him failed and as she was living at the Matrimonial Home with the First Defendant it appeared to the First Plaintiff that the only person the girl could and should talk ought to be her mother to whom she should talk to as woman to woman, not daughter to mother but only after the First Born child's wedding , not before (and this just in case the First Plaintiff was correct in his assumption which matter could cause more stress and pain to the Second Plaintiff because of the way her family and home was denied a proper home and family as she had planned, worked and fought for over the last four years as the First Plaintiff had become very much aware of through and because of the indifference and the contemptuous attitude the First Defendant had exhibited over that span of time. The First Plaintiff stated that somehow he made a serious mistake; he had assumed an imaginary situation; he wished to soften and delay any blow to the Second Plaintiff and stopped the girl from talking to her mother because he felt that adding more pain and or agony to what the Second Plaintiff had endured over the previous four years was his concern, not the Second Born and he felt that he seriously erred. The First Plaintiff did not speak of and or repeat what he had heard in hospital. The Second Plaintiff arrived in London with the First Defendant in February 1994; the first matter the Second Plaintiff spoke of to the First Plaintiff was the conversation she had in private with two the above sated four persons; somehow she was told and or she assumed the statement was 'the girl was pregnant ' when she indicated she needed guidance to decide. The Second Plaintiff was told that she assumed wrong, the words she repeated were out of context and that there never was a categorical statement as she spoke of; it was simply an assumption rightly or wrongly and it was used as the worse possible scenario that ought not to mar the wedding of the First Born child. The First Plaintiff even at that stage elected not to speak of what he heard in hospital; however months later as herein below stated a niece was called upon to repeat what the Second Born had spoken of soon after returning from Cyprus.

45. The First Defendant ignored the Second Plaintiff's pleadings and her demands; the First Defendant was for ever speaking of and spending most of his time on his secret plans with his brothers and sisters; there were numerous flights to South Africa and Cyprus; the First Defendant was staying away from the Matrimonial Home for weeks and months on end. Disclosing nothing and adamantly refusing to account and or explain to the Second Plaintiff what he was doing; he carried on regardless of the pleadings and as disrespectful of the rights of the Second Plaintiff as ever. The combination of secrecy, the complete and utter disregard of the rights and the needs of all others and failures by the First Defendant to respond to and or meet the demands from the Second Plaintiff were placing a lot of stress and pressures on the Second Plaintiff. The First Defendant simply ignored the Second Plaintiff and refused to recognise and or grant to the Second Plaintiff any rights to know what he was negotiating and or intending to do with the joint funds, which at all material times were under the control of the First Defendant. To add insults to the pains, the agonies, the and the injured feelings, imposed through his reckless indifference the First Defendant often referred to the Second Plaintiff as "the stupid one who knows nothing, what can this animal understand?" and such proclamations in the presence of others.

46. Throughout 1989 to 1992 the First Defendant ignored the Second Plaintiff and her demands to furnish her with information and full particulars; he adamantly refused to state what he was getting involved in and or doing with his brothers and sisters in Cyprus. No information, no documents and or any answers to the demands from the Second Plaintiff. In her frustration she turned for assistance and advice to two of her brothers, the First Plaintiff and the youngest brother, referred to as Junior herein. Junior eventually prepared a Letter of Authority for the First Defendant to sign in order for the Second Plaintiff to go to Cyprus; with accountants and solicitors she proposed to contact there she wished to proceed in any way she would consider at that stage advisable and appropriate; she desperately needed to acquaint herself with whatever the First Defendant was doing and or getting involved in. Junior called on the First Defendant at the salon in Seven Kings; in the presence of an uncle who accompanied him there he asked the First Defendant to sign the document thereby giving the Second Plaintiff authority to inspect and take copies of all relevant agreements and attached documents pertaining to the activities of the First Defendant in collaboration with his brothers and sisters within The Company and or other companies they had set up in Cyprus and or elsewhere; the First Defendant flatly refused to sign the document declaring that he had no intention to grant anyone any rights to interfere in his 'private and personal affairs'. The First Defendant later asked the Second Born child to prepare another document which he signed simply instructing The Company solicitors to offer information; the Second Plaintiff knew that the nephew of the First Defendant had been working at the solicitors at the time; AND she had also been made aware that the younger brother of the First Defendant, Mihalis, had spent a lot of time with the solicitors too. Between 1989 and 1992 the plans to develop and the actual works to be executed command funds; the joint funds are to be loaned to The Company but no documents were ever referred to the Second Defendant; no evidence of her rights to any funds and or loans secured.

47. The Second Plaintiff went to Cyprus, in June 1992 as referred to in paragraph 26; she wanted to secure information and full particulars; the Company solicitor, acting on instructions, refused to disclose anything; he went as far as to assert "Madam, in Cyprus the husband does whatever he likes and does not have to account to his wife; that is the law here". The Second Plaintiff pointed out she was there to find out what the First Defendant was doing with their joint funds, the results of forty years hard work, savings and sacrifices; the solicitor simply ignored her; friends introduced her to solicitors; the solicitor acting for the First Defendant and The Company in a telephone call invited the solicitor contacted by the Second Plaintiff to go round for coffee and talk over matters; the Second Plaintiff was told by the solicitor she was introduced to that he had no intention to entertain the invitation and or to discuss his clients business with solicitors for the other side. In the meantime there had been talk of land transfers to The Company and the Land charges/duties being met from the joint funds; stated to be recoverable at some later date.

48. Following the arrogant declaration, from The Company solicitor, that the law in Cyprus treats wives as of no consequence to male domination, the Second Plaintiff determined to find out as much as she possibly could by securing as many of copies of any documents she could find and or secure. She was most anxious to counter the false allegations the First Defendant had been spreading around and in particular that she had never worked, that she never had anything and generally that she had been a kept woman, a nobody turned into and made a somebody by the family of the First Defendant. Turning the wheels and assuming such insulting and offensive arrogance was too much to bear and all the while the Second Plaintiff was most concerned about the welfare of all three children; all ignored by the First Defendant as herein before and hereafter pleaded.

49. The Second Plaintiff considered that since the First Defendant had been so secretive about his activities and was not prepared to set her mind at ease, and or to attend to the children's needs and her own, she was going to act likewise. While he was away on his long overseas trips and journeys she looked and searched for relevant and pertinent papers to copy; she embarked upon this line of action after the abortive trip in Cyprus and the visit to the arrogant and male chauvinist solicitor. Upon her return to London she was informed that Cyprus had ratified the European Convention of Human rights and that The Company solicitor should go back to Law School; she was advised to secure as much evidence as she could if she was ever going to get anywhere with her rights under the law; she set out to achieve that goal while at the same time she persistently attempted to get information from the First Defendant voluntarily but without success; the First Defendant was always evasive and ruthlessly indifferent to the needs of all others but The Company and was for ever concerned with this brothers and sisters rather than the family he had created with the Second Plaintiff.

50. The Second Plaintiff gradually built up a selection of relevant documents; duplicates and triplicates were taken to friends for safe keeping and other copies were always at hand to refer to whenever the First Defendant was challenged and failed to qualify and or justify his activities. The most disconcerting document was an application for a bank loan; the First Defendant in his responses proclaimed himself to be the sole provider for his family when in fact he cared not about anyone; worse he was declaring he had not executed any Will; these while he was demanding and expecting of the Second Plaintiff to provide for own keeping through work at the salon in Seven Kings.

51. Copies were not referred to the First Plaintiff because he himself had been under a lot pressures and stress after being made redundant because of malicious and unfounded allegations made to the Managing Director of the company where the First Plaintiff worked in 1988. The offending party to the malicious lies was but the younger brother he had assisted financially many years ago; that younger brother and his wife had gone as far as to break up in 1979 and got back together again after the First Plaintiff allowed and extended a long outstanding loan facility for the purchase of a house for the residential needs of the younger brother, his estranged wife and their two children. Everyone knew of the assistance and loans that went back many years; everyone knew of the fact that while the younger brother was assisted through the extension of the loan to buy a house, the First Plaintiff was renting; everyone knew that the First Plaintiff placed priority on the needs of the broken family while his wife was pregnant with her second child. And everyone knew that the First Defendant had been speaking ill of the First Plaintiff for many years. In the circumstances the Second Plaintiff did not refer any copies to the First Plaintiff because among the documents existed many copies covering thousands by way of loans and assistance to the brothers and sisters of the First Defendant. The Second Plaintiff did not wish to expose the First Defendant for what he was because there existed other liberties the First Defendant had indulged in at the expense of the First Plaintiff.

52. Junior was made aware of the discrepancies in treatment and the unjustified allegations the First Defendant was making about the First Plaintiff. Among the copies that Junior was given by the Second Plaintiff, for safe keeping, there existed bank account payment entries; one such entry pertained to a sum the First Defendant had 'loaned' to a cousin; the sum was threefold the amount the First Plaintiff had borrowed from the First Defendant; the cousin needed the funds so that he could proceed with the wedding arrangements for one of the cousin's two daughters; the First Defendant assisted his cousin in the marriages of both those girls; both got married at a younger age than the Second Born child of the First Defendant; no one in the maternal family of the Plaintiffs ever heard the First Defendant 'boast' about his cousin owing him any money; no one ever heard of the cousin ever doing anything for the First Defendant's children and or the Matrimonial Home; no one had ever heard of the First Defendant raising issue and or making any allegations about his brothers, his sisters, and or any other relative of his being indebted to him. The Second Plaintiff knew of the First Plaintiff's denials as to the alleged liabilities the First Defendant was making, she knew also of the fact that Junior was jumping at every opportunity to insult and offend the First Plaintiff while he knew that the other brother was indebted to the First Plaintiff and that the First Plaintiff never spoke of and or insulted and offended anyone, not even after the despicable manner with which the indebted brother had gone to his Managing Director to cause wilfully and maliciously the loss of employment and the destruction of the First Plaintiff's career as the indebted brother boasted to one and all, prior to and after that premeditated and malicious act.

53. Among the documents copied by the second Plaintiff there exists evidence of:-

(a) The draft of the agreement entered into between the brothers and sisters of the First Defendant; it refers to The Company, but no copies of the Articles and Memorandum of Association were ever secured and or furnished to the Second Defendant, as demanded of The Company solicitor in the Summer of 1992.

(b) A draft agreement whereby family members were to loan funds to The Company endorsed with a rate of interest at 9%, whereas the rate of interest the First Defendant was stating and his youngest brother confirming in conversations between them following the funeral of the Second Born child in Cyprus, to be 11%. (The First Defendant having declared that the joint funds he was loaning to The Company as his only explanation of 'justifiable activities' at the expense of the Second Plaintiff without her interests exhibited anywhere and or her own signature endorsing such actions).

(c) A letter in the First Defendant's own handwriting wherein the Defendant was writing of arrangements to transfer funds to Cyprus that should be deposited at the Bank and to benefit at least from interest at the rate of 15% such as the funds were earning elsewhere.

(d) A letter from the First Defendant sent to his niece in Cyprus wherein he specifically "again it has been left to this arm of the Company ..." relating to finances expected from the First Defendant; it was the Second Born child who was instructed to write that letter.

PLAINTIFFS RESERVE RIGHT TO DISCLOSE AND USE MORE DOCUMENTS LATER

54. There exists other documented evidence but for the purposes of these Pleadings the Plaintiffs consider the above four documents to be sufficient disclosure at this point in time to establish that The Company exists in some form, that its constitution has not been disclosed to the Second Plaintiff, that in so far as the Second Plaintiff is concerned the joint funds that the First Plaintiff had under his control and command throughout the marriage of the First Defendant to the Second Plaintiff have been loaned to The Company by the secretive First Defendant without the consent of and or any reference proper and or approval of whatever the First Defendant entered into with his brothers and sisters, The Company itself and or with any other acting for and on behalf of The Company, any other companies and or other parties.

55. At all material times the Second Plaintiff was told and or was given the impression that all transfers of moneys from the joint funds were to be loans to the brothers and sisters of the First Defendant and later to The Company. At no time was the Second Plaintiff made party to any agreements that the First Defendant was making and or signing with any other party. As far as the Second Plaintiff is concerned any transfers and or use of the joint funds must have and ought to have been secured by the First Defendant; the Second Plaintiff gave verbal notices and warnings to the First Defendant and his first solicitor (and friend) in Goodmayes, Essex; the solicitor was told to advise his client not to indulge in any Breaches of Trust and or constructive frauds while the marriage was still standing a chance; repeated also prior to the loss of the Second Born child. The First Defendant, his brothers and his sisters and their family company, The Company, will be called to account for all such funds as have been transferred, loaned and or invested in The Company and or elsewhere from the joint funds without the authority and or the consent of the Second Plaintiff.

56. The Third Born child returned to London a few days before the First Defendant and the Second Plaintiff; they arrived back in London on 25th January 1994. To the existing problems between the First Defendant and the Second Plaintiff were added the tragic loss of the Second Born child and the rebellious and reactionary attitude towards both parents by the child. The First Defendant was expecting and demanding of the Second Plaintiff to 'control' the child, he would relentlessly blame her for the suicide of the Second Born child; and to make matters worse he was expecting and demanding of her to go to work at the salon. The First Defendant relentlessly blamed the Second Plaintiff for the suicide of the Second Born child; the Third Born child was left to his own devices and in order to have some income he went to work as a night guard. The First Defendant arranged it so that the flats and rented rooms of the two properties in Hornsey were not re-let as tenants moved out, he would not collect any rents (or so he later was asserting) and that the Second Plaintiff was caused and or made to attend to removing all the rubbish and cleaning the premises as were left in through his own neglect and or the agents he had been relying upon over the years. Working at and clearing the vacated accommodation was a welcome opportunity to be away from the relentless cruel and for ever scheming First Defendant; she decided she needed more time on her own to make decisions as to where she had been and was being lead to and where she wanted to go; on 18th April she took a flight to Cyprus. While there the First Defendant telephoned the Second Plaintiff and told her that the Third Born child was in hospital because his iron level (a Thalassimia sufferer) was and she should return to London; in the background she could hear friends and relatives of the First Defendant talking; the fact that a few days earlier the First Born child and her husband had flown from Cyprus to London caused the Second Plaintiff to take action; she telephoned their local hospital and eventually managed to speak to the Ward where the Third Born child was; as she spoke to the ward sister she overheard staff addressing the First Defendant as he arrived there; she was not given much information as to the circumstances and the situation of the child; the fact that the First Born must have known of the hospitalisation was food for thought; she made arrangements to fly back on the first available flight to London; she telephoned the hospital a few times and on each occasion the answers she had to straight questions were somewhat evasive, as the First Defendant' had been when he telephoned her. Back in London in the course of a visit to the child in hospital the child announced to all that he wanted to be left in peace and no visits from anyone; this wish the Second Plaintiff honoured for two days only. On the third day she simply telephoned the First Defendant and announced that she was going to visit her son, irrespective of his express wishes; the First Defendant volunteered to leave the hairdressing salon and to go to the

57. Attending Cruise bereavement counselling was causing further and additional pain to the bereaved mother; the First Defendant remained as indifferent to the loss as he had been about the needs of all the children throughout the years. To the First Defendant it was just a case of "It Happened". The First Defendant contained himself to blaming the helpless mother who did not speak about the new tortures she was being subjected to; no funds; left in the Matrimonial Home alone to live over and over again the loss of her pride and joy; her loving, caring and considerate daughter. Tormenting through lack of consideration and adding to the pain beyond comprehension; callousness beyond understanding and belief.

SECRET DEALS BETWEEN THE DEFENDANTS - Attempts to impose sale of property

58. In May 1994 the First Defendant wrote to the Second Defendant and her husband to remind them that a rent review was due under the terms of the Lease for the ground floor at 178 Weston Park. He wrote also that HE wished to sell the freehold to the property; the First Defendant later took the Second Plaintiff to visit the Lease holders at their residence on the pretext they had been invited for a meal and to discuss the rent he had proposed; during the visit, the matter of a proposed sale/purchase of the freehold was raised by the Lease holders; as usual the First Defendant was imposing through such devious ways his determined plans; without prior notification and reference to the Second Plaintiff he expected and anticipated capitulation. The Second Plaintiff made clear she had not been consulted and most definitely would not consent to sale of the property. On a number of occasions the Second Plaintiff told the First Defendant that if he needed funds for his plans with and for his brothers and sisters or to loan to their family Company in Cyprus he should sell the Matrimonial Home, pointed out that it would fetch more and the revenue would not be subject to Capital Gains Tax; she also pointed out the painful and tragic events and memories no one could possibly be expected to live over and over again through continued occupation of that property, reminding him of such consideration by her cousin's husband after they lost their young boy to cancer. The First Defendant ignored the Second Plaintiff and it was clear the First Defendant simply wanted to capitalise on the last assets in which the Second Plaintiff had legal title (without recourse to law) and he was determined to deprive her of such assets and rights.

59. Following the attempts to keep the Second Plaintiff away from the Third Born child while in hospital as above stated under paragraph ...... (the express wishes of the child others ignored and the Second Plaintiff respected) and because the causes and reasons for the hospitalisation were founded on an overdose of iron tablets (note; iron intake strictly forbidden to Thalassimia sufferers/carriers) the family doctor suggested counselling. The First Defendant and the Second Plaintiff attended Cruise bereavement counselling; at no time did the First Defendant ever consider the issues and causes that lead the Second Born child to take her own life; to him it was just a case of 'it happened'.

60. Following the attempt with the Lease holders the First Defendant devised other means through which to he sought to persuade the Second Plaintiff to agree to sale of the two properties; he introduced estimates running into thousands of pounds for and in respect of necessary repairs and renovations that ought to be executed urgently; he did not succeed yet he proceeded to instruct estate agents to sell the two properties; he demanded of the Second Plaintiff to accede to his decisions; the Second Plaintiff refused to be coerced, forced and or threatened into submission; she had no other security for herself and or the children; she had experienced enough of the miserly and cruelly indifferent ways of the First Defendant who actually went as far as to negotiate and agree a quick sale at the low price of £ 160,000 for both properties (because of a sitting tenant in one property the agency had stipulated dropping the price from their initial valuation of £ 180,000). The Second Plaintiff adamantly refused to sign away her rights to the two properties and or to let the First Defendant capitalise ones again at her expense; she had had enough of his conniving ways. In late July the Second Plaintiff telephoned the First Plaintiff; she was desperate and distressed; in the background could be heard the violent and abusive First Defendant making many an allegation about every member of the maternal family of the Plaintiffs; apparently the allegations had been ongoing for years; the Second Plaintiff telephoned Junior as well that night who later wrote to the First Plaintiff about those events; the said letter was not opened for over 25 months because the events that were unfolding at the time were more sinister than those encountered to that date.

61. The Second Plaintiff within days of the aforementioned telephone calls to her brothers she telephoned again the First Plaintiff; she needed to see him urgently; the First Defendant took the Second Plaintiff to see a doctor at the hospital where the Third Born child was taken after the child's attempt to take his own life with the iron tablets overdose. The pre-arranged meeting with the psychiatrist where the child had been referred to; the visit to the doctor was necessitated, the second Plaintiff was told, in order to discuss the Third Born child's situation; this after the child had left the United Kingdom and gone to Cyprus. The doctor saw the First Defendant privately first; he then invited the Second Plaintiff in; the doctor was interested and begun to question the Second Plaintiff about her background such as her family, her parents, her brothers and her sister; nothing about the Third Born child was raised by the doctor and when the Second Plaintiff demanded of the doctor to explain why after inviting her there to discuss her son's situation he was not concerning and or applying himself to the purpose of the invitation; the doctor replied that her son was over 18 years old and that he (the doctor) had no right to discuss his patient's case with any other. Following that reply the Second Plaintiff got up, bid the doctor farewell and told him that ought not to have called her there for one matter and seek to do otherwise. She proceeded to telephone the First Plaintiff (as above stated) who invited her along to discuss whatever she wanted to do about the issue of concern to her at the time. On arrival at the First Plaintiff's residence she told the him of the invitation to meet with the Third Born child's psychiatrist who then through words and actions betrayed other intentions; that she was very angry at what the First Defendant had attempted to do with the doctor and that she wanted something done; she asked of the First Plaintiff to write to the doctor; thereafter the content of the letter was not dealt with by the doctor who went underground; a nurse kept writing letters and inviting the Second Plaintiff to go along to the hospital, in what were blatant attempts to generate and create a case to suit the First Defendant's 'new plans' for the Second Plaintiff; when the First Plaintiff challenged the First Defendant to justify the attempt to create another Constantine and Stella case, using the same doctors (separate action in respect of the constructive frauds as were entertained, promoted, aided and abetted by the same doctors will be issued in due course) the First Defendant had the audacity to assert, "It is for her own good".

63. During the same month (August 1994) the Second Plaintiff had cause to ask the Plaintiff to write also to her niece, Miss Rita Antoniades. The reason and purpose of that letter was to enquire of the niece if she had proceeded to the execution of a mortgage application pursuant to an agreement arising out of rights to a property the Second Plaintiff had been deprived of for years because of breaches of trust and deceptions as had been indulged into by the father of the Plaintiffs.

64. One evening she telephoned the First Plaintiff and Junior because of the unbearable demands the First Defendant had been making of her. In the background, while she was speaking on the telephone, could be heard the First Defendant; violently and verbally abusive he was making all sorts of allegations about every member of the maternal family of the Plaintiffs. At the time she spoke of wishing to get away from it all as she had spoken of over the previous year in September (1993) before going to Cyprus, at which time the Second Born child had expressed the wish of joining her mother and getting away from the insensitive and selfish First Defendant who had no time for any other and or anything but as and of what he alone planned and chose. Because of the financial straight jacket the Second Plaintiff had been strapped in the First Plaintiff had accepted the Second Plaintiff's desire to raise independently finances through the legacy that had been a bone of contention in the family for some thirty years by then

65. Following the exposed attempts by the eldest sister Maria and other family members of the Plaintiffs to impose their own terms and conditions through deprivation of rights to and use of such funds and rights to properties as the Second Plaintiff had rights to the First Defendant would abandon the Second Plaintiff for long periods of time in the Matrimonial Home and fly off to be with his brothers and sisters in South Africa and or in Cyprus; the Second Plaintiff had to make do with only £ 42 (forty two pounds sterling) per week for all her food and other personal expenses and needs while abandon in the Matrimonial Home; during such periods the First Defendant would live his car (the only car to which over the years the Second Plaintiff was allowed occasional use) with one of the staff at the salon; the aforesaid £ 42 per week the Second Plaintiff travelled to Hornsey to collect from the sitting tenant in one of the properties in North London. The Second Plaintiff did not speak to anyone of this ill treatment of her person by the First Defendant; when the First Defendant was in London he would persist and demand of the Second Plaintiff to go to work at the salon so that she would earn her keep, pay for her food, her other personal expenses and to maintain the Matrimonial Home; the said demands the First Defendant would repeat and assert in the presence of others including the First Plaintiff later on.

66. The above stated ill treatment of the Second Plaintiff was observed and noted by the First Plaintiff to whom she turned for help after the attempts to use the very doctors that a sister-in-law had used in collaboration with a deceitful and dishonest brother of the Plaintiffs who had been party to the deceptions, the constructive frauds and the conspiracy that was uncovered in June 1996. Finally in October 1994 the First Defendant left a note for the Second Plaintiff abandoning to her the properties and the problems attached to them as he stipulated because he could not handle such matters, as he enumerated. The Second Plaintiff contacted the First Plaintiff and showed him the 'letter'; the First Plaintiff simply enquired of the Second Plaintiff what she proposed to do; the reply was "I will start cleaning up, painting and making good the properties so that I can benefit from rents such as my husband was benefiting from for years while he was denying all of us everything as you have seen for yourself and experienced when I was buying for Neophytos the CD player". The First Plaintiff was pleased for the Second Plaintiff and wished her luck with her proposed actions and told her that she could call on him for any help and or advise as she might find necessary; the Second Plaintiff said, at the time, that Junior also promised to help and assist in any way and had in fact promised to contact some plasterers and carpenters he knew who could execute for the Second Plaintiff such works for her.

67. A few days after the Second Plaintiff begun in earnest to concentrate her energies to clear out and prepare the first property in Hornsey North London, the First Plaintiff called at the property to see how she was doing; the Second Plaintiff was on her own and informed the First Plaintiff that she had been let down, junior had not sent anyone and she urgently needed to get some rendering and plastering before she could paint and decorate; she also needed to have some door frames repaired and or renovated because the First Defendant himself had damaged them when he broke into the rooms months earlier. The First Plaintiff telephoned Junior to see if he would honour his promise to the Second Plaintiff; he stated that he had been unable to find and or contact the persons he had in mind. In the circumstances the First Plaintiff promised to help the Second Plaintiff himself. The First Plaintiff thereafter did his best to make good such parts as had to be attended to in order to make the place decent and habitable. The First Plaintiff eventually repaired broken and damaged furniture after he was told by the Second Plaintiff that she was buying such items and materials as she needed to proceed with the repairs and providing for her food all using and relying on the sum of £ 42 per week as she collected from the old lady tenant in the ground floor of the property she was making good. The First Defendant could not believe that such was the situation; he was aware that the First Defendant had made a fool of himself the day he visited his wife, the Second Plaintiff, in hospital after the mastectomy operation and he could not believe that the First Defendant was so mean. The Second Defendant justified her a failures to speak earlier because of the need to give the children home; the First Plaintiff pointed out that she was not talking of a home but of a chamber of tortures such as he had observed when he was visiting the Second Plaintiff abandoned alone in the Matrimonial Home with no means of transport to go out, to visit friends and or whatever; the Second Plaintiff simply stated that she did not wish to create more problems for her family, such as it had been turned into by the mean and miser of a father and husband. In view of the revelations that the First Defendant had been so mean with his wife and their children the First Plaintiff spoke to the Second Plaintiff of the developments at Curries after she had gone to Cyprus and she informed the First Plaintiff that as far as she was aware the Third Born child asked for and received a refund of the moneys she had paid as a deposit, and that more than likely it must have been due to the need for funds such as the First Defendant would never part and or give to the children; the revelation that the First Defendant had been involved in behind the scenes activities to deprive her of her rights.

68. In the last week of November 1994 the Second Plaintiff, with the help of the First Plaintiff was able to make good two of the floors at the first property. The flat and rooms were advertised in Loot; at that point the Second Plaintiff spoke to the First Defendant of the need to open her own bank account so that she could bank the income from the rented rooms and flat and use such income towards the repairs and the improvements that were essential for the other property. While the First Defendant was overseas in South Africa, and following disclosure by the Second Plaintiff of what had been going on in connection with their joint funds, in the course of the previous five/six years (as herein before stated) and how the First Defendant had done his best to deprive the Second Plaintiff of any information, and that she had not been party to any of the activities and deals of the First Defendant with his brothers and sisters, the First Plaintiff suggested writing a letter to the solicitor of the First Defendant and to request of him to advise his client as to the law on Breach of Trust and in particular on Constructive Fraud because the First Defendant had been making many a threats to the Second Plaintiff over the previous year while she was refusing to sign away her rights and to permit the First Defendant to sell the two properties in London. The solicitor after speaking with to his client, the First Defendant (when the First Defendant returned to London) telephoned the Second Plaintiff and left a message on the ansaphone.

69. In October and November 1994 the First Defendant was repeatedly asked to hand over to the Second Plaintiff all relevant documents for a policy that was due to mature in December; he flatly refused to do so; it so happened that the First Plaintiff knew of the policy because it was started at about the same as he had started his own with the same company many years before the engagement of the Second Plaintiff to the First Defendant. The First Plaintiff had no option but to act and enter into and initiate correspondence between the insurance company and the Second Plaintiff; finally after the necessary depositions were supplied, to the company, arrangements were being made for a remittance to be sent to the Second Plaintiff and at that stage even the bank manager had the audacity to tell the Second Plaintiff that the proceeds of the policy should be paid into 'Tony's' account, such as the First Defendant maintained for the salon at Seven Kings; as a result of that interference the Second Plaintiff spoke to the First Plaintiff of other matters in which bank staff had imposed such terms and conditions over the years as the First Defendant was instructing them; one such other issue was the matter of the box containing her jewellery which the Second Plaintiff with the First Defendant had deposited with the bank many years ago; evidently she had never been allowed access to her jewellery since depositing with the bank; copies of documents the Second Plaintiff produced to the First Defendant were clearly endorsed with the simple fact that "either party" and the bank was challenged on the conduct of their staff over the years; the First Plaintiff told the Second Plaintiff that she ought not to have accepted such impositions from the First Defendant let alone from the bank staff and reminded her what he had said to the First Defendant in 1967 the week before the wedding. On receipt of the relevant check from the insurance company the First Plaintiff directed the Second Plaintiff to invest the funds in a high yield interest account as security and back up funds to call upon in any emergency until such time she reached some agreement with the First Defendant and because of the First Plaintiff's heart condition and problem throughout the previous two years he might not be around to help resolve and or help solve problems she was likely to encounter on the way.

79. While overseas after handing over the two properties, to the Second Plaintiff, the First Defendant telephoned the Second Plaintiff and directed her to collect the rent due from the Lease holders at the hairdressing salon. It was considered prudent not to see the Lease holder during the Christmas week when the rent fell due but to do so after the new year; when the Second Plaintiff was caused to write to the Second Defendant's husband who was rude and arrogant in a telephone call he initiated in the new year; he went as far as to assert that neither he nor his wife recognised the Second Plaintiff as their landlord and or as accountable to her; assertions and contempt reminiscent of the instructions from the First Defendant to the bank in relation to the Second Plaintiff’s jewellery box, the non recognition of her existence in connection with the references sought for and in respect of the promised birthday present to the Third Born child on his 18th birthday (the CD player arrangements with and at Curries); reminiscent of the interference by the First Defendant in the matter of the maturity of the insurance policy and many other instances at which times the First Defendant assumed the right to treat the Second Plaintiff as a possession, not a person and or a human being with feelings and or a legal entity with rights in law. To the arrogant and rude Lease holder the Second Plaintiff asked the First Plaintiff to forward copy of the letter from the First Defendant whereby he had abandoned the two properties in North London and to put him right as to the legal position bearing in mind that the Lease holder stated that he had paid the rent to the only person the Lease holders recognised as the landlord. The Lease holders were challenged to produce evidence that the alleged remittance was banked; the Plaintiffs wished to establish the First Defendant's complicity, conniving and deceitful ways; and if the First Defendant actually had acted (arranged to receive and bank) as the Lease holders asserted and indicated that he was wilful and malicious to boot; the Lease holder had no choice but to meet the Second Plaintiff's demands of them for it was pointed out to them that the Lease was granted to them was endorsed with the name and the signature of the Second Plaintiff as Lessor and Freeholder. When the First Defendant returned to London and the issues arising out of the telephone call and the note he had written in respect of the 'unpaid rents' he asserted that he did not give such instructions to the Second Plaintiff because he had himself collected and himself banked the rent due for Christmas; he proceeded to produce the bank paying in book and pointed out to the relevant deposit; the First Plaintiff drew the attention of the First Defendant to the date on the banking slip and then demanded of him to produce also his passport which could qualify that there was no way the First Defendant could have gone to the bank on the pertinent date because the First Plaintiff was not in the country. The First Defendant declined the invitation and went on to assert tat the Lease holders did not recognise the Second Plaintiff and it was then pointed out that no one would be allowed as of that day to impose their own terms and or conditions because of their personal interests, such as sale to them of the property because of secret deals between conspiring parties such as the Christmas rent remittance had exposed.

71. After tenants contracted with the Second Plaintiff (one of the flats was let through an agent who later was dismissed for misconduct and handling of rents received) for both floors at the first property the Plaintiffs made good through hard work effort and of their own means and the meagre £ 42 per week rent the Second Plaintiff was receiving from the ground floor in the same property the First Plaintiff was asked by the Second Plaintiff to assist her to improve and renovate the other property. This was the property the Lease holders had secretly 'agreed' to acquire the freehold of without any reference to the Second Plaintiff and the First Defendant expected and anticipated to accomplish through his usual tricks and embarrassing situations as he had always imposed on the Second Plaintiff throughout their marriage. The First Plaintiff accepted the invitation and agreed also to act as agent for the Second Plaintiff in respect of all the tenancies because of the questionable behaviour of the agent who had been granted and allowed to handle one of the first two flats. The second property was in a deplorable state; windows and timber everywhere was rotting away and the neglect over the years was too obvious to the most inexperienced person; the Plaintiffs were not surprised that the First Defendant was so anxious to sell at such low price as he had agreed earlier in the year; the Plaintiffs started work on the second floor and one of the first items they had to attend to were the rotten windows at the front of the building. In the course of renovating the first property the Second Plaintiff started to open her heart to the First Plaintiff (her brother) and for the first time he was hearing of life within the household as the First Defendant maintained; about the First Defendant's meanness, his selfish and indifferent ways, his neglect of the needs of others; his habitual winter time rebuilding works; his non use of the refrigerator; his lights off policy and why sky lights and glass panels on inside walls so as to allow light in the inner rooms and passages. The First Plaintiff found the frugality imposed on others considered the horse racing habits of the macho First Defendant and his bespoke suits while the children had to make do with refitted old clothes of their mother incomprehensible but what the First Defendant considered to be nothing but downright criminal neglect were the disclosures that while the First Defendant was spending thousands of pounds on and for the higher education of his nephew his own children were denied such facilities and or rights and caused to make their own arrangements, with one of them going to work at the first opportunity, living away from home and another after loosing her position with a good company who had seconded her studies in a sandwich course not encouraged to carry on with her studies. Most disturbing was the disclosure that the Second Defendant had been denied access to her jewellery and funds banked in the joint account. The catalogue of inhuman treatment was unbelievable and the First Plaintiff found it hard to believe that such a person existed and or that the Second Plaintiff had allowed herself to be treated in that manner; The Second Plaintiff explained that she had no choice for the sake of the children and the need to have a 'home' and the need to work for a better future for all; she had not known, however, of the plans of the First Defendant and or that he would have been so mean with the needs of the children, to the point of causing and bringing about embarrassment on her person and cancellation of the CD Player she had promised to the Third Born child. Because of such revelations the First Plaintiff told the Second Plaintiff that he was not surprised she had been a cancer victim following such treatment for some 18 years; he then told the Second Plaintiff that he could not believe that she had derived any pleasure at being treated so because as far as the First Plaintiff was aware she had never exhibited any masochistic trends throughout their growing years. The Second Plaintiff replied that most certainly there was no pleasure, there had been plenty of pain which she had learned to live after attempting to leave the First Defendant years ago but was told off by her mother as not the right thing to do 'in a Christian family' . Evidently the mother of the Second Plaintiff , who confirmed the event, was not inclined to hear of such a move by her daughter. However, she had second thoughts after becoming aware of the deceptions and the treacheries the First Defendant indulged and was indulging in since the tragic loss of the Second Born Child who was driven to take her own life in the manner and the time when she did so. The most disturbing matter was the behaviour of the First Defendant after that loss.

72. In consideration of the established fact that the First Defendant had received and banked the rent from the Lease holders of the ground floor of the building to be renovated and refurbished the Plaintiffs agreed to demand of the First Defendant to ensure there were funds in the joint account where he banked the cheque because the Second Plaintiff intended to withdraw from that account funds to meet the cost of new window frames for the second floor the Plaintiffs proceeded to order locally. Thereafter the Plaintiffs proceeded to renovate the flat and to refurbish making good all walls and ceilings, the central heating installation, the kitchen and bathroom; finally fitted wardrobes were built in the hall way after making good all floors. The Plaintiffs after consideration of the aims of the Second Plaintiff not to sell the property but to upgrade the property it was agreed between them and to the First Defendant's knowledge that after the First Defendant secured repossession of the first floor rooms from which the First Defendant had not received any rents for a long time and had retained solicitors to act for him the stairs should be changed because the timber was rotten. The First Defendant secured through his solicitors repossession of the first floor rooms and asked of the First Plaintiff to serve the relevant papers on the tenant who had been very aggressive and rude to both Plaintiffs since he was informed that the Second Plaintiff had taken over the property from the First Defendant.

73. While the First Defendant was overseas and the Plaintiffs were struggling to make ends meet and refurbish the properties in North London the Second Plaintiff received a letter from solicitors who were acting for the First Defendant in respect of a claim against the caterers who had contracted with the First Defendant to cater for the wedding of the First Born child. The letter was addressed to Mr. and Mrs. and in the circumstances the Second Plaintiff opened the letter because she was concerned it might pertain to urgent matters. (It was the first time the First Plaintiff was made aware of the fact that no one had any rights to their private mail). Attached to the letter was a bill of charges which the Second Plaintiff wished clarified; the First Plaintiff telephoned the solicitor who abruptly stated he did not have to account to Mrs. Englezakis (the Second Plaintiff). The solicitor was aware the First Defendant was overseas; like the Lease holders he stated that he only recognised the First Defendant as his client; he was invited to furnish full details upon which the submitted bill of account was founded. The First Plaintiff knew of the facts and the merits of the case and he insisted that the solicitor furnished to the Second Plaintiff a copy of the Particulars of Claim in respect of the action the solicitors had acted in; the solicitor flatly refused to comply and a visit at the County Court was necessitated but the staff needed at least the case number before they could supply a copy to the Second Plaintiff; the solicitor was contacted again and the young lady who asserted that they were not obliged to furnish any information to Mrs. Englezakis (the Second Plaintiff) even though her name was on the Summons and their bill of charges for which they would only account later to Mr. Englezakis (the First Defendant). The First Plaintiff proceeded to draw the young lady's attention the European Convention of Human Rights and the provisions therein in respect of Equality of the Sexes and that she should inform her principal that not all citizens who hail from Cyprus are as illiterate in law as he would have them be; the young lady was told to ensure that a copy of the Summons and the Particulars of Claim was made available to the Second Plaintiff because the police had already been contacted owing to the fact that there subsisted a case founded and resting on deceptions, fraudulent conversion and misappropriation of funds owing to the fact that a party who had admitted there existed no contract between it and the Plaintiffs in the action (Mr. and Mrs. Englezakis) had accepted a cheque from the Plaintiffs and banked it for and in respect of alleged liabilities by another. Thereafter the solicitors complied and furnished the particulars demanded of them for reference to the police. The police later called on the Second Plaintiff and produced copy of the relevant cheque and they were informed that the person who had used the cheque from Mr. and Mrs. Englezakis had filed for bankruptcy but that no excuse for the other party who had admitted there existed no contract between it and the account holders to bank the cheque.

74. In between his overseas trips to South Africa and Cyprus the First Defendant was asked to state his part in the bank manager's stipulations in respect of the funds due following the endowment policy maturity. He was also told that there were inexcusable and unjustifiable delays by the very bank to furnish references as were applied for in respect of the Second Plaintiff by another bank where the Second Plaintiff wished to open her own accounts. The First Defendant announced that his bank manager was not likely to give any references for the Second Plaintiff; in responding to a telephone call later the bank manager, who appeared to have been acting on instructions from the First Defendant, replied to the Second Plaintiff and submitted copy of a letter he had sent to her at the Matrimonial Home; evidently the First Defendant had received and withheld the letter from the Second Plaintiff; the First Defendant was warned never to do so again and never to interfere in the Second Plaintiff's 'private affairs' as he expected of and had benefited from the Second Plaintiff in respect if his private affairs with his brothers, his sisters, and their private company arrangements.

75. While the First Defendant was overseas the First Plaintiff attended to other matters such as a complain lodged with the Local Government Ombudsman arising out of questionable activities / defaults in respect of Housing Benefit submissions and allegations by the staff of the Local Authority, eventually leading to the making of an offer to the First Defendant. The First Defendant had often insulted the Second Plaintiff in the presence of the First Plaintiff; others witnessed his false and ill intended pronouncements; the First Defendants false assertions caused a lot of friction and many arguments between the First Defendant and the Second Plaintiff; the most disturbing element that caused the First Plaintiff to act was the mean and the penny pinching First Defendant liked receiving and loathed to part with. The 12 pence telephone call event, the demands made of the Second Plaintiff to work and to meet the cost of her food etc., and her 'share' for maintaining the Matrimonial Home were enough to warrant action. The First Defendant noticed that the First Defendant was being billed by British Telecom for his own telephone equipment; the Second Plaintiff confirmed that the equipment did belong to the family and that in fact the Second Born child had bought the ansaphone. He wrote to British Telecom who threatened with action for illegal use of the line and a fine, at which point the Second Plaintiff was more than concerned and in fact stated that she was afraid the First Defendant could cause a lot of problems on his return; the Second Plaintiff through her fears exhibited the absolute control the First Defendant had over her; she was assured there was no cause to be afraid because the First Plaintiff had faced similar intimidation and threats; the First Plaintiff promised to the Second Plaintiff that in the event British Telecom were caused by him to accept erroneous charges and a refund was successfully claimed by him he will expect half the amount and in the event British Telecom might succeed as they had intimidated then the First Plaintiff would meet such 'fine' on his own. British Telecom visited and inspected the lines and the equipment and eventually accepted that the First Plaintiff had correctly claimed that they ought to charge only for the telephone line. The First Plaintiff thereafter claimed a refund for the last six years of wrong charges.

76. When the First Defendant returned from his overseas trip in the new year, 1995, the First Plaintiff wrote to him and informed him of the refund/credit in the next bill from British Telecom and of the agreement between the Plaintiffs; on receipt of the letter the First Defendant spoke to the Second Plaintiff, used obscene and vile words in referring to the First Plaintiff's person and asserted that he had no intention to remit anything to the First Plaintiff, because he had not asked of him to do anything; when the First Plaintiff was informed of the reaction he told the Second Plaintiff to request of the First Defendant to respond by writing; the First Defendant failed to write, to speak of and or deal with the matter of the agreement between the Plaintiffs, the lump sum he was benefiting from and the future savings as had been secured and agreed with British Telecom for his benefit.

77. The Second Plaintiff had cause to speak to the First Defendant in respect of demands he had been making of her in respect of the rents she begun to receive from the premises she had rented out; he had been demanding of her to bank such funds as she was to receive in the joint account; he had also been making demands as to the works being executed on the first floor at the second property following completion and rental of the second floor. The First Defendant had gone as far as to make demands of the Plaintiff's to re-instate the first floor back to its original form, lay out and state. At that point the First Defendant was told not to interfere and was informed that the Plaintiffs had taken all necessary steps to challenge any allegations and fabrications as he had been making everywhere he went; he was told that there existed photographic and video evidence and that should he ever again demand of the Plaintiffs to 'return the premises to the state these were as he had handed them over in October 1994' he should also note that many a rotten piece of timber had been kept for delivery to him so that he should incorporate in the house he was proposing to build for himself in Cyprus and that the photographs and the video were sufficient. In telephone conversations with the First Born and Third Born children the Second Plaintiff qualified and clarified her stance and her plans for the properties in London. In a telephone conversation with her son-in-law she also pointed out that what the First Defendant had proposed and had adamantly attempted over the previous year was out of the question and that even the First Defendant's old friend and solicitor had told the First Defendant "this is no time to sell property in London"; she then explained to the son-in-law that the projected income/return from the properties would be higher than any other investment let alone from the private sale arrangements the First Defendant had entered into with the Second Defendant and her husband without first securing consent and or agreement from the Second Plaintiff; the son-in-law could see the reasoning of the arguments in support of the Second Plaintiff's stance, just as the solicitor had agreed months earlier.

78. The Plaintiffs with labourers they retained executed most of the demolition works that had to be done in the first floor and the new layout plans were undertaken by builders who were recommended by friends; at the same time the Second Plaintiff found herself attending to the urgent needs of her ailing mother who had looked after her infants many years ago; in the circumstances there arose delays and problems that could not be attended to as these arose. The First Plaintiff was also drawn into a long outstanding dispute that necessitated urgent attention and work; in the circumstances there was a cessation of the works on the first floor; there arose also the matter of the divorce proceedings the Second Plaintiff was instructing solicitors upon because the First Defendant's behaviour was unbearable and she wished to leave the Matrimonial Home; the police had to be called on at least three occasions because of violence and assaults; one of them had also been reported to the doctor who had invited the First Plaintiff to the hospital under false pretences (see paragraphs 59 and 61 above). The First Plaintiff had informed her and her solicitor agreed that her interests in the Matrimonial Home should be registered before she left there in order to protect her interests. The numerous stays of the mother of the Plaintiffs in hospital were very demanding of the Second Plaintiff in particular; the First Defendant was fully aware of the situation and the circumstances throughout; he himself spoke of such to other parties.

79. On 14th December 1995 the First Plaintiff wrote a succinct letter to the solicitors acting for the First Defendant in the divorce proceedings; the letter was a direct response to falsehoods and malicious fabrications and allegations the First Defendant had instructed his solicitors to repeat in a letter they sent to the solicitors acting for the Second Plaintiff; in his letter the First Defendant covered other aspects such as he had been forced to write of to other family members earlier in the year; such matters as were raised in the letters the First Defendant and the two children living in Cyprus had been made aware of and the First Defendant and the First Born child had been challenged to deny the factuality of the First Plaintiff's statements as he was forced to speak and write of.

80. In the morning of Tuesday 19th December 1995 the Second Plaintiff telephoned the First Plaintiff and stated that the ground floor Lease holder had just telephoned her to report water flooding the salon from above.. The First Plaintiff arranged to meet with the Second Plaintiff as a matter of urgency and both made their respective ways there. By the time the First Plaintiff arrived at the premises the Second Plaintiff was already there; so was the First Defendant who was busy removing a celotex ceiling tile from the false ceiling about the centre of the salon; water was dripping from all above the false ceiling and this appeared to be from all over the ceiling; a friend of the Lease holder (the Second Defendant) was sweeping the floor in the salon; the particular friend of the Second Defendant lived close by and was a regular visitor in the salon; she was known to the First Plaintiff because back in the early sixties she worked for the First Plaintiff and his partner in business at the time. The First Plaintiff had cause to doubt the water flooding from above because the water to the floor above had been cut off months earlier; also the central heating system and the combi boiler had also been emptied because of the changes to the new layout and the pipes that were installed; there was no possibility that any water could possibly have found its way to the boiler and or to the pipes unless someone had opened the water supply to the flat and had also opened the supply to the boiler and the supply from the boiler itself; the First Plaintiff’s first reaction was to rush to the back room in the salon where he confirmed there was no water flooding; that fact indicated sinister activities because the back room was lower than the front salon ceiling and if any water had found its way into the central heating system upstairs the first sign and flooding would have been from the lower points and pipes that had no radiators connected to them Asked if anyone had opened the water supply to the flat above, in the last few days, the Second Plaintiff stated that there was no such cause. The First Plaintiff made his way to the flat above, noted that no water flood and or damage had been caused in the passage leading upstairs (same level and pipe system as the salon); upstairs the First Plaintiff confirmed his suspicions and noted another questionable issue; someone had poured water on the plank of timber at two points, where two pipes were rising above it to which later would be connected a radiator; all other pipes did not exhibit such miraculous water seepage. There was urgent need to take action in order to challenge the attempt to cause and or create conditions leading to 'claims and counterclaims'. The First Plaintiff made his way to the ground floor where the First Defendant was busy asserting and alleging that the whole ceiling would have to be changed; the Second Defendant begun to raise issues such as 'her business would suffer over Christmas and that it was all due to the amateurs working upstairs. The First Defendant had already removed a couple of celotex ceiling tiles from the false ceiling; himself joined in and was keen to promote and entertain notions that the water damage was due the amateurs working upstairs. The Second Defendant made coffee for all while the allegations were going on; following a challenge from the First Plaintiff as to where the water came from, bearing in mind the supply to the flat above had been shut for months, the First Defendant who had been verbally abusive by then got up and physically attacked the First Plaintiff. As soon as the First Plaintiff was free from the grip of the First Defendant, he made his way to the second floor and telephoned the local police; they first called to see the assailant and others in the salon. The police contained themselves to writing down the names of persons who volunteered to be witnesses and insisted that the matter was not a police matter but a private case, notwithstanding the visible injuries the First Plaintiff had sustained in the attack.

81. The First Defendant telephoned as a matter of priority the insurance broker and asked for the telephone of the insurers for the building; the First Defendant had been involved in other dubious insurance claims at the Matrimonial Home; thereafter he had been denied contents insurance cover. The Plaintiffs were not in the mood to sit idly by while others took leave of their senses in pursuit of their dishonest goals; through false claims and allegations such as the two Defendants were asserting in order to bring about capitulation to the demands of the First Defendant (and the wilful thinking and complicity of the Second Defendant) to bring about and or to cause the Second Plaintiff to sell the property to the party who was such a willing playmate in the promotion of the alleged water floods from above. The First Plaintiff telephoned also the solicitor acting for the Second Defendant in the divorce proceedings and the associated matrimonial issues arising in the circumstances; the solicitor was informed of the artificial water floods, the assault, the police failures to take any interest in the injuries the First Plaintiff had sustained in the attack and that the insurers of the building were also notified of the likelihood of a false and fraudulent claim arising out of the staged water floods.

82. Following attendance to the above telephone calls the First Plaintiff went to the Whittington Hospital; the injuries he had sustained in the attack were duly recorded by the doctor who attended to him. From the hospital he went back to the property where the Second Plaintiff was waiting for a photographer to telephone back, also a plumber to attend there in order to note and report on the obvious condition of the central heating system, the boiler itself and the pipes to which no radiators had been attached for months. The First Plaintiff recorded on video the state of the first floor central heating pipes as the professional photographer was photographing the obvious; the plumber submitted a written report. In a conversation the plumber stated that he had also noted:- (a) the lack of any water seepage from any other pipes except the ones above the salon at the front of the building, (b) the lack of any water seepage at the lower level in the back room and (c) the statement from the Second Plaintiff that the First Defendant had gone to collect a set of steps from upstairs which he used to remove celotex ceiling tiles from the lower false ceiling in order to release the water from above them, on arrival at the premises; somehow the visit upstairs and the existence of water between the ceilings but not above the higher ceiling caused him to regard the whole situation as nothing but a staged exercise doomed to failure. The First Plaintiff subsequently wrote to the insurers of the building and submitted copy of the statement he prepared.

83. The First Plaintiff went to Highgate Magistrates Court on the day after attending to all other urgent matters at the premises; it was late when he arrived there and he was asked to go back first thing the following morning. The following morning the issue of the questionable and miraculous water floods and the assault on the First Plaintiff the previous day were duly stated to the Magistrate assigned to the case. The First Plaintiff was obliged to state also the background of deceit, secret deals and the neglect of the children and the wilful attempts at the expense of the Second Plaintiff (his sister) were related to the Court by way of explanation as to why the assault by the architect of all. In so far as the First Plaintiff was concerned the matters thereafter were in the hands of the authorities. On Saturday 23 December 1995, three days after laying the information before the Magistrate, a person the First Plaintiff had seen only twice before, approached the First Plaintiff, enquired of him if he had a brother in law who was a barber and had a shop somewhere in Ilford and if the barber and his wife had divorced. The First Plaintiff confirmed the facts the stranger related to him. The stranger then proceeded to advise the First Plaintiff to make himself scarce and to leave London because his he was in mortal danger. The stranger went on to qualify his advice to the First Plaintiff; evidently in the evening of Thursday 21 December 1995 (the day somehow gave credence to what was stated by the stranger) the barber had gone to Haringey to some cafe frequented by underworld characters there; apparently the First Defendant had gone as far as to place a contract on the life of the brother of the wife who was divorcing him. The stranger went on to inform the First Plaintiff that it appeared someone in the cafe at the time said he knew of the barber and his wife; also of the First Plaintiff; that person, stated the stranger, after the barber left told the 'underworld characters' not to rush into anything; apparently he also informed them of the fact that the barber had caused, through neglect and indifference to her needs, his daughter to take her own life and that they should first find out about the character of the man the barber wanted out of the way; the stranger went on to say that the other person appeared to be well informed from what he was saying to the underworld characters; the stranger spoke in a very serious manner and was convinced the barber meant business; the stranger advised repeatedly the First Plaintiff to leave London for his own good because the basis of the barber's contract had been "get rid of him, whatever it takes"; the stranger also stated "you never know, if they (underworld characters) are desperate (for money) they could act". The warning and advice were of most concern to the First Plaintiff; and he proceeded to report the matter to the very police station whose officers defaulted to take any action and or steps as arose out of the artificial water floods and the assault on the First Defendant. The Police took no notice, did not record the matters reported to them and did not concern themselves with the obvious effects on the First Plaintiff; scorning and ridiculing the First Plaintiff for 'paying attention to such warnings'; in effect the police simply brushed the matter aside; they ignored the fact that one was speaking of a callous and indifferent person to the suffering he was causing to others through mental cruelty such as he had been imposing on his wife for years; the police obstructed the First Plaintiff from using a cassette recorder to record the matters he was reporting to them even though he stated he was to give a copy of the recording to friends to be used in the event anything did happen to him; one of the police officers took the First Plaintiff to a back room; he was but understanding and in fact was sarcastic and mocked the First Plaintiff for the state he was in. For eight days the First Plaintiff stayed away from his own residence, changed his pattern, was afraid to use his car and tried very hard to keep the new developments to himself because he did not wish to add to the worries his mother had been subjected to because of the conniving and crafty First Defendant had been doing to her daughter; the worries, anxieties and stress the mother had been going through (over and during the last 2/3 years) had even caused her a heart attack. Eventually the First Plaintiff thought it best to speak to the Second Plaintiff who had sensed something was wrong and had affected the First Plaintiff and his pattern of behaviour.

MAGISTRATES COURT DEFAULTS AND BREACHES OF PUBLIC DUTIES

84. The First Plaintiff received nothing himself from the Court or the police; he applied to Highgate Magistrates Court for information; he was told the case had been listed for hearing at Haringey Magistrates Court on 30 January 1996. The First Plaintiff wrote a specific letter to the Home Secretary on 9th January 1996, posted same by recorded delivery which was confirmed delivered by Royal Mail; the letter was addressed to the Home Secretary in person, was clearly endorsed 'STRICTLY FOR PERSONAL ATTENTION" and that it was to be treated as an OPEN LETTER. A letter dated 17 January 1996 from the First Plaintiff, to the Chief Superintendent of police produced an unsigned response from the Divisional Commander dated 24th January 1996. On the date of the set hearing, the First Plaintiff attended Haringey Magistrates Court accompanied by the Second Plaintiff; also the president of the International League for Human Rights of the United Nations and the secretary of the League. The case was not listed under the surname of the First Defendant but under his first name. The assailant (the First Defendant) against whom the First Plaintiff had given information to the Court was nowhere to be seen; it was obvious the First Defendant was not attending Court on the day; when the case was called the victim (the First Plaintiff) raised the issue of the absence of the assailant and enquired of the clerk to the Magistrate (one) if the assailant had pleaded guilty by post and had asked of the Court to deal with the case in his absence; the clerk to the Magistrate fumbled with a file in front of her and eventually stated there was no evidence in the file that the Summons had been served on the accused. Neither the clerk nor the Magistrate sitting on the day concerned themselves with the 'revelation and the inexcusable assertion' such as the clerk relied upon to justify the absence of the accused (First Defendant). The Magistrate determined to take afresh a deposition to the Court from the First Plaintiff, AFTER the First Plaintiff produced photographic evidence of the injuries sustained and copies of the hospital records; he also reported to the Court that there had been additional threats to life attached to a contract placed by the First Defendant, a callous person who was as indifferent as could be following the suicide of his daughter (the Second Born child) also following an attempt by his son (the Third Born child) to take his own life too; also that the assailant even sought to have his wife (who was divorcing him) certified as mentally unstable, through deceit and fraudulent misrepresentations in order to achieve the goals he was aiming to score at the expense of others. The stresses and the pressures in having to re-live again, the impossible existence (looking over ones shoulder and the worries) following the contract and threats to life were too much for the First Plaintiff on the day; especially so when considering recounting the gross indifference of all public servants to that date; the First Plaintiff apologised to the Court for his inability to control his emotions but he was very much aware that one was dealing with a callous person who simply carried on as if the loss of a wonderful girl, and the attempt by the son and the attempts at the well being of others, including the bereaved mother, and the deprivation of the rights of others to a decent existence were trivial and irrelevant matters. The Court promised that a new Summons would be issued and the Clerk told the First Plaintiff that he should instruct solicitors to collect it from the Court and effect service on the assailant. The Court was informed that the two persons in the Court room at the time were from the International League for Human Rights on the United Nations and that they would collect the Summons and serve it on the assailant, thereafter to file an appropriate affidavit confirming service; copy of the original Summons dated 20 December 1995 was secured from the Court office on the day. The following day the representative from the League called to collect the fresh/new Summons but was informed that it was to be served by the police instead; further delays and further protraction added to the existing pressures and extended to new impositions on the First Plaintiff who was deprived through the threats to life the right to lead and enjoy a normal life. The new Summons was returnable and due for a hearing on 12 March 1996. In view of the asserted failure to serve the original Summons the First Plaintiff wrote to the chief clerk to the Magistrates Court to enquire as to the reasons; in a reply the Chief Clerk wrote back to state that he could not confirm a Summons had been issued but proceeded to state also 'it was sent to the police to serve......"

85. Leading up to the hearing of 12 March 1996, the First Plaintiff prepared a deposition (duly sworn affidavit) to which was attached the Statement of events as he had recorded them on the day and thereafter; also notes from the police following physical assaults by the First Defendant attached also to verbal abuse and assaults; also the letter sent to the First Defendant's solicitors dated 14 December 1995 (see paragraph 79 above ) and a letter from the hospital where the First Defendant attempted through fraudulent misrepresentations to create with assistance from others his 'ideal' situation leading to complete domination and subjugation of the Second Plaintiff; attached also was the letter/note he had left for the Second Plaintiff handing over and abandoning to her the problems he had created and generated with the two buildings in North London. The deposition and the attached documents, exhibits were delivered to the Court and a signature and Court seal secured at the time. On 12 March The First Plaintiff requested of the Court permission to record the proceedings using his personal cassette memo recorder; he was flatly denied that right even though he had stated that he was acting alone and needed to keep true records of the 'proceedings before the Court'. A young lady, who stated he was a barrister (no solicitor accompanying and or assisting her on the day) informed the Court that she was representing the accused; she asked for an adjournment because her client was pleading "Not Guilty" and went on to state to the court that her client was to raise issues pertaining to 'ownership of a property'. The Court was informed that the victim, prosecuting his own case after the police defaulted to take any interest in matters known to them, had served on the Court an affidavit with attached exhibits;; the First Plaintiff applied to the Court on the day for a Witness Summons and the lady sitting as clerk to the Magistrates asserted there were no such provisions at and in respect of Magistrates Court hearings; the Court adjourned the case to 9th May 1996 the young barrister requested of the First Plaintiff (the victim prosecuting the case on his own) to forward to the solicitors who were representing her client (the very solicitors acting in the divorce/matrimonial proceedings); she gave her name as Miss Pavlou. On 13th March 1996 the First Defendant wrote to the Court demanding acknowledgement of the lodged affidavit and exhibits; also for clarification as to the need for a subpoena. The Chief clerk did not respond and following another letter from the First Plaintiff dated 29 March 1996, responded on 16th April 1996 to assert 'hearsay' falsehoods from the public servant (the clerk to the Magistrates) who had declared there were no provisions for a subpoena; the clerk to the Magistrates Court apparently introduced such other elements as she had dreamed of in respect of the proceedings that the First Plaintiff was not allowed to record (and had his recorder confiscated to be returned at the end of the hearing on 12 March 1996. The letter from the Chief Clerk to the Magistrates Court was received on 17 April 1996 and the First Plaintiff responded immediately. On 18 April 1996 the First Plaintiff wrote to the Chief Superintendent of police and the Crime Manager at the police station that remained as unconcerned as ever in respect of all that was reported to its officers (INVESTIGATIVE branch of the law enforcement agencies as are maintained at the expense of the public they are meant to serve); on the same day the First Plaintiff wrote also to the Police Complaints Authority; the letter to the police was delivered by hand and the letter to the Police Complaints Authority was posted using the Recorded Delivery Service and delivery was confirmed. On 13 March 1996 the First Plaintiff sent a letter to the Wolf Inquiry Team and to the Lord Chancellor in person at the House of Lords.

86. The Police write to the First Plaintiff on 14 March 1996, confirmed part only of the reasons they had been called (the assault injuries sustained containing themselves to the visible cut which they referred to as a scratch). In the meantime and following the failures to serve the Summons on the First Defendant the First Defendant had been boasting and asserting to everyone that the police were in the palm of his ands an that they would do nothing (as facts evinced throughout December 1995 to March 1996 when the Barrister appeared at Court on 12 March and there were submissions in writing, as were demanded of the Chief Clerk, to the Court either by the First Defendant and or his solicitors). On 17 March 1996 the First Plaintiff wrote to the solicitors acting for the First Defendant; he forwarded copies of the affidavit and the attached exhibits to the address endorsed in the letterhead of their correspondence; the communication and enclosures were returned by Royal Mail; evidently the solicitors had moved a few doors away down the same road but had not made any arrangements with Royal Mail to re-route and or re-direct their mail. The First Plaintiff was obliged to deliver the papers by hand subsequently. At no time did the solicitors respond and or contact the First Defendant; they acted as contemptuously of the right of the citizen to act and represent himself. The Head of operations from the police wrote to the First Plaintiff and submitted copy of the letter from the Crime Manager dated 14 March; failures to submit copies of records as were recorded and maintained by the police, the boasting from the First Defendant, and the attached implications to suggested theatrics were sufficient to concentrate on the crux of the matter, the causes, reasons and intent of the assaults (verbal and physical) the threats to life as had bee reported to the police and as earlier had been reported to the Second Plaintiff's solicitors.

87. The First Plaintiff prepared a deposition (sworn affidavit) from and by the Second Plaintiff wherein she stated the facts of the case and what was behind the verbal assaults and the behind the scenes activities as were indulged into by the First Defendant with willing playmates, who themselves were benefiting at the expense of the Second Plaintiff as intended by the First Defendant. The First Plaintiff prepared also another deposition (sworn affidavit) covering his knowledge of the facts leading to the events that gave rise the miraculous water leaks and the assault on his person. Both affidavits were supported by documented evidence. The Clerk to the Court (another lady for the occasion) enquired of the First Plaintiff if he had any recording equipment with him and if he intended to record the proceedings; to the reply that he would like to do so as he was acting alone and needed to keep full records of the proceedings with the Court's permission; again he was denied the right as and on the grounds he stipulated. Copies of the two affidavits were handed to the Clerk to the Court and to the Barrister appearing for the First Defendant; the Court was informed that the evidence the First Plaintiff and the Second Plaintiff were to submit to the Court on the day, was supported by documents because of the assertion that Barrister made in respect of the claim to ownership of a property the assailant (First Defendant) had stipulated to the Court on 12 March 1996. The Barrister representing the First Defendant sought permission to discuss the content of the affidavits with her client in private; there followed a recess for that purpose; there was later a. visit to the offices of the Court for assistance and guidance; Barrister was overheard telling her client (the First Defendant) "I did not know that I had to answer and deal with such matters"; this was on their way back to the Court room and the witness (the Second Plaintiff) to the assault (who was also the main victim of the First Defendant) was waiting outside until such time as she would be called in to give evidence. The Barrister asked of the Court to adjourn the case and stipulated that the affidavits were unacceptable for the purpose of the hearing before the Court; any depositions ought to be in Section 9 Form; the First Plaintiff addressed the Court and pointed out that a deposition is a deposition and the content and the documented evidence could not change; what was essential and important was the content and not the package. The Court was also informed that to the affidavit lodged with the Court on 12 March 1996 and as was submitted by Recorded Delivery post to the solicitors acting for the assailant (First Defendant) was attached a STATEMENT by way of and as an exhibit; it constituted contemporaneous record of the events; and that the photographic evidence was sufficient to establish the cause and reason for the attack as was 'stated' and 'pleaded'. The Bench on the day was constituted of three lady Magistrates; the case was adjourned without opening the case by way of any evidence save the existence of the submitted affidavits. The case was listed for hearing on 9th July 1996.

88. Two Section 9 Statements were prepared; one dated 3rd July 1996 by the Second Plaintiff, the witness and the main intended victim of the Defendants; the second dated 4th July 1996 by the assaulted First Plaintiff; both were delivered by hand to Haringey Magistrates Court on 5 July 1996 and were attached to a letter addressed to the Chief Executive of the Courts. On the same day the First Plaintiff wrote also to the solicitors acting for the First Defendant and delivered by hand same and the attached Section 9 Statements. On the same day, 5 July 1996 the clerk to the Justices wrote to the First Plaintiff and informed him that there had been an error; the hearing was to be on 8th July 1996, not on the 9th as initially stipulated. The First Plaintiff went to the Court on 8 July accompanied by a witness to the proceedings who was asked to keep notes of same; the witness (the Second Plaintiff) remained outside until such time as she would be called in to give evidence. Before the case was called in Barrister for the First Defendant handed to the First Plaintiff a hand-written 'letter' from the solicitors purportedly acting for the First Defendant; it was dated 5 July 1996. It was but another example of contemptuous mentalities through which they anticipated and or expected of the First Plaintiff to request for an adjournment as they had been causing and generating in pursuance of the income generating practices one becomes aware of in the course of Court 'proceedings' that invariably are not related to the core of the cases before the Courts. The Court on the day was constituted of one lady Magistrate and two gentlemen; the chair was one of the gentlemen. The Clerk to the Magistrates was a gentleman who I was later informed was Mr A Gent, hereinafter referred to as the Third Defendant. Attending and present in the Court for the day were a number of friends of the Defendants including the Second Born child who specifically flew back to London from Cyprus to be with the father that had no funds for him to study, no funds for him to buy a birthday present as the mother had arranged, BUT could use the child to coerce the Second Plaintiff into releasing such funds as the Second Plaintiff had in Cyprus so that the child could buy a run about car that nearly cost the child his life after a crash (domination and subjugation of the Second Plaintiff through deprivation of funds as always intended by the First Defendant as was covered in letters sent to relatives some 14 months earlier when the First Defendant went to Cyprus in order to raise and promote malicious lies and fabrications intended to cause the First Plaintiff damages in his standing as a person within the family an relations and later returned to London announce that family members were to beat the First Plaintiff black and blue on the basis of the malicious lies the First Defendant had spread in his campaign).

89. At the onset of the hearing Barrister for the First Defendant stipulated to the Court that the Section 9 Statements were not acceptable (yet stated no grounds when challenged). The First Plaintiff pointed out that the documents had been served on the Court just as the Affidavits and attached exhibits had been earlier and no one could suppress such documents to satisfy other ulterior motives. The Third Defendant (as clerk to the Court) intervened to read to the bench the letter from the Clerk to the Justices (G Fillingham Esq.) dated 16th April 1996, wherein the author was asserting that the letter from the First Plaintiff dated 13th March 1996 could not be traced, yet delivery to the Court had been confirmed by Royal Mail and subsequently copy of same had been resubmitted with the response of 17th April 1996 from the First Plaintiff. The Third Defendant (Clerk to the court) was challenged and invited to read also the letter of 17th April 1996 from the First Plaintiff to the Chief Executive of the Courts (sent c/o of the Chief Clerk to the Court). The Third Defendant (Clerk to the Court) defaulted to do so; in the circumstances the First Plaintiff demanded of the Clerk to state if on file the Court had the three affidavits and the attached exhibits, also the two Section 9 Statements that were delivered to the Court the previous week and signed for; the Third Defendant (Clerk to the Court) refused to confirm to the bench the existence of such documents, as the First Plaintiff insisted. The Chair of the Bench who had from the onset 'admonished' the First Plaintiff because he took of his jacket (sweating heavily because of the anxiety caused through and because of the false assertions to the Court by the Third Defendant) told the First Plaintiff that such matters were of no relevance to the Court; the First Plaintiff pointed out that each case rests on the facts and the evidence in support thereof; and in the instance at hand everyone appeared to be hell bent on theatrical presentations alone and determined to suppress evidence, as in well known cases that had surfaced years later and after substantial damages had been done. The Third Defendant intervened and stated that the Court should proceed with oral evidence the First Plaintiff had to state in support of the case before the court, and the First Plaintiff demanded of the Third Defendant if he was going to note down the statements and the supporting evidence to be produced to the Court, also arguments as might arise as already had through the issue of the letters, the Sections 9 statements and the depositions on oath with the attached documented evidence which ought to be noted by him in pursuance of his public duties; failing that, the First Plaintiff informed the Bench, the First Plaintiff was nor prepared to partake in theatrical presentations to be recorded only as the Third Defendant (the Clerk to the Court) elected and or had predetermined. The Chair of the Bench enquired of the First Plaintiff what he proposed to do and he was informed that the First Plaintiff had every right to walk out of the Court and take such other steps as he saw fit bearing in mind that to that day he had been faced with countless obstructions that culminated in the contempt to the natural course of justice through false assertions pertaining to the letters referred to earlier and to the submitted documents, depositions and documented evidence he had just referred to. The Third Defendant (Clerk to the Court) stated to the bench that there existed no such documents as the First Plaintiff was referring to; the First Plaintiff produced out of the files of papers in front of him the hand written letter the Barrister appearing for the First Defendant had just that morning handed to him; he pointed out to the bench that no one could ignore such evidence that in itself at least confirmed the existence of the Section 9 Statements receipt of which had been acknowledged by the solicitors representing the First Defendant (the accused); the Court, the First Plaintiff went on, could not ignore the fact that on the previous occasion the very Barrister appearing for the First Defendant (the accused) had asked for an adjournment on the grounds that she was not aware of what the case was about and what was being alleged and or raised against her client; the chair of the Bench intervened again and the First Plaintiff produced from his files of papers a photocopy of the Daily Mirror Front page Headlines of 12th May 1992, the Words were clear, British Justice, BLIND, DEAF, DUMB; the issues arising out of the Judith Ward case; NONE OTHER THAN SUPPRESSION OF EVIDENCE as the Third Defendant was intending to do from the onset; the Bench was shown also the McVicar case as was reported by Victor Lewis-Smith in the Daily Mirror of 22 June 1996, just two weeks earlier, and the gum-chewing officer in charge; contempt to justice and theatrics as reported depicting clearly where British Justice and members of the media stood. The Third Defendant at that point intervened and threatened the First Plaintiff with committal to prison; he sought to justify his abuse of office on grounds of alleged refusal by the First Plaintiff to give evidence; the Third Defendant (Clerk to the Court) proceeded to read a relevant paragraph from the manuals in front of him. The First Plaintiff warned that if the Bench were inclined to endorse such intimidation then the First Plaintiff would have no option but to institute appropriate proceedings against anyone partaking in such violations of rights, through abuses of public office, on release from the threatened deprivation of his liberty arising out of denials of and obstructions to rights. At that point the chair and the bench with the Third Defendant encouraging the bench, agreed to call in the police in order to commit the First Plaintiff to prison. The commotion and theatrics were deemed to be fun for the friends of the First Defendant, who the First Plaintiff recognised as nothing but possible witnesses to the theatrics on the agenda for the day; all, including the Third Born child, had nothing to contribute to the case before the Court; they were but spectators with and for a purpose. The First Plaintiff would occasionally ask of the person who accompanied him in Court on the day if he was making notes of the events and the words/ issues being raised in the Court. The Bench after the declaration as to violation of rights, so blatantly indulged into, retired while the First Plaintiff to all intents and purposes was under arrest to be taken to prison at the behest of such persons as had been abusing their public office to that date. The Bench returned to the Court room later and invited the First Plaintiff to apologise for his outburst; he responded by pointing out that there was at least one witness in the Court who could testify if such was the case; that the person had been keeping notes as he could catch up with and if the Bench was of opinion that the First Plaintiff had been given no cause to point out the consequences to abuses by the Third Defendant (as Clerk to the Court) and the threatened imprisonment then the First Plaintiff would apologise, but if the Bench was of opinion that no documents such as were referred to existed then they should proceed with the threatened committal. At that point the Barrister appearing for the First Defendant admitted to the Court that she had been handed affidavits at the onset of the previous hearing on 9th May 1996, but she could not confirm that there existed another affidavit as of 12 March 1996. The Bench to all intents and purposes noted that statement and so did the Third Defendant who again announced that such as the documents were, they were inadmissible for the purposes of the hearing before the court; the case, however, the Court could proceed with and hear evidence. The First Defendant was sworn in so as to proceed and give evidence to the Court. No sooner had the First Plaintiff begun to address the Court and the Third Defendant interrupted in order to obstruct him from producing evidence such as the photograph showing the cut the First Plaintiff sustained when the First Defendant assaulted him; the Third Defendant also obstructed the production of the medical records as had been secured from the Hospital. On at least four instances the First Plaintiff threatened to walk out of the Court, if the Third Defendant (the Clerk to the Court) was to persist in obstructing the production of evidence in support of the statements of the First Plaintiff; on each and every occasion the bench assured the First Plaintiff that notes were kept and that in any event they were being guided by the Clerk to the Court, the Third Defendant. The case had been booked for a half day hearing and it was adjourned to the following week at lunch time. The First Defendant asked of the person keeping notes at the back of the Court room to keep the originals and to copy his notes clearly subsequently to post them to the First Defendant which would be kept as contemporaneous evidence of the events of the day in court. Later the Second Plaintiff informed the First Plaintiff that while she was waiting outside she kept hearing about the First Plaintiff being imprisoned and that the Second Defendant and the First Defendant were enjoying what was going on especially as the guards were rushed into the Court room; the First Plaintiff explained that there was no way that intimidation and threats through abuses of office had or were likely to deter him for standing up for his and her rights. The First Defendant reminded her of the builder case and how he had fought on relentlessly.

90. Thereafter the First Plaintiff contacted the solicitor, who to all intents and purposes had been and was acting in the interests of his client, the Second Plaintiff. The solicitor's failures to apply to Court and to secure an injunctions against the First Defendant who had been reported to the solicitor for persistently interfering and obstructing the Plaintiffs in the renovation of the two properties he handed over to the Second Plaintiff; such interference extending to the relationships of the Plaintiffs with the tenants, as with the Second Defendant and her husband who in the instance at hand were but accessories and abettors (if not instigators) of the alleged water floods from empty pipes and the water supply that had been cut off for months. All in order to cause and or bring about capitulation for the Second Plaintiff to sell the property as the Defendants had agreed over a year earlier. The First Plaintiff had repeatedly taken up issue with the solicitor acting for the Second Plaintiff in respect of The First Defendant's interference and relentless obstructions in the work of the Plaintiffs. The solicitor was fully aware of the fact that the First Defendant had, without first securing consent from the Second Plaintiff and through constructive abuses and breach of trust, transferred joint funds under the First Defendant's control overseas and such funds were and had been under the sole control of the First Defendant; such funds and assets the solicitor for the Second Defendant knew to be and were well in excess of fourfold the value of the two properties in North London and the Matrimonial Home in Newbury Park Essex; yet he defaulted to act and or to take any steps to protect his client's, the Second Defendant's interests; the said solicitor had gone as far as to assert that the First Defendant had every right to expect and demand that the income from the properties the First Defendant handed over to the Second Plaintiff should be banked in the joint account (held in joint names between the Second Plaintiff and the First Defendant). the said solicitor with intent was overlooking the fact that the First Defendant had been collecting rents from the very properties for over twenty years and had neglected the very properties which the First Defendant did abandon in a deplorable state and did hand over in such state as the Plaintiffs recorded; the very solicitor through engagement to the Second Born child who was caused to take her life, was fully aware of and knew of the extent of the liberties, the breaches of trust and the neglect of the needs of others the First Defendant was responsible and guilty of, for such facts and realities the said solicitor was well aware of. The said solicitor had also come to recognise that not only the First Defendant through neglect and indifference to the needs of others, but also members of the paternal family of the First Defendant had through interference in his relationship with the Second Born child sought to and did cause the break up of the relationship and all for their very own reasons. The First Plaintiff requested of the solicitor to brief a Barrister in the matter that was before the Court after giving full details of the events of the day at the Magistrates Court and the intimidation and threats to freedom by the Third Defendant, purporting to have been acting as an independent and unbiased public servant. The solicitor was informed that the solicitors representing the First Defendant had through the hand written note/letter handed to the First Plaintiff on the day recognised the existence of the Section 9 statements in respect of which the First Plaintiff was to secure the necessary endorsements by such other parties as could support the evidence in support thereof. A visit was necessitated to the solicitor who was given full details of the proceedings and the attempts to suppress the evidence in respect of the background and the conspiracy that existed between the two Defendants arising out of the private agreement as to sale and purchase of the property where the miraculous water leaks/floods had brought about the challenge of the Defendant to justify how and why the water leaks/floods from empty pipes to which the water supply had been cut off for months; the challenge leading to the assault and the threats to life with the ensuing reported contract on the life of the First Plaintiff because he was an obstacle to the criminal in intent activities of the First Defendant including the attempts at constructive subjugation and domination through conditions imposed by others on the Second Plaintiff.

91. On 16th July 1996 the barrister instructed by the solicitor attended Court, placed herself on record through a meeting with the Clerk to the Court and subsequently had a short meeting with the Plaintiffs. On entering the Court the First Plaintiff noted and pointed out to the barrister that the Chairman of the bench was not sitting on the occasion and that only two of the Magistrates were at the bench; the barrister ignored the point raised. At the onset of the ensuing hearing she asked of the Court to permit the First Defendant to finish his statement to the Court (as she had been instructed by the First Plaintiff); the Third Defendant asserted that the Court had finished taking evidence from the First Defendant at the previous sitting of the court. The First Plaintiff took the stand and in the course of giving evidence, ones again was denied the right to adduce any evidence and or refer to any other matter arising out of the assault on his person by the First Defendant. in the course of cross examination the Barrister representing the First Defendant attempted to and sought to generate the impression that there existed ongoing disputes between the First Plaintiff and the First Defendant; that all other matters were irrelevant except the fact (as was alleged to her and she was asserting ) the First Plaintiff disliked the First Defendant; the First Plaintiff's response was that the Court had to deal with the merits o the case before it; the assault and the facts and events prior to giving cause to challenges of concocted and fabricated water leaks from an empty new pipes to central heating system the water supply to which had been cut off for months following interference by the accused in the work that the wife who divorced him had undertaken to do with the help of her brother; the brother the accused disliked and assaulted because he was nobody's fool and who dared challenge the miraculous water leaks that lead to the assault and the sustained injuries. The barrister introduced elements of the divorce and her clients assertions in respect of such developments, and the response was that there exist letters as to what the accused indulged in at the expense of all others but himself and his plans without any due consideration for any other and that such letters were attached to affidavits, sworn statements, subject to perjury law; the issue of the divorce arose and the First Plaintiff pointed out that as a practising Christian Orthodox he could call upon witnesses to establish his stance; at no time did the First Defendant consider the First Plaintiff's pleadings of him to consider the needs of his wife and his children first and foremost (over a span of some four years); the issue of the divorce and the First Defendant's attitude and mentality as an alleged Christian was clearly exposed in the instructions the First Defendant gave to his solicitors; the First Defendant was too keen to rush into a divorce as letters establish and neither he nor any other change the facts and the truth through misdirected and or misconducted proceedings. The First Plaintiff repeatedly pointed out that letters attached to the affidavits everyone was hell bent and intent to suppress, as in the Judith Ward case, cover many an aspect and in particular the concocted and miraculous water leaks and floods at a property the accused had set his mind to sell without the consent of and or any consideration to the rights of the woman who had consented to the First Defendant's name being added as joint owner. Generally the cross examination was on such matters rather than the assault itself and the events of the morning leading to it; it had been made clear from the onset and the behaviour of the Third Defendant in the purported conduct of the hearings and his public duties that theatrics and records as would be selectively kept (through denials of rights to record the proceedings) which matters were of utmost importance to the manner in which Court proceedings are misconducted at will and with intent by public servants who serve other ulterior motives such as income generating conditions through imposed need for adjournments via surprises (the letter from the solicitors handed to the First Plaintiff by the barrister on 16th July 1996 and matters arising thereof) also defaults to act in time (such as ignoring the existence of affidavits and attached evidence hoping that such can be suppressed for ever).

92. When the Second Plaintiff (witness) was called in to give evidence she was dazed and appeared to be at a loss; she could not concentrate and was unable to respond immediately; the matters were in the hands of the directors of the theatrical presentations as the First Plaintiff found out later. When the First Defendant took the Oath one of his first Statements was that he was not divorced (not absolute yet because of the manipulations and defaults of the solicitor acting for the Second Plaintiff) and begun to blame the First Plaintiff for the break up of his marriage to the Second Plaintiff; in giving evidence to the Court among other irrelevant issues that the directors of the proceedings entertained and indulged in was an element of most interest to the First Plaintiff; the First Defendant alleged that the First Defendant sues everybody and went on to falsely allege that the First Plaintiff even sued his mother. Because of that last element the First Plaintiff asked of the barrister representing him at the time to ensure that he be re-called to the stand to counter the allegations.

93. The Second Defendant in giving evidence, declared her unwillingness to recognise the Second Plaintiff as her landlord and went on to allege that the works (construction/renovations) upstairs (above the hairdressing salon she took over from the Second Plaintiff) had been a nuisance for two years. The Second Plaintiff went as far as to allege that the water leaks from above she did not know who and how were cause and went as far as to suggest that such were caused by the victim and or the Second Plaintiff. In cross examining the witness the barrister instructed by the solicitor acting for the First Plaintiff on the occasion was ignoring notes passed to her on such issues as arose out of the statements and replies the Second Plaintiff was stating on Oath. Because of the adamant failures of the Barrister to deal with and or raise any of the issues raised in the notes handed to her the First Plaintiff had no option but to dismiss her and take over the cross examination of the witness; the barrister was asked to take notes of the proceedings thereafter but she simply sat by and chatted with the other barrister. The First Plaintiff was obstructed by the Third Defendant (Clerk to the Court) as at the previous hearing. The First Plaintiff pointed out to the Second Plaintiff that she was on Oath and that she was aware photographs were taken at the premises above and at the salon by a professional photographer and that there existed a video recording too; she was then asked to state how many ceiling tiles had been removed from the lower false ceiling; after her response she was asked to state if any of the ceiling tiles had been removed was by the door and she confirmed that one was; asked which door she replied the back door; the First Defendant then attempted to produce the photographic evidence as was lodged and filed at Court, also served on the solicitors for the First Defendant which were attached to the affidavits as served and filed. The Third Defendant yet again obstructed the First Plaintiff to adduce the evidence he had taken pains to prepare; the Third Defendant asserted that no photographs could be used and or adduced in evidence when the photographer was not in Court to give evidence himself; it was pointed out to the Court that the First Plaintiff had secured the necessary witness statements; the Third Defendant insisted that it was not permissible to adduce such photographs in Court and the Bench allowed that obstruction to justice by stating they were being guided by the Clerk to the Court. The First Plaintiff asked to recall to the stand the Second Plaintiff but he was not allowed to do so; as far as the Third Defendant and the Court were concerned the theatrical presentations as the Third Defendant had directed were over. The two Magistrates retired and not long after return to 'announce' they found the accused not guilty; whereupon enquired of the Court and the Magistrates to state if the Court had noted the Second Defendant's reply to the question as to by which door was one of the ceiling tiles removed; the Magistrates confirmed that hey had noted the answer was the back door. The gentleman Magistrate was noted gesturing to the barrister acting for the First Defendant on the day. The Second Plaintiff also observed the gesture and the failures of the Barrister, purportedly acting for the Plaintiff on the day, to take any notes after the First Plaintiff took over the cross examination of the Second Defendant. The Second Plaintiff told the First Plaintiff that she noted the fact the Barristers were busy chatting away while the First Plaintiff was being obstructed by the Third Defendant when cross examining the Second Defendant.

94. The First Plaintiff enquired of the Second Plaintiff as to why she had been so lost and dazed when she came into the Court to give evidence, and unable to deal with 'giving evidence and being cross examined'; he knew it was the first time the Second Plaintiff found herself in the intimidating atmosphere of a Court room but he was concerned as to why; the not guilty pronouncement, he told the Second Plaintiff did not concern him because the facts of the case were clear and documented. He explained that the two Defendants went along with the theatrics as more than likely they had been directed; what they did was of their own choosing; the element of the misplaced position of the ceiling tile by the wrong door was clear; obstructing the First Plaintiff to challenge that issue was but a constructive fraud on the Court (the bench) a fraud on the two Defendants and on Justice itself. No one could or can ever change the photographic evidence that establishes the Second Defendant was lying in oath he informed the Second Plaintiff. He was however concerned at the fact she had been so dazed and lost; the reply from the Second Plaintiff was most disconcerting; apparently while she was waiting outside the Court room there was but continuous commotion; the police, guards and other Court staff, ushers, etc. were busy asserting that they would be called in any minute to arrest the First Plaintiff for committal to prison and it was worse than the previous week; the Second Plaintiff was convinced, she said, that they were going to put him (the First Plaintiff) in prison and she would be at the mercy of the husband she had divorced and the solicitors; she had, she said, lost faith in as much as after loosing her daughter at least her husband would have been considerate of others, but all her husband was ever interested in was what he could get out her. It was blatantly clear the shenanigans outside the Court had achieved their aim; disorienting the witness, intimidating and causing stress and anxieties on an unprecedented scale had succeeded to bring about the effect such as the First Plaintiff witnessed. The First Plaintiff proceeded with the Second Plaintiff to go to the Tottenham High Street police station; the police there were not interested in the matters being reported to them. It was but a typical example of the organised denial and violations of rights. The Plaintiffs telephoned the solicitor who had retained the actor for the First Plaintiff and had been acting for the Second Plaintiff in respect of the divorce ancillary relief proceedings. An appointment was made for the Plaintiffs to attend the solicitor's office in order for the solicitor to attend to the issues that arose out of the events of the day at the Magistrates Court, also subsequently at the police station. When attending the solicitor the Second Plaintiff asked of her solicitors to take a statement from her for she wished to depose of the events outside the Court room on affidavit; the solicitor ignored her request which she repeated a few times in the course of the meeting; the possibility of an Appeal was discussed but the solicitor stated that until he had received all of the papers in respect of the case he could not advise and or act; the First Plaintiff told him that he was familiar with the situation as to no rights of Appeal for the prosecution unless there subsist exceptional circumstances; the First Plaintiff requested instead for a conference with a suitable Barrister at which point in time he would raise such other issues as arose out of the proceedings at the Magistrates Court; the solicitor was also informed that steps had been taken to secure in writing the relevant order from the Court upon which to instruct and or act accordingly. Within days of the not guilty pronouncement from the two Magistrates the First Defendant, who had declared on Oath he was not divorced, was caused to betray what had been on the cards in the background; following a letter he had received from the solicitor acting for the Second Plaintiff, the First Defendant was asserting he wished for no reconciliation and wanted matters over as soon as possible; and on the grapevine he was declaring to one and all he was going to freeze the Second Plaintiff's accounts. On the one hand he was assuming powers of attorney and or authority over the Second Plaintiff and on the other hand he was no longer married and or wished to have anything to do with the Second Plaintiff. The First Plaintiff telephoned the solicitor acting for the Second Plaintiff and asked for an urgent conference with Barrister as had been discussed and that a remittance would be handed over at the meeting the solicitor arranged in respect of the matrimonial issues.

95. Prior to attending the meeting with the solicitor the Plaintiffs discussed the implications to that date as far as the 'divorce proceedings were concerned and the issues the solicitor had been asked to deal with:-

a) Injunctions against the First Defendant because of interference with the tenants.

b) Injunctions for violence verbal and physical.

c) Application and Court Order for the First Defendant not to dispose of the hairdressing salon in Seven Kings which the Second |Defendant was asserting on the grapevine he was to pass on to one of the workers there and allegedly for free.

It was agreed that the solicitor had not acted on any of the above and that the latest developments as arose out of the theatrical productions at the Magistrates Court were suspect and the Plaintiffs should take steps to uncover the web of the undercover activities. In the course of the meeting with the solicitor the issue of the wrongly constituted Court on 16 March was specifically raised; so was the issue of failures by the Chief Clerk to the Court and the Magistrates themselves to consent to an Appeal by case stated; all contemptuously ignored the letters that were sent and or delivered to them; the issue of the need to get copies of the questions/notes as were handed to the Barrister the solicitor instructed and or retained for the 16th March 1997 was also raised. The letters sent and exchanged with the solicitor were also discussed at the onset of the meeting.

96. The solicitor stated that it was best to let the Barrister deal with such matters at the conference which he was arranging as a matter of urgency. The solicitor at the time proposed to deal with the issue of the ancillary divorce proceedings and in particular with the affidavit in support of the application to Court. There had been previous 'drafts' of affidavits that the solicitor prepared following meetings for that purpose. Originally the solicitor spoke of and suggested negotiating an agreed settlement between his client (the Second Plaintiff) and the First Defendant; the suggestion implied that the Second Plaintiff had been nothing but the kept woman of some generous person and that the Second Plaintiff had abandoned all her rights to joint funds, properties and other assets to the First Defendant, as and in line with the First Defendant's male chauvinist attitudes; the idea and suggestion was of course unacceptable. Later the solicitor through an affidavit he had prepared he ignored and or suppressed all joint funds as were held in Cyprus and elsewhere and as were transferred to Cyprus by the First Defendant for and in the interests of the First Defendant's brothers and sisters through and for loan and the use of the 'family company the brothers and sisters had set up in Cyprus' as above stated; the solicitor was fully aware and knew as of and because of his engagement to the Second Born child born of the marriage that the Second Defendant had not consented to the First Defendant's activities that she had been obstructed from getting g any information upon which to grant and give her consent, that there existed no documentation upon which the Second Defendant could justify either consent and or participation by the Second Plaintiff in the activities of the First Defendant, his paternal siblings and or their family company. The solicitor in drafting affidavits persistently suppressed such other assets and funds generated jointly through the long marriage and hard work, entrusted to the First Defendant to handle in so far as there was consent; the solicitor knew that consent had been withdrawn as of the time when the First Defendant refused to furnish full particulars of the First Defendant's involvement in a 'family company', the constitution of which was private and secret and in which the Second Defendant had not committed herself personally to partake. The solicitor knew that in so far as the Second Defendant was concerned only loans had been provided to the family company and that such were to carry an appropriate rate of interest, as documents and letters she was able to copy from papers the First Defendant would live in the Matrimonial Home and or as were transmitted by fax to the First Defendant c/o the insurance brokers next door to the salon in Seven Kings. The solicitor's persistent failures to deal with such issues as arose, violence, threats to life, the reported interference with the tenants and finally the conspiracy with the Second Defendant to impose the sale of the property because of alleged water leaks and damages as were staged by the Defendants and or others acting for and or with them, had been cause for concern to both Plaintiffs.

Matrimonial proceedings ancillary relief affidavit SUPPRESSING MATERIAL FACTS by design.

97. The solicitor begun to draft anew the warranted affidavit; it was agreed that, as usual, a copy should be submitted to the Second Plaintiff for comments prior to final draft. The submitted affidavit yet again suppressed all the funds and assets under the control of the First Defendant, as if such did not exist. Another aspect was the issue of the Third Born child, who was in London at the time for the theatrical presentations at the Magistrates Court; the solicitor of his own volition introduced the element of that child being an alleged student; the First Defendant never concerned himself with any education from junior school to High School; it was always the Second Defendant who concerned herself and fought for such facilities, as the First Defendant was making available to his nephews and nieces, to be similarly available to all of the children the First Defendant was responsible for impregnating the Second Plaintiff with. The idea that the Third Born child was to be used and his existence abused yet again was preposterous; the First Defendant through his conniving ways attempted such use in 1993; he brought the child to London and to all intents and purposes encouraged the child to enrol at a private college in South Kensington; fees were even met by the First Defendant; the child was even encouraged to look for accommodation in South Kensington; the child was even encouraged to aim for high powered expensive cars; AND the First Defendant was proposing to the Second Defendant the transfer of the two properties in North London, one to the Second Born child and the other to the Third Born child; the situation was highly suspect because the First Defendant had been proclaiming the two properties in North London were but a liability, that he could not cope and or deal with the problems arising out of such ownership and responsibilities YET HE WAS PROPOSING transferring such headaches and responsibilities to two inexperienced children who the First Plaintiff was proclaiming would be benefiting from the income from their respective property each to assist them with their studies in the United Kingdom; the professed generosity of the miser and mean First Defendant was as admirable as questionable were his intentions to 'transfer the properties to the two children. The First Defendant exposed his true colours in the presence of the Third Born child at the time (1993); the First Defendant stated he had to got to his solicitors to attend to matters pertaining to Haris' divorce proceedings (the youngest brother of the First Defendant as was imposed with the sister Theonitsa, on the Second Plaintiff (as above stated under paragraph ......) . On the day the First Defendant addressed the solicitor in connection with the alleged divorce proceedings business; the solicitor reminded the First Defendant that they had discussed the matter on the telephone and accordingly he had written letters to the other side; the First Defendant then told the solicitor that while he was there with his wife he wished to proceed with the transfer of the two properties to the children as they had discussed, whereupon the solicitor produced blank forms for her to sign; The Second Plaintiff told the solicitor, very clearly that she was not signing any blank papers and that she had been taken there for another matter; thereafter the Third Born child intervened to state to the solicitor that there had been talk of and 'intended purposes and agreements' and that he was not surprised his mother was not complying with the request for her signatures on blank papers; it was clear even to the Third Born child that the First Defendant attempted to secure signatures form the Second Plaintiff under false pretences abusing the mother's desire while overlooking the mother's instincts that all was not as presented; later, in the evening, the Third Born child demanded of the First Defendant to explain himself and in the ensuing conversations the child begun to make notes of what the intended purposes of the First Defendant were in connection with the proposed transfer; the notes were later torn and thrown away (picked up, put together and photocopied as evidence of the deceits and false pretences indulged into by the First Defendant in pursuit of his own plans and goals at the expense of all others that he uses). There followed the CD player events that exposed the conniving abuser of the children's existence; the Third Born child who was used and encouraged to look for expensive accommodation in South Kensington, who was encouraged to look for an expensive car, DID NOT EVEN QUALIFY FOR A BIRTHDAY PRESENT such as the mother had committed herself to buy. ALL OF THE AFORESAID facts were stated to the solicitor, yet in the affidavit he drafted and submitted to the Second Plaintiff he assumed the right to promote assertions such as were advanced by the First Defendant and or his solicitors without any foundation. The solicitor also introduced another unwelcome element through the use of words such as "our investments"; the solicitor knew otherwise through his engagement to the deceased and the use of those words were clearly intended to lead to what was being attempted "consent and or acquiescence by the Second Plaintiff in the matter of the joint funds and assets loaned / transferred (without consent) by the conniving First Defendant to the family company of the First Defendant". The solicitor was contacted after the Plaintiffs discussed the implications arising; as the solicitor had chosen to ignore the joint assets under the command and control of the First Defendant and as he appeared to be promoting the pretentious assertions pertaining to the Third Born child to be a student the Second Plaintiff with the help of the First Plaintiff sent an appropriate letter to the Third Born child through which the Second Plaintiff clearly spelled out the position in respect of the joint funds and assets; the letter was intended to be a jolt to the First Defendant who carried on nurturing ideas of domination, subjugation and fraudulent conversions in his efforts to deny the Second Plaintiff any semblance of life without sacrifices for the benefit of the conniving, mean, and miser First Defendant who was bent on using anything and everything simply to bolster his ego and his paternal family at the expense of the family the Second Plaintiff created with the First Defendant. The Second Plaintiff flatly refused to endorse and or sign the submitted affidavit from the solicitor, who had received copy of the letter the Second Plaintiff sent to the Third Born Child; in the said letter besides the matter of the suppressed (by the solicitor) assets in Cyprus and elsewhere the Second Plaintiff specifically covered the aspect of the proclamations and assertions by the First Defendant that he was going to transfer the business (salon where the Second Plaintiff had worked for over ten years; she made clear in the letter that IF the Third Born child wished to study she was going to demand the transfer of the salon to her as sole lease holder in the ancillary proceedings because she was aware of the earnings and potential there; she committed herself through that letter while challenging the Third Born child to cease playing at musical chairs (intended to and implying the father, First Defendant playing the tunes as and when the child had to move from one chair to the other) ands the implication explained to the solicitor who appeared to ignore such relevant issues while the First Defendant was left to his devices with assistance from such others as he was benefiting through direct actions and or through defaults.

98. The background to the Matrimonial proceedings and all such other pleadings pertaining to ownership of the salon and the property the subject matter of the alleged water leaks and floods were known to the Second Defendant; transfer of business and the Lease through which the Second Defendant and her husband have benefited was with the Second Plaintiff's consent and the Lease itself carries the signature of the Second Plaintiff. In the circumstances the Second Defendant in entering into an agreement without first securing consent from the Second Plaintiff acted improperly and without care and or consideration of the Second Plaintiff's rights in law; such rights the Second Defendant through her husband, later wilfully attempted to encourage violation thereof. After the First Defendant had entered into the undisclosed agreement with the Second Defendant and her husband not to recognise the Second Plaintiff and not to remit any rents to her, and after they were caused to incur costs and to satisfy the Second Plaintiff that they had in fact remitted the rent due in December 1994, which rent the First Defendant had alleged had not been paid by them, the husband of the Second Defendant, as another male chauvinist, wrote to the First Defendant "do as you think appropriate (to her)" or words to that effect, words over which the First Defendant gloated. at the time of the agreement the Second Defendant and her husband entered into with the First Defendant they sought and secured an appropriate for their purposes Surveyors report in respect of the property (178 Weston Park, London N8). The Second Plaintiff has been aware for some time now that the First Defendant defaulted to apply himself to the task of the rent review as of 1994; the implications that the rent was not increased as an inducement to the Second Defendant and her husband to co-operate with the First Defendant in his relentless attempts to cause damages to the Second Plaintiff is all too clear.

99. In addition to the involvement and the implication of the Second Defendant in the matter of the staged water leaks and floods in the joint efforts of the Defendants to cause damages to the Plaintiffs the Second Defendant concerned herself and was involved in another attempt by the First Defendant to cause damages to the Plaintiffs. No sooner had a Shorthold tenancy agreement been entered into with a young couple in respect of the second floor flat above the salon and the First Defendant appeared on the scene; accompanied by the Second Defendant the First Defendant insisted and demanded access to the premises; the Second Defendant eagerly insisted and commanded of the young lady (who was alone at the time in the premises) to let the 'landlord' in; the young lady contacted the Plaintiffs who visited her; the Plaintiffs asked of the young lady to write to them about the incident; her boyfriend arrived during the visit and objected to the young lady writing to the Plaintiffs about the incident; however, she did comply with the Plaintiffs request. Thereafter the boyfriend begun reporting inexcusable problems with the premises, all of which were promptly dealt with; eventually the boyfriend reported damages to the floor in the kitchen which were likely to cause injuries; by then the young lady tenant reported that she had been and was being subjected to physical violence by her boyfriend; she stated that she had to call the police on a number of occasions and that she was leaving her boyfriend having found alternative accommodation. With the young lady gone the boyfriend became aggressive and arrogantly even denied access to the premises for the Plaintiffs and or their workmen to inspect the damaged floor for the purposes of estimates and or making good; following a letter to the tenant from the Plaintiffs the tenant telephoned the Second Plaintiff was abusive, used foul language and in general was very aggressive. The Plaintiffs simply informed the tenant that they were intending to exercise their rights under the terms of the tenancy agreement. Thereafter the tenant refused to pay any rents and became more aggressive. The Plaintiffs had no choice but to issue a Default Summons; the tenant upon receipt telephoned the Second Plaintiff and was abusive, used foul language again and generally threatened the Second Plaintiff. The Plaintiffs received no Defence to the case, enquired of the Court if anything had been served by the Defendant in the action and the First Plaintiff was informed that the Defendant (tenant) had been sent documents he back because he had not completed them properly; in the circumstances the Plaintiffs decided to call upon the tenant and to enquire what he proposed to do because they intended to apply for and enter judgement against him; the Plaintiffs were accompanied by a third party. The tenant ignored the knocks on the door to the flat; after persistent knocking the tenant came to the door; he was violent in his language towards the First Plaintiff and physically pushed the First Plaintiff forehead to forehead backwards and against the wall. The tenant arrogantly asserting in is outburst "You do not own this property' reminiscent of the contemptuous attitude of the Second Defendant and her husband following the exposed conspiracy between the First Defendant with the Second Defendant and her husband in the matter of the allegedly unpaid rent for December 1994. The verbal and physical assault by the tenant was reported to the police who as usual asserted that it was a case of common assault. The tenant thereafter made himself scarce and on entering the premises to show to other prospective tenants the Plaintiffs noticed that there was evidence of use of drugs in the premises; the matter was reported to the police who failed to take immediate action and or any real interest; photographs of the items left all over the place were taken and the police were accordingly informed. It was some time before a police constable called to inspect the use of drugs by the tenant who abandoned the premises and as far as the Plaintiffs knew the girl friend of the tenant had called the police because of physical abuses.

100. The First Defendant interfered in other tenancies, intending through deceptions to cause such other damages as will be pleaded in separate Summonses returnable on such other parties who saw fit to conspire with the First Defendant and or to entertain invitations by him on such rewards as the First Defendant used in order to accomplish co-operation from such other parties who consciously were lending themselves to deceptions and constructive frauds on the Plaintiffs.

101. Conference with Barrister was not attended by the solicitor who was familiar with the case as it evolved at the Magistrates Court and was also aware of the Matrimonial causes behind the miraculous water floods; a colleague of the solicitor was present, however. The Barrister was acquainted with the submissions The First Plaintiff had delivered to the solicitor; the submissions were based on the foundations for an application to the Magistrates for consent to an Appeal by way of case stated. The Barrister informed the Plaintiffs that he was not surprised the Magistrates and the Clerk to the Court failed to respond to the First Plaintiff's communications and submissions. He advised that in the circumstances there were no provisions under the British Legal system to challenge the decision reached at the Magistrates Court; there subsisted no right of Appeal for the prosecution was the basis of the opinion. Any action against the Magistrates whether they endorsed the defaults and or the threats and intimidation by the Clerk to the Court and or the suppression of evidence would not go down well with the Judges because in any event they will defend such action against the Magistrates on the grounds that they were being guided by the Clerk to the Court. In the circumstances the Barrister was asked to confirm in writing his advice; the First Plaintiff informed the Barrister that he wished to challenge the denial of rights through obstructions to record the proceedings before the Magistrates Court because that issue leads the violation of the rights to OPEN COURT HEARINGS, on grounds of discriminatory treatment and denial of equal rights, also under article 13 because of no remedy under the present legal system, such as the Barrister had stipulated The Barrister agreed to forward his opinion and advice in writing through the solicitor.

102. When the solicitor forwarded Barrister's written opinion it was noted that there was fundamental error; the First Plaintiff who was the prosecuting party (since the police defaulted to take action) was wrongly typed and misconstrued as the accused; the solicitor was informed and he suggested the First Plaintiff should amend the document; he was informed that it was out of the question; the First Defendant was not going to do so for it lead to possible allegations and or assertions that the document through amendment was a forgery. The First Plaintiff insisted that a correctly typed and presented Barrister's opinion should be submitted and forwarded.

THESE SUBMISSIONS TO BE SENT TO MINISTERS responsible for LAW Enforcement

Copy of the pleadings and submissions hereto will be submitted to the Home Secretary and to the Lord Chancellor through the Plaintiffs Members of Parliament because of the gross dereliction of Public office by police officers and the Clerks to the Magistrates' Court. The ministers are responsible for the well being of the citizens and the freedom to indulge, obstruct, deny and violate rights as provided under the law, National and International as ratified and endorsed by the United Kingdom are matters for the two ministers whose duty is to the citizens and to the government of the day; none other. The Plaintiffs will seek an early responses to the claims herein stated and pleaded.

The PLAINTIFFS CLAIM :-

I. That the Police through failures and defaults to investigate as the investigative branch of the Law the miraculous water leaks and alleged floods from above encouraged and promoted the criminal activities of the First Defendant and that the Police knowingly promoted the subsequent threats to life through the reported contract on the life of the First Plaintiff (paragraph/s 80-84,89,94)

II. That the Police through failures to serve the Summons on the First Defendant were encouraging and promoting the threats to life to take their toll of a person all knew to have suffered from a severe heart Angina condition. (paragraph/s 84,83 )

III. That the Police in failing to take action of themselves in respect of the assault that caused actual and grievous bodily harm were promoting and giving credence through their defaults the First Defendant's assertions that they are in the palm of his hands, because most of the police at Barkingside are customers at his barber shop. (paragraph .80 )

IV. That the Police in imposing on the First Plaintiff the need to prosecute of his own were with intent abusing his rights to be free to exercise his profession and or to do such other gainful work as all citizens should be and are guaranteed under the Law, National and International.(paragraph 80 )

V. That the Police in failing to furnish the necessary documented evidence in respect of previous violent attacks by the First Defendant on the Second Plaintiff, and on the First Defendant they were with intent obstructing Justice and aiding through defaults the arrogant and disrespectful of the rights of others First Defendant and his accomplices; yet again giving credence to the First Defendant's assertions that the police are in the palm of his hands. (paragraphs As I above )

VI. That the police in failing to act in respect of other indulgences (Summonses to follow) were through default encouraging and promoting the deceptions and the fraudulent conversions such as they were made aware of, yet again giving credence to the First Defendant's assertions and allegations that the police are in the palm of his hands. (paragraphs As I above )

VII. That the Police in failing to act in any of the matters referred to and reported to them they were relying on breaches of Public Duty as subsequently were indulged into by the Clerks at the Magistrates' Court in much the same manner as in the case ' Perry -v- Yiannides ' in which matters the Metropolitan Police did similarly indulge in encouraging and promoting the dishonesties, the frauds, the violence, the threats to life, through anticipation of denial of rights and or justice. (paragraph 84-96 )

VIII. That the Clerk to the Magistrate on 30th January 1996 in asserting that there existed no evidence a Summons had been served was not speaking of fact and or truth and that she was aware no Summons had been issued by the Court on 20th December 1995.

IX. That the Clerk and the Magistrate sitting at Haringey Magistrates' Court on 30th January 1996 in inviting the First Plaintiff to re-state the case against the First Defendant were through that invitation disclosing the fact that no Summons had been issued in the first instance on 20th December 1995. (paragraph 84 )

X. That the Clerk and the Magistrate on 30th January 1996 proceeded to and invited the First Plaintiff to re-state the case against the First Defendant only after recognising the First Plaintiff attended hospital on the day of the assault and had taken also such other steps and measures as were deemed essential at the time of the assault so as to support the case against the violent and criminal the police through other contacts wished to assist and or cover up through defaults and gross dereliction to public duty and office. (paragraph 84 )

XI. That the Clerk to the Magistrate on 30th January 1996 in seeking to impose legal costs through retainers of solicitors and process servers was wilfully and with intent violating the First Plaintiff's rights under Article 1 of the First Protocol of the European Convention on Human Rights. (paragraph 84 )

XII. That the Court staff and officers at the Magistrates' Court in obstructing the Secretary of the I.L.F.H.R -- U.N and or the representative of same to collect and serve the Summons as was issued subsequent to the case against the First Defendant being re-stated on 30 January 1996 were through their failures and the subsequent service of the Summons by the police confirming and admitting obstructions to Justice to that date by public servants, from the police to the Clerks of the Magistrates Courts themselves and the violations as 'imposed' on 30th January 1996 (costs to serve through solicitors and process servers). And that there subsisted intent to cause damages through violations as above stated XI, and breaches of Public Duty (paragraphs above I-VII)

XIII. That the Clerk to the Justices in writing to the First Plaintiff that he could not confirm a Summons had been issued following the initial application to Court on 20th December 1995, was stating fact and that in seeking to shift blame for failure to serve on the police subsequently the Clerk was causing the police to proceed to serve the freshly issued Summons following the invitation, on 30th January 1996, to re-state the case against the First Defendant in the presence of the two witnesses form the I.L.F.H.R-U.N. who were attending Court on the day.(paragraph 84 ) and that the Third Defendant was aware the police acted in breach of Public duty between 19/12/95 - 30/1/96

XIV. That the Metropolitan Police served a Summons on the First Defendant only because of the Hospital Records, the evidence in respect of the sustained injuries, and only because the two persons attending Court on 30th January witnessed the state of and the effect of the threats to life the First Defendant had indulged into through the reported, to the police, contract on the life of the First Plaintiff. And that the Police through defaults were in breach of sections 134-135 of the Criminal Justice Act 1988.

XV. That the Clerk to the Magistrates' Court on 12 March 1996 in obstructing the First Plaintiff to record the proceedings before the Court was violating his rights to have true and unadulterated records of the proceedings before the Court in accordance with the provisions for OPEN COURT hearings under Article 6 of the European Commission on Human Rights. And that in any event any excuse and or assertion and justification by way of such other persons as the Court may direct to record manually at additional cost constitutes in itself a violation of Article 1 of the First Protocol of the European Convention of Human Rights, Article 6, and Articles 14, and 17. (paragraphs 85 to 93 )

XVI. That the Clerk to the Court on 9th May 1996 in obstructing the First Plaintiff to record the proceedings and in confiscating his cassette recorder, and returned after the hearing / proceedings before the Court, was with intent obstructing the First Plaintiff as above (XV) claimed. And that the clerk in asserting there existed no provisions at the Magistrates Courts, for Witness Summonses to subpoena persons to give evidence was but another denial of rights and access to Justice and violation of Articles 3 and 5 while the existence of the First Plaintiff was subject to threats to life as were reported to the police and stated at Court on 30th January 1996. And that there was gross dereliction of Public Duty and violations as above stated XV and XI.

XVII. That the Court Clerk in seeking advice and or guidance from the office on 9th May in respect of the submitted and lodged depositions was seeking avenues through which to suppress the depositions and the evidence upon which the case before the court was founded and rested. And that whosoever instructed the suppression of the deposition and the statement attached thereto was simply instructing the suppression of evidence. And that the form of the suppressed deposition was and remains immaterial in law by virtue of its content and not its packaging. And that the failure to proceed with the case on the date and the adjournment was but an excuse to generate and create the usual income generating and promotional excuses for the benefit of persons licensed to practice 'law' while overlooking and ignoring it. (paragraph 80 through to 89 )

XVIII. That the Clerk to the Court (Third Defendant) in promoting falsehoods on 9th July 1996 in respect of the letters and submitted depositions / statements / exhibits as were signed for and lodged at the Court was consciously and or deliberately seeking to misdirect and misconduct the hearing/trial through suppression of the contemporaneous evidence lodged with the Court. And that the Court and or its staff in failing to acknowledge the depositions, subject to Perjury Law, were seeking to generate avenues through which to cover up either their complicity and or the attempts to suppress evidence lodged at the Court, through breaches of Public Duty and violations of Rights I - XVIII.

XIX. That the Clerk to the Court (Third Defendant) on 9th July in seeking to suppress and failing to record the existence of the depositions and the attached exhibits as were submitted and lodged at Court on 9th May 1996 was similarly engaging in the denial of rights as above pleaded. AND FURTHER that the Third Defendant through knowledge of the content of the submitted depositions was but an accessory to the promotion of a violent society and the endorsement of violence within and after the break up of marriage and the impositions of violent persons on law abiding and considerate citizens. And that the Third Defendant was conscious and aware that the request for depositions from the First and Second Plaintiffs on 9th May 1996, in an alternative form constituted a violation of Article 1 of the First Protocol of the European Convention of Human Rights. And that the Clerk to the Court knew and recognised that the letter delivered, by the barrister from the solicitors representing the First Defendant, to the victim (the First Plaintiff) who was prosecuting his own case was but a late delivery leading to the need for an adjournment which act in itself was intended to lead to the usual manifestations inherent in the income generating practices by solicitors and other legally trained persons. And further and or in the alternative to generate and create a trial resting only on theatrics and THE SUPPRESSION OF EVIDENCE.

XX. That the threats and intimidation by the Clerk to the Court (the Third Defendant) on 16th July 1996, as was endorsed by the Magistrates who went as far as to authorise the attendance of guards to place the victim, the First Plaintiff, under arrest and the intent to commit to prison the victim of violence, prosecuting his own case after being ignored (as in the Pery -v- Yiannides case) by the Metropolitan Police, was but invasion on the person, blackmail, harassment, obstructions to the right to prosecute ones own case unimpeded, and that the said actions were gross violations of all articles referred to above and violations of Articles 3 and 14. And that further the Clerk to the Court and the Magistrates in endorsing the ill treatment of the First Plaintiff, especially since they were made aware of the fact the Clerk was determined to suppress and IGNORE evidence, all acted in breach of sections 134 and 135 of the Criminal Justice Act 1988. (paragraph 89 )

XXI. That the denial and obstructions to record magnetically the proceedings was but violations as above pleaded failures and defaults by the Clerk to the Magistrates (Third Defendant) constituted a violation of Articles 6 and 14 of the European Convention of Human Rights. And that the submitted notes subsequently were but an exhibition of contempt to all provisions of law national and International and a gross violation of Articles 3 and 14 of the European Convention of Human Rights resting and founded on the denial to record the proceedings magnetically in totality.(paragraph 85-93)

XXII. That the failures to record the statements of the victim (First Plaintiff) on 9th and 16th July 1996 in totality and in the selective fashion the Clerk to the Court (Third Defendant) embarked upon constituted violations as above pleaded. AND specifically so because of the obstructions to and the denials to the right to record magnetically the proceedings at no cost to the Court and or the state. (paragraphs 89 - 93)

XXIII. And that the Clerk to the Court (Third Defendant) in entertaining and recording such falsehoods as he chose to do without foundation and or support of any other the Third Defendant was seeking to generate and create intended violations of the most fundamental of rights. And that in recording the First Defendant's false assertions and allegation that the First Plaintiff had ever taken Legal Action against his own mother was but wishful thinking both on the parts of the First and Third Defendants. (paragraphs 91-93 )

XXIV. That the Clerk to the Court (Third Defendant) on 16th July 1996 in obstructing the victim (First Plaintiff) prosecuting his own case, to recall a witness the Second Plaintiff to give evidence in respect of the state of her marriage to the First Defendant (who had alleged he was not divorced while letters existed to his consent and that the Decree Nisi had already been entered) was but a violation with intent of the rules of procedure. And that in similarly obstructing the Prosecuting party (First Plaintiff) on each and every point and along the way both on the 9th and the 16th of July 1996, the Clerk to the Court was similarly obstructing and denying rights to the First Plaintiff in gross violations of Articles 3, 5, 6 and 14 of the European Convention of Human Rights. (paragraphs 91-93 )

XXV. And that in obstructing the prosecuting party (the First Plaintiff) to adduce the photographic evidence whereby the prosecution would establish the Second Defendant had lied when she categorically asserted with emphasis that the removed false ceiling tile was by the back door the Clerk to the Court (Third Defendant) was consciously and if not deliberately creating nothing but grounds for further and additional causes of action as hereto, in and for the benefit of the legal circles, who systematically and habitually benefit from such mistakes, errors, and or with intent practices in the purported interests of justice. (paragraphs 91-93 )

XXVI. And that the Clerk to the Court throughout acted in gross dereliction of office and public duty in pursuit of other objectives than those prescribed by his office and duties to the Public at large and in the service of Justice. And that all other parties who through breached and or defaults of their public duties and office were but affording the Clerk to the Court incompetent and inexcusable grounds upon which to rely on non existent and or non submitted depositions and other documents submitted to the Court. And that the Home Secretary is duty bound to Order an investigation on all points herein above and below pleaded.

XXVII. And the Plaintiffs claim that any reliance placed on an alleged Order by the Court based and founded on the grossly misconducted and misdirected proceedings leading to and resting on an alleged order by a wrongly constituted bench, after one of the Magistrates failed to turn up and or partake in further theatrical productions as were directed by the Clerk to the Court (the Third Defendant), is unsafe unsound and based on Fraudulent in intent proceedings. (paragraphs 91 to 93 )

XXVIII. And the Plaintiffs claim that the intimidation, harassment and threats through the theatrical productions outside the Court room were but wilful and intentional 'shenanigans' directed at the Second Plaintiff whose reliance on the resolve of the only person standing by her in her hours of need was paramount and that the renewed threats outside the Court room to commit to prison the only person upon which the Second Plaintiff relied were nothing but shameful activities at the very least constituting invasion on the person, threats to peace of mind, threats to invasion of person resting on violations of Articles 3, 5, 6 (protection of private life) and 14, and breaches of sections 134 and 135 of the Criminal Justice Act 1988. And that the Home Secretary orders an investigation.

XXIX. And that the Third Defendant by virtue of his conduct and the manner with which he lent himself to constructive frauds through fraudulent Court proceedings and practices is not fit to serve and or hold the office of Public a servant in the conduct of any Court business and that the matters raised herein should be referred to senior competent officers at the Home Office and the Lord Chancellor's Department for a full inquiry, because the Public must be protected from such malpractice and in particular the failures and or obstructions to record proceedings in full magnetically s provided under current law for and in respect of police interviews. (paragraphs 91-93 )

AND THE PLAINTIFFS CLAIM :-

XXX. That the First and Second Defendants did with intent and malice aforethought take part in and conspired with others to create the alleged water leaks that were nothing but a staged production of fertile and criminal minds seeking to and attempting to generate a fraudulent claim for alleged damages from the inoperative central heating system to which the water supply had been cut off for months. And the Plaintiffs CLAIM DAMAGES in respect of all ensuing work and expenses incurred consequential to the activities of the Defendants and ALL LOSSES subsequent to the lies in Court of the First and Second Defendant entertained by the Third Defendant who obstructed the challenges through denial to the rights to recall a witness and to adduce the photographic evidence at hand.

XXXI. And that the Second Defendant and her husband in their efforts to cause the Second Plaintiff to capitulate and or to cause and or force the Second Plaintiff to abandon her plans to renovate the property and to consent to sale of same to them did naively and or foolishly indulge into and or entertained the staged water leaks and flooding as above stated without due consideration to and for the consequences of such actions and or activities; irrespective of whether such actions and or activities were of the making of the Second Defendant and or her husband and or induced and or indulged into by and or with any other. And the Plaintiffs CLAIM DAMAGES against the Second Defendant and such other party who aided, coerced and or invited and entertained the staged water leaks that gave rise to the assault and the consequential proceedings and this action.

XXXII. And that the Second Defendant in declaring she did not recognise the Second Plaintiff as her landlord was overlooking and or neglecting the fact that the Lease granted to her and her husband was endorsed by the Second Plaintiff. And that the Second Defendant acted wrongly, wilfully and or maliciously and with intent sought to degrade and or insult the standing of the Second Plaintiff through directions, instructions, and or as agreed with the First Defendant; and that whether as a result of the original private deal and or agreement to acquire the property, the Second Defendant and her husband ought not to entertain and or nurture notions of an enforced sale through lack of funds as induced by and or agreed between the Defendants and exposed in December 1994 / January 1995 with the Second Defendant's husband entertaining and or partaking in the conspiracy as of then. And the Plaintiffs CLAIM DAMAGES imposed on them by way of additional work an loss of time, and consequential due to denial of and obstructions to receive funds by way of rents contracted with tenants encouraged and invited not to meet their contractual obligations.