M. D. Eastwood
/
Overview & Briefing 4
Judicial Briefing Guide for Court How the Cases Connect The Story
Orders Sought 4
Relief Sought 33 Quantum (£8.2M+ pleaded) Why One Judge Must Hear All Settlement Exposure The Costs Trap
Void Ab Initio 29:0
29 Adverse : 0 Favourable 1 in 537M 21 Void Orders (All Void) MHCM Calendar Defence Admissions Defence Contradictions Equality of Arms Filing Pattern (0/12 RA) Staff Impact (6 Resignations) Gaslighting 13
No Time Bar Applies 9 Grounds
Grounds of Voidness 23
CA-2024-001353 · s.31A SCA 1981
Appeal Overview 23 Grounds of Voidness Argument Map KB Hearing (7 June) Waiver/Estoppel
Judicial Review 12
7 bodies · 34 ECHR · permission sought
JR Targets 7 ECHR Violations 34 Institutional Failures Solicitor Misconduct Transcript Obstruction 0/12 Adjustments Granted Subject Access Requests SAR Tracker 3 overdue Pre-Action Letters Constitutional DWP Judicial Review Wheelchair Ramp
The 6 Cases 6
Chelsea Harbour Ltd (R1) Lower Richmond Properties Ltd & Vista (London) Ltd (R2, R3) Personal Damages Insolvency KB Injunction Defendants

Evidence & Documents 11
103 exhibits · 160 authorities · 1395 events
Evidence Hub Exhibits 103 Gallery Chronology 1395 Authorities 160 Key Quotes Revenue & DCF Costs Analysis OR Response + 15 Enclosures Applications All Documents
Reference & Tools 14
Ask the Case Search / Master Timeline Order Timeline CPR Heatmap CPR Dictionary Citation Index Glossary Evidence Trails Document Timeline Evidence Matrix Evidence Audit Argument Index Data Health Open Justice Assurance and Governance Health Report
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BL-2024-001089
High Court (Chancery Division)
https://www.michaeldariuseastwood.com/legal
Legal/Cases/BL-2024-001089
This site is published under the open justice principle. All court proceedings referenced here are matters of public record. Third-party personal data has been redacted in accordance with GDPR. Public availability here does not itself prove that a document has been filed, served, or sent. Read the full disclaimer.

BL-2024-001089

N5A Relief from Forfeiture

STAYED (VOID MHCM ORDERS) MHCM Affected
Court
High Court (Chancery Division)
Case Number
BL-2024-001089
Claimant
Michael Darius Eastwood (Representative)
Defendant
Chelsea Harbour Ltd (R1)
Filed
29.07.2024
Quantum
Damages to be assessed by the court
Days in Default
540++
Next Step
Administrative Regularisation / Default Judgment
Notes

Subject to void LCRO and costs orders sealed during MHCM. No Defence filed for 540+ days. N227 request and N244 application both undetermined. Chelsea quantum to be assessed by the court after liability is established.

Grounds (28)

G-A1
MHCM Statutory Nullity
10 orders made during the Mental Health Crisis Moratorium (28 Dec 2024 to 16 Apr 2025) are void ab initio under Regulation 7(12) DSRR 2020. Each order is void not merely because of when it was made but because of what it contains and what it does. The DDJ Wood order (6 January 2025, MHCM Day 9) fraudulently inserted costs "forthwith GBP 22,528" (enforcement), an unless strike-out (conditional enforcement), and a retrospective extension validating the late Defence. The Master Kaye costs stay (6 February 2025, MHCM Day 40) conditioned the proceedings on payment of void costs (enforcement of debt). Every order that depends on or follows from the 6 February costs stay is also void as a derivative nullity. The LCRO (27 February 2025, MHCM Day 61) restricts the debtor's access to the court (enforcement). The TWM certifications are enforcement acts. The statutory prohibition is mandatory and admits no discretion.
LOCKED
G-A4
CPR 40.12 Breach (Fabricated Order Terms)
Two sealed orders contain terms not pronounced at any hearing. DDJ Wood (06.01.2025, BL-2024-001166 (former County Court ref L10CL352), MHCM Day 9): costs 'reserved' at hearing sealed as 'forthwith 22,528' with strike-out of Mastermind Group Ltd as Second Claimant added (only possible because Master Clark's void transfer had split the single claimant into two parties). DM Glover (18.09.2024, BL-2024-001089): sealed order contains unpronounced directions restricting evidence, interim stay of ALL applications (no application made), bundle ban, and forced name change/claim split under threat of strike-out. 3 reasonable adjustment requests denied at the hearing. Undisclosed material used. Glover order is VOID on 4 independent grounds: (1) CPR 40.12 fabricated terms; (2) CPR 23.1 no application; (3) EA 2010 s.20 RA failure; (4) natural justice breach (Ridge v Baldwin [1964] AC 40). Reclassified from VOIDABLE to VOID 24.03.2026.
LOCKED
G-A5
LCRO Void (MHCM Period)
The Chancery Division LCRO of 27 Feb 2025, imposed by Master Kaye on BL-2024-001089 alone, was made on Day 61 of the MHCM. It was imposed by the same judge the Claimant had complained about 7 days earlier. It is void ab initio under Reg 7(12) as it constitutes enforcement action during the moratorium. The proceedings were undefended (no defence filed for 540+ days). Any further Chancery Division filing risks escalation to a General Civil Restraint Order (GCRO).
LOCKED
G-A6
LCRO Void (Apparent Bias)
The Chancery Division LCRO on BL-2024-001089 was imposed by Master Kaye 7 days after a formal complaint against her. The same judge who was the subject of the complaint imposed the order on undefended proceedings (no defence filed for 540+ days). The ruling at para 41 expressly cites the complaint as evidence of 'persistence.' A fair-minded observer would conclude there was a real possibility of bias. CROs disproportionately target litigants in person. Any further Chancery Division filing risks a GCRO.
LOCKED
G-A7
LCRO Void (Procedural Unfairness)
The cluster of 27 Feb 2025 orders was made ex parte without notice or opportunity to be heard. No CPR 3.3(5)(b) notification. No CPR 3.11 warning before CRO. Violates Lord Leggatt's Rule One (Potanina).
LOCKED
G-A8
LCRO Void (Disproportionate)
No lesser sanctions considered before imposing a 2-year Chancery Division LCRO on BL-2024-001089 alone. Imposed by the same judge the Claimant had complained about 7 days earlier, on undefended proceedings (no defence filed for 540+ days). No costs warning, no extended CRO. The nuclear option applied without proportionality analysis. TWM count arguably incorrect (N460 refused a non-existent application). Any further Chancery Division filing risks escalation to a GCRO.
LOCKED
G-A9
Default Judgment Entitlement
R1 (Chelsea Harbour) 540+ days in default. No Defence filed. N227 request and N244 application both undetermined. R2/R3 (LRP/Vista) Defence filed 27 days late in a court without jurisdiction (the County Court, following the void transfer of BL-2024-001166), without CPR 3.9 relief or Denton analysis. The court granted substantive relief to defaulting defendants without first determining the anterior Part 12 / Part 23 issue.
LOCKED
G-A11
EA 2010 Discrimination
Systematic discrimination arising from disability (s.15), failure to make reasonable adjustments (s.20), discrimination in provision of services (s.29), and breach of Public Sector Equality Duty (s.149) across all proceedings.
LOCKED
G-A12
Reasonable Adjustments Denied (0/12)
12 reasonable adjustment requests across all courts; 0 granted. 100% refusal rate. No evidence of any PD 1A consideration at any hearing. Rolls Building disability framework conceived around physical access only; neurodivergent conditions invisible.
LOCKED
G-A13
Procedural Unfairness (Cumulative)
The totality of irregularities (29:0 adverse ratio, MHCM void orders, PD 1A denial, complaint weaponisation, TWM clustering, transcript denial) renders the proceedings fundamentally unfair under Article 6 ECHR.
LOCKED
JR-2
Transcript Obstruction (5+ Formal EX107s + Informal RA Requests, 0 Transcripts)
At least 5 formal EX107 transcript applications filed across multiple courts, plus further informal requests as reasonable adjustments. Not a single full transcript provided in over 200 days. Rolls Building ignored applications. County Court returned forms addressed to 'Mr Darius'. Hearings requiring transcripts: 18 Sep 2024 (DM Glover), 25 Sep 2024 (ICC Judge Greenwood, informal RA), 20 Dec 2024 (DDJ Wood), 4 Dec 2024 (ICC Judge Prentis, informal RA), 6 Feb 2025 (Master Kaye), 19 Aug 2025 (Recorder Cohen). Without transcripts, appeals cannot proceed.
LOCKED
JR-7
29:0 Adverse Decision Ratio
28 consecutive adverse decisions (21 judicial + 7 institutional) against a disabled LiP with defendants in default. Probability of occurring by chance: 1 in 536,870,912. No rational decision-making process could produce this outcome.
LOCKED
JR-8
16 Substantive Emails Ignored
16 substantive emails sent to multiple court addresses across all proceedings. Not a single substantive response. Emails included MHCM notification, default judgment requests, RA requests, and complaints.
LOCKED
JR-10
No Investigation of Ross False Statements
Steven Ross (Harold Benjamin LLP) made 4 false statements across 2 courts: 3 in witness statements, 1 in pleading ('changing the locks' vs WhatsApp + transcript showing 'padlocked'). Plus 1,336-page misleading bundle and enforcement during MHCM. No SRA investigation.
LOCKED
JR-11
17 Orders Without CPR 23.1 Applications
17 orders granted to defendants or against the Applicant without any CPR 23.1 application notice being filed. Made on court's own initiative or at oral request, without service, and in several instances during MHCM.
LOCKED
JR-14
No Investigation of Counsel Conduct During MHCM
Whether counsel participated in ex parte applications during MHCM period. Core Duties 1, 3, 5 engaged. Rules rC3, rC4. Conditional/investigatory pending SAR results.
LOCKED
JR-16
Article 6 (Denial of Access to Justice)
Combined effect: GBP 34,528 costs barrier (R (UNISON) v Lord Chancellor), Chancery Division LCRO (BL-2024-001089 only, imposed by the same judge complained about 7 days earlier on undefended proceedings) blocking applications, default judgment suppressed 540+ days, transcripts withheld preventing appeals. Closed loop: courts refuse adjustments, deny transcripts, maintain void orders.
LOCKED
JR-18
A1P1 (Deprivation of Property Through Void Proceedings)
Loss of business, office, chattels, IP, and income through enforcement of void orders. Article 1, Protocol 1 ECHR protects peaceful enjoyment of possessions.
LOCKED
JR-19
0/12 Reasonable Adjustments (100% Refusal)
12 formal RA requests across all courts. Not a single one granted. Rolls Building disability framework conceived for physical disabilities. Neurodivergent conditions do not exist in their documentation. No PD 1A reference anywhere.
LOCKED
JR-20
No PSED Consideration Evidenced
Section 149 EA 2010 imposes a duty to have due regard. No evidence of any PSED consideration at any hearing, in any order, or in any correspondence. The duty is proactive, not reactive.
LOCKED
JR-21
13+ Months Ignoring Complaint (PSED Failure)
Formal complaint filed 20 Feb 2025 against Master Kaye documenting disability discrimination. JCIO has not investigated in 13+ months. PSED requires due regard to eliminating discrimination. Ignoring complaints about discrimination is itself a PSED failure.
LOCKED
G-A19
Open Justice Violation (Anonymous Listing)
The 06.02.2025 hearing was listed as 'A v B' on the public cause list without any CPR 39.2 order authorising anonymity. No reason given. No application made. Open justice is a constitutional principle. This unexplained departure requires explanation.
LOCKED
OV-1
29:0 Adverse Decision Ratio
Supports both bias (appeal) and irrationality (JR). 28 consecutive adverse outcomes. P < 1 in 536,870,912.
LOCKED
OV-2
17 Orders Without CPR 23.1 Applications
Supports both procedural unfairness (appeal) and procedural impropriety (JR).
LOCKED
OV-4
Fabricated Order Terms
Supports both CPR 40.12 breach (appeal) and illegality (JR).
LOCKED
G-A20
No Disclosure Ever Reached
In neither BL-2024-001089 nor BL-2024-001166 was disclosure ever discussed, ordered, or conducted. Document-dependent issues (service validity, notices, lease/licence status, lockout records, disposal records) were determined summarily without disclosure. This is a compelling reason under CPR 24.2(b) why the claims should not have been disposed of before proper disclosure case management. The record was incomplete and asymmetric.
LOCKED
G-A21
Stay vs Strike-Out: Defendant's Conduct Confirms Interim Character
In BL-2024-001089, R1 applied for a stay of proceedings, not a strike-out for abuse of process under CPR 3.4(2)(b). A stay presupposes the proceedings have life. If Kelly had determined everything, the proper course was strike-out. The defendant's choice of remedy is an implicit admission Kelly was interim. Master Kaye independently confirmed this at 6 February 2025.
LOCKED
G-A22
Strict Liability Conversion (Kuwait Airways)
Chelsea Harbour sold property belonging to Michael personally and Mastermind Group Ltd for GBP 1,100 to Barrington Marketing Limited. Mastermind Promotion Ltd held the lease but is dormant with zero property rights. No itemised list provided. Sale after cease and desist letter. Strict liability conversion: Kuwait Airways v Iraqi Airways [2002] 2 AC 883. Only quantum remains. Causes of action assigned to Michael in April 2024 (pre-liquidation). Steven Ross WS admits disposal.
LOCKED

Court Orders (9)

DateJudgeTypeStatusMHCM DayDefects
1 October 2024 Deputy Master Glover Directions Order VOID Unpronounced Terms (CPR 40.12): fabricated directions including bundle restriction; No Application (CPR 23.1): interim stay of ALL applications imposed without application; Forced Name Change/Claim Split: threatened under strike-out, party format accepted by Master Kaye, KB, and CoA; Failure to Make Reasonable Adjustments (EA 2010 s.20): 3 requests denied (present case first, scheduled breaks, written submissions); Undisclosed Material (natural justice, Ridge v Baldwin [1964] AC 40): facts not disclosed inside hearing included in sealed order; Article 6 ECHR: right to fair hearing breached (could not address undisclosed terms or facts)
5 February 2025 Master Kaye s.130(2) Leave Refusal VOID Day 39 MHCM Violation; TWM Certified during Moratorium
6 February 2025 Master Kaye Master's Ruling (Interim Payment) VOID Day 40 MHCM Violation; Enforcement of Debt (£12k); No Application
6 February 2025 Master Kaye Stay & Strike Out Order VOID Day 40 MHCM Violation; Enforcement Mechanism (Unless Order)
20 February 2025 Master Kaye Ex Parte Stay Dismissal VOID Day 54 MHCM Violation; Ex Parte Without Notice
27 February 2025 Master Kaye Costs Order VOID Day 61 MHCM Violation; Porter Bias Nexus (7 days); Enforcement (£21k)
27 February 2025 Master Kaye Limited Civil Restraint Order VOID Day 61 MHCM Violation; Restraint of Rights; Porter Bias Nexus
27 February 2025 Master Kaye N460 Permission Refusal VOID Day 61 MHCM Violation; Enforcement Finality; Pre-emptive Refusal
27 February 2025 Master Kaye Stay of Enforcement Order VOID Day 61 MHCM Violation; Refusal to Stay Enforcement

Void Cascade (MacFoy Principle)

“You cannot put something on nothing and expect it to stay there.” Per MacFoy v United Africa Co Ltd [1962] AC 152: a void act cannot found any subsequent act.

1 October 2024
Directions Order VOID
Deputy Master Glover. Unpronounced Terms (CPR 40.12): fabricated directions including bundle restriction. No Application (CPR 23.1): interim stay of ALL applications imposed without application. Forced Name Change/Claim Split: threatened under strike-out, party format accepted by Master Kaye, KB, and CoA. Failure to Make Reasonable Adjustments (EA 2010 s.20): 3 requests denied (present case first, scheduled breaks, written submissions). Undisclosed Material (natural justice, Ridge v Baldwin [1964] AC 40): facts not disclosed inside hearing included in sealed order. Article 6 ECHR: right to fair hearing breached (could not address undisclosed terms or facts).
5 February 2025 MHCM Day 39
s.130(2) Leave Refusal VOID
Master Kaye. MHCM Violation. TWM Certified during Moratorium.
6 February 2025 MHCM Day 40
Master's Ruling (Interim Payment) VOID
Master Kaye. MHCM Violation. Enforcement of Debt (£12k). No Application.
6 February 2025 MHCM Day 40
Stay & Strike Out Order VOID
Master Kaye. MHCM Violation. Enforcement Mechanism (Unless Order).
20 February 2025 MHCM Day 54
Ex Parte Stay Dismissal VOID
Master Kaye. MHCM Violation. Ex Parte Without Notice.
27 February 2025 MHCM Day 61
Costs Order VOID
Master Kaye. MHCM Violation. Porter Bias Nexus (7 days). Enforcement (£21k).
27 February 2025 MHCM Day 61
Limited Civil Restraint Order VOID
Master Kaye. MHCM Violation. Restraint of Rights. Porter Bias Nexus.
27 February 2025 MHCM Day 61
N460 Permission Refusal VOID
Master Kaye. MHCM Violation. Enforcement Finality. Pre-emptive Refusal.
27 February 2025 MHCM Day 61
Stay of Enforcement Order VOID
Master Kaye. MHCM Violation. Refusal to Stay Enforcement.

Evidence (41)

CA-MED-003 VERIFIED
ADHD Diagnosis Evidence
Evidence of ADHD diagnosis from approximately 2014.
Relevance

Establishes protected characteristic predating all events.

CA-FIN-003 VERIFIED
Historical IP Revenue Schedule
Revenue schedule from sole trader (2014) to peak (2022). Shows 1,446% growth.
Relevance

Proves trajectory of growth destroyed by defendant conduct.

CA-FIN-007 LOCKED
Revenue Records 2014-2023
Complete revenue history. £99,373 (2017 sole trader) to £624,569 (2022 peak) to £140,327 (2023 colla
Relevance

Proves 1,446% growth trajectory and 77% collapse caused by lockouts.

CA-FIN-006 VERIFIED
Supporting Business Materials / IP Evidence
IP materials, client databases, and business assets evidence.
Relevance

Proves IP value for conversion and Wrotham Park damages.

CA-EVD-008 LOCKED
Highland House Lease/Licence Agreement
Original agreement for Unit 205. Contains unused Clause 1.2 and 5.1.
Relevance

Proves exclusive possession (Street v Mountford). Sham licence label.

CA-FIN-004 VERIFIED
DCF / Investor Evidence Supporting Valuation
Investor evidence: £600,000 commitment, £300,000 paid. Withdrawn after IP sold to competitor.
Relevance

Proves investment destroyed by Chelsea Harbour conduct.

CA-HAR-002 VERIFIED
Staff Resignation Evidence (6 Staff, Jul 2023 - Jan 2024)
Email evidence of 8 staff departures caused by business disruption from lockouts: O.L. (Sales Manager, resigned 7 Feb 2023, last day 10 Mar 2023, ET claim GBP 4,047), P.C. (Sales Consultant, withdrew 27 Feb 2023), D.M. (HR Consultant, withdrew 27 Feb 2023), T.H. (Executive Assistant, resigned 20 Jun 2023, unpaid wages), K.R. (Promotion Manager, resigned 19 Jun 2023, last working day 30 Jun 2023, mental health cited), D.M. (Assistant Promotion Manager, last day 24 Aug 2023, owed GBP 1,600), M.B. (Promotion Manager, left 5 Dec 2023 NO NOTICE, 'left with no choice', has lawyer), D.M. (Artist Success Manager, resigned 13 Dec 2023, 'lack of pay and unworkable conditions'). All dates Gmail-verified. ACAS conciliation MU102123/23 for R. & Ors.
Relevance

Proves 8 staff departed due to lockout disruption. Revenue collapsed from GBP 624,568 (2022) to GBP 140,327 (2023) to GBP 5,612 (2024). Directly caused by LRP/Vista harassment.

CA-FIN-001 LOCKED
Pitch Deck / Business Valuation (Dec 2023)
Mastermind Promotion Ltd pitch deck and business valuation showing 1,446% growth trajectory.
Relevance

Proves company value and growth destroyed by lockouts. Supports quantum.

CA-HAR-001 LOCKED
WhatsApp: 'We Padlocked But Did Not Change the Lock'
Silvia (Chelsea Harbour) admits: 'We padlocked but did not change the lock.' Invited Michael to offi
Relevance

Proves NOT peaceable re-entry. No exclusive possession taken. Forfeiture was sha

CA-EVD-003 VERIFIED
Public Listing 'A v B' Anonymisation (1)
Court listing showing 'A v B' anonymisation of Chelsea Harbour proceedings.
Relevance

Proves unauthorised anonymisation. No anonymity order exists.

CA-EVD-004 VERIFIED
Public Listing 'A v B' Anonymisation (2)
Second court listing showing 'A v B' anonymisation.
Relevance

Confirms pattern of unauthorised anonymisation.

CA-EVD-005 VERIFIED
Public Listing 'A v B' Anonymisation (3)
Third court listing showing 'A v B' anonymisation.
Relevance

Confirms pattern of unauthorised anonymisation across multiple hearings.

CA-EVD-006 VERIFIED
Default Judgment Application (N227)
N227 default judgment request. Refused due to wrong case number (originated from Shoosmiths' draft).
Relevance

Proves court adopted defendants' error then blamed applicant.

CA-FIN-002 LOCKED
DCF Schedules / Future Profit Estimate
Discounted cash flow valuation. WACC 12%, EBITDA margin 30%, NPV £11.82M.
Relevance

Quantum basis for damages claim. Wrotham Park damages methodology.

CA-FIN-005 VERIFIED
Five-Year Forecast
Five-year business forecast projections based on historic growth trend.
Relevance

Supports NPV calculation and future loss claim.

CA-FIN-013 LOCKED
Historical Revenue 2015-2022 (8 Years Verified)
Complete revenue history: £40,403 (2015) to £624,568 (2022). Total IP revenue £1,702,143. CAGR 47.9%
Relevance

Foundation for DCF valuation. 8 verified data points. Proves 1,446% growth and a

CA-MED-004 VERIFIED
Dr McDermott Report
Dr James McDermott psychiatric assessment.
Relevance

Confirms ADHD/ASD and impact on litigation capacity.

CA-PROC-001 LOCKED
Procedural Mismanagement Evidence
Compiled evidence of procedural failures across courts.
Relevance

Demonstrates pattern of institutional failures across proceedings.

CA-PROC-003 VERIFIED
Reasonable Adjustments Request Log (Chelsea)
Log of RA requests made in BL-2024-001089. 12 requests, 0 granted.
Relevance

Proves 100% RA refusal rate. EA 2010 s.20 failure.

CA-EVD-010 VERIFIED
Waiver Evidence - Post-Forfeiture Landlord Conduct
Evidence demonstrating Chelsea Harbour Ltd waived right to forfeit by continuing to treat Michael as tenant after alleged forfeiture. Includes marketing unit, maintenance notifications, "Dear Tenant" communications.
Relevance

Proves waiver of forfeiture. Chelsea Harbour continued landlord-tenant relationship after alleged forfeiture date.

CA-CORR-007 LOCKED
Marketing Unit While Lease Active
Silvia: 'We have started marketing your unit.' Michael: 'Not permissible while lease is active.'
Relevance

Repudiatory breach by landlord. Marketing while lease subsists.

CA-CORR-006 LOCKED
'Dear Tenant' Email After Alleged Forfeiture
Chelsea Harbour fire safety email addressed to 'Dear Tenant' after alleged forfeiture.
Relevance

Waiver of forfeiture. Segal Securities v Thoseby. Conduct inconsistent with forf

CA-MED-002 LOCKED
Dr Woolley Report (26 Apr 2024)
Dr James Woolley psychiatric report confirming ADHD and ASD. HMCTS RA Reference 67862925.
Relevance

Establishes protected characteristic (Equality Act 2010 s.6) and entitlement to

CA-TRN-001 VERIFIED
7 June 2024 Transcript (HHJ Kelly)
Transcript of hearing before HHJ Kelly. Only partial transcript received. 200+ days withheld.
Relevance

Proves transcript obstruction. Only 1 of at least 5 formal EX107 applications resulted in any tr

CA-TRN-003 LOCKED
HHJ Kelly Judgment Transcript (Revised by Judge)
Judgment-only transcript of 7 June 2024 hearing. Revised and edited by HHJ Kelly before release. NOT
Relevance

Contains para 50 ('remains open to bring substantive claim') which contradicts S

CA-WS-001 LOCKED
First Witness Statement of Ferdinand Steinhuber (31 Jul 2024)
Independent investor witness statement. S&S Steinhuber GmbH (Austria, €27M turnover, 80 staff). Alre
Relevance

Independent third-party validation of business viability and quantum. Proves inv

CA-CERT-021 VERIFIED
Proof of Proper Service of Chelsea Harbour Claim
Certificate proving proper service of claim on Chelsea Harbour Ltd. Counters any argument about service defects.
Relevance

Proves valid service - defeats any service objection.

CA-CERT-001 DRAFT
MHCM Certificate (BSS0000297093)
Official Mental Health Crisis Moratorium certificate covering 28 December 2024 to 16 April 2025.
Relevance

Foundational proof for statutory nullity (Reg 7(12) DSRR 2020) of all orders dur

CA-EVD-001 VERIFIED
Evidence Document (from filing)
Supporting evidence document from court filing.
Relevance

Cross-cutting evidence supporting multiple claims.

MDE-EVD-003 VERIFIED
Evidence Document (from filing)
Supporting evidence document from court filing.
Relevance

Cross-cutting evidence supporting multiple claims.

CA-PROC-002 LOCKED
Master Kaye Ruling (Feb 2025)
Full ruling. Para 37(xii): fabricated claim Michael complained about CoA. Para 141: confirms no appl
Relevance

Contains fabricated allegation at para 37(xii) and LCRO admission at para 141.

CA-CORR-008 VERIFIED
Email to a court clerk (5 Feb 2025)
Corrective material sent to Master Kaye's clerk before hearing.
Relevance

Proves Michael engaged constructively. Court ignored submissions.

CA-CORR-015 VERIFIED
Email Not Forwarded to Judge (5 Feb 2025, 10:41am)
Email sent at 10:41am on 5 February 2025 (day before Master Kaye hearing) was not forwarded to the judge. Proves court staff obstruction of LiP's submissions.
Relevance

Proves procedural unfairness - correspondence suppressed before critical hearing.

CA-PROC-007 VERIFIED
Legal Memorandum for Master Kaye Hearing (6 Feb 2025)
Claimant's Legal Memorandum and Authorities - comprehensive written submissions for the 6 February 2025 hearing before Master Kaye. Filed at 07:32am on the morning of the hearing due to 0/12 RA denials.
Relevance

Proves last-minute filing pattern. Filed at 07:32am for a morning hearing because no reasonable adjustments were granted.

CA-PROC-008 VERIFIED
Reasonable Adjustments and Bundle Issues Evidence
Evidence of reasonable adjustments requests and bundle access issues for the 6 February 2025 hearing. Documents the pattern of RA denial.
Relevance

Proves 0/12 RA pattern and bundle access inequality.

CA-CORR-001 VERIFIED
Subject Access Request (20 Feb 2025)
SAR sent to HMCTS for all records relating to the case.
Relevance

Outstanding SAR. No response received. Evidence of institutional obstruction.

CA-ORD-005 LOCKED
Sealed Order (27 Feb 2025) - Records Complaint Considered
Master Kaye sealed order recording that complaint was considered. LCRO imposed 7 days after complain
Relevance

Proves complaint-to-LCRO nexus. Apparent bias (Porter v Magill).

CA-ORD-006 LOCKED
N19 LCRO Form (27 Feb 2025)
Grepe v Loam order form. No defendant application. Master Kaye Ruling para 141 confirms this.
Relevance

LCRO imposed without any application from defendants.

CA-CORR-013 VERIFIED
Subject Access Request to Insolvency Service (10 Mar 2025)
SAR sent to the Insolvency Service under UK GDPR Art 15 for all personal data relating to CR-2024-00
Relevance

Outstanding SAR. No response received. 346+ days overdue. Records may contradict

CA-MED-001 LOCKED
Crisis Team Letter ASD (24 Mar 2025)
Crisis team letter confirming ASD diagnosis and ongoing mental health crisis.
Relevance

Confirms protected characteristic (EA 2010 s.6) and ongoing crisis during MHCM p

CA-CORR-014 VERIFIED
Subject Access Request to DWP (18 Feb 2026)
SAR filed via UC journal under UK GDPR Art 15 for all personal data from entire claim period (Feb 20
Relevance

Outstanding SAR. No response. 34+ days overdue. Case manager redirected to gener

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