BL-2024-001166 (former County Court ref L10CL352)

County Court at Central London

https://www.michaeldariuseastwood.com/legal

BL-2024-001166 (former County Court ref L10CL352)

Part 7 Damages (Harassment / Conversion)

SUMMARY JUDGMENT (VOID DERIVATIVE) MHCM Affected

Court

High Court (Chancery Division); void transfer to County Court at Central London

Case Number

BL-2024-001166 (former County Court ref L10CL352)

Claimant

Michael Darius Eastwood

Defendant

Lower Richmond Properties Ltd (R2), Vista (London) Ltd (R3)

Filed

12.08.2024 (High Court)

Quantum

£4,907,000 (subject to court assessment)

Days in Default

540++

Next Step

Set Aside SJ / Transfer back to High Court

Notes

Proceeding based on void pre-service transfer. Defence filed 27 days late in a court without jurisdiction (the County Court, following the void transfer), without CPR 3.9 relief or Denton analysis. R2/R3 were not parties to the Kelly interim injunction hearing (KB-2024-001508). The Cohen summary judgment is challenged as a derivative nullity.

Grounds (32)

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. The statutory prohibition is mandatory and admits no discretion.

LOCKED

G-A2

MacFoy Cascade (Derivative Nullities)

Orders founded on void MHCM orders are themselves void. The DDJ Wood order (Day 9) validated a late Defence; Cohen's summary judgment was founded on that Defence. The entire chain collapses.

LOCKED

G-A3

Jurisdictional Nullity (Pre-Service Transfer)

Transfer from High Court to County Court on 13 Aug 2024 was made before service was effected (court email confirming service 28 Aug 2024). A court cannot transfer proceedings over which it has not yet acquired jurisdiction. Master Clark also split the single claimant ('Michael Darius Eastwood (Representing As Mastermind Promotion Ltd and Mastermind Group Ltd)') into two separate parties: 'Michael Eastwood (Representing As)' and 'Mastermind Group Ltd'. This enabled the defendants to strike out the second claimant through DDJ Wood's void sealed order (MHCM Day 9).

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)/BL-2024-001166, 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-A9

Default Judgment Entitlement

R1 (Chelsea Harbour) 540+ days in default. R2/R3 (LRP/Vista) Defence filed 27 days late without CPR 3.9 relief. N227 request never determined. CPR 12.3 mandates entry as a ministerial function.

LOCKED

G-A10

Summary Judgment Wrong (Cohen)

Recorder Cohen granted summary judgment on 19 Aug 2025 on a Defence validated by a void DDJ Wood order (MacFoy cascade). The Defence itself contains sworn admissions conceding liability. Flannery breach: 'other reasons besides exclusive possession' never identified.

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

G-A14

Judge Swap (Dight to Cohen)

HHJ Dight CBE (the judge in Lees v Kaye who understood MHCM law) was scheduled but replaced at the last minute by Recorder Cohen KC, who then got the MHCM analysis wrong. No explanation for the swap. SAR filed.

LOCKED

G-A15

TWM Imposed on PTA Never Applied For

Cohen's N460 refuses permission to appeal. Michael stated at the hearing he was NOT applying for PTA. Cohen imposed a TWM on an application that was never made. The N460 also invented an application to refuse. Wasif/Grace standard violated on multi-limb applications.

LOCKED

G-A16

Equality of Arms (Cohen Email Access)

Defendants' counsel (Ciara Fairley) had Recorder Cohen's private judicial email before Michael did. Cohen adopted counsel's draft order, refused all LiP corrections, and told the LiP it was 'not appropriate' to correspond with the judge. Article 6 breach.

LOCKED

G-A17

Flannery Breach (Unidentified Reasons)

Cohen stated there were 'other reasons besides exclusive possession' for granting summary judgment but never identified them. A judge who fails to give adequate reasons commits a Flannery breach.

LOCKED

G-A18

CPR 40.12 Corrections Refused

Cohen refused all 7 CPR 40.12 correction requests without engaging with them individually. The sealed order contains 'extemporary' (a non-word) and other errors. The order was sealed with uncorrected mistakes.

LOCKED

JR-1

CE-File Deleted Set-Aside Application

HMCTS deleted the Applicant's set-aside application from the CE-File system, then told him any High Court filings would be struck out. Created a procedural impossibility: could not challenge the transfer in either court.

LOCKED

JR-2

Transcript Obstruction (8 EX107s, 0 Transcripts)

8 EX107 applications filed across 3 courts. Not a single full transcript provided in over 200 days. Rolls Building ignored all 6. County Court returned 2 addressed to 'Mr Darius'. 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-12

Judge Swap (Dight to Cohen) Unexplained

HHJ Dight CBE (the Lees v Kaye MHCM judge) was scheduled for the 19 Aug 2025 hearing. He was swapped for Recorder Cohen at the last minute with no explanation. Cohen then got the MHCM analysis wrong. SAR filed to investigate.

LOCKED

JR-13

'Mr Darius' on EX107 Forms

County Court returned EX107 transcript applications addressed to 'Mr Darius' (the Applicant's surname is Eastwood). a County Court clerk, County Court clerk, 18 Sep 2025. Form rejected because two production companies were selected instead of one.

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-17

Article 14 + Article 6 (Discrimination in Fair Trial)

The Applicant was treated differently because of his disability. Recorder Cohen: 'had you had counsel maybe you would have won.' Rather than providing adjustments to level the playing field, the court punished the disability.

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

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-3

Equality of Arms (Cohen Email Access)

Supports both Article 6 fair hearing (appeal) and procedural impropriety (JR).

LOCKED

OV-4

Fabricated Order Terms

Supports both CPR 40.12 breach (appeal) and illegality (JR).

LOCKED

OV-5

Defence Admissions Ignored

Supports both SJ was wrong (appeal) and irrationality (JR).

LOCKED

Court Orders (5)

Date	Judge	Type	Status	MHCM Day	Defects
13 August 2024	Master Clark	First Transfer Order	VOID		Fourie Pre-service; No Reasons
3 September 2024	Deputy Master Dovar	Second Transfer Order	VOID		Founded on Void First Transfer; Pre-service Solicitation
6 January 2025	DDJ Wood	Unless Order / Costs Order	VOID	Day 9	MHCM Violation (Reg 7(12)); 7 Fabricated Terms; Pre-service Transfer Derivative
19 August 2025	Recorder Cohen KC	Summary Judgment Order	VOID		MacFoy Principle; Unsealed Application; PD1A Denied
19 August 2025	Recorder Cohen KC	N460 Permission Refusal / TWM on PTA	VOID		Founded on Void SJ; TWM Imposed on PTA Never Applied For; Derivative: Rests on the void Summary Judgment

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.

13 August 2024

First Transfer Order VOID

Master Clark. Fourie Pre-service. No Reasons.

3 September 2024

Second Transfer Order VOID

Deputy Master Dovar. Founded on Void First Transfer. Pre-service Solicitation.

6 January 2025 MHCM Day 9

Unless Order / Costs Order VOID

DDJ Wood. MHCM Violation (Reg 7(12)). 7 Fabricated Terms. Pre-service Transfer Derivative.

19 August 2025

Summary Judgment Order VOID

Recorder Cohen KC. MacFoy Principle. Unsealed Application. PD1A Denied.

19 August 2025

N460 Permission Refusal / TWM on PTA VOID

Recorder Cohen KC. Founded on Void SJ. TWM Imposed on PTA Never Applied For. Derivative: Rests on the void Summary Judgment.

3 September 2024

Second Transfer Order DERIVATIVE NULLITY

Fruit of the poisonous tree. Derivative of void first transfer. Pre-service solicitation.

19 August 2025

Summary Judgment Order DERIVATIVE NULLITY

Fruit of the poisonous tree. The fruit of the poisonous tree. Summary judgment on application never served on Applicant.

19 August 2025

N460 Permission Refusal / TWM on PTA DERIVATIVE NULLITY

Fruit of the poisonous tree. Void because the judgment it relates to is void. TWM certified on permission to appeal that was never applied for. 28th adverse decision.

Evidence (16)

MDE-MHCM-001 LOCKED

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 during MHCM period.

MDE-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 period.

MDE-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 PD 1A adjustments.

MDE-EVD-001 LOCKED

Procedural Mismanagement Evidence

Compiled evidence of procedural failures across courts.

Relevance

Demonstrates pattern of institutional failures across proceedings.

MDE-EVD-002 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.

MDE-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.

MDE-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.

MDE-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.

MDE-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.

MDE-FIN-005 VERIFIED

Five-Year Forecast

Five-year business forecast projections based on historic growth trend.

Relevance

Supports NPV calculation and future loss claim.

MDE-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.

MDE-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 8 EX107 applications resulted in any transcript.

MDE-SAR-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.

MDE-SAR-002 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-2024-000527. Includes internal communications regarding Mr Wheeler and decisions made about the case.

Relevance

Outstanding SAR. No response received. 346+ days overdue. Records may contradict statements made by Mr Wheeler in court. Suppression engages contempt jurisdiction.

MDE-SAR-003 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 2024 to present). Includes internal emails re WCA referrals, MR records, case manager Conor complaints, RA requests, sanctions, claim review records, and all journal entries and audit trails.

Relevance

Outstanding SAR. No response. 34+ days overdue. Case manager redirected to generic GOV.UK form instead of acknowledging. Data would prove 2-year WCA delay (costing 9,300 LCWRA), retaliatory claim review within 24 hours of disability rights assertion, and MR 'cleared in error' for 5 months. Pre-Action Protocol for JR filed same date.

Chronology (29 events)

22 July 2022

Agreement on mid-month payment terms with Lower Richmond Properties

Mastermind Group Ltd and Defendants agree to flexible payment arrangement acknowledging cash flow cycle. Establishes landlord's acceptance of modified payment terms creating estoppel.

1 August 2022

Unilateral rent increase without tenant consent

Defendants breach lease agreement by increasing rent unilaterally without notice or consent, imposing unexpected financial strain on Mastermind Group Ltd in violation of contract terms.

17 October 2022

First unauthorised lockout of Lower Richmond premises

First of six lockouts without proper notice or legal justification. Disrupts daily operations without prior warning. Breach of quiet enjoyment covenant under lease. Pattern of harassment commences.

14 November 2022

Second and third unauthorised lockouts

Further destabilizes business operations causing missed client meetings and direct revenue loss. Pattern of systematic harassment establishes course of conduct for Protection from Harassment Act 1997 s.3 purposes.

18 January 2023

Fourth unauthorised lockout leads to Sales Consultant resignation

Key Sales Consultant resigns citing operational instability. Direct causation between lockouts and staff loss established. Impairs revenue generation capability creating consequential losses.

7 February 2023

Sales Manager resigns due to ongoing disruptions

Resignation citing inability to perform duties due to continuous lockouts. Testimonial evidence of lockout impact on business viability. Loss of key personnel damages operational capacity.

17 February 2023

Harassment warning to LRP/Vista (police involved)

Demonstrates prior formal notice, supports course of conduct under PHA 1997, and aggravates quantum for injury to feelings/psychiatric harm. Cross referenced to BL-2025-000147 heads of loss.

24 March 2023

PA/Office Manager resigns - administrative collapse

Loss of internal coordination capability. Administrative infrastructure collapses. Directly attributable to defendants' conduct creating untenable working environment per Protection from Harassment Act.

27 April 2023

Fifth unauthorised lockout hinders team rebuilding

Hinders efforts to rebuild sales team. Critical projects delayed. Demonstrates continuing course of conduct relevant to s.3 Protection from Harassment Act 1997. Pattern consolidates.

20 May 2023

Sixth unauthorised lockout - forced vacation under duress

Final lockout forces Mastermind Group Ltd to vacate premises under duress. Operational collapse complete. Constructive eviction. Incurs relocation costs and business interruption losses. Total £4.9m+ damages.

8 June 2023

Forced relocation from Lower Richmond premises completed

Company vacates due to untenable conditions created by systematic lockouts. Additional relocation costs incurred. Loss of established business location. Consequential damages flow from defendants' systematic breaches.

1 December 2023

Revenue collapse: £650,000 (2022) to £140,000 (2023)

Financial impact establishes quantum: £560,000 actual loss for 2023 (from forecasted £800,000 to actual £140,000). Directly caused by lockouts, staff losses, and operational instability per causation principles. Establishes damages baseline.

12 August 2024

Case BL-2024-001166 issued and approved in High Court Chancery

Claimant granted four months to serve claim pursuant to CPR 7.5 (service deadline: 12 Dec 2024). High Court Chancery Division jurisdiction properly established based on claim value £4.9m+ substantially exceeding £100,000 County Court threshold.

13 August 2024

Master Clark transfers BL-2024-001166 to County Court BEFORE SERVICE

CRITICAL JURISDICTIONAL DEFECT - VOID AB INITIO - Transfer violated Fourie v Le Roux [2007] UKHL 1: court has NO jurisdiction over proceedings before service effected establishing lis pendens. CPR 30.3(2)(a) requires consideration of claim suitability, but such discretion cannot be exercised absent jurisdiction. ALL subsequent County Court proceedings founded on void transfer are themselves void.

16 August 2024

Set-aside application filed challenging jurisdictional transfer defect

Prompt objection to fundamental jurisdictional defect preserves claimant's rights. Cited appropriate High Court forum based on claim value and factual/legal connection to parallel BL-2024-001089 proceedings.

22 August 2024

Court officer a CE-File administrator contacts Defendants unilaterally

NATURAL JUSTICE BREACH - Court officer communicates with one party about substantive procedural matters without notice to other party. Violates fundamental equal treatment obligation and fair hearing principles. Al-Medenni v Mars UK Ltd [2005] EWCA Civ 1041.

28 August 2024

Court confirms to Defendants that service had not yet occurred

DOCUMENTARY EVIDENCE proving Master Clark's actual knowledge that 13 Aug transfer was premature and jurisdictionally defective. Email creates clear contemporaneous record that court KNEW service not effected when transfer order made on 13 Aug - FATAL to validity of transfer.

30 August 2024

BL-2024-001166 claim deemed served by post on defendants

FIRST MOMENT County Court could have had ANY jurisdiction over proceedings per Fourie v Le Roux. Service effective this date establishing lis pendens. Defence deadline: 27 September 2024 (28 days after service per CPR 15.4(1)(a)). All prior County Court orders void for want of jurisdiction.

3 September 2024

Deputy Master Dovar email containing damaging admissions

Email acknowledged: (1) 'Defendants have no notice of any claim' (confirms pre-service transfer violated Fourie); (2) 'Sums claimed are large' (contradicts County Court transfer justification). Documentary evidence of serious procedural irregularity.

27 September 2024

CRITICAL DATE: Defence deadline passes - NO DEFENCE FILED (BL-2024-001166 (former County Court ref L10CL352))

DEFENDANTS IN DEFAULT under CPR 15.4. Claimant entitled to default judgment under CPR 12.3(1). From this date forward claimant has clear mandatory entitlement. Every day since (now 410+ DAYS) represents continuing default without judicial remedy despite repeated applications.

30 September 2024

N227 Request for Default Judgment filed with court

Proper and timely default judgment application made 3 days after defence deadline expired. Court had MANDATORY duty under CPR 12.3(1) but systematically failed to discharge statutory duty. Ignored for 11 months (10+ follow-ups).

24 October 2024

UNAUTHORIZED Defence filed 27 days beyond deadline

Filed by defendants knowing: (1) NO sealed extension order exists; (2) Filed 27 days beyond 27 Sept deadline; (3) Default judgment application pending. Defence is INVALID and of no legal effect without relief from sanctions per Billington v Davies [2007] EWCA Civ 1324.

20 December 2024

Hearing before DDJ Wood - ORAL PRONOUNCEMENTS DIFFER FROM SEALED ORDER

ORDER FABRICATION - Judge's actual oral pronouncements: (1) Costs expressly stated as 'RESERVED' (not 'forthwith' as sealed order states); (2) NO automatic strike-out provision ordered; (3) NO name amendment provisions authorized. These DIFFER MATERIALLY from subsequently sealed 6 Jan 2025 order.

6 January 2025

FRAUDULENT ORDER SEALED DURING ACTIVE MHCM (BL-2024-001166 (former County Court ref L10CL352))

VOID AB INITIO - MULTIPLE INDEPENDENT NULLITY GROUNDS: (1) Order sealed during active MHCM (day 10) in DIRECT breach of Reg 7(12); (2) Contains FABRICATED provisions never pronounced: (a) automatic strike-out, (b) £22,528 'forthwith' costs when costs were 'reserved', (c) unauthorised name changes. Per Lees v Kaye [2022] EWHC 1151 (QB), such orders are 'null and void'.

22 May 2025

Discovery of 6 Jan 2025 order fabrication (first sight in defendants' bundle)

Claimant discovers fabricated provisions in 6 Jan order for FIRST TIME - 136 DAYS after sealing. Extended concealment period explains apparent 'delay' in challenging order. Per Aktas v Adepta [2010] EWCA Civ 1170, order never properly served cannot found appeal time limits.

19 August 2025

SUMMARY JUDGMENT HEARING (Recorder Cohen KC) - SYSTEMATICALLY UNFAIR

SYSTEMATICALLY UNFAIR HEARING - (1) Refused counter-application; (2) Proceeded despite SJ application NEVER properly served; (3) Recorder had 'insufficient time' to read evidence; (4) Refused CPR 3.10 discretion 'notwithstanding claimant's vulnerability and disability'; (5) Dismissed MHCM nullity; (6) Failed to consider Defence's OWN ADMISSIONS.

19 August 2025

Summary judgment granted for Defendants on liability - DERIVATIVE NULLITY

JUDGMENT VOID - Built entirely on: (1) Void 6 Jan order (MHCM breach); (2) Invalid Defence (27 days late without CPR 3.9); (3) Void pre-service transfer. Defence ITSELF admits lockouts without notice (para 10.5.2) and no disability adjustments (para 17.4). Per MacFoy: 'cannot put something on nothing'.

1 September 2025

Comprehensive Application for Reconsideration filed under CPR 24.11

Seeks: (1) Reconsideration of 19 Aug SJ; (2) Declaration 6 Jan order void; (3) Default judgment on liability; (4) Alternative SJ FOR Claimant (Defence admissions establish liability); (5) Interim payment £250,000.

10 November 2025

Lower Richmond/Vista remain in default - INVALID LATE DEFENCE ON RECORD

410+ DAYS CONTINUING DEFAULT. Defence filed 27 DAYS LATE WITHOUT CPR 3.9 relief = LEGAL NULLITY per Billington v Davies [2007] EWCA Civ 1324 at [17]: 'if no extension of time is obtained before the deadline expires, then the defence which is subsequently filed is of no effect'.