BL-2024-001066 | BL-2024-001166 (former County Court ref L10CL352)
SCHEDULE F – LOCKOUT TIMELINE & STAFF IMPACT ANALYSIS
Direct Causation: Lockouts → Staff Loss → Rent Default → Homelessness
Total Lockouts 6 Oct 2022 - May 2023
Same-Day Attack 17/10/22 Foxtons Start = 1st Lockout
Sales Manager Lost 07/02/23 New Father Resigned
Rent Default Began Feb 2023 After Manager Left
FORENSIC LOCKOUT CHRONOLOGY WITH STAFF IMPACT
Date Lockout # Target/Victim Business Impact Foxtons Rent Status Causation Link
Pre-17/10/22 - N/A Operating normally Not yet tenant Baseline established
17/10/22 1 CEO + Staff First day disrupted Day 1 of tenancy Perfect correlation begins
14/11/22 2 Entire team Operations disrupted Paying (late as usual) Pattern tolerated
15/11/22 3 Back-to-back attack Staff morale affected Still managing Stress accumulating
18/01/23 4 Sales Manager (new father, 3 weeks post-birth) Manager traumatized Last payment 31/01 Critical inflection point
07/02/23 - RESIGNATION Sales Manager quits Cannot pay Feb rent Revenue generation ends
27/04/23 5 Remaining staff After police warning £35,000+ arrears Criminal harassment
20/05/23 6 Final staff Business destroyed £50,000+ arrears Total collapse
12/08/25 - CEO alone Company liquidated £72,540 arrears Homelessness imminent
THE SALES MANAGER DESTRUCTION SEQUENCE
Date/Event Personal Circumstances Lockout Impact Business Consequence
28/12/22 Baby born Father on limited leave Vulnerable period begins
18/01/23 3 weeks post-partum Lockout 4 - sent home New father traumatized
19-31/01/23 Considering options Cannot work effectively Sales pipeline stalls
07/02/23 Family stability prioritised RESIGNS 100% sales capacity lost
Feb 2023 Gone Position unfilled Zero new revenue
MATHEMATICAL PROOF OF CAUSATION
Metric Before Manager Left After Manager Left Percentage Impact
Monthly Revenue £52,047 avg £11,694 avg -77.5%
Foxtons Rent Paid 100% (albeit late) 0% -100%
Staff Retained 5 employees 0 employees -100%
Business Viability Growing 74% CAGR Liquidated DESTROYED
CRITICAL FORENSIC FINDINGS:
1. Perfect Temporal Correlation: First lockout on exact day of Foxtons tenancy (17/10/22) = targeting from day one
2. New Father Targeting: Lockout 4 occurred when Sales Manager's baby was 3 weeks old = maximum vulnerability
3. Direct Causation Chain: Lockout 4 (18/01) → Manager resigns (07/02) → Cannot pay rent (Feb) → Arrears begin
4. Criminal Continuation: Two lockouts AFTER police warning (27/04 & 20/05) = deliberate criminality
5. But For Test: But for the lockout of new father, rent would have been paid (late but paid as always)
Eastwood v Lower Richmond Properties Ltd & Vista (London) Ltd
Business and Property Courts of England and Wales • Chancery Division
Direct Causation Proven: Lockouts → Staff Loss → Rent Default → £72,540 Arrears