Master Timeline

Annual revenue: GBP 99,373. Year 3. +35% YoY. Business establishing.

Annual revenue: GBP 169,667. Year 4. +71% YoY. Significant growth.

Annual revenue: GBP 172,256. Year 5. Stable. +1.5% YoY.

r 2024 requesting, among other things: (HMRC-COR-003) “bank statements for both accounts from 01 January 2020 till the company ceased trading

Annual revenue: GBP 170,044. Year 6. Stable through COVID. -1.3% YoY.

nk statements for Mastermind Group Ltd held in connection with the liquidation, for the period from 1 January 2021 to the date of liquidation

Annual revenue: GBP 352,442. Year 7. +107% YoY. Acceleration phase begins.

First payment made to LRP/Vista. Payment dates varied throughout tenancy, evidencing waiver of strict payment terms.

The Applicant's payment dates varied throughout the entire term: 31 December 2021, 14 January 2022, 16 January 2022, 14 February 2022

The Applicant's payment dates varied throughout the entire term: 31 December 2021, 14 January 2022, 16 January 2022, 14 February 2022

The Applicant's payment dates varied throughout the entire term: 31 December 2021, 14 January 2022, 16 January 2022, 14 February 2022

Double payment unreturned £2,286 14 February 2022

On 14 February 2022, the Applicant made a double payment of £4,572 to LRP/Vista

On 14 February 2022, two payments of GBP 2,286 were made to LRP/Vista

ayment dates varied throughout the entire term: 31 December 2021, 14 January 2022, 16 January 2022, 14 February 2022

hout the entire term: payments were made on 31 December 2021, 14 January 2022, 16 January 2022, and 14 February 2022

4: "On 2 July 2022, the parties agreed that the payment date would be amended to 'mid month'

Agreement on mid-month payment terms with Lower Richmond Properties

Agreement to mid-month payments between Michael and LRP/Vista. Further evidence of waiver of strict payment deadlines (High Trees principle).

On 22 July 2022, Shafina Virani (LRP director) agreed to mid-month payments in writing: "With regard to rental paym

R2 never disclosed this double payment and still owes me that money

ce LRP-PAY-001 Payment records (2021-2023) Part 3: Varied payment dates, double payment LRP-PAY-002 22 July 2022 mid-month agreement Part 3: Promissory estoppel LRP-DEF-001 Defence filed 24 October 20...

legal right cannot later enforce it where the other party has relied on that representation

Unilateral rent increase without tenant consent

FIRST LOCKOUT. LRP/Vista locked Michael out of Unit 205 without notice. Beginning of systematic harassment campaign.

First lockout: October 2022

First unauthorised lockout of Lower Richmond premises

Second and third unauthorised lockouts

SECOND LOCKOUT. LRP/Vista locked Michael out of Unit 205 without notice.

Second lockout: December 2022

Business revenue reaches peak of GBP 624,568. CAGR 47.9% over 7 years (2015-2022). Growth of 1,446% (15.46x). Business in acceleration phase.

Historical revenue 2022: £624,568 (peak year before lockouts)

Fee dispute discussion with LRP/Vista. The next morning Shafina Virani locked the office without notice.

FOURTH LOCKOUT. Shafina Virani (LRP/Vista) locked office without notice the morning after fee dispute discussion. Five staff members resigned in cascade as direct consequence. Revenue began catastrophic collapse.

Fourth lockout: 18 January 2023

Fourth lockout: 18 January 2023. Shafina Virani locked office without notice the morning after fee dispute discussion. 5 staff resigned in cascade.

Fourth unauthorised lockout leads to Sales Consultant resignation

The fourth lockout, on 18 January 2023, was the final blow for my team

efendant “exercised rights… to exclude Mastermind from the Suite temporarily” on 18 January 2023, three weeks after the birth of the Claimant’s child

THIRD LOCKOUT. LRP/Vista locked Michael out of Unit 205 without notice.

Third lockout: February 2023

Ollie Lydon (Sales Manager at Mastermind Promotion Ltd) resigned on approximately 7 February 2023, with formal confirmation from HR (Denise Murphy) on 14 February 2023 that his resignation was effective from 10 March 2023. His resignation was a direct consequence of the 18 January 2023 lockout. He subsequently filed an Employment Tribunal claim (Case No. 2303659/2023) in August 2023 for GBP 4,047 unpaid commissions. His resignation triggered a cascade: Phil Coley withdrew sales consultant services on 27 February 2023, and Denise Murphy withdrew HR services on 1 March 2023. All three departures occurred within 6 weeks of the lockout.

Ollie Lydon (Sales Manager) sent formal resignation email from personal Gmail (lydonollie@googlemail.com) at 10:46. Confirmed by HR on 14 Feb. Last day 10 March 2023. Linked to 18 January 2023 lockout. Outstanding wages GBP 7,995.11.

Sales Manager resigns due to ongoing disruptions

ths of that lockout, all verified by Gmail evidence: (a) Ollie Lydon, my sales manager, resigned on 7 February 2023 (20 days after the lockout)

Ollie Lydon's resignation was formally confirmed by Denise Murphy (HR) on 14 February 2023. Her email to Ollie at lydonollie@googlemail.com (his personal Gmail) states: 'I am writing following your resignation with notice from your position within Mastermind Group Ltd to confirm your resignation effective from 10th March 2023.' Ollie had given notice around 7 February 2023 (Denise's email that day: 'It's clear you won't sway his mind to stay'). The resignation was a direct consequence of the 18 January 2023 lockout. Michael's email of 10 April 2023 states: 'my only sales person Ollie resigned specifically due to it'.

Claimant issued written harassment warning on 17 February 2023 stating 'I wil...

Harassment warning to LRP/Vista (police involved)

Michael issued written harassment warning to LRP/Vista: 'I will report you to police.' Despite this warning, TWO further lockouts followed. Defence para 10.7.3/10.11 admits the warning AND subsequent lockouts. Proves mens rea under PHA 1997.

R2/R3 Defence §10.7.3 / §10.11: Admits Claimant threatened police/harassment complaint (17 Feb 2023) AND continued with two further lockouts (27 Apr, 20 May 2023) POST-WARNING (Proves Mens Rea / PHA 1997).

R2/R3 admit harassment warning received 17 Feb 2023 (Defence para 10)

(b) Phil Coley, my sales consultant, withdrew his services on 27 February 2023, citing the cash flow crisis caused by the lockouts and the loss of the sales manager

(c) Denise Murphy, my HR consultant, withdrew her services on 27 February 2023 (the same day as Phil Coley), cascading from the departures

Denise Murphy (HR consultant, The HR Dept) withdrew her services on 27 February 2023. Her email 'Overdue Invoice and withdrawing services' states: 'The introduction with Phil was and would have hugely benefited your company and I must say the manner in which you have dealt with Phil's services has been professionally embarrassing.' On 1 March 2023 she confirmed to Michael: 'Unfortunately, I cannot agree to continue to work with you.' On the same date she told Ollie Lydon (who contacted her about his resignation): 'I am sorry to hear this but I no longer work with Mastermind, I asked Michael to let the team know.' Denise's withdrawal was caused by Phil Coley's withdrawal, which was caused by the revenue collapse from the lockouts.

Phil Coley (sales consultant) withdrew services. Same day: Denise Murphy (HR consultant) withdrew services citing Phil's withdrawal and overdue payments. Both caused by lockout-driven revenue collapse.

Phil Coley (sales consultant/representative engaged to rebuild the sales team after Ollie's departure) withdrew his services on 27 February 2023. His email states: 'At this stage I am withdrawing my services.' He subsequently re-engaged by mid-March 2023 after the cash situation was discussed, but the withdrawal caused critical delay in replacing Ollie and rebuilding the sales function. Phil was introduced to Mastermind by Denise Murphy (HR). His withdrawal was a direct consequence of the business disruption caused by the LRP/Vista lockouts destroying revenue and creating cash flow problems.

Lydon, my sales manager, resigned on 7 February 2023 (20 days after the lockout)

PA/Office Manager resigns - administrative collapse

FIFTH LOCKOUT. LRP/Vista locked Michael out of Unit 205 AFTER the 17 Feb 2023 harassment warning. Proves continuation of course of conduct with knowledge it was unwanted.

Fifth lockout: 27 April 2023 (AFTER harassment warning of 17 Feb 2023)

Fifth unauthorised lockout hinders team rebuilding

My later Schedule F chronology identifies 27 April 2023 and 20 May 2023 as two of the post-warning lockouts

Subtotal (conservative) £12M+ Claim 2: BL-2024-001166; former County Court ref L10CL352 (Lower Rich

My later Schedule F chronology identifies 27 April 2023 and 20 May 2023 as two of the post-warning lockouts

SIXTH LOCKOUT. LRP/Vista locked Michael out of Unit 205 AFTER the harassment warning. Proves 'course of conduct' under PHA 1997 s.1. Defence admits six lockouts without notice (para 10.5.2).

Sixth lockout: 20 May 2023 (AFTER harassment warning)

Sixth unauthorised lockout - forced vacation under duress

(19 Jun), Hagan (20 Jun), Mensano (24 Aug), Byrne (1 Dec), Marshall (13 Dec 2023)

Group grievance letter from 5 staff (Balchikliev, Hagan, Li, Mensano, Raptopoulos) re unpaid wages since March 2023, missing payslips, no P60, no pension, no NI/tax paid. Meeting request refused.

Five staff members have now resigned as direct consequence of lockouts and harassment. Revenue collapses from GBP 624,568 to GBP 140,327 (77% drop).

Five staff members resigned from the business as a direct consequence of the ...

Staff departed in cascade following 18 January 2023 lockout. Gmail-verified dates: Ollie Lydon (Sales Manager) resigned 7 Feb 2023 (last day 10 Mar 2023); Phil Coley (Sales Consultant) withdrew 27 Feb 2023; Denise Murphy (HR Consultant) withdrew 27 Feb-1 Mar 2023; Tommy Hagan (Executive Assistant) resigned 20 Jun 2023 citing unpaid wages; Konstantinos Raptopoulos (Promotion Manager) resigned 19 Jun 2023 (formal resignation letter from personal Gmail). Last working day 30 Jun 2023. Mental health absence from 4 Jul 2023; Dino Mensano (Assistant Promotion Manager) last day 24 Aug 2023 owed GBP 1,600; Michael Byrne (Promotion Manager) walked out 1 Dec 2023 with NO NOTICE (confirmed "no choice" on 5 Dec 2023) ('You made it impossible for me to work. I was left with no choice', has lawyer); David Marshall (Artist Success Manager) resigned 13 Dec 2023 citing 'lack of pay and unworkable conditions'. Revenue collapsed from GBP 624,569 (2022) to GBP 140,327 (2023) to GBP 5,612 (2024).

Forced relocation from Lower Richmond premises completed

New lease agreement signed with Chelsea Harbour Ltd

(d) Konstantinos Raptopoulos, my promotion manager, resigned on 19 June 2023, citing mental health suffered due to circumstances at work and unpaid wages

Konstantinos Raptopoulos (Promotion Manager) sent formal resignation letter from personal Gmail (konstantinosraptopoulos@gmail.com) at 23:09. PDF attachment. Last working day 30 Jun 2023.

(e) Tommy Hagan, my executive assistant, resigned on 20 June 2023 (the same day as Raptopoulos), citing unpaid wages

Tommy Hagan (Executive Assistant) sent formal resignation letter and owed salary calculation from personal Gmail (t.hagano0o0@gmail.com) at 23:42. Two PDF attachments. Owed salary Mar-May 2023.

(f) Dino Mensano, my assistant promotion manager, left on 24 August 2023, owed £1,600 in unpaid wages

Dino Mensano (Assistant Promotion Manager) last day. Email: 'As you know today is my last day and you assured me that I would get my outstanding pay of GBP 1,600 paid by today.' Owed GBP 1,600 + GBP 1,710.66 final pay.

After the alleged forfeiture, Michael retained his key to the Chelsea Harbour premises. Chelsea Harbour took only a spare key. His signage remained on the doors for months. Even two weeks after the new tenant (Barrington Marketing Limited) moved in, his signage was still displayed and his office was still padlocked. Peaceable re-entry requires unequivocal resumption of possession. That did not happen.

Mr Mingtao Wang issued possession claim against Michael Eastwood at Wandsworth County Court for alleged rent arrears

Chelsea Harbour sent over ten 'Dear Tenant' emails from December 2023 through June 2025 to Michael, including maintenance notifications, PEEPs (Personal Emergency Evacuation Plans), meter reading access, and mail collection arrangements. Multiple communications referred to 'your office'. Chelsea Harbour even offered to waive the arrears in exchange for early determination of the lease. Each of these acts is an unequivocal recognition that the tenancy continued to subsist. Waiver by election is irrevocable once the landlord performs such an act with knowledge of the breach (Matthews v Smallwood [1910] 1 Ch 777).

Michael Byrne (Promotion Manager) walked out with NO NOTICE. Email: 'Due to the financial difficulty Mastermind finds itself in I am declining your offer of employment beyond my probation period.' On 5 Dec: 'You made it impossible for me to work. I was left with no choice.'

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

(g) Michael Byrne, a promotion manager, left on 5 December 2023 with no notice: "You made it impossible for me to work at Mastermind

On 10 December 2023, Chelsea Harbour Limited ('R1') padlocked my commercial premises at Chelsea Harbour, London SW10, w

Padlocking of Chelsea Harbour premises by landlord

entry admitted (KB WS para 10; CHE WS para 8): Chelsea Harbour admits it re-entered the Premises on 11 December 2023

" (h) David Marshall, my artist success manager, resigned on 13 December 2023, citing "lack of pay of my wages and other unworkable conditions

David Marshall (Artist Success Manager) resigned. Email subject 'Notice': 'Due to lack of pay of my wages and other unworkable conditions. I would like to notify you of my intention to leave. Working for you has seriously affected my mental health.'

) 7 August 2024 BL-2024-001089 "re-entered the Premises by changing the locks " Yes Silvia WhatsApp 19 December 2023 N/A "We padlocked but did not change the lock" No (contemporaneous) HHJ Kelly trans...

In a WhatsApp message on 19 December 2023, Silvia (Chelsea Harbour) stated: "We padlocked but did not change the lock

WhatsApp message from Silvia confirms premises were 'padlocked but did not change the lock.' Directly contradicts Steven Ross's later witness statement claim of 'changing the locks.' Key evidence of solicitor misconduct.

Business revenue GBP 140,327 (77% collapse from peak). The acceleration phase was destroyed by the lockouts.

Historical revenue 2023: £140,327 (77% collapse after lockouts)

Application filed: Application to Rescind Winding-Up Order. Outcome: REFUSED. Refused by ICC Judge Prentis on 04.12.2024. EA 2010 s.20 failure. No reasonable adjustment assessment. Judge interrupted evidence. Bounce Back Loan raised prejudicially.

Chelsea Harbour started marketing the Applicant's unit while his lease was active

lsea Harbour started marketing and then re-let the unit while the lease dispute remained active

Invalid termination notice sent via email

Harassing demands to vacate during active lease period

On 22 January 2024 I was told that payment of the alleged arrears would unpadlock the office and continue the lease

On 22 January 2024, Chelsea Harbour stated that payment would unpadlock the office and continue the lease

HMRC issues winding-up petition against Mastermind Group Ltd

DWP work coach Dipak requested Work Capability Assessment multiple times over two years (Feb 2024 to Feb 2026). Requests ignored by decision makers. Michael only received LCWRA on 16 February 2026 after starting a NEW claim, bypassing whoever was blocking him on the old one. Cost: 22 months of LCWRA withheld (9,300).

First fit note and UC claim

Michael's first fit note was issued in February 2024. UC claim commenced. Medical evidence of ADHD/ASD provided to DWP from Dr James Woolley, consultant psychiatrist.

Two-year failure to action WCA requests

During those four months, the Applicant sent a legal letter on 4 February 2024 raising the dispute and seeking answers

Legal letter sent to Chelsea Harbour raising dispute about forfeiture. Chelsea Harbour never responded.

uesting reasonable adjustments dated 21 February 2024 (enclosing Dr James Woolley’s letter of 16 February 2024) 9

ADHD accommodations formally requested from Chelsea Harbour

ADHD disclosed to HMRC with Dr Woolley's psychiatric report. On the SAME DAY, HMRC gazetted the winding-up petition. Simultaneous disability disclosure and punitive action.

I sent a medical report from Dr James Woolley, Consultant Psychiatrist

Letter to HMRC requesting reasonable adjustments dated 21 February 2024 (enclosing Dr James Woolley’s letter of 16 February 2024) 9

Prior to the winding-up petition being gazetted , on 21 February 2024, I sent HMRC Debt Manager Mrs S Huntley a detailed letter which: (a) Expressly disclosed my ADHD di

HMRC letter declining request for reasonable adjustments (Mrs S Huntley, Debt Manager, dated 22 February 2024) 6

HMRC refused on 22 February 2024, one day after receiving the medical evidence, without acknowledging the disability

HMRC’s response, sent by Mrs Huntley on 22 February 2024 , one day later, did not acknowledge my disability, did not address the medical evidence, did not e

Mrs Huntley (HMRC) refused engagement with disability-related reasonable adjustment request, one day after ADHD disclosed with Dr Woolley's report.

Mrs Huntley of HMRC refused engagement with the applicant's disability-relate...

On 22 February 2024, Mrs S Huntley of HMRC Enforcement and Insolvency Services refused, without even acknowledging the

tinued to address the Applicant as "Tenant" after the alleged forfeiture

Michael Eastwood emailed Wandsworth County Court at 18:04 on the SAME DAY as the hearing. Email explained: (1) he missed due to ADHD; (2) attached psychiatrist letter from Dr James Woolley; (3) requested adjournment; (4) applied for breathing space. CC'd to wandsworth.breathingspace@justice.gov.uk

Possession hearing at Wandsworth County Court (L0PP3377). Michael missed due to ADHD executive function impairment. Possession order made in absence. No reasonable adjustments. Same-day email at 18:04 explaining ADHD with psychiatrist letter.

Possession hearing took place at Wandsworth County Court. Michael Eastwood did not attend due to ADHD-related executive function impairment causing him to miss the date. Possession order made in his absence.

Court responded: 'You should receive a copy of any order within 5-10 working days after the hearing.'

Court advised that Help with Fees is available via gov.uk website.

Michael Eastwood asked about fees for N244, explaining financial difficulties.

Michael Eastwood asked: 'Does that mean a judgement was issued today in my absence? That form is to set a judgement aside.'

Wandsworth County Court responded by email advising that any request to adjourn should be made by formal N244 application. Directed to gov.uk website for form.

First HMRC winding-up hearing

N244 set-aside application filed at Wandsworth (L0PP3377) with comprehensive medical evidence from Dr Woolley. Application was IGNORED for 623 days (20 months). No acknowledgment, no listing, no determination.

From this date, Wandsworth County Court took no action on the N244 application. No acknowledgment, no listing, no determination, no refusal, no contact whatsoever.

Michael Eastwood filed comprehensive N244 application to set aside possession order. Application included: (1) Detailed covering letter explaining ADHD and depression; (2) Letter from psychiatrist Dr James Woolley; (3) Evidence disputing rent payment claims (4 payments made not 1); (4) Explanation of office landlord dispute causing financial stress; (5) Section 11 reasonable adjustments request. Attachment: 8,568KB PDF file.

Causes of action assigned to Michael personally (pre-dates winding-up by 5 months). Property sold to Barrington Marketing Ltd for GBP 1,100 without itemised list, after cease and desist letter.

Chelsea Harbour Ltd sold property belonging to (a) Michael Darius Eastwood personally (personal items and intellectual property) and (b) Mastermind Group Ltd (company assets) to a competitor, Barrington Marketing Limited, for approximately GBP 1,100. Mastermind Promotion Ltd held the lease but is dormant with zero property rights. Chelsea Harbour had no authority to sell property belonging to the other entities. This is strict liability conversion (Kuwait Airways v Iraqi Airways [2002] 2 AC 883).

Chelsea Harbour sold Michael's property and MGLtd property for GBP 1,100 to Barrington Marketing Limited

The causes of action relating to Mastermind Group Ltd's property were assigned to Michael Darius Eastwood personally in April 2024, five months before the winding-up order of 25 September 2024. Because the assignment pre-dates the liquidation, those causes of action never vested in the liquidator (Re Saunders [1997] Ch 60). Michael retains the right to pursue Mastermind Group Ltd's property damages within BL-2025-000147.

Chelsea Harbour sold Michael's property without providing any itemised list of goods before disposal, in breach of sections 12 and 13 of the Torts (Interference with Goods) Act 1977. The sale occurred AFTER Michael sent a cease and desist letter (8 April 2024) AND filed an unsealed injunction application to prevent the disposal.

Emergency injunction application (N16A) submitted to Wandsworth County Court at 23:26 on 8 April 2024 with Dr Woolley medical evidence. Cease and desist sent to Antony Burns at Chelsea Harbour at 23:44. Despite the injunction application, Chelsea Harbour pushed a new tenant into the premises and unlawfully disposed of Michael's belongings which were not owned by the company on the lease (Mastermind Group Ltd is dormant, not Mastermind Promotion Ltd).

No itemised list provided before sale of property

The sale occurred after the Applicant sent a cease and desist letter (8 April 2024) and filed an unsealed injunction application specifically to prevent the disposal

Unsealed emergency injunction sent 8 April 2024; Chelsea pushed tenant in and sold belongings

Chelsea Harbour did not assert 'peaceable re-entry' until approximately 18 April 2024, four months after the alleged forfeiture. For four months they were silent on the basis for their actions. A legal letter sent 4 February 2024 raising the dispute was never responded to. The delay in asserting peaceable re-entry, combined with the retained key, continued signage, and Dear Tenant emails, means the forfeiture was never unequivocal.

Chelsea Harbour first asserted 'peaceable re-entry' - four months after the alleged forfeiture. They had been silent on the legal basis for their actions.

Critically, Chelsea Harbour did not even assert that the event was a "peaceable re-entry" until 18 April 2024, approximately four months after the alleged forfeiture in December 2023

first clear assertion by Chelsea Harbour that it believed it had enacted peaceable re-entry came on 18 April 2024

ormal assertion by Chelsea Harbour that it believed it had achieved peaceable re-entry only came on 18 April 2024, months after the original padlocking

In the draft Particulars of Claim dated 25 April 2024, served on LRP Ltd and Vista (London) Ltd, I included a comprehensive provision (Section 10) expres

The Particulars of Claim against LRP/Vista, signed with a Statement of Truth on 25 April 2024 and sent to LRP/Vista by email on 26 April 2024 , five months before the winding-up order of 25 Sep

ic communications on 15 January, 23 January, 31 January, 5 March, 10 April, 15 April, 22 April, and 25 April 2024

rovision was expressed in documents verified by Statements of Truth (the Particulars of Claim dated 25 April 2024 and the sealed Amended Particulars of Claim dated 21 August 2024), communicated to and...

” The covering email of 26 April 2024 made this explicit: “even in the event of Mastermind Group Ltd’s liquidation, the struc

Medical report of Dr James Woolley, Consultant Psychiatrist, dated 26 April 2024 (ADHD, medication, impact on functioning) 10

The Particulars of Claim were sent to them on 26 April 2024 and their in-house solicitor, Marco Mandelli , received, reviewed, and responded to them

The assignment took effect on 26 April 2024 , five months before the winding-up order of 25 September 2024

inst LRP/Vista, signed with a Statement of Truth on 25 April 2024 and sent to LRP/Vista by email on 26 April 2024 , five months before the winding-up order of 25 September 2024, expressly provides for...

Second HMRC winding-up hearing

Unlawful sale of claimant's chattels and intellectual property

g (KB WS para 12; CHE WS para 10): Chelsea Harbour admits it re-let the Premises to a competitor on 1 May 2024

N5A Relief from Forfeiture claim initially prepared

5 legal actions against company - ALL caused by lockout revenue collapse, wages STILL OWED

LRP/Vista lockouts caused revenue collapse (GBP 624,568 to GBP 5,612), making it impossible to pay staff. This caused: (1) ET 2213543/2023 Raptopoulos & Ors group claim - outstanding, (2) ET 2303659/2023 Lydon GBP 4,047 - outstanding, (3) ACAS MU102123/23 conciliation, (4) Money claim by Sarah Jelliman 28 May 2024, (5) DAS insurance claim 24/0449672. Staff wages remain unpaid. These unpaid debts are direct consequential losses caused by LRP/Vista harassment and should be included in the quantum against R2/R3.

Employment Tribunal case 2213543/2023: Raptopoulos, Mensano, Hagan, Balchikliev, and others v Mastermind Group Ltd. Group claim for unpaid wages. R21 Judgment issued 3 Jun 2024. Staff wages remain unpaid because the business was destroyed by LRP/Vista lockouts. The unpaid wages are a direct consequential loss caused by the harassment. Includes: Raptopoulos (Sales Manager), Mensano (GBP 1,600), Lydon (GBP 4,047 commissions), Hagan, Balchikliev (Viktor), and others.

Employment Tribunal group claim 2213543/2023 by 5+ staff - wages STILL OWED

The first witness statement (4 June 2024) was filed before the 7 June hearing

-001508) Extracted from the Witness Statement of Steven Ross (solicitor for Chelsea Harbour), dated 4 June 2024, filed in KB-2024-001508 (Injunction proceedings)

Document Date Court What Ross Said Under Oath First Witness Statement (KB) 4 June 2024 KB-2024-001508 "re-entered the Premises by changing the locks " Yes Witness Statement (Chancery) 7

R1 (Chelsea Harbour Ltd) has filed no Defence to BL-2024-001089 after 540+ d

Steven Ross (Harold Benjamin LLP) files KB witness statement containing 2 false statements: (1) 'HHJ Kelly's dismissal was the end' (Kelly actually said 'open to bring substantive claim'); (2) 'relief from forfeiture never reserved' (Kelly said 'losses capable of being reflected in damages'). Also describes re-entry as 'changing the locks' when premises were padlocked.

Steven Ross stated 'HHJ Kelly's dismissal was the end, no further claim permi...

Steven Ross stated 'relief from forfeiture never reserved nor possible' (KB W...

Steven Ross stated re-entry was 'changing the locks' (KB WS para 10, 4 Jun 2024)

Steven Ross witness statement (4 June 2024) admits Chelsea Harbour disposed of Michael's property

Steven Ross's witness statement dated 4 June 2024, prepared for the Kelly hearing on behalf of R1 (Chelsea Harbour Ltd), admits that Chelsea Harbour disposed of the Applicant's property. This admission is the conversion evidence. The property was sold to Barrington Marketing Limited for approximately GBP 1,100 without any itemised list, after Michael sent a cease and desist letter and filed an unsealed injunction application. This is strict liability conversion.

The Steven Ross witness statement (R1, 4 June 2024) admits disposal of the Applicant's property, a strict liability conversion

n, and failure to make reasonable adjustments), the Steven Ross witness statement admissions (dated 4 June 2024, admitting the disposal of the Applicant's personal property and Mastermind Group Ltd's ...

Despite this procedural irregularity, HHJ Kelly determined the application

(b) That full approved transcripts of the hearings before HHJ Kelly (7 June 2024), DDJ Wood (20 December 2024), DM Glover (approximately January 2025), Master Kaye (5-6 February an

At the King's Bench hearing on 7 June 2024, the interim injunction application named "Michael Darius Eastwood (Representing As Mastermind Prom

At the hearing on 7 June 2024, HHJ Kelly asked the Applicant to give a sworn undertaking regarding property in the office before

But the courts' discrimination - beginning at that hearing on 7 June 2024 - denied me the default judgments that would have provided the funds to pay the HMRC debt and preve

CA-2024-001353 is the appeal of the King's Bench hearing of 7 June 2024 - the point at which I say the pattern of discriminatory treatment began (MDE-TRN-001 [OR-260], pp

HHJ Kelly hearing (KB-2024-001508). Transcript proves Ross lied. Kelly's transcript para 50: 'It remains open to the claimants to bring a substantive claim.' Kelly para 47: 'Any actionable losses would be capable of being reflected in damages.' Kelly refused full hearing transcript ('no reason in interest of justice'). Costs GBP 10,000.

Interim injunction hearing in King's Bench (KB-2024-001508)

She then decided whether the full record of that hearing should be produced

Since the Kelly hearing on 7 June 2024, 21 orders have been made which the Applicant contends are void

The 7 June 2024 hearing before HHJ Kelly (KB-2024-001508) is the only instance in which any transcript was provided

The Kelly hearing on 7 June 2024 was an application for interim injunctive relief under American Cyanamid Co v Ethicon Ltd [1975] AC

The appeal CA-2024-001353 was filed on or around 20 June 2024 following the Kelly hearing (7 June 2024, KB-2024-001508)

The root cause - the hearing of 7 June 2024 - is already before this Court

The second track of discrimination began on 7 June 2024 at the hearing before HHJ Kelly in the King's Bench Division

arguments and evidence in the hours or minutes before the hearing (skeleton at 5:10am for Kelly on 7 June 2024; skeleton at 07:32am for Kaye on 6 February 2025; bundle filed 48 minutes before Cohen on...

ed the £10,000 costs order from the King’s Bench interim injunction hearing (HHJ Kelly, 7 June 2024) to apply for a stay of the Chancery proceedings

no reasonable adjustments provided; hearing missed due to disability; set-aside application ignored 7 June 2024 injunction King's Bench Division Interim injunction (stale 20+ months) 283A

ould understand that everything documented in this letter traces back to one event : the hearing on 7 June 2024 before HHJ Kelly in the King's Bench Division

s in BL-2024-001166 (former County Court ref L10CL352); (c) All Insolvency Court hearings in CR-2024-000527; (d) The King's Bench hearing of 7 June 2024; (e) All Court of Appeal hearings in CA-2024-001353

specific misrepresentations contradicted by the approved transcript of HHJ Kelly’s hearing on 7 June 2024, including the incorrect statement that the hearing was “the end of the proceeding...

" The original N161 Appellant's Notice and the King's Bench interim injunction of 7 June 2024 name the Applicant as "Michael Darius Eastwood (Representing As Mastermind Promotion Ltd and Master

30 application seeks to reopen the PTA refusal against HHJ Kelly's interim injunction decision of 7 June 2024; it does not seek to relitigate the substantive Chancery claims (BL-2024-001089, BL-2024-0...

Appellant does not seek to renew the application for permission to appeal the order of HHJ Kelly of 7 June 2024 (KB-2024-001508), which was refused by Lord Justice Dove on 24 March 2026

HHJ Kelly stated at paragraph 31 of her judgment: 'It is not for the court today to make any findings of fact where there are disputes between the parties or for the court to determine complex legal issues.' This confirms the hearing was interim, not a final determination. Yet Lord Justice Dove treated Kelly's conclusions as 'unimpeachable' - final-trial language for an interim hearing.

KB-2024-001508 costs order: £10,000 (HHJ Kelly, 7 Jun 2024)

Kelly paragraph 31: 'not for the court today to make findings of fact'

R2 (Lower Richmond Properties Ltd) and R3 (Vista (London) Ltd) were not parties to the Kelly interim injunction hearing (KB-2024-001508) or to Dove's PTA refusal. They are defendants only in BL-2024-001166, which is an entirely separate claim that was never before Dove. Dove could not have determined BL-2024-001166 because R2/R3 were never before him.

R2/R3 (LRP/Vista) were not parties to the Kelly hearing or Dove's PTA refusal

Skeleton argument emailed at 05:10am on day of KB hearing (7 June 2024)

Skeleton argument for KB-2024-001508 hearing emailed to KB Judges Listing Office at 05:10am and to Steven Ross at Harold Benjamin at 05:13am on the morning of the hearing. Court told him to email it the previous evening. Forced to prepare overnight. Evidence of inequality of arms and denial of reasonable adjustments.

The Court of Appeal should understand that everything documented in this letter traces back to

ember 2023 N/A "We padlocked but did not change the lock" No (contemporaneous) HHJ Kelly transcript 7 June 2024 KB-2024-001508 Para 42: premises were padlocked Court record DC10

he Defendant’s misleading witness statement, identifying six specific contradictions with the 7 June 2024 transcript; Dr Woolley’s letter of 6 November 2024; certificates of service; and k...

iple (2024-2025) Requested NONE Court of Appeal CA-2024-001353 Requested NONE King's Bench Division 7 June 2024 Requested JUDGMENT ONLY (see below) 139

ks to reopen the refusal of permission to appeal against HHJ Kelly's interim injunction decision of 7 June 2024

letter drawing attention to contradictions between the Defendant’s witness statement and the 7 June 2024 transcript (CHE-COR-001 [OR-1165], p

of Lord Justice Dove dated 24 March 2026 refusing permission to appeal the order of HHJ Kelly dated 7 June 2024 is reopened under CPR 52

peal: Urgent Intervention Required Wheeler Misunderstands Void Orders The Origin of This Injustice: 7 June 2024 Request to the Court of Appeal Guide for the Court Consolidated Chronology Glossary of A...

s); Article 5 engaged KB-2024-001508 King's Bench Division Concluded Interim injunction (HHJ Kelly, 7 June 2024)

the Barrington occupation (Chancery Division) CA-2024-001353 Appeal from HHJ Kelly’s order of 7 June 2024 (Court of Appeal) BL-2024-001166 (former County Court ref L10CL352) County Court proceedings arising from void transfer of BL-202...

Third HMRC winding-up hearing

Email: CA-2024-001353 - Appeals Against Interim Injunction Orders – Case Nos:

The appeal CA-2024-001353 was filed on or around 20 June 2024 following the Kelly hearing (7 June 2024, KB-2024-001508)

Email: Re: CA-2024-001353 - Appeals Against Interim Injunction Orders – Case

Corrected N161 applications were submitted on 21 June 2024 (Sana at the Registry)

Email: Urgent Re: CA-2024-001353 - Appeals Against Interim Injunction Orders

Permission to appeal granted for CA-2024-001353 (Chelsea Harbour appeal).

24 , the case lawyer Mr Brodrick stated: “This permission to appeal application was issued on 9 July 2024

The Applicant served the Appellant's Notice and related documents on 14 July 2024

Application filed: Motion for Confidentiality (Medical Records). Outcome: PART_GRANTED. Court noted requirement but deemed order unnecessary.

Motion for Confidentiality (Medical Records)

N244

Claim issued: N5A Relief from Forfeiture

" The substantive claim was subsequently issued (BL-2024-001089, sealed 29 July 2024)

Claim filed: BL-2024-001089. Type: N5A Relief from Forfeiture. Court: High Court (Chancery Division).

N5A Claim Form (BL-2024-001089) issued and sealed by High Court

The Applicant's case in BL-2024-001089 (Amended Particulars of Claim, sealed 29 July 2024) is that: (a) No peaceable re-entry occurred

Ferdinand Steinhuber (S&S Steinhuber GmbH, Austria, turnover EUR 27M, 80 staf...

Ferdinand Steinhuber WS (31 Jul 2024) confirms premises were 'padlocked' not ...

Claim BL-2024-001089 served on Defendant

Claim served: BL-2024-001089.

N5A Claim served on Chelsea Harbour

Service deemed effective under CPR 6.14

Application filed: Defendant Application for Stay of Proceedings. Outcome: GRANTED. Granted by DM Glover on 01.10.2024. Stay on basis of unpaid KB costs order (10,000). The ONLY sealed Defendant application in the High Court.

Application filed: EX107 Transcript Request: HHJ Kelly (07.06.2024) — Full Hearing. Outcome: REFUSED. HHJ Kelly refused full hearing transcript: 'no reason in the interest of justice for a transcript of the proceedings to be produced' (08.08.2024). Judgment-only transcript later approved and provided (revised by judge before release). Full hearing transcript would have shown Ross's false statements in real time.

Chelsea Harbour files Stay/Strike-out application

Defendant Application for Stay of Proceedings

EX107 Transcript Request: HHJ Kelly (07.06.2024) — Full Hearing

Fourth HMRC winding-up hearing

EX107

N244

24 KB-2024-001508 "re-entered the Premises by changing the locks " Yes Witness Statement (Chancery) 7 August 2024 BL-2024-001089 "re-entered the Premises by changing the locks " Yes Silvia WhatsApp 19...

But the second witness statement (7 August 2024) was filed after the hearing at which "padlocked" was established on the court record

Steven Ross files Chelsea Harbour witness statement (BL-2024-001089). Repeats 'changing the locks' lie (para 8) AFTER the HHJ Kelly hearing where 'padlocked' was established from transcript. 4th false statement across 2 courts.

g the appeal bundle because the King's Bench refused the full hearing transcript at public expense (8 August 2024, HHJ Kelly: 'there is no reason in the interest of justice for a transcript')

he Applicant's EX107 application for the full hearing transcript was refused by the King's Bench on 8 August 2024

Claim issued: Part 7 Damages (Harassment / Conversion)

BL-2024-001166 issued in the High Court (LRP/Vista claim). This is the ONLY valid High Court case number for this claim. BL-2024-001166 was subsequently created by a void transfer.

BL-2024-001166 was issued in the High Court on 12 August 2024

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

Claim filed: BL-2024-001166. Type: Part 7 Damages (Harassment / Conversion). Court: County Court at Central London.

On 13 August 2024, the very next day , Master Clark transferred the claim to the County Court at C

The proceedings against LRP/Vista were filed in the High Court as BL-2024-001166 on 12 August 2024

Master Clark void pre-service transfer. BL-2024-001166 transferred from High Court to County Court ONE DAY after issue, BEFORE service effected. Void per Fourie v Le Roux [2007] UKHL 1. Root of BL-2024-001166 nullity chain. All subsequent County Court acts void per MacFoy.

Case transferred: Pre-service Void

(7) An order quashing the transfer orders of 13 August 2024 (Master Clark) and 3 September 2024 (DM Dovar) in respect of BL-2024-001166 as jurisdictional and d

-ORD-012 DJ Mauger arrest warrant (19 November 2025) MDE-16 JR-ORD-013 Master Clark transfer order (13 August 2024) MDE-17 JR-ORD-014 DM Dovar second transfer order (3 September 2024) MDE-18 JR-ORD-01...

166, formerly BL-2024-001166 (former County Court ref L10CL352)) was transferred to the County Court by a void transfer order (Master Clark, 13 August 2024, made 17 days before service, in breach of Fourie v Le Roux [2007] UKHL 1)

BL-2024-001166 (High Court claim BL-2024-001166) was transferred to the County Court on 13.08.2024 before service was effected (service occurred on 30.08.2024). A court email dated 28.08.2024 confirmed 'service has not yet been effected', evidencing that the transfer was ultra vires – under Fourie v Le Roux [2007] UKHL 1 such an act is void ab initio.

Case transferred: BL-2024-001166. 13.08.2024 (Pre-service Void)

Classification: JURISDICTIONAL VOID. Defects: Fourie Pre-service; No Reasons. The root of the BL-2024-001166 nullity chain. All subsequent County Court acts are void per MacFoy.

It was transferred to the County Court at Central London by Master Clark on 13 August 2024 (one day after issue, before service on the Defendants) and assigned case number BL-2024-001166 (former County Court ref L10CL352)

It was transferred to the County Court by Master Clark (13 August 2024) and sealed as BL-2024-001166 (former County Court ref L10CL352)

Master Clark First Transfer Order (13.08.2024)

Master Clark transferred BL-2024-001166 on 13 August 2024 — ONE DAY after iss...

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

Master Clark void pre-service transfer: BL-2024-001166 transferred to County Court before service (13 Aug 2024)

Master Clark's pre-service transfer of BL-2024-001166 to the County Court (13 August 2024, one day after issue, before service) and Deputy Master Dovar's re-transfer and resealing under CPR

On 13 August 2024, the very next day , Master Clark transferred the claim to the County Court at Central London witho

Order: Master Clark First Transfer Order (13.08.2024). JURISDICTIONAL VOID. The root of the BL-2024-001166 nullity chain. All subsequent County Court acts are void per MacFoy.

The Applicant also contends that the transfer order of Master Clark (13 August 2024, BL-2024-001166 (former County Court ref L10CL352)) is a jurisdictional void, having been made 17 days before service on the Defendants was

The following day, 13 August 2024, Master Clark transferred the case to the County Court

When BL-2024-001166 was transferred on 13 August 2024, the Applicant's witness statements were likely never placed before the judge

When Master Clark transferred BL-2024-001166 to the County Court (13 Aug 2024), the party name was split. The accepted High Court designation was 'Michael Darius Eastwood (Representing As Mastermind Promotion Ltd and Mastermind Group Ltd)' (single claimant, sole trader format, accepted by Master Kaye, King's Bench, and Court of Appeal). After transfer, BL-2024-001166 listed it as two separate parties: 'Michael Eastwood (Representing As)' as first claimant (absurd and prejudicial) and 'Mastermind Group Ltd' as second claimant. This split enabled the defendants to strike out the second claimant through the DDJ Wood sealed order (06.01.2025, MHCM Day 9) as an unpronounced fabricated term.

his pattern of inconsistent party treatment, from Clark's original name split on the void transfer (13 August 2024) through to Dove's reduction to "Eastwood," demonstrates that the Applicant's party d...

Application filed: Application to Set Aside Transfer Order (Jurisdiction Challenge). Outcome: DELETED_FROM_CE_FILE. Application and supporting evidence DELETED from CE-File system by court staff (a CE-File administrator). Applicant then told he could not appeal in the High Court and had to go to the County Court. But County Court has no jurisdiction because transfer was void (Fourie pre-service).

Application to Set Aside Transfer Order (Jurisdiction Challenge)

N244

(e) The Claimant's set-aside application filed via CE-File on 16 August 2024 was deleted from the system

(vi) 16 substantive emails (sent to multiple court email addresses) ignored: The Claimant was not

Set-aside application filed challenging jurisdictional transfer defect

Defence deadline for R1 (Chelsea Harbour Ltd) in BL-2024-001089. No Defence filed. Chelsea remains in default 540+ days as of March 2026.

Defence deadline: BL-2024-001089

DEADLINE: Defence due for BL-2024-001089. NO DEFENCE FILED.

Defence due date (BL-2024-001089)

First, it proves that the claim had not been served as at 20 August 2024, seven days after Master Clark's transfer order

On 20 August 2024 , one week after the purported transfer, I made a request under CPR 17

Assignment of causes of action from company to Michael personally in sealed Amended Particulars of Claim. Assignment was BEFORE winding-up order (25 Sep 2024). BL-2025-000147 is personal claim arising from this assignment.

Causes of action assigned from company to Michael personally on 21 August 202...

articulars of Claim in the issued proceedings (BL-2024-001166), signed with a Statement of Truth on 21 August 2024 , which at §10

the pre-winding-up equitable assignment provision in the sealed Amended Particulars of Claim dated 21 August 2024

uth (the Particulars of Claim dated 25 April 2024 and the sealed Amended Particulars of Claim dated 21 August 2024), communicated to and received by the intended obligor (LRP/Vista, via their in-house...

On 22 August 2024 , directions for that set-aside application were communicated by a CE-File administrator , a court offic

Court officer a CE-File administrator contacts Defendants unilaterally

Email: Automatic reply: Courtesy Copy: Sealed N244 Application – Claim No: BL

Application filed: Application to Strike Out Defendant's Stay Application. Outcome: DISMISSED. Dismissed 06.02.2025 (MHCM Day 40).

Application to Strike Out Defendant's Stay Application

N244

Court confirms to Defendants that service had not yet occurred

Court email confirms 'service has not yet been effected' on BL-2024-001166 -- 15 days AFTER Master Clark's transfer. Conclusive proof that the transfer was pre-service and therefore void.

Court email dated 28 August 2024 confirmed 'service has not yet been effected' — 15 days AFTER the transfer. Proves transfer was pre-service void.

The court itself confirmed in an email dated 28 August 2024: "service has not yet been effected" - proving the transfer was made without jurisdiction

Application filed: Application for Costs to be Reserved/Deferred. Outcome: DISMISSED_TWM. Certified Totally Without Merit on 06.02.2025 (MHCM Day 40) despite valid argument.

Application for Costs to be Reserved/Deferred

N244

Claim BL-2024-001166 served on Defendant

4 was 27 September 2024 (28 days from service on 30 August 2024)

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

Claim served: BL-2024-001166.

Service of BL-2024-001166 effected on defendants. This is AFTER the void 13 Aug 2024 transfer order, confirming the transfer was pre-service.

Service was not effected until 30 August 2024, seventeen days after the transfer

The claim was served on the Defendants on 30 August 2024

HHJ Kelly approved judgment-only transcript at public expense after 2 months of loops. Refused full hearing transcript: 'no reason in interest of justice.' Judgment was revised by judge before release. Full hearing would have exposed Ross's false statements.

HHJ Kelly refused full hearing transcript: 'no reason in interest of justice'

Deputy Master Dovar makes second transfer order (BL-2024-001166). Derivative nullity: founded on void first transfer. Pre-service solicitation.

(7) An order quashing the transfer orders of 13 August 2024 (Master Clark) and 3 September 2024 (DM Dovar) in respect of BL-2024-001166 as jurisdictional and derivative voids

-013 Master Clark transfer order (13 August 2024) MDE-17 JR-ORD-014 DM Dovar second transfer order (3 September 2024) MDE-18 JR-ORD-015 Recorder Cohen KC summary judgment (19 August 2025) MDE-19 JR-DO...

A second transfer by DM Dovar (3 September 2024) is a derivative nullity

Classification: DERIVATIVE NULLITY. Defects: Founded on Void First Transfer; Pre-service Solicitation. Derivative of void first transfer. Pre-service solicitation.

Court's own re-transfer under CPR 17.1(1) proves first transfer was never lawful

Deputy Master Dovar Second Transfer Order (03.09.2024)

Deputy Master Dovar email containing damaging admissions

Deputy Master Dovar re-transferred and resealed BL-2024-001166 in the County Court under CPR 17.1(1) on 3 September 2024. If the first transfer by Master Clark (13 August 2024) had been valid, no second transfer and resealing would have been necessary. The court's own action is evidence that the first transfer was never lawfully effective. The second transfer is a derivative nullity (MacFoy).

If the first transfer had been valid, no second transfer and resealing would have been necessary

In her decision of 3 September 2024 , Deputy Master Dovar noted that the “Defendants have no notice of any claim” as a fact

The court's own need to re-transfer and reseal proves the first transfer was never lawfully effec

The second transfer by Deputy Master Dovar (3 September 2024) is a derivative nullity of that first void transfer

The second transfer is a derivative nullity: it was founded on the first void transfer

will be struck off”; • The circular reasoning in Deputy Master Dovar’s decision of 3 September 2024, which relied on the Defendants’ lack of knowledge of the claim to justify th...

Application filed: N227 Default Judgment Request (Chelsea Harbour). Outcome: IGNORED. Never processed by court. Mandatory ministerial duty under CPR 12.3(1) breached. 540+ days unprocessed.

Application filed: N244 Application for Default Judgment / Summary Judgment. Outcome: STAYED. Adjourned en bloc at DM Glover hearing 18.09.2024. Never relisted for substantive hearing. 9+ months judicial inaction.

N227 Default Judgment Request (Chelsea Harbour)

N227 default judgment request filed in BL-2024-001089 against Chelsea Harbour (R1). As of March 2026, remains unaddressed (540+ days with no court action). CPR 12.3 mandates entry as ministerial function.

N244 Application for Default Judgment / Summary Judgment

A second transfer order was made on 4 September 2024, again without a hearing

N227

N244

Classification: DERIVATIVE NULLITY. Defects: Validation of Void Act: Sealed claim form in High Court *after* purported transfer to County Court; Proves Court did not recognise the 13.08.24 transfer as valid. Evidence of conflicting jurisdiction.

First N227 default judgment request filed 4 Sep 2024 - never determined

N227 default judgment request was filed on 04.09.2024 in BL-2024-001089, but as of March 2026 it remains unaddressed (540+ days with no court action).

N244 Application No.1 filed - Default or Summary Judgment

Order: Unknown (Sealing Officer) Sealing of Claim Form (Post-Transfer) (04.09.2024). DERIVATIVE NULLITY. Evidence of conflicting jurisdiction.

ions” until determination of the Stay Application, which encompassed my N227 request filed on 4 September 2024, thereby converting a request-based route under CPR 12

The Applicant requested multiple extensions (1 August, 8 August, 16 August, 28 August, 6 September 2024), explaining the transcript delay and his ADHD difficulties

Email: Courtesy Copy: Default Judgment or, alternatively, Summary Judgment -

At the hearing before Deputy Master Glover on 18 September 2024 (the 1 October 2024 order), the Applicant raised the question of default judgment

Directions hearing before Deputy Master Glover (BL-2024-001089)

Hearing: Deputy Master Glover Directions Order (01.10.2024)

Hearing: Directions Order before Deputy Master Glover. Order sealed 1 October 2024.

On 18 September 2024 , Deputy Master Glover at the directions hearing in BL-2024-001089 described the hearing as “

On 3 October 2024, following the 18 September 2024 Glover directions hearing in the Chancery Division, the Applicant wrote to CMSA raising concerns ab

Second , Deputy Master Glover’s order dated 1 October 2024 (for the hearing on 18 September 2024) at paragraph 14 adjourned “the remainder of the Claimants’ Applications” until...

The sealed order, dated 1 October 2024, contained terms not discussed or pronounced at the hearing

The transcripts of the 18 September 2024 hearing, which would establish whether the “adjourn all” clause in paragraph 14 of Depu

about the Court of Appeal to my formal complaint); • The refusal to provide transcripts of the 18 September 2024 hearing, which would establish whether the “adjourn all applications” ...

ntion I am unable to verify because the Chancery Division has refused to provide transcripts of the 18 September 2024 hearing

Deputy Master Glover at the 18 September 2024 BL-2024-001089 hearing proposed forcing a name change or claim split on the party designation. Michael wrote to Master Kaye on 20 September 2024: 'Deputy Master Glover has granted me one week to respond regarding a proposed name change or to split the claim.' This was an unpronounced fabricated term in Glover's directions order, threatened under strike-out. The party name had been accepted by Master Kaye, King's Bench, and the Court of Appeal.

The sealed order of 1 October 2024 contains directions that were not the subject of submissions or

Mrs Khanom granted extensions and the Applicant filed the transcript of judgment on 19 September 2024

ICC Judge Greenwood makes winding-up order (CR-2024-000527). Made without evidence properly before court. Applicant mentioned JR of another judge during hearing. First victimisation. EA 2010 failure (no RA assessment).

Classification: VOID (Natural Justice + EA 2010 + Jurisdiction). Defects: EA 2010 s.20: No reasonable adjustments made. Claimant denied ability to submit evidence due to disa; EA 2010 s.27: Victimisation. Claimant mentioned formal complaint and JR before order made. Adverse r; Natural Justice (Ridge v Baldwin [1964] AC 40): Claimant denied right to present evidence. Decision ; SI 2014/817 Sch 1: Wrong court for corporate insolvency (requires London High Court); Made without evidence: judge ruled without hearing Claimant's case. Reclassified from VOIDABLE to VOID on 24.03.2026. First victimisation event. Claimant told judge about formal complaint and JR. Judge did not provide reasonable adjustments for ADHD/ASD to submit evid

FIFTH AND FINAL winding-up hearing - Order made liquidating MGL

On 25 September 2024 , the matter came before ICC Judge Greenwood for the winding-up hearing

(e) Declaration that the winding-up order of ICC Judge Greenwood (25 September 2024, CR-2024-000527) is void for: denial of the right to present evidence ( Ridge v Baldwin [1964] AC 4

7 The Present Position: The Insolvency Service (January 20

HMRC’s refusal of reasonable adjustments was the proximate ca

ICC Judge Greenwood Winding-Up Order (25.09.2024)

ICC Judge Greenwood made the winding-up order on 25

Order: ICC Judge Greenwood Winding-Up Order (25.09.2024). VOID (Natural Justice + EA 2010 + Jurisdiction). Reclassified from VOIDABLE to VOID on 24.03.2026. First victimisation event. Claimant told judge about formal complaint and JR. Judge did not provide reasonable adjustments for ADHD/ASD to submit evidence. Ruled against Claimant without hearing his case. 5 independent grounds for voidness: (1) EA 2010 s.20 failure to adjust; (2) EA 2010 s.27 victimisation; (3) Natural justice (Ridge v Baldwin); (4) SI 2014/817 wrong court; (5) No evidence heard. The arrest warrant, public examination, and all subsequent insolvency acts flow from this void order.

PE transferred to CLCC (void); arrest warrant outstanding (void) KB-2024-001508 King's Bench Divis

The Greenwood winding-up order (25 September 2024, ICC Judge Greenwood) is void on Equality Act and natural justice grounds, with strong grounds for

The assignment took effect on 26 April 2024 , five months before the winding-up order of 25 September 2024

Winding-up order dated 25 September 2024 (CR-2024-000527, Mastermind Group Ltd) 8

l 2024 and sent to LRP/Vista by email on 26 April 2024 , five months before the winding-up order of 25 September 2024, expressly provides for the assignment of the company’s business-related cau...

were assigned to the Applicant personally in April 2024, five months before the winding-up order of 25 September 2024

Application filed: Defendant Application for Extension of Time for Defence. Outcome: GRANTED_IMPLICITLY. DDJ Wood order of 06.01.2025 implicitly validated the late Defence. No sealed extension order exists. Defence filed 27 days late on 26.10.2024.

Defendant Application for Extension of Time for Defence

On 26 September 2024 , Chief Master Shuman responded to my complaint about the 18 September hearing via a court clerk, cl

of reasonable adjustments as “a significantly longer hearing” and “pauses” (26 September 2024), which bears no resemblance to the evidence-based clinical recommendations subseq...

APPLICATION_UNSEALED

On 26 September 2024, Shoosmiths emailed the court: "please see attached copy of our Application Notice and Draft order

The core bundle was uploaded on 26 September 2024 (file size exceeded 50MB, causing technical difficulty)

Defence deadline: BL-2024-001166

CRITICAL DATE: Defence deadline passes - NO DEFENCE FILED (BL-2024-001166)

DEADLINE: Defence due for BL-2024-001166.

Defence deadline for R2/R3 (LRP/Vista) in BL-2024-001166. Defence NOT filed by this date. Deadline missed by 27 days.

I filed a Request for Default Judgment (N227) on 30 September 2

eight because: (a) The R2/R3 Defence was filed 27 days late (24 October 2024, against a deadline of 27 September 2024) without any application for relief from sanctions under Denton v TH White Ltd [20...

ourt case number derived from the void transfer of BL-2024-001166)

xtracted from the Defence filed 24 October 2024, 27 days late (the deadline under CPR Part 15 being 27 September 2024)

Application filed: N227 Default Judgment Request (LRP/Vista, County Court ref). Outcome: IGNORED. Never processed. Filed 3 days after defence deadline expired (27.09.2024). Court had mandatory duty under CPR 12.3(1).

N227 Default Judgment Request (LRP/Vista, County Court ref)

N227 Default Judgment Request (duplicate filing, temporary ref)

N227

I filed a Request for Default Judgment (N227) on 30 September 2024 and sent 22 follow-up emails to the Court between 1 and 24 October 2024 chasing its status

N227 Request for Default Judgment filed with court

N227 default judgment request was filed on 30.09.2024 in BL-2024-001166, but as of March 2026 it remains unaddressed (510+ days with no court action).

On 30 September 2024 , I wrote to a court clerk requesting that the N227 default judgment application be processed

Second N227 default judgment request filed 30 Sep 2024 - never determined

Deputy Master Glover directions order (BL-2024-001089). Contains unpronounced terms: provisions 'never discussed in court,' bundle ban imposed without argument. CPR 40.12 variance. Voidable.

At the hearing before Deputy Master Glover on 18 September 2024 (the 1 October 2024 order), the Applicant raised the question of default judgment

Order sealed from 18 Sep hearing - PARAGRAPH 11 BUNDLE BAN

Second , Deputy Master Glover’s order dated 1 October 2024 (for the hearing on 18 September 2024) at paragraph 14 adjourned “the remainder of the Claima

The hearing before Deputy Master Glover took place on 18 September 2024

The sealed order of 1 October 2024 contains directions that were not the subject of submissions or argument at the hearing

The sealed order, dated 1 October 2024, contained terms not discussed or pronounced at the hearing, including directions that were never t

ng in the Chancery Division, the Applicant wrote to CMSA raising concerns about the order sealed on 1 October 2024, which contained fabricated terms not pronounced at the hearing, and requesting an em...

(b) DM Glover (1 October 2024): The sealed order contains provisions 'never discussed in court,' including a restriction making t

(d) Declarations that the directions order of DM Glover (sealed 1 October 2024) is void for breach of natural justice ( Ridge v Baldwin ), fabricated terms ( CPR 40

, the fabrication of order terms is independently a ground for setting aside

Classification: VOID. Defects: 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, K; Failure to Make Reasonable Adjustments (EA 2010 s.20): 3 requests denied (present case first, schedu; Undisclosed Material (natural justice, Ridge v Baldwin [1964] AC 40): facts not disclosed inside hea. Reclassified from VOIDABLE to VOID on 4 independent grounds: (1) CPR 40.12 fabricated terms (sealed order does not reflect judicial act); (2) CPR 23.1 no application for interim stay or bundle ban; (3

DM Glover sealed order (1 Oct 2024): contains provisions 'never discussed in ...

Deputy Master Glover Directions Order (01.10.2024)

For the DM Glover order (1 October 2024), which is void for breach of natural justice, CPR 40

On 1 October 2024 , Master Kaye responded (via Jules): “The request for default judgment was therefore unnecess

Order: Deputy Master Glover Directions Order (01.10.2024). VOID. Reclassified from VOIDABLE to VOID on 4 independent grounds: (1) CPR 40.12 fabricated terms (sealed order does not reflect judicial act); (2) CPR 23.1 no application for interim stay or bundle ban; (3) EA 2010 s.20 failure to make reasonable adjustments (3 denied at hearing); (4) Natural justice breach (Ridge v Baldwin) - facts not disclosed inside hearing. Updated 24.03.2026.

Secondly, the earlier sealed order of 1 October 2024 contained an unpronounced bundle restriction that prevented me from filing my own evidence while al

The Chilling Effect Part VI: Fabricated Order Terms DDJ Wood: 6 January 2025 Deputy Master Glover: 1 October 2024 Part VII: Defence Admissions Six Admitted Lockouts No Reasonable Adjustments Foreseeab...

The DM Glover sealed order (1 October 2024) contains a bundle restriction and adjournment of all applications that were not pronounced at the

The same procedural landscape included the sealed 1 October 2024 order containing an unpronounced restriction preventing the Applicant from filing his own bundle, w

e” ; • The wrongful treatment of the N227 / Part 12 request as something to be deferred (1 October 2024), with Master Kaye (via Jules) declaring the request “unnecessary” and cl...

Email: Urgent Submission – (COMBINED) - N227 Request for Default Judgment and

On 3 October 2024, following the 18 September 2024 Glover directions hearing in the Chancery Division, the Applicant

munications about the "A v B" anonymisation of my case; (d) Communications about the sealing of the 3 October 2024 order; (e) All personal data held relating to me and these proceedings

Claim issued: Appeal (Refusal of Interim Injunction)

Claim filed: CA-2024-001353. Type: Appeal (Refusal of Interim Injunction). Court: Court of Appeal (Civil Division).

On 7 October 2024, the case was transferred to CMSB (Manpreet Singh) and Master Bancroft-Rimmer assumed responsibilit

At the rescission hearing on 10 October 2024 before ICC Judge Prentis (order sealed 4 December 2024), I attempted to present evidence of the com

for the rescission application (the order having been sealed on that date following the hearing on 10 October 2024)

On 14 October 2024, a court clerk sent the Applicant a PDF entitled "Information for people with disabilities visiting

In my letter to Master Kaye of 15 October 2024 , I wrote: “I respectfully submit that my status as a litigant in person should not result in

On 22 October 2024 , Master Kaye sent a detailed letter (relayed via her clerk, a court clerk) in which she engaged con

Email: Fwd: CR-2024-000527 - Rescission and Stay of Winding-Up Order

” (HMRC-RPT-001 [Enc-11]) On 23 October 2024, ICC Judge Barber heard the initial application (with Benedict Evans of counsel instructed via the

Admission: Lower Richmond Properties Ltd / Vista (London) Ltd

Defence filed (27 days late): BL-2024-001166

1 of the Defence (signed by Zulfikar Virani, director, under Statement of Truth, 24 October 2024): "The only duty which the Defendants owed the Claimant was a duty not to harass him, within the me

2) Lower Richmond Properties Ltd (R2) Vista (London) Ltd (R3) Regularisation disputed Defence filed 24 October 2024 sealed extension to 25 October 2024 £5M+ Harassment (PHA 1997) EA 2010 discrim...

2025-000147 remains subject to a sealed stay on the file; and BL-2024-001166 has a Defence filed on 24 October 2024 with time extended to 25 October 2024, whose validity and effect are disputed

3 Admissions (Lower Richmond Properties Ltd / Vista (London) Ltd): Extracted from the Defence filed 24 October 2024, 27 days late (the deadline under CPR Part 15 being 27 September 2024)

4 Sealed order recorded extension to 25 October 2024 and Defence filed on 24 October 2024; Applicant disputes the validity and effect of that regularisation DDJ Wood Jan 2025 4 CPR 40

4 was 27 September 2024 (28 days from service on 30 August 2024)

Admission by Lower Richmond Properties Ltd / Vista (London) Ltd: "It is admitted that adjustments were not made for him.". Legal effect: Breach of Equality Act 2010 s.20 & s.29 (Strict Liability).

Defence filed 24 October 2024; sealed extension to 25 October 2024 181

Defence filed: BL-2024-001166. 24.10.2024 (27 days late)

Further or alternatively, even if that filing were treated as relevant, it was filed on 24 October 2024, twenty-seven days after the CPR 15

In BL-2024-001166 (formerly BL-2024-001166 (former County Court ref L10CL352)), the Defence was filed on 24 October 2024 and the sealed record states that time for filing was extended to 25 October 2024

In BL-2024-001166; former County Court ref L10CL352, the Defence was filed 27 days late on 24 October 2024 (Shoosmiths, 12:41 email timestamp)

LRP-PAY-002 22 July 2022 mid-month agreement Part 3: Promissory estoppel LRP-DEF-001 Defence filed 24 October 2024 (27 days late) Parts 3, 14, 18: Late defence, admissions LRP-TERM-001 Invalid termina...

LRP/Vista Defence Admissions (BL-2024-001166) Extracted from the Defence filed 24 October 2024, 27 days late , by Shoosmiths LLP (instructed by Stephanie Tozer KC, Falcon Chambers)

R2/R3 (LRP/Vista) Defence filed 24 October 2024 at 12:41 (Shoosmiths email timestamp verified). Deadline was 27 September 2024. 27 days late. No CPR 3.9 relief.

R2/R3 (LRP/Vista) Defence filed 27 DAYS LATE at 12:41 (Shoosmiths email timestamp verified). No CPR 3.9 relief from sanctions application. No Denton analysis. Procedural nullity. Defence contains admissions conceding liability: six lockouts (10.5.2), no adjustments (17.4), post-warning lockouts (10.7.3), postpartum exclusion (10.7.2), causation of disruption (20.3).

R2/R3 (LRP/Vista) Defence filed 27 days late (24 Oct 2024, 12:41, Shoosmiths)

R2/R3 (LRP/Vista) filed a Defence on 24 October 2024 (27 days late, in the wrong court under the invalid County Court case number BL-2024-001166 (former County Court ref L10CL352), without CPR

R2/R3 Defence filed in wrong court (invalid BL-2024-001166 (former County Court ref L10CL352) case number)

RP/Vista Defence (signed by Zulfikar Virani, director of both Defendants, under Statement of Truth, 24 October 2024) makes admissions that substantially support the core liability case

The R2/R3 Defence was filed on 24 October 2024 under case number BL-2024-001166 (former County Court ref L10CL352) in the County Court at Central London. BL-2024-001166 (former County Court ref L10CL352) is an invalid case number derived from the void transfer of BL-2024-001166. The Defence was therefore filed in the wrong court, in addition to being 27 days late with no CPR 3.9 relief or Denton analysis.

The sealed record shows a Defence filed on 24 October 2024 with time extended to 25 October 2024, but the Claimant says the later DDJ Wood order of 6 January

UNAUTHORIZED Defence filed 27 days beyond deadline

admissions have additional procedural weight because: (a) The R2/R3 Defence was filed 27 days late (24 October 2024, against a deadline of 27 September 2024) without any application for relief from sa...

ds first on variation or set-aside), and BL-2024-001166 (the sealed record shows a Defence filed on 24 October 2024 with time extended to 25 October 2024, whose validity and effect I dispute, includin...

e sealed record in BL-2024-001166 now shows time extended to 25 October 2024 and a Defence filed on 24 October 2024

efault Judgment (N227) on 30 September 2024 and sent 22 follow-up emails to the Court between 1 and 24 October 2024 chasing its status

filing a Defence to 4pm on 25 October 2024, thereby retrospectively validating the Defence filed on 24 October 2024 (one day before the new deadline, but 27 days after the original deadline); (b) Dism...

he 0/12 reasonable adjustment refusal record, the R2/R3 Defence admissions in BL-2024-001166 (filed 24 October 2024, admitting the lockouts, business disruption, and failure to make reasonable adjustm...

usiness List where it was validly issued; (iii) determine whether the Defence filed 27 days late on 24 October 2024, in the wrong court (under the invalid County Court case number BL-2024-001166 (former County Court ref L10CL352)), without a...

ys was used to regularise the BL-2024-001166 (former County Court ref L10CL352) Defence position; the sealed record shows a Defence filed on 24 October 2024 with an extension to 25 October 2024, whose validity and effect the Applicant disput...

) Vista (London) Ltd (R3) Regularisation disputed Defence filed 24 October 2024 sealed extension to 25 October 2024 £5M+ Harassment (PHA 1997) EA 2010 discrimination 6 lockouts Lease in substanc...

2 Defence position; the sealed record shows a Defence filed on 24 October 2024 with an extension to 25 October 2024, whose validity and effect the Applicant disputes; the Master Kaye s

4 Sealed order recorded extension to 25 October 2024 and Defence filed on 24 October 2024; Applicant disputes the validity and effect of that regularisa

Defence filed 24 October 2024; sealed extension to 25 October 2024 181

On 25 October 2024, I entered a Standard Breathing Space moratorium (60 days, ending 23 December 2024)

The sealed record now shows a Defence filed on 24 October 2024 and an extension of time to 25 October 2024

The sealed record references an extension to 25 October 2024, but the Applicant never received a sealed extension order, no Denton v TH White Ltd [2014] 1 WLR 3

The sealed record shows a Defence filed on 24 October 2024 with time extended to 25 October 2024, but the Claimant says the later DDJ Wood order of 6 January 2025 was itself void and that the resu

The sealed record states that time for filing the Defence was extended to 25 October 2024 and that the Defence was filed on 24 October 2024

These two moratoriums cover the period from 25 October 2024 to 16 April 2025 with only a brief gap (23 to 28 December 2024)

d stay on the file; and BL-2024-001166 has a Defence filed on 24 October 2024 with time extended to 25 October 2024, whose validity and effect are disputed

e sealed order of 6 January 2025 purported to: (a) Extend the period for filing a Defence to 4pm on 25 October 2024, thereby retrospectively validating the Defence filed on 24 October 2024 (one day be...

nd BL-2024-001166 (the sealed record shows a Defence filed on 24 October 2024 with time extended to 25 October 2024, whose validity and effect I dispute, including for the reasons set out in Billingto...

ently filed his N227 default judgment request using the correct case number, the court responded on 30 October 2024: "Please provide a valid claim number as the one you provided is incorrect

Email: Digital Service of Rescission of Winding Up Order and Stay of Executio

On 1 November 2024 , the case lawyer Mr Brodrick stated: “This permission to appeal application was issued on 9

On 1 November 2024, the case lawyer Mr Brodrick directed the Applicant to file an amended supplementary bundle

Statutory demand £13,565 served on Claimant for KB costs

ADHD diagnosed by Dr James Woolley (consultant psychiatrist, 6 Nov 2024)

ADHD formal diagnosis letter issued by Dr James Woolley (consultant psychiatrist). HMCTS Reasonable Adjustments reference 67862925 allocated. Establishes EA 2010 s.6 disability beyond argument.

Claimant was formally diagnosed with Attention Deficit Hyperactivity Disorder (ADHD) on 06.11.2024 by Dr. Jonathan Woolley (Consultant Psychiatrist), establishing a mental health disability under Equality Act 2010 (HMCTS Reasonable Adjustments reference 67862925 issued).

Dr James Woolley is the consultant psychiatrist who diagnosed ADHD (~2014, fo...

Dr Jonathan Woolley ADHD diagnosis letter (Consultant Psychiatrist FRCPsych)

Dr Woolley’s letter of 6 November 2024 recommended, among other measures: breaking complex instructions into smaller steps; providing an o

On 6 November 2024, Dr James Woolley (Consultant Psychiatrist, Schoen Clinic Chelsea) wrote a letter specifically for

entifying six specific contradictions with the 7 June 2024 transcript; Dr Woolley’s letter of 6 November 2024; certificates of service; and key exhibits omitted from the Defendant’s bundle...

on Deficit Hyperactivity Disorder (ADHD) : Consultant Psychiatrist report of Dr James Woolley dated 6 November 2024; and (b) Autism Spectrum Disorder (ASD) : Consultant Psychiatrist report of Dr James...

235 interview on 8 November 2024, written responses on 17 December 2024, a proactive Lloyds Bank enquiry on 20 January 2025, detaile

Following my section 235 interview on 8 November 2024, Mr Wheeler emailed me on 13 November 2024 requesting, among other things: (HMRC-COR-003) “ba

Participated by video call in a formal section 235 interview conducted by the Official Receiver on 8 November 2024 ; (b) Provided a detailed written response with Starling Bank statements on 17 Decemb...

has at no stage refused to cooperate with the insolvency process

ublic authority should treat a disabled citizen who has actively cooperated at every stage : (a) On 8 November 2024 , participated by video call in a formal interview conducted by the Official Receive...

2024-11-12_L10CL352 (Previously BL-2024-001166) - Request for Default Judgment-

Following my section 235 interview on 8 November 2024, Mr Wheeler emailed me on 13 November 2024 requesting, among other things: (HMRC-COR-003) “bank statements for both accounts from 01 Jan

The Applicant complied, uploading via the Document Upload Centre link shared by Mr Singh on 14 November 2024

In her report dated 15 November 2024, Deputy Official Receiver an Insolvency Service officer confirmed that rescission would not adversely impact cred

Official Receiver’s rescission report dated 15 November 2024 (pursuant to section 147 Insolvency Act 1986 ) SCHEDULE OF AUTHORITIES Jurisdiction and Nullity Aut