Solicitor Conduct

"On 11 December 2023 the Defendant re-entered the Premises by changing the locks." FALSE. WhatsApp from Silvia (Chelsea Harbour, 19 Dec 2023): "We padlocked but did not change the lock." HHJ Kelly transcript para 42: premises were padlocked. Investor Ferdinand Steinhuber (WS para 4.2) independently confirms "the padlocking was temporary." Three independent sources contradict Ross.

Identical false claim repeated in a second witness statement in a different court. Ross knew by this date that the transcript said "padlocked." He was at the hearing. He repeated "changing the locks" anyway. Two Statements of Truth. Two potential contempt proceedings.

Ross claims HHJ Kelly held "there was no serious issue to be tried" and that "the dismissal of the application was the end of the proceedings." FALSE. The transcript at para 50: "It remains open to the claimants to bring a substantive claim." Ross's statement is designed to persuade the Chancery Master that the claim has already been adjudicated. It has not.

Made during the hearing itself. The full hearing transcript would show this. HHJ Kelly refused to provide the full transcript. The only transcript released was the judgment, revised by the judge before release. The evidence of this false statement is being actively suppressed.

Four false statements under oath. A 1,336-page misleading bundle. Enforcement of void costs during MHCM. The court has jurisdiction under CPR 46.8 to make a wasted costs order against legal representatives whose improper, unreasonable, or negligent conduct has caused costs to be wasted. Harold Benjamin's conduct satisfies all three limbs.

Filed a 1,336-page bundle for the 6 February 2025 hearing that omitted the Claimant's evidence while burying the court in irrelevant material. The Claimant was banned from filing his own bundle by DM Glover's unpronounced order.

Despite R1's witness admitting conversion (sale of chattels for £1,100) and R1's correspondence demonstrating waiver of forfeiture, Harold Benjamin has made no application under CPR 14.1(5) to withdraw these admissions. The admissions stand as confessions of judgment.

Defence due 27 September 2024. Filed 26 October 2024 (27 days late). No application for relief from sanctions under CPR 3.9. No Denton analysis. The Defence was retrospectively "validated" by DDJ Wood's void order of 6 January 2025.

Extension of time application (26.09.2024) and strike-out/summary judgment application (22.05.2025): neither sealed, neither properly served, neither with certificate of service. Cannot found relief under CPR 23.7 / PD 23A.