Dolmans, Solicitors                                                                                                                                   8CF02269

Cardiff                                                                                                                                             30^th October 2008

Kirk v South Wales Police     5 Court Actions of Police Harassment                                                  7CF07345

Abuse of Process Application

 Dear Sir,

• 1. Further to your 23rd October 2008 letter and His Honour Judge Chambers's Internal Memo, dated a year ago, the situation has not but changed, it has in fact changed for the worse.
• 2. Tomorrow, Friday, the HM Treasury Solicitor will quote from his defences against a judgment 8CF02269, by default, brought against the South Wales Police, 5^th Action, for my false imprisonment on the excuse his myriads were so engrossed in trying to get me certified as a Vexatious Litigant the 6^th Action was ‘overlooked' for 6 months.
• 3. HM Treasury Solicitor Internal Memos, you also have, indicate the legal process to get me certified has been going on now for 7 years without my contribution or even prior knowledge!
• 4. My fifty odd Judicial Review Applications were primarily against your client for trivial motoring matters costing me more to attend than the fines incurred. I suspected the convictions were going to be used against me by the Free Masons in the Royal College of Veterinary Surgeons and your client's motive, when Inspector Collins of Barry Police wrote to the college in January 2001 in order to have my name removed from the register, proved to be correct. The deceit metered out in that debacle is for another court both here and at Strasbourg. see http://www.kirkflyingvet.com/
• 5. Lord Justice Thomas in July 2007 told my barrister, in front of me, not to attend my Application for a Trial By Jury for the 3 Actions of false Imprisonment, CF6141159‐MC65, CF101741, CF204141 excuses ever since being that the transcript is ‘corrupted' and cannot be transcribed. Someone is lying.
• 6. 2 weeks later His Lordship stated in front of me and Mr Patrick Cullinane Esq. that he did not know just who should hear the Abuse of Process Application, discarded the papers as if an empty cigarette packet and proceeded to expedite my denial of a civilian jury against your client, the only purpose for bringing the 10 years of relentless police harassment cases in the first place.
• 7. Your 24^th October 2008 letter again refuses to admit police burgled my veterinary surgery to re instate their police inspector's daughter into my flat, admit there was a magistrates hearing on the 9 month investigation, both sides of the English Channel, into my purported ownership of a Guernsey Registered Veterinary Ambulance, eventually ‘stolen' before your client as bailee or there was any arson on my home.
• 8. Your 24^th October letter goes on to say my requests direct to Barry Police, dated 4th October 2008 and to the Chief Officer, Ms Barbara Wilding, dated 2^nd October 2008, to identify the progress on 39 random samples of police incident numbers, all related to the Actions currently before Sir Nicholas Chamber QC, is wrong. You again prevaricate complaining I should write to you...what utter nonsense. Each incident number was created by your client in a standard covering letter indicating in plain English I was to write to the South Wales Police on the progress of recovery of my stolen goods, apprehension of ‘tipped off' villains in the Barry area for arson, theft, burglary and assault, all ‘modus operandi' mysteriously stopping the very day Inspector Collins had achieved my being ‘struck off' the veterinary register on 29th May 2002.
• 9. My miserable 10 years in Guernsey at least taught me to pick up a law book, albeit Normandy Law, not Code Napoleon, as no advocate was allowed to act for me or allow me legal representation from the UK. I have again looked at the books and it is plain to me the track record of your client during the 10 years of harassment is an exact copy of the conduct of the Guernsey Insular Authority that led me to the Privy Council more times than any other known litigant in the past century. Guernsey harassment was Free Mason motivated.
• 10. Normandy Law and I suspect UK Law on Tort is based on similar principles.

4^th Action 7CF07345, as Amended, will contain, in each incident, once there has been full disclosure by your client:

• 1) The police have a public duty to properly investigate crime
• 2) There has been a breach of that duty
• 3) Maurice Kirk and his family have suffered damage.
• 4) There is evidence of malice. ‘Proximity' argument is exactly why the police continue to refuse to admit they have record of the 100 or so indexed incidents that led to my ignored March 2008 Court Application requesting a Sworn Affidavit by the police that they have the contrary, ‘no such records'.

The amended 1^st, 2^nd, 3^rd, 4^th & 5^th Actions against South Wales Police will have further samples of Misfeasance by the relevant public authorities, already identified in the 16 years of litigation and criminal conduct by certain parties with whom you acquaint.

I again apply to the Cardiff County Court for an adjournment in these proceedings, 7CF07345, as I do for CF6141159‐MC, CF101741, CF204141 & 8CF02269 and again apply to the court on an Application of Abuse of Process and for the Court to Order proper Section 31 Disclosure by the South Wales Police or whatever other appropriate law based on their criminal conduct. 

I, Maurice John Kirk, confirm the content of this my witness statement, supported by 16 years of documentation, most already before the court or under the control of CPS, RCVS and the South Wales Police, is true.

Cc John Smith MP

Kirk v South Wale Police 5 Actions of Harassment                  CF6141159‐MC65

                                                                                                              CF101741, CF204141

                                                                                                             7CF07345, 8CF02269

Statement by Maurice J Kirk                                                                                          29^th September 2008

Defense's argument: 4^th Action, 7CF07345, is partly time barred and with ‘no causes of action'

Plaintiff's Position Statement

Further to my Application for Abuse of Process investigation, in 2007, still unheard, citing the deliberate delays caused by others in my lawful pursuit for damages against the South Wales Police it now has the nerve to state, see Dolmans Statement 24th September 2008, that it is I, the Plaintiff, that has deliberately delayed the outcome of these Actions, currently running into their 16^th year.

Delay has been deliberate by the legal trade as is their usual tactic or ‘modus operandi', to increase costs, to wear down and frustrate the ‘litigant in person' relying on the standard ‘treacle treatment' metered out and aided and abetted by a filthy UK  judicial system driven only by avarice.

 i.e. I am expected to run out of money, run out of steam or simply die, before this case is settled.

Delay has been none of my doing, other than well documented medical problems on one occasion.

 My  finding out today that the tapes of the case have all been destroyed, pre 2005, the very period the HM Attorney General had me investigated, means  I must have and APPLY for FULL DISCLOSURE  of the created documents in that time period, currently in the control of both the Defence and HM Treasury Solicitor. The court tapes would have been copied to the HM Attorney General. Only then can I fully argue the 4^th Action is not ‘out of time' and has a cause of action. A joint ‘understanding' had been agreed between parties to defer the 4^th Action until the format [jury or not?] of 1^st and 2^nd Actions had been finalised. That was not finalised until Lord Justice Thomas, effectively, refused me legal representation, any chance of a  jury trial or any  Abuse of Process Investigation  in the 14^th and 28th July 2007 hearings in the Court of Appeal witnessed by my barrister on the first occasion and litigant friend, Patrick Cullinane Esq. on the second occasion.

This ‘understanding' between parties to defer the 4^th Action is referred to in correspondence between defence and plaintiff's solicitor, eg  dated 23^rd July 2002, defence short hand note taken  and emails all relating to 28^th Oct 2008 hearing.  His Honour Judge Chambers QC will also have a note of the ‘understanding', most likely. To have joined all 4 Actions would have scuppered any Plaintiff argument for a ‘document light' jury trial. The only purpose for litigation to commence, in 1992, was on the clear understanding it would be before a jury and NOT a judge, sitting alone.

The Defence knew full well the tapes would be ‘destroyed' and so the record of the conversation by the defence {28^th Oct 2002], complaining I had lodged a 3^rd Action [June 2002] without a lawyer when it had been ‘agreed between lawyers' no further actions or incidents would be added to the current proceedings until the jury trial had been settled one way or the other, have been destroyed. I do not believe a word of it. This defence complaint of the 3^rd Action was stated in the presence of His Hon Judge Chambers on 28^th October 2002 and supported by His Honour Judge Jacks remarks [Bristol Court] on the very issue that I was not to add further incidents to the court proceedings if I considered the law allowed me a jury trial.

Deliberate delay was also caused by:

• 1. Bobbetts Mackan, my original Bristol solicitors, who were both dishonest and grossly incompetent causing the striking out of almost a third of their original badly drafted claim when it first hit court.

• 2. over 30 law firms, specialising in police harassment then refusing to act on my behalf once word had got about that I had sacked Bobbetts Macken and had commenced legal proceedings against them for negligence.

• 3. the South Wales Police having refused, since 1992, to consider any compensation what so ever for their losing 121 charges out of around 130 brought against me with numerous false imprisonments and now claiming around £200,000 legal costs from either me or the tax payer to pay, no doubt again, without a proper taxation procedure or accountability for their conduct.

• 4. HM Court Service ‘et al' for my appeal to the Court of Appeal, from the Swansea court, in November 2004, when I was refused a jury trial, delaying my case for 17 months while the HM Attorney General intervened. All done without my knowledge in a most clandestine way and only unearthed by the leaking of HM internal memos.

• 5. the interference by Mr Justice Andrew Collins, manager of the Administrative court of the Royal Courts of Justice, 26th January 2005, by his handing down a 2 year Extended Civil Restraint Order, ECRO, deliberately to block disclosure of the unlawful conduct of the South Wales Police disclosing confidential police files to the Royal College of Veterinary Surgeons, contrary to Home Office Regulations 45/1987, to support their complaint to get me struck off and so lose income.

 This is heavily featured in the 4^thAction, 7CF07345 but the ECRO not just delayed the 4^th Action, prejudicing the 6 year time bar, it also caused the blocking of the 5^th Action, 8CF02269, against the South Wales Police for well over another year. The 5^th was then expedited to conclusion, in but a few weeks, [Full Judgment in full 16th June 2008] once the ECRO expired in late January 2008. The fact the Home Secretary continues to refuse to pay up is a deliberate tactic to deter my continuing with the remaining 4 Actions against her welsh bully boys. Another example of the ongoing Abuse of Process tactis enjoyed by those immune to prosecution.

• 6. the interference by HM Attorney General, in around 2002, who employed a team of Whitehall lawyers to try and have me certified as a Vexatious Litigant and which led to the HM Treasury Solicitor rounding up ‘all court files with Kirk's name on' from Chester, Cardiff, Bristol and all points west.....well over 150 files and court hearings, in both civil and crown courts, were then scattered around Whitehall for over 2 years with the predicted consequences.

This caused total disruption to my preparation for litigation and yet another example of the gutter tactics by lawyers when they have been proved liars and cheats in open court. My barrister, for example, employed for a short time was refused sight of the court files, needed to be briefed because they were still in London! The Cardiff court staff, stated several times, they did not know where they were and in writing admitted there were originally 5 boxes now only 2 boxes.

I have served on the court an internal memo of an e-mail between the Cardiff court manager and HM lawyers for the HM Attorney General stating my files were ‘all over the shop', some mislaid and never to be seen again.

My photos of the remaining boxes, at that time, feature in the 4^th Action when, surprisingly there are now more boxes again, today, having turned up but no one will again disclose their audit trail knowing CPR do not give exemption for these files to have been disclosed to certain of the 3^rd parties, as with Home Office rules on police records.  Only leaked HM Treasury Solicitor  internal memos [sample lodged 22^nd July 2008 with Cardiff court] and proof of these files having gone to London, from another source, confirms my belief there should be An Abuse of Process Investigation by the appropriate authority before my case for damages an continue.

• 7. My unprecedented manoeuvre when I, the Plaintiff, handed over all my records, 80 odd lever arch files, then under my control, to the defence revealing in graphic detail the 10 years of what their sustained harassment had caused to my family, until they had me struck off. It was to expedite the whole proceedings either by possible arbitration, let a judge just read the audit trail of both parties under An Abuse of Process Application but also to make sure the police were made to disclose to their lawyers the relevance of the incidents in 4^th Action before they were was an argument they were ‘time barred'. Now with the police forewarned of my information they are playing every trick to delay or destroy the records in the police station

• 8. Because I had no idea it would take 15 years to establish, down such a route riddled in HM deceit, ‘Kirk was to have no jury'. It was not until many years into the case and my increasing interest in the conduct of judges, Home Secretary's and HMCS rather than poor old ‘Mr Plodd' did I have to take the drastic action of handing over my full record to the enemy.

 So many incidents in the 4^th Action cross link with the original 3 Actions, thus ensuring their predicted excuse later, the main reason why the defence, not the plaintiff, has delayed in disclosure. Their excuse was, of course, in November 2007, date of service of 4^th Action, ‘' our police records are destroyed'' despite countless requests by me to retain and orders by courts to disclose. South Wales Police have destroyed documents, it would appear, involving serious crime conducted against both me and my personalty during the critical 10 years to the 29^th May 2008 when my name was removed from the veterinary register following the purported single complaint from the defendant, The Chief Constable of the South Wales Police.

Preparation in the past 4 years by Dolmans in studying my 80 odd files, with comments in open court by the defence before His Honour Judge Chambers of ‘their content' being ‘inconsistent with Particulars of Claim', assures me the defence have no argument now they have been ‘ambushed' by fresh incidents of more than 6 years ago especially when the incident number was logged by the investigating police officer in the 200 hundred odd cases of failed ‘duty of care'.

Just because I have proved to others widespread criminal conduct by those immune to prosecution by some accident or design of a  Royal Charter or ‘Her Majesty's Royal Prerogative' does not prevent me from exercising my rights under CPR, Human Rights Act 1998 and 1948 ECHR Convention. Refusal by everyone to order a criminal investigation comes as no surprise.

Incident numbers and the police audit trail caused by investigation from Plaintiff's complaints of theft, arson ,burglaries, prosecutions etc were and always have been their own making and under their control and the police  are the only benefactors for delay for the records to be ‘shredded' or ‘lost' when there is fear ‘truth will out'.

• 9. the polices continuing denial of many of the police recorded incidents and is contrary to the Fraud Act and until there is proper disclosure of police records, I receive payment from the HM Home Secretary for the 5^th Action, in order to seek legal advice and there has been a Criminal/Abuse of Process investigation, I am unable to amend the final Particulars of Claim of the 4^th Action.

From The Times

March 25, 2008

Power to extend limitation time to bring action

Court of Appeal

Published March 25, 2008

Giles v Rhind and Another (No 2)

Before Lord Justice Buxton, Lord Justice Sedley and Lady Justice Arden

Judgment February 28, 2008

The court had power to extend the limitation period where a party, allegedly in breach of duty, had entered into a transaction defrauding creditors.

The Court of Appeal so held when dismissing an appeal by the second defendant, Caroline Rhind, from Mr Justice David Richards ([2007] Bus LR 1470) who had granted permission to Edward John Giles to amend his particulars of claim in an action concerning a transaction which allegedly fell within section 423 of the Insolvency Act 1986, and where, for the purposes of the Limitation Act 1980, there was alleged to have been a deliberate concealment of relevant facts.

The second defendant asserted that the claim was statute-barred since the relevant transaction was entered into outside the relevant limitation period.

Mr Giles and the first defendant, Roderick Middleton Rhind, had been the directors and principal shareholders of a company. By a shareholders' agreement in 1980, Mr Rhind owed Mr Giles an express duty of confidence in relation to the company's affairs.

Following Mr Rhind's resignation as director and the sale of his shares he agreed with Mr Giles the claimant personally not to breach his obligation of confidence: ( The Times October 23, 2002) Mr Giles challenged the allocation of the proceeds of sale of the property, governed by a deed, apparently dated 1992, as between the defendants. He contended, inter alia, that the deed was a transaction in fraud of creditors to which section 423 applied.

Ms Georgia Bedworth for Mrs Rhind; Mr Richard O'Dair, by the direct access scheme, for Mr Giles; Mr Rhind did not appear and was not represented.

LADY JUSTICE ARDEN said the expression "breach of duty" in section 32(2) in the 1980 Act included a claim under section 423 of the 1986 Act.

Section 32(2) was enacted pursuant to the recommendations of the Law Reform Committee's Final Report on Limitation of Actions (1977) (Cmnd 6923) and the court could look at that report to see the mischief to which section 32(2) was directed. The committee did not recommend that the new provision should be limited only to some causes of action.

Her Ladyship could not think of any reason why Parliament should wish to restrict section 32(2) to only some of the causes of action within sectin 32(1): namely actions for breach of trust, breach of contract or tort.

The limitation period applicable to actions for recovery of land was capable of extension under the concealed fraud provision in the Real Property Limitation Act 1833, which postponed the limitation period until the claimant for rent or possession could reasonably have known that he had been deprived of possession by fraud.

Furthermore, a transaction under section 423 was a type of transaction of which there was likely to be concealment and thus there would be a heightened policy reason for application of section 32(2) to claims under that section.

Her Ladyship would reject the proposition that because section 423 was so widely drafted and could have applied to events occurring over a considerable period of time, section 32(2) should not be interpreted to extend beyond breaches of duty in the narrow sense.

If Parliament created a cause of action which applied over a long period of time and a large variety of transactions, it would be wrong for the court to impose an indirect restriction on section 423 by excluding it from section 32(2) if that provision would otherwise on its natural meaning apply to it.

Lord Justice Sedley and Lord Justice Tuckey agreed.

Solicitors: Hewitsons.

This, my statement, is true to the best of my belief.

Signed

Dated            29^th September 2008

Copies to:           Mr John Smith MP

                             Mr Vince Cable MP

                             Royal College of Veterinary surgeons

                             http://www.kirkflyingvet.com/

Between

Maurice Kirk

                                                                                                                     Claimant

And

  South Wales Constabulary

                                                                                                                     Defendant

Particulars of Claim

"Delay is the deadliest form of denial"

Delay in lodging this substantive claim against the Defendant was by mutual agreement of parties due to matters arising from the Claimant's right to have a Trial by Jury for the Actions, BS614159 CF101741 & CF20414 over the similar time period.

Failed ‘disclosure' by both the Defendant and the Royal College of Veterinary Surgeons, contrary to court orders, delay by HM Court Service to process current actions, interference by Crown Prosecution Service, HM Attorney General, Mr Justice Andrew Collins and others either to hand down an Extended Civil Restraint Order or obtain  a Vexatious Litigant Order, clearly to protect the Defendant, all done without the  Claimant's prior knowledge has contravened his rights under the European Convention of Human Rights and Fundamental Freedoms and the 1998 Human Rights Act.

In 2001 the Claimant instructed solicitors for this Action to include matters not already incorporated in the 3 current actions (numerous false imprisonments and malicious prosecutions) lodged by the Claimant against the same Defendant as most were not all eligible for Trial by Jury.

The Claimant applies for leave to amend these particulars with up to 20 further incidents following proper ‘disclosure' by the Defendant it having been sought by the Claimant for over the past 10 years.

The Defendants have a duty and power to stop and arrest any person that they may reasonably suspect as having committed a criminal offence.

Further, the Defendants as a police authority have a duty and obligation to fully and diligently investigate any complaint from the general public in respect of any criminal offence.

Further or in the alternative, the Defendants have a duty and obligation as bailees to use their best endeavours to protect any property which comes into their control and in particular to protect any stolen property to ensure that it is not damaged or vulnerable to further theft.

Further or in the further alternative, the Defendants, once their investigations are concluded, have a duty to provide to the injured party relevant information concerning the results of such investigations including, in particular, the identity of any person suspected of having caused wrong to the injured party.

The statutory and/or common duties and obligations herein mentioned are owed by the Defendants to the Claimant as the person directly affected and or wronged and they are negligent breach of those duties and obligations or have assaulted him and/or have committed trespass to his person or property and the Claimant has suffered loss and damage.

Particulars

The Defendants failed in their duty to properly, if at all, investigate and/or apprehend the perpetrators of crime.

The Defendants failed to prevent or limit loss for the Claimant.

Any one of the 100 or so incidents cited below, taken either in conjunction with the 40 or so incidents already in current Case numbers BS614159, CF101741 & CF20414 (eligible for jury trial) or not indicate malice and/or a failure of duty of care by the Defendant.

• 1. In 1993 at 52 Tynewydd Road, Barry, the property of the Claimant, persons known to the Defendant occupied part of the premises without permission. The garage of the said premises contained a WW2 US Army aircraft, a Piper Cub and spares exceeding a value of £15,000. Also veterinary memorabilia, a collection by 2 generations of the claimant's family, with value exceeding £11,000.

The above property was destroyed by fire and the squatters boasted about it. The Plaintiff was interrogated at the police station being accused of arson for financial gain. The aircraft and main contents of the garage were uninsured. The Claimant suffered loss due to Defendant conduct.

• 2. On 30^th June 1993 the Claimant's Barry property was burgled and suffered criminal damage. The Claimant suffered loss due to the conduct of the Defendant.

• 3. On 10^th Feb 1994 the Claimant's motor vehicle suffered damage, exceeding £700, leaving the road to avoid an accident caused by the excessive speed of another vehicle. The Defendant refused to divulge particulars of any of the drivers of the cars that sustained substantial damage and serious injury. The Claimant suffered loss due to the conduct of the Defendant.

• 4. On the 13^th June 1994 the police falsified evidence before Barry Magistrates relating to the plaintiff driving around a roundabout, adjacent to Barry Police Station, South Wales.

Further, the plaintiff was convicted for ‘driving without due care and attention' as he caused an imaginary car to ‘stop' before entering the roundabout while the defendants' veterinary ambulance was parked due to a uniformed police officer's direction.

The Defendant knew the plaintiff had suffered a motorcycle accident and was in hospital on the day of the Magistrates hearing which was heard in his absence despite the Defendant knowing the Claimant was in Bridgend Hospital casualty unit that morning and unfit to attend.

 In 2002 before the Royal College of Veterinary College (RCVS) court evidence was heard from the Defendant that the Plaintiff's veterinary Ambulance never exceeded 4 mph on that roundabout with no other traffic on the 4 lane roundabout at any of the time except police cars, lots of police cars.

There was no car required to stop due to the claimant's alleged ‘careless driving'. The police officer originally giving that evidence was not at the scene at the time of the alleged offence.

The Royal College of Veterinary Surgeons ruled on the 29^th May 2002 the conviction of ‘driving without due care and attention' rendered the Claimant to be ‘unfit to practice veterinary surgery and was struck off for life. The Claimant suffered loss due to defendant's conduct.

• 5. On 10^th Feb 1994 the Claimant's motor vehicle suffered damage, exceeding £700, leaving the road to avoid an accident caused by the excessive speed of another vehicle. The Defendant refused to divulge particulars of any of the drivers of the cars that sustained substantial damage and serious injury. The Claimant suffered loss due to the conduct of the Defendant.

• 6. Between 1994 and 30^th August 1995 the Claimant's surgery in Llantwit Major was burgled 3 times the crime reported to the Defendant. In Crown Court on the 22^nd March 1996 the Defendant on oath denied the surgery had been burgled during the period quoted above. The plaintiff was convicted of ‘allowing' clinical waste from the said premises to be found elsewhere with costs incurred to the Claimant exceeding £8000.

The Defendant was aware the RCVS and judge knew the fact that the only other veterinary practice in the town possibly liable had submitted a false veterinary certificate to the prosecution and the principle had given appropriate evidence in order not to be subject to the same possible prosecution. A small black bag containing clinical waste had been found with some 50 others of unlawful household waste on the edge of the town car park.

The Royal College of Veterinary Surgeons ruled on the 29^th May 2002 the conviction of ‘failing to prevent the deposit of controlled waste' rendered the Claimant to be ‘unfit to practice veterinary surgery and was struck off for life. The Claimant suffered loss due to the conduct of the Defendant.

• 7. In 1995 the Claimant's motorcycle was stolen out side his surgery in Barry. Claimant suffered loss due to the Defendants' conduct.

• 8. On 8^th June 1995 the claimant's Cardiff surgery was burgled with criminal damage. Claimant suffered loss due to the Defendants' conduct.

• 9. In 1995 the Defendant received a complaint from the Claimant of criminal damage and theft of property exceeding £2000 by a previous occupier of the property, 52, Tynewydd Road, Barry. A thief was also caught red handed by the Claimant in the property but instead he was fined £500 for ‘common assault' the conviction only obtained by perjury committed by the Defendant.

The Royal College of Veterinary Surgeons ruled on the 29^th May 2002 the conviction of ‘common assault' rendered the Claimant to be ‘unfit to practice veterinary surgery' and was struck off for life. The Claimant suffered loss due to the Defendant's conduct.

In 1995 the Claimants' veterinary ambulance was stolen in Barry and later found a few streets away by the Defendants. They were asked to immobilise it or protect it while the Plaintiff arranged immediate collection. The Claimant suffered total loss due to the Defendant's conduct.  

• 10. On 14^th September 1995 the Claimant was assaulted and had his premises severely damaged by fire by persons known to the Defendants. The plaintiff entered the premises and fought the flames alone with 2 fire extinguishers neither of which appeared to function. Examination of the appliances later revealed they were both faulty missing internal mechanism. The Defendant refused to investigate a complaint on those who supplied the fire extinguishers. The Claimant suffered loss due to the Defendant's conduct.

• 11. On 3^rd May 1996 the Claimant's stolen motor vehicle was found in a police car park. Defendant refused to reveal the circumstances. Claimant suffered loss due to the Claimants conduct.

• 12. On or around 1996 the Claimants' surgery in Barry was burgled using a JCB excavator. The burglars were caught by the Claimant. The Claimant suffered loss due to the Defendant's conduct.

• 13. On the 17^th October 1997 the Defendants watched and did nothing as drunken youths threatened assault and criminal damage on the Plaintiff and his property. The Claimant, at around midnight, was attempting to attend to an emergency in a marked veterinary ambulance only to have the windscreen smashed and serious damage done to the body work. The claimant suffered loss due to the Claimants conduct.

• 14. In January 1998 the claimant caught a burglar in his Barry premises. The claimant suffered loss due to the Defendant's conduct.

• 15. On 1^st April 1998 the Claimant's Llantwit Major Surgery was again burgled and the claimant suffered loss due to the defendant's conduct.

• 16. On 1st June 1999 in the Cardiff Crown Court, during an Abuse of Process Application by the Plaintiff, the Crown Prosecution Service lawyer, Ms Jackie Seals, committed perjury in that she deliberately lied on matters relating to a purported ‘Breach of the Peace' allegation committed by the Plaintiff at the Vale of Glamorgan Agricultural Show where the Claimant had been on duty.

Prosecution documents were falsified and presented before the Cardiff Crown Court and custody records shredded. The Defendants fabricated new charges months later, held back these new charges even when the Claimant attended court on a summons not indicating its purpose.

The Claimant was only ever handed the court copies of summonses by the clerk of the justices and the trial proceeded immediately with the Defendant being refused an adjournment as is the custom here.

The Breach of the Peace allegation was removed from the list at lunch time following the clerk of the court warning the prosecution that if the Claimant refused to be ‘bound over' the Claimant would have to go to prison. The Claimant suffered imprisonment and loss exceeding £20,000 due to the Defendant's conduct.

• 16 1^st June 1999 in the Cardiff Crown Court the Plaintiff was again assaulted by Howard Davies, recently retired South Wales Police inspector, in the presence of the Defendants. The Claimant suffered personal injury and loss due to the Defendant's conduct.

• 17 11^th June 1998 by way of correspondence to the Claimant's Member of Parliament it was admitted by the Defendant, in writing, that neither the Civil Aviation Authority nor the Defendants could pursue prosecutions against a Mr Christopher Paul Ebbs of Dursley, Gloucestershire, a purported Aircraft engineer, as he was undergoing ‘Psychiatric treatment'. The Defendant's were only to well aware to Ebbs's nefarious life history as a congenital liar. The Claimant suffered false imprisonment and loss exceeding £50,000 due to defendant's conduct.

• 18 In November 1999 the defendant stopped the Claimant on the road to produce driving documents without lawful authority. The claimant suffered loss due to the Defendant's conduct.

• 19 On 1^st December 1999 the Defendant arrested the Claimant and took his motor vehicle leaving it unlocked and inside with dangerous veterinary drugs, lethal to humans. For 6 weeks the vehicle was left on the road side with the Defendant failing to inform the plaintiff of its whereabouts.

The incident led to a zero reading definitive breath test at Fairwater police station, Cardiff, 20 miles away where the Claimant was dumped but the Crown Court dismissed the Claimant's Appeal for ‘failing to provide a specimen of breath at the road side' in the Claimant's absence despite the fact the Defendant had been supplied with a doctor's certificate that the Claimant, unrepresented, was recovering from abdominal surgery and was on morphine derivative drugs.

The arresting officer gave false evidence in the Barry Magistrates court, not for the first time, causing the Crown Prosecution Service having to offer an alternative charge of ‘obstructing a police officer'. The Claimant refused it as he was again refused ‘disclosure' with the Defendants having again destroyed custody records applied for whilst in custody and in writing immediately after his release.

The Royal College of Veterinary Surgeons ruled on the 29^th May 2002 the conviction of ‘failing to provide a specimen of breath' rendered the Claimant to be ‘unfit to practice veterinary surgery' and was struck off for life. The Claimant suffered loss due to the Defendant's conduct.

• 20 On 5^th April 2000 the Defendant assaulted the Claimant in Newport Road, Cardiff caught on police video, destroyed and/or withheld custody video/records ordered to be released by both Cardiff and Newport Crown Courts. The Claimant suffered loss due to the Defendant's conduct.

• 21 In August 2000 the Claimant was jailed for Contempt of Court.

 The RCVS lawyers deliberately withheld their knowledge of this conviction from the protracted court proceedings, commencing 29^th January 2002 in order to have the Claimant removed from the veterinary register for life.

 Courts where the law applied, 1966 Veterinary Surgeons Act and 1967 law, Statutory Instrument no.659, paragraph 8.2b (The Claimant's right to adduce evidence),  included  the RCVS court, Administrative Court, Court of Appeal, Privy Council , European Court and over 40 Judicial Review Applications.

The Emergency Judicial Review Application following the September 2007 incident with the RCVS removing the Claimant' s name from the list for his 7th Application to be reinstated to ‘practice veterinary surgery' is delayed by no fault of the Claimant.

The Defendants conspired with the lawyers of the RCVS to prevent the reasons why the claimant was sent to prison for ‘contempt of court' as the "nature and circumstances surrounding the conviction" indicated the Defendant had perverted the course of justice.

Disclosure of the confidential material including the ‘criminal record', already admitted and witness statements relating to the Claimant by the Defendant to the RCVS in 2001 reveals the magnitude and vindictive nature of those ultimately responsible, the authority that both instigated complaints to the RCVS in the first place but gave false evidence so often to secure criminal convictions [see Actions, BS614159, CF101741 & CF20414]

Following receipt of the compelling jury notes passed to Judge Cooke he deliberately stopped the trial only to prevent further evidence being obtained by cross examination of the conspiracy between the Defendant and the RCVS.

The Judge's conduct was unlawful.

The Defendants had a number of high ranking police officers present  to keep the police commander at Barry Police station fully informed, minute by minute, the transcript reveals.

These police officers witnessed the criminal conduct of the judge, CPS and police officers on oath who were committing perjury. The Defendants witnessed themselves in the well of the court caught repeatedly signalling to their colleagues in the witness box.

The Claimant suffered loss due to the Defendants' conduct.

• 22 On 10^th Nov 2000 the Claimant reported a burglary and criminal damage on his surgery premises in Barry. The Claimant suffered loss due to the Defendant's conduct.

• 23 In 2000, following the Defendant's request for the Claimant to rescue a horse at night from a flooded ravine with the assistance of the Barry Fire Brigade, despite submitting a fee note considerably less than that recommended by the British Veterinary Association at the time, the Claimant had to commence prosecution proceedings in the Petty Debts Court in order to obtain payment. The Claimant suffered loss due to the Defendant's conduct.

• 24 On 13^th December 2000 in Cardiff the Claimant was arrested by the Defendants and locked up with his 3 English Springer Spaniels. .No charges, no caution, no explanation causes the claimant to fear harassment with malice. The Claimant suffered loss due to the Defendant's conduct.

• 25 On 20^th Dec 2000 at the Claimant's Cowbridge Road West, Cardiff surgery the Defendant refused to reveal details of a driver of a vehicle following a motor accident on the Claimant's property. The Claimant suffered loss due to the Defendant's conduct.

• 26 On the 20^th Dec 2000 at the same premises as (19) a burglary and theft of drugs was dealt with by the Defendant in the usual manner. The Claimant suffered loss due to the Defendant's conduct.

• 27 In December 2000 the plaintiff's surgery, Barry Veterinary Hospital, Barry suffered theft of articles reported to the Defendant. The Claimant suffered loss due to the Defendant's conduct

• 28 On 7^th January 2001 at Cold Knapp Beach, Barry the Defendant, having called the Claimant to attend 2 dogs purportedly fallen over a cliff, obtained evidence and the identity of witnesses favourable to the plaintiff but failed to disclose it. The Claimant suffered loss due to the Defendant's conduct.

The Defendants during 2001 disclosed confidential police records relating to the Claimant, some of which was incorrect and was used by the Royal College of Veterinary Surgeons in order to render the Claimant ‘unfit to practice veterinary surgery'. The Claimant suffered loss exceeding £100,000.

The Defendants in March 2002 attended the RCVS court, contrary to a Court of Appeal Order and gave information that was manifestly false when purported to be non hostile witnesses for the Claimant. The Claimant suffered further loss due to the defendant's Conduct.

The Defendants entered into a financial contract with the Royal College of Veterinary Surgeons to be their ‘client', being the only complainants of the Claimant's alleged conduct on 7^th January 2001. The purpose to enter into such a clandestine contract was in order to avoid favourable Disclosure of evidence to the Claimant from either the RCVS or Defendants under their premise that all information from witnesses gathered by them [including the Claimant's own clients], concerning the RCVS allegations against the Claimant, was ‘privileged'. Whether ‘qualified' or ‘absolute' is anybodies guess with the current state of the UK Judicial system.

In return for confidential police information, contrary to Home Office Regulations 45/87, the Royal College of Veterinary Surgeons ensured the Claimant would be refused any witnesses relating to the convictions [by using a medically unfit ‘Learned Legal Assessor' for the RCVS hearings], originally obtained by the Defendants, now at risk of having convictions being overturned if the Defendants were to be subjected to giving evidence on oath, again. The convictions were necessary, however trivial, under the 1966 Veterinary surgeons Act, in order for the RCVS to render the Claimant ‘unfit to practice veterinary surgery' for life.

The conduct of the RCVS, Defendants and many others that daily exploit the lucrative UK legal industry, answerable to no one, not even the taxpayer, was unlawful.

Immunity to prosecution under the purpose of a Royal Charter and oath of bias taken by every UK judge is contrary to the 1998 Human Rights Act despite all this nonsense having been ratified by her Majesty The Queen in the first place.

 The welsh Crown Prosecution Service, those most culpable for perverting the course of justice, cannot therefore be co- defendants in this Action for damages.

Similarly the RCVS cannot also be joined as co-defendant. Further, the Claimant, his father and his wife would be tempting the ultimate sanction.   

The Claimant and his family have suffered not inconsiderable loss and mental anguish by the 15 year conspiracy.

Back ground to support paragraph 28.

• 29 By 2001 the Defendants had been made aware of the monies (5 figures) routinely donated from public funds by the Defendants to the Cardiff Animal Shelter (deceased) who were then unaccountable to the associate organisation under which whose name they were purported to operate.

By 2001 The Defendants had been made aware of the complaints directed to the RCVS by the ‘Cardiff and District Veterinary Practitioner's Association' concerning the widespread animal suffering in South Wales caused by the Defendant's ‘donations' of public funds to an autonomous run charity implementing a rogue policy for the neutering of animals for an area with at least a 40 mile radius to just one practice in Barry, South Wales that did not have adequate 24 hour cover.

.

By 2001 the Defendants had been made aware that the specific veterinary surgeon was invariably unavailable at night or on week ends using an unintelligible tape message for those members of the public requiring urgent veterinary attention. These included animals that had just under gone neutering operations by his practice.

The Defendants were therefore well aware on the day of the emergency, on Sunday 7th Jan 2001, the true state of affairs with his veterinary surgery not a mile from the beach.

The Defendant maliciously allowed hours to pass unnecessarily before the Claimant could attend the scene.

 The clinical condition of the dog was clearly indicative of criminal negligence.

 Implications on the other Barry veterinary practice were not then apparent to the Claimant as he had no way of knowing, until later, when the owner was traced, just who was responsible for the appalling state of the wretched animal.

The Defendants conspired with the RCVS lawyers to be their ‘clients' when they already knew the Defendants were a ‘client' of the Claimant they were complaining  about.

The Defendants knew and were negligent in being silent when the RCVS ruled that failure by the Claimant to divulge to the disciplinary committee the confidential client information regarding the 2 dogs, between veterinary surgeon and the South Wales Police, was the substantive reason for his name being removed from the register.

The Defendants acted with malice by complaining to the RCVS of the failure of the Claimant to "discuss with the general public" what he confidentially found following a clinical examination.

Clinical findings, witnessed by the Defendants included indications of hypothermia, a collapsed, moribund patient having suffered a suppurating [frank pus] malignant mouth tumour the size almost of a cricket ball for some months/years. The patient was in pain and appeared to be dying. Immediate removal of both patients to the Veterinary Hospital was paramount. 

When the RCVS realised they were prosecuting the wrong veterinary surgeon they:

        1) Falsified eye witness statements,

       2) Gave the Claimant false addresses of eye witnesses so they could not be traced

       3) Withheld witness statements

       4) Refused all 30 odd witness summonses needed to be served on behalf of the Claimant

       5) Used their cronies in the Court of Appeal to block them again even blocking defence witnesses not even objecting to giving evidence or requiring a witness summons

       6) fabricated the Defendants, members of the public and investigators to be their ‘clients' in order to block both favourable and damming DISCLOSURE.

• 30 The Defendants were notified of the unnecessary animal suffering. It was spelt out in words of one syllable to the Defendants and RCVS warning them of the obvious consequences if the wide spread animal suffering in the area was allowed to continue. It was taped, photographed and shortly to go on new website, http://www.kirkflyingvet.com/ in 2008 the latter being the only medium left for citizens in the UK for any chance in obtaining that elusive sanction of established injustice.

Further, information under the control of Inspector Collins and favourable to the Claimant was withheld from the RCVS legal proceedings despite specific requests for that material by the claimant. The conduct was unlawful.

Information supplied by the Defendants and used on oath at the RCVS proceedings were known by the Defendant to have been false. Failure to correct these anomalies was unlawful.

Defendants who attended the 2002 RCVS enquiry, posing as ‘defence' witnesses, was unlawful and malicious there in order to do harm to the Claimant.

The Defendants' false information, on oath, in both Charge A and in Charge B at the 2002  RCVS proceedings led to the Claimant's name being removed from the veterinary register and has been relied on by the RCVS ever since on each subsequent attempt by the Claimant  to be put back on the register. The Defendant's conduct was unlawful.

The Defendants conspired with the RCVS lawyers to be their ‘clients' or visa versa when they knew the Defendants were a ‘client' of the Claimant complained about.

Failure by the Defendants and RCVS to disclose which one was the ‘client', fabricated late in order to withhold investigator's notes, eye witness accounts and the identity of witnesses favourable to the claimant, given to the 1996 Data Protection Act Information Commissioner but not disclosed for the 2002 hearing, was unlawful.

The Defendants knew and did nothing about it when the RCVS ruled that failure by the Claimant to divulge to the disciplinary committee confidential client information, between their veterinary surgeon and them selves, without their consent was the substantive factor for his name being removed from the register for life. Their conduct was unlawful.

• 31 The Defendants knew the RCVS ‘Learned Legal Assessor', Sir John Wood, retired medically unfit judge, Allison Foster QC, Geoffrey Hudson of Penningtons, solicitors and many other lawyers cited in these 4 actions were thoroughly deceitful and their conduct was unlawful.

• 32 In August 2001 the Claimant reported the theft of his property in Barry and the Claimant suffered loss due to the Defendant's conduct.

• 33 In 2001 the Claimant was stopped on the motorway arrested and handcuffed for the theft of a motor vehicle. The claimant suffered loss due to the Defendant's conduct.

• 34 During 2001 statements of complaint, listing more than 47 incidents of lawyers lying in court, were reported to the Defendants. The claimant suffered loss due to the Defendant's conduct.

• 35 In December 2001 17 complaints by the Claimant of perjury by others. The Claimant suffered loss due to the Defendant's conduct.

• 36 The Claimant has had been refused legal representation by over 80 law firms specialising in police harassment cases. The Claimant suffered loss.

• 37 In 2001 the Claimant instructed solicitors for the main Particulars of Claim compounding matters not already incorporated in the 3 current actions and not necessarily eligible to Trial by Jury. The Defendants and Royal College of Veterinary Surgeons were put on notice of pending legal action as co Defendants.

• 38 During a quieter spell of police harassment, between 2000 and 2001, 30 or so court appearances related to whether or not he had motor vehicle insurance?

 The court was told by the Claimant the Defendants had for years been playing the same old game of police harassment as their counterparts had done on him in a different but equally notorious British jurisdiction, Guernsey in the Channel Islands.

 There the police had succeeded in hounding the insurance agents on the island to such an extent by their telephone tapping for 2 years of the Claimant's surgery, threatening visits and phone calls to their offices that the Claimant was refused, it appeared, any insurance for anything!

 Today, the 10 years conduct of the Defendant and the purpose in both jurisdictions is only too apparent with the Claimant remembering that soon after getting the ‘message' from the ‘Insular Authority' in that feudal island his life was threatened by the local Masonic Lodge if he  did not leave the island immediately.

The Claimant's insurers in Somerset, England, were of different stuff and lodged several official complaints of the harassment received by the Defendants.

The Claimant has been forced by the Defendant's harassment to produce perfectly valid driving documents over 40 times with the Defendants knowing under the ‘balance of probabilities', under statute law, they are always likely to be valid.

The unlawful conduct of the Defendants has made the Claimant have to change the vehicle he is seen in often every month, use foreign registrations, some in fictitious names with fairy tale addresses or with his favourite, in the names of famous aviators or aviatrix of yesteryear.

The Claimant suffered loss due to the Defendant's conduct.  

• 39 On the 24^th July 2002 the Defendant conspired with others to arrest the Claimant in the Cardiff Civil Justice Centre in order to prevent a judgment by default against the Defendant, for failing to lodge his defences in time. Undue force was used causing actual bodily harm and the arrest was unlawful. The Claimant was later released from custody without explanation. The Claimant suffered loss due to the Defendant's conduct.

• 40 In 2002 the Claimant caught a burglar on the Veterinary Hospital, Barry premises. The Defendants refused to arrest, prosecute or identify the person to the Claimant. The Claimant suffered loss due to the Defendant's conduct.

• 41 In October 2002 the Complainant reported criminal damage to his Llantwit Major surgery identifying the culprit known to the defendant. The Claimant suffered loss due to the Defendant's conduct.

• 42 In October 2002 the Defendants received complaints of squatters on the Claimant's premises. The Claimant suffered loss due to the Defendant's conduct.

• 43 On 9^th January 2003 the Claimant's motor vehicle was destroyed by arson. The Claimant suffered loss due to the Defendant's conduct.

• 44 On 22^nd March 03 criminal damage exceeding £1,500 was reported to the Defendants with those responsible known to the Defendants. The Claimant suffered loss due to the Defendant's conduct.

• 45 On 07^th Aug 2003 the Claimant was made to stop and produce driving documents. The Defendant sent particulars to John o Groats' police station and they have never been seen since. The claimant suffered loss due to the Defendant's conduct

• 46 On 9^th September 2003 the Claimant caught a burglar in his Cardiff surgery premises. The claimant suffered loss due to the Defendant's conduct.

• 47 Between 2003 and 2005 the Claimant laid statements of complaint of perjury and perversion of justice by the RCVS before the Judicial Committee of the Privy Council committed in 7 separate hearings in Downing Street. Information was sent to both the Metropolitan Police Force and the Defendants for appropriate action. The Claimant suffered loss due to the Defendant's conduct.

• 48 In 2005 and again in 2006 the Claimant complained to the Defendant that the clerk to Mr Justice Andrew Collins, Manager of the Royal Courts of Justice's Administrative Court, during the Claimant's appeal for his Lordships' handed down 26^thJanuary 2005 Extended Civil Restraint Order (ECRO) was unlawful.

 The Clerk denied his Lordship had written to the Claimant direct, failed to inform the Court of Appeal that his Lordship had written direct to the Claimant but within the statutory time to the Claimant for the ECRO to be subjected to an appeal.

His Lordship asked the Claimant for evidence that Mr Gary Flather QC had in fact directed the RCVS to disclose (see paragraph 28). The RCVS transcript was sent by return of post. The Claimant suffered loss due to the Defendant's conduct.

• 49 Mr Patrick Cullinane Esq., supported by transcripts and statements of complaint directed to the Defendants, witnessed and will confirm Mr Justice McComb, Mr Andrew Collins and at least 2 RCVS hearings, for ‘disclosure' for this Claim and reinstatement to ‘practice veterinary surgery' were conducted with criminal intent to abuse due process. All disregarded the files lodged as they had scribbled on them, from the orders of the HM Attorney General's Office, ‘.Maurice John Kirk - Potential Litigant'. The Claimant suffered loss due to the Defendant's conduct.

• 50 In 2006 the Defendant was informed the Registrar of the Judicial Committee of the Privy Council refused several times to refer the Claimant's Humble Petitions to Her Majesty to the court as it outlined the proof of the conspiracy between the Defendant's and the RCVS. On one occasion a court application, special delivery from Brittany, France, was returned unopened to the recipient, The Registrar, un aware of its content with only the name of the sender of the parcel. The Claimant suffered loss due to the Defendant's conduct.

• 51 Between 0ctober and November 2006 the Defendant, despite receipt of previous complaint of illegal trespass, threats of violence and criminal damage, failed to prevent persons known to the Defendant to inflict further damage and theft at his old surgery in Grand Avenue, Ely, Cardiff. The Defendants stood and watched the wielding of the sledge hammer. The Claimant suffered loss, exceeding £15,000, due to the Defendant's conduct.

• 52 In 2007 the Defendant was asked by the Claimant to investigate the criminal conduct caught on both tape and camera of the RCVS lawyers outlined in a letter of complaint, recorded delivery, to Cannon Street Police Station, London. The latter refused service of said information. The Claimant suffered loss due to the Defendant's conduct.

• 53 On the 12^th October 2007 the Defendant refused to investigate the destruction or deliberate loss of court files lodged at the Cardiff Civil Justice Centre. The court admitted there had been 5 boxes but with the Attorney General's intervention years earlier and with the Treasury Solicitor sending all these files for Actions, BS614159, CF101741 & CF20414 to ‘interested parties', as the internal memo put it, the court were down to one box. This was confirmed by a sequence of photographs within the confines of the HM court building, taped personally by the Claimant in open court and further confirmed by court correspondence.

• 54 On 12^th October 2007 Fire broke out in the Cardiff Civil Justice Centre, apparently, as the Claimant was leaving and if it had not been for the quick arrival of a number of fire appliances the last and lonely box of the Claimant may have also been destroyed.

• 55 On the 12^th October 2007 the Defendants refused at Cardiff Central police station to accept a 9 page statement of complaint headed, Abuse of Process or take a statement relating to the ongoing illegal activity within the UK judiciary. The Defendant refused to secure, for safe keeping, the lonely box in the Cardiff Justice Centre. The Claimant suffered loss due to the Defendant's conduct.

• 56 The Claimant at the RCVS court, 62, Horseferry Road London, on both 7^th November 2005 & 6^th October 2006 arranged for the Defendants to witness, first hand, the ‘Abuse of Process' and further proof of a conspiracy.

• 57 On 18^th January 2007 The Claimant was placed in police custody overnight following orders from the Barry Magistrates:

• 1) Quashing a conviction that the RCVS used in 2002 rendering him ‘unfit to practice veterinary surgery' [On the 7^th September 1997 the Claimant failed to present his valid motor insurance to the correct police station].
• 2) The Claimant was to serve a term of imprisonment if he did not pay the fines and CPS costs outstanding since 1996.

The Claimant offered the Defendant payment in full in order to be released from custody.

• 58 He offered UK cash, credit cards, business and private cheque books even a few Euros thrown in or his wife could bring the cash that night. These forms of payment and application for his wife to pay at the gate before being transferred to Cardiff prison in the morning were all refused. The Claimant suffered loss due to the Defendant's conduct.

.Mr Justice Collins later refused the service of Claim Form N1 (CPR part 7) containing similar allegations on the Secretary of State for the Home Office, his lordship using his Extended Civil Restraint Order due to expire on the 26^th January 2008.

• 59 Some other thefts, burglaries, acts of arson, personal injury and criminal damage suffered by the claimant in the 10 years are referred to in some of the following Crime Reference numbers:

1. 12996/93
2. DA/2134/93
3. E/6284/93
4. 2124/93
5. EA/00/9637
6. Ea/00/9516
7. CA/00/28310
8. EA/251/051200
9. EA/00/9703
10. CA/0027437r
11. EA/01/7170
12. EA/99/7990
13. EA/99/9058
14. EA/99/7990
15. EA/98/2816
16. EA/98/5720
17. EA/98/5403
18. LA/98/736
19. DA/97/10941
20. DA/97/10071
21. DA/97/7596   
22. EA/97/2130
23. EA/97/2450
24. DA/97/6474
25. EA/96/5731
26. DA/94/12521
27. DA/94/12740
28. EA/97/5304
29. EA/97/3319
30. EA/97/2450
31. EA/97/2130
32. EA/96/7162
33. EA/96/1883
34. EA/95/6841
35. EA/94/12996
36. E/8126/93
37. DA/94/2030
38. EA/94/1617
39. DA/94/2372
40. DA/94/2085
41. EA/94/1617

This list is NOT exhaustive due to the Defendant's apparent inability to disclose incidents reported without crime reference numbers. The Claimant suffered loss due to the Defendant's conduct. 

ALL support evidence of a pattern of conduct by the Defendant's failure to properly investigate crime during the time the Claimant had to spend in welsh law courts and prison cells to quash 130 malicious criminal charges brought by the South Wales Constabulary. 

• 60 Failed Disclosure with intent to deceive and delay.

• a. 10 years prior to 2002 the Defendants had conducted a policy of obstructing justice, failing to investigate crime and actively perverting the course of justice.
• b. Incidents cited for damages over that time had been segregated out for an independent tribunal, a Trial by Jury or the claimant would never have been so stupid as to commence legal proceedings.
• c. But Actions BS614159, CF101741 & CF20414 were then joined without the consent of the Claimant on the lawyer pretext there would be a jury.
• d. .The UK judiciary with the Defendants swindled the Claimant of that basic right before Mr Justice Thomas and Mr Patrick Cullinane Esq in September 2007 at The Royal Courts of Justice.
• e. Mr Justice Thomas admitted both he and Mr Justice Maurice Kaye, from whence the appeal to the Court of Appeal had come, had neither read the lodged application papers by the claimant for a Trial by Jury nor did they need to.
• f. The appeal for a jury had been lodged at the Court of Appeal in December 2004 and deliberately delayed to quietly phase out UK jury trials even though it is still on the statute book.
• g. The Defendants were informed and their conduct was unlawful.

• 61 Claimant applies that this action is heard by Trial by Jury.

Cessation of harassment and the right to practice veterinary surgery was concurrent

By reason of the matters aforesaid, the Claimant has suffered loss, damage, distress, anxiety, damage to his reputation and was deprived of his liberty 

And the Claimant claims costs, aggravated and exemplary damages at interest rate pursuant to Section69 of the County Courts Act