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1 Pares Land Walk
Rochdale OL16 5SX
11 April 2005
Claim No. HQ05X00419
Listing Number 05/TLQ/0318
High Court of Justice
Queen’s Bench Division
Royal Courts of Justice
Strand
London WC2A 2LL
Sirs
Geraint Davies MP and Barrister Sarah Branson represented by solicitors Mill & Partners v Moore
I refer to your Notice of Date for Returning Pre-Trial Checklist and Notice of Trial, both dated 6 April 2005, and both quoting Listing Number 05/TLQ/0318. I have not received a reply to my letter to the Court of 28 February 2005. Would the Court be good enough to expedite sending me a response to that short letter?
The two 6 April 2005 forms sent to me by the Court are addressed to the “Defendant’s Solicitor.” My 28 February 2005 applications to the Court include a request that “the Court appoints solicitors to represent The Defendant, subject to the availability of funding.”
Would the Court please expedite a determination of that application? Most of the documents I have received from the Court are addressed to solicitors acting for Defendant, and those that are not, tell me to obtain legal advice.
I have asked Geraint Davies MP, Barrister Sarah Branson and their solicitors Mill & Partners, to lift the ban on my access to legal services, subject to the availability of funding. To the extent that any have responded to that request at all, they have all refused. I have asked solicitors to represent me and all of those that replied refused.
May I please remind the Court that many English Court Service forms are not addressed exclusively to solicitors? Parliament, with the Ministers and Judges responsible for those forms, clearly intended that parties subject to Claims of this type, should have, and need to have, legally qualified representatives, subject to the availability of funding.
The Claimants say they require the Court to issue an order for my imprisonment. This Court has granted the Claimants every Order they have hitherto sought, even when the Claimants have said they had no need or reason to seek the Order.
The threat of imprisonment is compelling grounds for the appointment of solicitors to act
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for me, and so I ask that the Court is mindful of the gravity of imprisonment, in its consideration of my application that “the Court appoints solicitors to represent The Defendant, subject to the availability of funding.” May I also please remind the Court that the highly qualified, experienced and professional Barrister, Miss Sarah Branson, has appointed solicitors to represent her in this matter.
As I am not qualified, not experienced, not proficient and not competent in these matters, by need is much greater than Miss Sarah Branson’s need. May I also point out that any observation that Geraint Davies MP and Barrister Sarah Branson are proxies for the unending cycle of abusive litigation brought against me on the orders of Broomleigh Housing Association and their solicitors Cook & Partners, is additional reason for my need of legal representation, and no grounds for denying my application.
Amongst other reasons, the appointment of solicitors by Miss Sarah Branson, and Geraint Davies MP, who normally has his legal position protected by Miss Sarah Branson, suggests their solicitors are receiving instructions direct from Cook & Partners, solicitors to Broomleigh Housing Association. I am not asking the Court to accept this as true, but I would appreciate it if I were not subject to the insinuations I normally receive from the judiciary and other officers of Courts, when I mention the difficulties presented to me by these proxy Claims for Broomleigh Housing Association.
I will retain the Court’s forms until I receive a reply to this letter. I hope the Court will not put me to the indignity of completing those forms, which say unqualified, and inexperienced litigants in person, such as me, are not competent to complete them.
Would the Court please transfer the hearing of this matter to a venue nearer to my home? The Queen’s Bench Division, apparently hearing this matter, does hear applications in Birmingham.
The Court has ordered me not to contact Miss Sarah Branson, accepted claims by Miss Sarah Branson that she has never met me, but that the thought of my presence somehow creates a feeling of fear in Miss Sarah Branson. The Court can protect Miss Sarah Branson from this alleged fear, if it exists, by moving the hearing of this Claim at least as far north as Birmingham.
Would the Court be good enough to ask Mills and Partners, solicitors to Geraint Davies MP and Barrister Sarah Branson, to reply properly to my letters to them of 29 and 14 March 2005, copies of which I attach to this letter? I would like to avoid this litigation, but to reach any agreement with the Claimants, I do need information from the Claimants.
Yours faithfully
T Moore
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