Page 121 - Bundle for MF Final

Bates no 120

APPLICATION FOR ASSISTANCE OF A M KENZIE FRIEND
c
TABLE OF CONTENTS & CONTENTIONS

PURPOSE OF THIS SUBMISSION

This application urges the Court to allow Michael John Comer ("MJC"), the father of the First
Defendant (Louise PJ Siggers - LPJS), to serve as a McKenzie Friend with rights of audience. His
biography is at Attachment 11. LPJS can no longer afford legal representation - for reasons
explained in paragraph 2 - and needs assistance with the complex evidence in this case.

MAIN CONTENTIONS

LP JS contends that:
1. The Claimant has a track record of submitting false claims, misleading his solicitors,
committing perjury and ignoring Court Orders;
2. He has a habit of making gifts and then demanding them back;
3. He was a boarder in Nutley Place for over nine years and underpaid his share of living
expenses by at least £163,628;
4. His current application is contrived and dishonest;

• There never was any "common agreement" or TO LAT A compliant understanding
that he had, or would ever obtain, an equity interest in Nutley Place;

• LPJS's will and other evidence confirms this is the case;
• The £500,000 he paid into LPJS's mortgage account - on a cheque drawn to
BARCLAYS BANK PLC (Attachment 2) - was a voluntary transfer of interest with no
expectation of return. It appears primarily motivated by the Claimant's need to
conceal his assets and false duplicative claims from one or more insurance companies
who had compensated him with around fl.5 million for what was essentially a
minor injury to his hand;
• His duplicity leading up to, in and after the Final Hearing of LPJS's divorce led to her
losing lifetime maintenance of around £765,000. It is possible that his behaviour
was deliberate to contrive this result;

5. The Court is urged to establish the truth over the legitimacy the Claimant's funds before
reaching any conclusions. It is far from the simple TOLA TA case the Claimant pretends;

6. The Claimant's current demand appears to amount to £615,164.01 and LPJS's counter­
claim to £928,628;

7. The Court will note that Judge Todd's Order, in the Central Family Court in May 2018,
was based on the conclusion that the £500,000 paid by the Claimant into LPJS's
1
st
mortgage account on 21 December 2016 was a gift and her asset •

1 At that time, the Claimant expected to receive compensation of over £3 million
. . '