Page 126 - Bundle for MF Final

Bates no 125

APPLICATION FOR ASSISTANCE OF A M KENZIE FRIEND
c
PARTS 1 to 3: INTRODUCTION
8. LP JS' s solicitors then proposed:

a. an exorbitant fee budget for preparation and a full day's outing for a Senior Partner,
6
Associate and Counsel from their West End offices to Uckfield, East Sussex with the
vaguest hope of, and no plan for, reaching a settlement :
7
b. a separate budget for a trip to Nutley, East Sussex to survey Nutley Place, "inspect the
property" and the Claimant's DIY work. This was despite their "informal opinion"
that the Claimant's case was without merit:

c. an additional budget to analyse all of the papers in LPJS's divorce case to determine
8
which might be privileged against disclosure 9=
9. The above background is mentioned to explain why LPJS is no longer afford legally
represented 10-

10. In September 2019, the Claimant's solicitors agreed to hold a round table meeting, but
insisted that it:

(a) exclude the parties and;

(b) prohibit MJC, or any anyone else, assisting LPJS even to the limited extent of
being present in the waiting room to give her moral support;
11. It appeared that LPJS's solicitors were willing to agree to the above, or to any sort of
meeting with the Claimant's solicitors providing it involved an excursion to East Sussex , 11
where they said it would give them a better chance to "work their magic and negotiate a
settlement". LPJS was far from convinced and believed that a meeting confined to lawyers
and fixated on TOLA TA would be a "legal fee fest" and a waste of time.

12. MJC proposed (and LPJS agreed) a detailed protocol for a meaningful round table
meeting that would ensure all of the evidence - "warts and al/"would be made available
to both parties and tested by cross-examination under Oath.
13. This would establish an agreed factual base and make it less likely that the Claimant could
succeed in misleading his solicitors in the way he had deceived Kingsley Napley (see
paragraph 100).

14. Once the facts - and the bona fides of the Claimant's funds - had been established, LPJS
believed a settlement would be more likely. She has made every reasonable effort to
achieve this.

6 In LPJS's opinion
7 In the absence of the facts
8 At least 2,000 pages when LPJ5 was prepared to waive privilege
9 LPJ5 did not agree - on principle - in legal manoeuvring that would result in a court being misled
10 LPJS accepts that her ex-solicitors will have a different view and that they terminated our relationship because
MJC would not underwrite their budgets
11 Without the parties attending
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