Page 128 - Bundle for MF Final

Bates no 127

APPLICATION FOR ASSISTANCE OF A M KENZIE FRIEND
c
PART 4:SOURCE OF FUNDS
4 SOURCE OF CLAIMANT'S FUNDS
32. The bulk of Claimant's funds - some of which he now claims were passed to LPJS as loans
or TOLA TA conformable "contributions to property" - originated as compensation from
multiple personal accident and loss of licence insurance policies amounting to
fl,859,395.74 (Attachment 1).
19
33. The provenance of these funds as well as:

a. The Claimant's motivation for depositing £500,000 into LPJS mortgage account on
21 December 2016, in a panic, without any meaningful discussion or a line of
st
20
documentation. through a convoluted. manipulative process and;
b. His concealment of personal accident damages of £525,397.60 paid by AIG on 28 th
October 2016. Possibly equally important is why easyJet, who was in repeated and
direct contact with Kingsley Napley over all disclosure requirements, did not
21
independently report the AIG policy or show the premiums on his payslips ;
c. His motivation for, and efforts to. disassociate himself from all ownership interest
in the £500,000 paid to LPJS;

st
d. His refusal to give evidence in the Final Hearing of LPJS's divorce on 21 May
22
2018 and to clarify on oath whether the £500,000 was a loan or a gift 23 ; having
already told LPJS it was "our" money (see paragraph 72);
e. His determination to mislead Kingsley Napley 24 , Diamond Insurance, the Courts
and others by deception and perjury (see paragraph 100);

are fundamental to this case for three main reasons:

1. They are central to his credibility and his current but shamelessly untruthful
assertions that the £500,000 was an "agre in writ", under a 'Joint
5
undersnding", TOLATA "contribution which was "secu on Nutley Place2 ";
2. It supports LPJS's contention that the £500,000 was in every legal and other sense
a "gift" involving an unconditional transfer of title to her;

3. It is critical that the Court confirms the provenance of the Claimant's funds and
ensures that any redistribution of assets is not liable to proceeds of crime or
"fundamental dishonesty" reversal;

19 Including reimbursement of costs
20 The payment could have been made electronlcafly, but It would have shown the name of the beneficiary on the
statement
21 Col/us/on has not been eliminated
22 It was overwhelmingly In his interest to give evidence and to state Qf that were the case 7 that the £500,000 was a
loan. This Is another example of his determination to "disown" the £500,000. In fact, It Is Inconceivable that he
would not have given this evidence If the £500,000 was his.
23 Defined as (a) a voluntary transfer of property from one to another and (b) made without consideration
24 His sollc/tors
25 The home that LPJS had bought, was described In the Family Court as "sacrosanct" and was awarded to LPJS In Its
entirety
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