Page 129 - Bundle for MF Final

Bates no 128

APPLICATION FOR ASSISTANCE OF A M KENZIE FRIEND
c
PARTS 1 to 3: INTRODUCTION
23. They also attached an amended list of the personal effects the Claimant says he left in
Nutley Place (see paragraph 225).

24. They took the opportunity of adding an item which the Claimant had previously agreed
in writing LPJS could keep and another which he knew she had purchased from her own
funds.

25. LPJS believes that the Claimant's property schedules are contrived to harass her and her
family and have little merit. He chose to leave his property behind when he deserted his
adopted family in July 2018 and was given every opportunity since to recover it.
26. Efforts to identify and produce the Claimant's property have been hampered by MJC's
continuing illness and a serious, life-threatening accident involving one of LPJS's children.

3 EXTRA IMPORTANCE OF THE CMC-FDR

27. The failure to arrange a meaningful round table meeting results in the CMC-FDR being far
more complex than necessary. The following paragraphs set out the main points LP JS
urges the Court consider and to explain why she needs assistance from a McKenzie friend.

28. LPJS contends that the proceedings were launched by the Claimant with the vindictive 16
objective of evicting her and her children from their home and in the process acquiring an
interest in it to which he knows he is not entitled.

29. The following narrative - and LPJS's case in general - alleges that the Claimant has
employed a high degree of cunning to defraud insurance companies and steal an interest
in her home. She appreciates that the burden falls on her to prove this. Her solicitors were
strongly opposed to even hinting at dishonesty and warned that:

"Courts don't like to hear the P word" and "are woefully unqualified to deal with
7
it ......... .it will act against you".

LP JS trusts they were mistaken and urges the Court to permit her to present evidence
clearly and unemotionally. She will need assistance to do this.

30. This submission does not cover every point that might be relevant if the case proceeds to
trial. However, it is a fair and honest submission to show the complexity of the matters to
18
be confronted · Some paragraphs are for contextual and continuity purposes only. There
is some duplication, but this unavoidable.

31. Much of the evidence in this submission is based on documentation provided by the
Claimant when he sought MJCs advice about his insurance claims (see paragraph 89), was
left on LPJS's computer, transferred from family mobile telephones and recording
machines or copied from public records. It has all been lawfully obtained and is believed
to be admissible.

16 The Claimant left LPJS contrary to all his promises
17 Fraud

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