Page 207 - Bundle for MF Final

Bates no 206

CLAIM NO F00BN141
FIRST DEFENDANT'S POSITION STATEMENT

4. SOURCE OF THE CLAIMANT'S FUNDING

27 The Claimant initially expected to receive between £2,000,000 and £4,000,000 12
in compensation for what was little more than a minor hand injury and bruising to
his ribs and shoulder (See McKApp paragraph 5.1). Once he learned that Diamond
Insurance had admitted liability, his complaints of debilitating tinnitus appeared
( "like an AC/CD concert being in his head all day') that "put his passen at risk".
By its nature, tinnitus is largely self-diagnosed, and the Claimant exaggerated his.

28 He then set on a course to maximise his compensation (See the "Next Big One"
Exhibit C) and lied to his solicitors, insurers and advisors to achieve this. He was
confident that, at the right time, he could pass all medical examinations and get his
pilot's licence reinstated.

29 Soon after Diamond Insurance paid out a total of £469,000, the Claimant threw
out his medication and said, "I won't be needing this anymore"

30 The Claimant swore a number of iterations of the SCHEDULE [for the High Court]
which he knew to be false. His certification was as follows:

"loss of earnings and benefits
For the avoidance of doubt and in the spirit of openness, the claimant confirms
that he has rece insurance payments. Lump sum payments have been made for
the loss of his lice but under polici for which he himself paid These are
therefre irrevant to the claim. He has also receved income replacement
insurance, but the policy required him to make a subrogted claim on behalf of the
insure The claim is therefore for his full loss

13
This wording conceals the fact that he had received £525,397.60 compensation
under a personal accident policy (not a loss of licence) funded by easyJet (not by
"himself'). The Claimant admits concealing it.

31 The AIG policy is highly relevant because it duplicates the Diamond Insurance
coverage. In an email dated 7 October 2017 at 10.46, when he had little other
th
option but to tell the truth, the Claimant emailed the FD's father (see McKApp
paragraph 99 et seq).

I also received an accident Insurance payout from AIG through EasyJets company accident insurance which I haven't
mentioned to KN simply because they never asked for it. When KN asked for all records from HR in EasyJet they
have only supplied them my loss of llsence payouts from Hiscox and EasyJet, the AIG payout has not been
mentioned. I might be wrong here not disclosing AIG payout of £534000, but I wanted KN to maximise my claim In
the way of not finding excuses letting the Defendant off lightly.

32 This is a clear admission of fraud, perjury and his intent to mislead his legal and
other advisers.

33 The Claimant was worried - bordering on paranoia - that Diamond Insurance was
keeping him under surveillance, had accessed his bank accounts and would require
detailed financial disclosures, possibly on oath.

12 Which puts the £500,000 "gifi" into context
13 On 26th October 2016