Page 273 - Bundle for MF Final

Bates no 272

• Serving an entirely false Court Order, supposedly by District Judge Harvey, to the effect that
she and the Second Defendant must disclose privileged information relating to the Final
Hearing of their divorce as follows:

"All applications, statements, (including Forms E), affidavits, replies to questionnaires, position
statements and skeleton arguments draft.ed and provided by her or on her behalf in the Family
Proceedings which took place between the First and Second defendants and concluded on or about
June 20/8"

Judge Harvey in fact made no such order and your client has failed to confirm who drafted
that order and why an incorrect order was served upon our client. Our client's conclusion
is that your client was seeking to obtain disclosure to which he was not entitled and has
since delayed his detailed list and documents as ploy to gain an unfair advantage.

• Excluding her Position Statement from the bundle you were responsible for preparing for
the hearing at Brighton County Court on 28 January 2020. The failure to our client's position
statement appears to have misdirected the Judge in forming a view on the issue of your
client's will;

• Denying her the right of any assistance from any person as a McKenzie Friend at that hearing
and subsequently marginalizing her on the specious grounds that the case was "not
complicated" and that her father was antipathetic towards your client;

• Failing to produce disclosure listings in enough detail to enable us to inform our inspection.
Exchange of lists was due before 16.00 on 24 March 2020. On that day we advised you that
our detailed list (in fact running to over 78 specific items, by date and description) was
available for exchange. You responded stating your list was not ready and asking for a further
extension of three weeks. Your actions were interpreted by our client as an attempt to
obtain her listing without releasing your clients.

• On 25 March 2020, we agreed an extension of the directions in respect of directions to 30
March 2020. Less than 24 hours later we received a Form N265 which identified only five
broad categories of disclosure, which are so obscurely described as to be meaningless. The
form also claimed privilege over all documents relating to the source of your client's funding.
Those documents are highly relevant and key to his motivation for gifting £500,000 to our
client and thereafter totally disassociating himself from it. It is not at all clear why you stated
that you would require an additional three weeks to produce this document.

Our client remains committed to acting in good faith and to make every reasonable effort to disclose
and obtain the evidence necessary to reach a fair solution.