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Mr. Shepheard, who had conduct
of the case, in the name of the Treasury Solicitor, on behalf of Judge
Simpson. and unlawfully, on behalf of Mrs. West, declined to correspond
with me, after I provided him with my affidavit, on September 17, 1996.
The affidavit accused him of perjury, and other unlawful acts, committed
for the protection of Judge Simpson. I cannot be sure that it was the affidavit,,
that contributed to the termination of his employment in the Office of
the Treasury Solicitor, but in any event I have not heard from him since.
PERJURY: Mr. Shepheard perjured himself, on December 1, 1995, by knowingly swearing a false affidavit.
FALSE STATEMENTS IN PARAGRAPH 3, OF HIS AFFIDAVIT.
False
Statement 1.
"On
the 12th September 1995, I finished drafting the 'Defence' of both Defendants'."
EVIDENCE THAT DEMONSTRATES
THE ABOVE FALSE STATEMENT FALSE.
i) AFFIDAVIT (disclosing
the false statements)
ii) DEFENCE
iii) FURTHER AND BETTER PARTICULARS
OF THE DEFENCE.
iv) BILLS OF COSTS.
a) The
clearly visible date September 5, on the completed Defence document:
admitted by Mr. Shepheard himself, in his affidavit, that he did delete
it, and substituted it with the date 12th;
b) the
fact that, if the drafting of the Defence, had truly been completed on
September 12, the deleted date 5th, could not appear on the finished
document;
c) the
fact, that the completed 'Defence', which was served, demonstrates, by
is own heading,t that it was started as the defence of both Defendants',
which fact, is again supported, by Mr. Shepheard himself, in the 1st, and
2nd sentences, of his paragraph 3, and the date 5th, which has been deleted
by him, as his paragraph 3, also confirms, demonstrates, that it was undoubtedly
completed, as both Defendants' defence, before the date: 5th was
added, at the end of the document;
d) the
amended date: 12th, is written in ink, demonstrating, that it was
added to the completed 'Defence', which is in type, as is the deleted
date 5th;
e) and it
is manifest, that if a defence document, admitted to have been started
as the Defence of both Defendants', is dated 5th, that it was completed
on that date, and it is also patently clear, that if further drafting of
material needed to be done, such drafting could not be added to a document
that has been typed up, and completed. If further drafting, or
drafted material, had to be added to the document, that was typed up, and
completed, the only possible way to add to it would be to prepare a
completely fresh document, and in such an event, it would necessarily
have to bear the typed date 12th, with no deleted, typed date
5th;
f) the
'Bill of Costs', (page 2) corroborates, that the Defence of the 2nd
Defendant, (and 1st Defendant) was prepared on September 5, and it discloses
no claim for work done on the 12th, the date that Mr.
Shepheard has sworn that he finished drafting the Defence;
On the face of the indisputable: original documentary evidence, that supports, and corroborates, a) b) c) d) e), and f), above, it is clear that Mr. Shepheard did not, finish drafting the 'Defence' on September 12. He has not, nor can he, provide any reasonable, or believable answer, to the allegation.
False
statement 2.
"
The Second Defendants' instructions to me on the 6th September, provided
me with material on which the pleading was finished on the 12th September."
EVIDENCE
THAT DEMONSTRATES, THAT THE ABOVE FALSE STATEMENT: IS FALSE.
g)
It is evident from the defence document itself; that not one piece
of material was provided by Mrs. West, and Mr. Shepheard will be unable
to point any out, when, and if my complaints to the Metropolitan Police,
are investigated, because not one particular for the denials of the allegations,
and stated known facts, on which my Statement of Claim relied, has been
provided, by either Defendant: contrary to the rules of the Supreme
Court;
h) it
is evident,, from Mr. Shepheard's reply, in paragraph 3, of the purported
'Further and Better Particulars' of the 'Defence', that the 2nd Defendant,
(Mrs. West) did not provide him with any material, on which the
pleading was finished: the reply given, by Mr. Shepheard is:
"The
Second Defendant is, in any event, entitled to claim the privilege, against
self-incrimination, to refuse to answer any
such question, or request."
The reply is,
in any event, untrue: designed to take advantage of my ignorance of the
law. He would not have served that reply, if I had been legally represented.
Mrs West, being a private citizen, is required to answer allegations of
criminal misconduct, as is everyone else. If it was, lawful for private
individuals to claim privilege against self-incrimination; there would
be no Courts: no Prisons: no Justice System. The false reply given, for
my eyes, indicates that Mr. Shepheard was desperately, trying to maintain
Mrs. West's silence, but more importantly, in the context of his false
affidavit, it is another indication that Mrs. West did not provide him
with material, with which the pleading was finished, on September 12, or
at any other time. If Judge Simpson was to be protected, to the best of
Mr. Shepheard's ability: the last thing that he wanted was for Mrs. West
to provide him with material.
POTENTIAL
EVIDENCE.
i)
Despite being considered to be a hostile witness, Mrs. West will be
unable to support Mr. Shepheards false statement, that she provided Mr.
Shepheard him with material, on September 6, or at any other time,, and
she will be unable to give details of any such evidence: unable
to point to any material, provided by her: there simply is not any. The
only evidence that she can possibly give, if she has a mind to do so, can
only support me: her accuser;
j)
she will be unable to support Mr. Shepheard's false affidavit:
that she: a private citizen, instructed him: a legal Officer: in the employ
of the Treasury Solicitor, to legally represent her. As a Court shorthand
writer, she knew, and knows, as does everyone else, that a private citizen
is not entitled to instruct a Government Department to legally represent
her, for an alleged corrupt act, out of public funds, or at all. Further,
is the indisputable fact, that Mrs. West who had already acknowledged
service of the Writ of Subpoena, nearly one month before September 6, stating
her intention of acting in person, and that indisputable fact, also reveals,
that she had no intention of instructing anyone, and had
no intention of providing material, which material, that she undoubtedly,
could have provided, would inevitably, have exposed the corrupt Judge Simpson.
False
statement 3.
"On
the 6th September, I received confirmation, through the Lord Chancellor's
Department,, from Mrs. West, that she wished the Treasury Solicitor to
act an her behalf."
EVIDENCE
DEMONSTRATING THE ABOVE FALSE STATEMENT: FALSE.
k)
The indisputable fact, that Mr. Shepheard, being a legal Officer, knows,
again, as we all do, that Mrs. West, being a private citizen, was, and
is not, entitled to the privilege of legal representation, by a Government
Department, for an alleged corrupt act, out of public funds: where vicarious
liability does not apply;
l)
The fact that Mrs. West, must have been aware, that she was not entitled
to instruct the Treasury Solicitor, nor to ask Mr. Shepheard to represent
her, in the name of the Treasury Solicitor, and it is most unlikely, that
a precedent can be found, where a private individual has informed, either
the Lord Chancellor, or the Treasury Solicitor, that the Treasury Solicitor's
legal representation is required. to defend an action alleging corruption,
and where such instruction has been obeyed;
m)
also the fact, that even had the above false statement been true, Mr.
Shepheard would have known, that to legally represent Mr. West, in the
name of the Treasury Solicitor, was unlawful.
POTENTIAL
EVIDENCE
n)
Mrs. West's potential answer, as to whether she informed, the Lord
Chancellor's Department, that she wished the Treasury Solicitor, to act
for her on, or before September 6, or at all;
o)
her potential evidence, as to whether she did, or did not, instruct
the Treasury Solicitor, through either the Lord Chancellor's Department,
or through Mr. Shepheard, to represent her;
p)
the non-existence of original or copy correspondence, between Mrs.
West, and the Lord Chancellor's Department, that confirms Mr. Shepheard's
false statement;
q)
her potential answer as to whether the Lord Chancellor's Department,
or the Treasury Solicitor's Office, contacted her, at any time before September
6,, to ascertain, whether she did wish the Treasury Solicitor to act for
her;
FURTHER
CONCLUSIVE DOCUMENTARY EVIDENCE OF MR. SHEPHEARD'S DECEPTION AND UNLAWFUL
REPRESENTATION OF MRS. WEST TO MAINTAIN HER SILENCE FOR THE PROTECTION
OF CIRCUIT JUDGE ALAN SIMPSON.
1.
Mrs. West's own 'ACKNOWLEDGEMENT OF SERVICE', which put her on lawful Court
record, as acting in person.
2.
The unlawful 'ACKNOWLEDGEMENT OF SERVICE' ', FILED While Mrs. West was
on lawful Court record, as acting in person.
3.
The unlawful transfer of proceedings to London, under Order 77, Rule 2.
Mr. Shepheard
did not trigger the transfer of proceedings, under Order 77, as he did
not take over conduct of the case until September 5, but he knew from that
date, that the action had been erroneously transferred, with false grounds
for the transfer having been stated on the acknowledgement of service form,
but he kept silent, until confronted, by Master Tennant two weeks later:
September 19; after my application, for the action to be re-transferred
back to Hull. The false grounds, that were submitted to the Action Department,
at the Royal Courts of Justice are:
a) that
the Defendants' residence is not within the district of the District Registry:
patently untrue;
and
b) that
there is no indorsement on the Writ that the Plaintiff's cause arose within
that district: again, patently untrue.
4. Unlawful 'NOTICE OF CHANGE OF SOLICITOR';
i)
Served by Mr. Shepheard, upon myself, and upon Mrs West, to draw her
attention to the fact that conduct of the case against her had been taken
from her, the 'NOTICE' being served, without it having been sealed by the
Court, and without it having been filed with the Court, contrary to
the rules of the Supreme Court, Order 67, r, 1. para. (1), and (3)
ii
The rules state that a change of Solicitor can take effect only from
the date that it is served, and filed. but Mr. Shepheard's unlawful 'Notice'
was not filed, and in any event, it purports to take effect from August
29, 1996: the date that the erroneous acknowledgement of service was
filed: over one month earlier.
ii)
The unlawful 'Notice' states:
a) To - The above named Second Defendant, Sheila Margaret
West: indicating;
that she had no knowledge, that Mr. Shepheard had any intention
of legally representing her, before September 22; that she could not
have instructed him, nor could she have provided material, before September
22; that the conduct of the case was indeed, taken away from her, without
her consent, and without her prior knowledge; that Mr. Shepheard could
not, and did not, finish drafting the Defence of both Defendants' on September
12:
b) states - The Treasury Solicitor has been appointed to act as the
Solicitor of the Second Defendant, in place of the Second Defendant, Sheila
Margaret West in person; demonstrating;
that because Mr. Shepheard had been appointed to act for Mrs. West, as
the 'Notice', dated September 22, informed her, he was not instructed,
by her on September 6, when she was on Court record, as acting in
person; Mrs. West is not in the position to appoint: ordain; anyone; if
she had truly either instructed, or appointed Mr. Shepheard she would not
have been notified of it, over two weeks later: Although Mr. Shepheard,
purports, to have been appointed, it is unrealistic to suppose, that either
Mrs. West, or whoever it was, that truly appointed him, would have instructed,
or ordered him, to commit corrupt acts, and if his appointment was one
of a judicial nature, it would be close to being unbelievable to most people,
although I have experienced exactly what can happen, when one of Her Majesty's
Judges' has acted corruptly: it is wrongly believed that a corrupt Judge
must be protected, for the good name of the Lord Chancellor's Department,
and for the good name of the English Justice System: utter rubbish.
I now rely
on the outcome of the Metropolitan Police investigation, into my allegations,
against Mr. Shepheard, in the knowledge that the matter of his serious
corrupt acts, including his perjury, can not be ignored. I have furnished
the Metropolitan Police with copies of all of the documentary evidence,
referred to here, and that organization now knows, that Mr. Shepheard has
absolutely no answer to my allegations, against him. I look forward to
criminal charges being laid against him. He will have no alternative, but
to admit to his corruption, in the knowledge, that the documentary evidence
would, in any event, prove the case, and in the knowledge that both
Mrs. West, and the person who he unlawfully protected: Judge Simpson, have
his measure. They; I believe, will admit that my allegations, against them,
are true, if, and when, they are charged to answer them.