Maladministration insurance claim for none existent buildings

Dear Sir or Madam,

Will you confirm or deny under the Freedom of information Act it is
an act of maladministration for Sefton Council to affirms that an
insurance claim has been made against it for the demolition of none
existent buildings.

Yours faithfully,

fred robinson

Dear Hilary Pook,

I ask about a situation regarding a theoretical situation regarding
the ability of Sefton Council to make unfounded Insurance claims.
to what complaint do you refer.

Yours sincerely,

fred robinson

Dear Hilary Pook,

Can any Council, not only Sefton, issue claim to its insurers
regarding the demolition of none existent buildings and not fall
under the maladministration rules.

Yours sincerely,

fred robinson

Dear LGOAT Mailbox,

Dear Mr Buckley

I do not understand how your response deals with my FOI request as
it appears you are treating it as a complaint. Please answer the
FOI question.

Yours sincerely,

fred robinson

Dear Hilary Pook,

The Ombudsman has in fact found that Sefton Council can issue
fraudulent insurance claims to its insurers. the question is, is
this maladministation

Yours sincerely,

fred robinson

Dear Hilary Pook,

Can the complaint team deal with crime by the Ombudsman

Yours sincerely,

fred robinson

Dear Sir or Madam,

Can the complaint team deal with the crime of aiding and abetting
crime by the Ombudsman which the Ombudsman is fully aware of and
holds information from this year about.

Yours sincerely,

fred robinson

Dear Hilary Pook,

the one you refer me to of course.

Yours sincerely,

fred robinson

Dear Hilary Pook,

The "advice team" you refer me to to make a "complaint" to work on
behalf of the Ombudsman to do what? if not deal with complaints ?

Yours sincerely,

fred robinson

Dear Hilary Pook,

If you thought I was making a complaint about crime you are
mistaken.

And there was clearly no point in you mentioning to me a complaint
team that has no jurisdiction in the matter of crime.

I am informed by the Ombudsman the correct course in disputes about
the Ombudsman's findings is by way of a judicial review and
clearly, no "team" that deals with complaints can answer FOI
requests, otherwise they, and not you, would be dealing with me
now.

In the event it is not maladministration for a Council to make
fraudulent insurance claims, there would be no grounds for a
"complaint".

A "complaint" involves the complainant making a "complaint" to a
body on a specified matter that it has the power to resolve. I am
not making a "complaint", as I do not believe a "complaint" can be
made by way of the FOIA, you of course may be able to correct me on
that point if I am wrong.

My Request is with regard to: maladministration by a Council
arising from their processing a fraudulent insurance claim with the
resultant unjustified cost of thousands and thousands of pounds to
its Council Tax payers arising from the processing of a fraudulent
insurance claim regarding the demolition of none existent
buildings: and whether this is maladministration or not.

The fact that it may also be a crime, is something the police
disagree with me about and say is a civil matter, either way, it is
immaterial to the function of the Ombudsman.

The Ombudsman has it within its power to answer the request as to
whether the above circumstances are maladministration, and that is
what I have requested an answer to.

Yours sincerely,

fred robinson

Dear Hilary Pook,

I am asking to be advised about a matter of fact under the FOIA, if
this is not possible, please refer me to the legislation, not by
download but by reference to the particular section of the Act.

Yours sincerely,

fred robinson

Dear Hilary Pook,

Are you saying I now have right to ask the Ombudsman to decide this
question despite the fact that it relates directly to a fraudulent
insurance claim the Ombudsman has stated I could have made to the
Council's insurers and, despite her constructive knowledge that
such a claim was impossible and it is a complaint the Ombudsman has
consistently stated cannot be investigated by the Ombudsman as
there is a legal remedy available to me with regard to the
imaginary damage caused by this imaginary claim which is beyond her
jurisdiction.

Yours sincerely,

fred robinson

Dear Hilary Pook,

I request an internal review.

Yours sincerely,

fred robinson

Dear Hilary Pook,

I DRAW YOUR ATTENTION TO THE FOLLOWING:

Freedom of Information Good Practice Guidance No. 5

Time limits on carrying out internal reviews

following requests for information under the Freedom of Information
Act 2000 The Information Commissioner’s Office (ICO) has produced
this guidance as part of a series of good practice guidance
designed to help understand and apply the Freedom of Information
Act 2000 (FOIA). FOIA makes reference to complaints procedures at
section 45 (concerning the Code of Practice) and at section 50;
both relate to circumstances where an applicant wishes to complain
about the response of a public authority to a request for
information. The reference at section 50 concerns the discretion
that the Commissioner is allowed to exercise not to make a decision
in cases where a complainant has not exhausted a public authority’s
complaints procedure (also referred to as internal review). The
Commissioner considers it important that internal reviews are
completed as promptly as possible and so is introducing this
guidance setting out what he considers to be a reasonable timescale
for public authorities to undertake an internal review following a
request by an applicant. Section VI of the Section 45 Code of
Practice states that “each public authority should have a procedure
in place for dealing with complaints .... in relation to its
handling of requests for information.” This comprises desirable
practice for the purposes of FOIA, but it should be noted that
under the Environmental Information Regulations it is a requirement
for public authorities to consider representations made by
applicants for information. Consequently, most public authorities
under FOIA should already have the procedures in place to allow
them to perform an internal review. It is also important to note
that Refusal Notices must include either details of the public
authority’s complaints procedure or a statement that it does not
have one. This will assist the Commissioner in determining whether
or not an applicant, on making a complaint under section 50, has
exhausted the complaints procedure of the public authority.

The spirit of the Code is that internal reviews should be completed
as soon as possible. For example:

• a complaints procedure should be designed to allow prompt
determination of complaints (para 39) • target times should be set
for dealing with complaints (para 42).

• the code also recommends that the target times are reviewed
regularly and that each authority should publish them together with
information on its success in meeting those targets.

• there is also an implied recommendation, supported by guidance
issued by the Department for Constitutional Affairs, that the
complainant should be kept fully informed throughout the review
process. The Commissioner supports these recommendations and
intends, from time to time, to monitor conformity with them. Some
other factors to be noted are as follows:

• FOIA requires a request to be complied with “promptly and in any
event not later than the twentieth working day following the date
of receipt” which suggests that internal reviews should also be
completed promptly.

• Internal review is an important second opportunity for the public
authority to engage with an applicant and there are clear benefits
to both parties if the review is concluded within a reasonable
timeframe.

• The Freedom of Information Act (Scotland) 2002 stipulates an
internal review should be completed within 20 working days
following receipt of the request for review.

In view of all the above the Commissioner considers that a
reasonable time for completing an internal review is 20 working
days from the date of the request for review. There may be a small
number of cases which involve exceptional circumstances where it
may be reasonable to take longer. In those circumstances, the
public authority should, as a matter of good practice, notify the
requester and explain why more time is needed.

In our view, in no case should the total time taken exceed 40
working days. In such cases we would expect a public authority to
be able to demonstrate that it had commenced the review procedure
promptly following receipt of the request for review and had
actively worked on the review throughout that period. Some public
authorities have complaints procedures which have a number of
stages or levels. The Commissioner does not expect an internal
review of a response to an FOI request to have more than one stage.
Given that this is a review of a statutory process with clear
rights for requesters and obligations on public authorities, a
degree of formality is expected.

Enforcement

The Commissioner wants to ensure that a complainant has exhausted a
public authority’s internal review procedure, but at the same time
the complainant should not be unreasonably delayed in having his
complaint considered under section 50. Equally, it will be
beneficial to both complainant and public authority if an internal
review leads to a prompt and satisfactory outcome such that a
subsequent complaint to the Commissioner is not required. The
Commissioner has therefore set out above what he regards as
“reasonable” in terms of the timescale for completing an internal
review. He is keen to ensure that the time limit is adhered to and
that there are no unreasonable delays in carrying out reviews.

Internal reviews are referred to in the Code of Practice, and
significant or repeated unreasonable delays in dealing with
internal reviews may lead to monitoring by the Enforcement team
and, in some instances, structured intervention, for example, the
issuing of a Practice Recommendation. The Commissioner’s
Enforcement Strategy provides more detail about practice
recommendations and structured intervention.

More information

If you need any more information about this or any other aspect of
freedom of information, please contact us.

Phone: 08456 30 60 60 01625 54 57 45 (National rate) E-mail: please
use the online enquiry form on our website

Website: www.ico.gov.uk

AND

Annex 1 - Civil Service Values

1. The Civil Service is an integral and key part of the government
of the United Kingdom1. It supports the Government of the day in
developing and implementing its policies, and in delivering public
services. Civil servants are accountable to Ministers, who in turn
are accountable to Parliament2.

2. As a civil servant, you are appointed on merit on the basis of
fair and open competition and are expected to carry out your role
with dedication and a commitment to the Civil Service and its core
values: integrity, honesty, objectivity and impartiality. In this
Code:

• ‘integrity’ is putting the obligations of public service above
your own personal interests;

• ‘honesty’ is being truthful and open;

• ‘objectivity’ is basing your advice and decisions on rigorous
analysis of the evidence; and

• ‘impartiality’ is acting solely according to the merits of the
case and serving equally well Governments of different political
persuasions.

3. These core values support good government and ensure the
achievement of the highest possible standards in all that the Civil
Service does. This in turn helps the Civil Service to gain and
retain the respect of Ministers, Parliament, the public and its
customers.

4. This Code3 sets out the standards of behaviour expected of you
and all other civil servants. These are based on the core values.
Individual departments may also have their own separate mission and
values statements based on the core values, including the standards
of behaviour expected of you when you deal with your colleagues.

Standards of behaviour

Integrity

5. You must:

• fulfil your duties and obligations responsibly;

• always act in a way that is professional4 and that deserves and
retains the confidence of all those with whom you have dealings;

• make sure public money and other resources are used properly and
efficiently;

• deal with the public and their affairs fairly, efficiently,
promptly, effectively and sensitively, to the best of your ability;

• handle information as openly as possible within the legal
framework; and

• comply with the law and uphold the administration of justice.

6. You must not:

• misuse your official position, for example by using information
acquired in the course of your official duties to further your
private interests or those of others;

• accept gifts or hospitality or receive other benefits from anyone
which might reasonably be seen to compromise your personal
judgement or integrity; or

• disclose official information without authority. This duty
continues to apply after you leave the Civil Service.

Honesty

7. You must:

• set out the facts and relevant issues truthfully, and correct any
errors as soon as possible; and

• use resources only for the authorised public purposes for which
they are provided.

8. You must not:

• deceive or knowingly mislead Ministers, Parliament or others; or

• be influenced by improper pressures from others or the prospect
of personal gain.

Objectivity

9. You must:

• provide information and advice, including advice to Ministers, on
the basis of the evidence, and accurately present the options and
facts;

• take decisions on the merits of the case; and

• take due account of expert and professional advice.

10. You must not:

• ignore inconvenient facts or relevant considerations when
providing advice or making decisions; or

• frustrate the implementation of policies once decisions are taken
by declining to take, or abstaining from, action which flows from
those decisions.

Impartiality

11. You must:

• carry out your responsibilities in a way that is fair, just and
equitable and reflects the Civil Service commitment to equality and
diversity.

12. You must not:

• act in a way that unjustifiably favours or discriminates against
particular individuals or interests.

Political Impartiality

13. You must:

• serve the Government, whatever its political persuasion, to the
best of your ability in a way which maintains political
impartiality and is in line with the requirements of this Code, no
matter what your own political beliefs are;

• act in a way which deserves and retains the confidence of
Ministers, while at the same time ensuring that you will be able to
establish the same relationship with those whom you may be required
to serve in some future Government; and

• comply with any restrictions that have been laid down on your
political activities.

14. You must not:

• act in a way that is determined by party political
considerations, or use official resources for party political
purposes; or

• allow your personal political views to determine any advice you
give or your actions.

Rights and responsibilities

15. Your department or agency has a duty to make you aware of this
Code and its values. If you believe that you are being required to
act in a way which conflicts with this Code, your department or
agency must consider your concern, and make sure that you are not
penalised for raising it.

16. If you have a concern, you should start by talking to your line
manager or someone else in your line management chain. If for any
reason you would find this difficult, you should raise the matter
with your department’s nominated officers who have been appointed
to advise staff on the Code.

17. If you become aware of actions by others which you believe
conflict with this Code you should report this to your line manager
or someone else in your line management chain; alternatively you
may wish to seek advice from your nominated officer. You should
report evidence of criminal or unlawful activity to the police or
other appropriate authorities.

18. If you have raised a matter covered in paragraphs 15 to 17, in
accordance with the relevant procedures5, and do not receive what
you consider to be a reasonable response, you may report the matter
to the Civil Service Commissioners6. The Commissioners will also
consider taking a complaint direct. Their address is:

3rd Floor, 35 Great Smith Street, London SW1P 3BQ.
Tel: 020 7276 2613
email: [email address]

If the matter cannot be resolved using the procedures set out
above, and you feel you cannot carry out the instructions you have
been given, you will have to resign from the Civil Service.

19. This Code is part of the contractual relationship between you
and your employer. It sets out the high standards of behaviour
expected of you which follow from your position in public and
national life as a civil servant. You can take pride in living up
to these values.

June 2006

Yours sincerely,

fred robinson

Dear Hilary Pook,

FOR YOUR INFORMATION: MY FOI REQUEST:

I FIRST REFER YOU TO THE LETTER BELOW I WROTE TO MRS THOMAS, THE
LGO ON JULY 9TH 2001

YOUR REF: 00/c/17558/pat 3/am

I refer you to a letter from Mr Oxley to myself dated 23/2/01 in
which he summarised my complaint against SMBC as

"that the Council issued a claim to its insurers without your
knowledge or permission"

I refer you to my reply dated 27/3/01 which corrects this
summarisation and states the complaint to be that the Council
issued a claim to their insurers based on information they knew to
be false.

The information that I had issued a complaint to the Council as
summarised by Mr Oxley on 23/2/01 was forwarded to the Council.
The
Council responded to that complaint , not my actual complaint.

It appears that the complaint I am really pursuing has not been
addressed despite the many references to it in the correspondence
to your office reproduced below.

10/11/00 + 18/12/00 There is now another issue that I wish to make
a complaint about, this is that the Council have issued a 'claim'
or 'potential claim' to their insurers in regard to my property,
based on information known by then to be false.

28/12/00 Thank you for your acknowledgement of my letter of 18th
December 2000, you do not make it clear if you will respond to my
further complaint against Sefton MBC in regard to the improper
insurance claim they allege I have made.---Will you please inform
me if you are treating my complaint to you that Sefton MBC have
acted incorrectly by issuing an improper insurance claim,
allegedly
from me, based on information they know to be untrue.

6/2/01 Thank you for your acknowledgement of my letter of 18th and
28th December 2000, you do not make it clear if you will respond
to
my further complaint against Sefton MBC in regard to the improper
insurance claim they allege I have made.---

Will you please inform me if you are treating my complaint to you
that Sefton MBC have acted incorrectly by issuing an improper
insurance claim, allegedly from me, based on information they know
to be untrue, as a matter of maladministration.---

My letter to you of 24th January 2001 you required more than an
acknowledgement, in it I asked it you were accepting that Sefton
MBC had committed an act of maladministration by issuing an
insurance claim to their insurers based on information they knew
to
be incorrect. As requested on 24th January 2001, will you answer
the question of whether you are accepting the complaint of
maladministration in regard to the insurance claim based on false
information submitted by SMBC to their insurers

Over the past months I have provided you time and again with the
evidence and references that confirms the above. The overwhelming
evidence is that SMBC have without a doubt acted in a manner
calculated to pervert the facts and conceal their misdeeds at my
expense. This has been done by the calculated use of
misinformation, lies and failure to provide answers to my
legitimate and justifiable questions.

23/2/01 The Council as far as I can establish have no liability in
regard to any damage to my property at any time after 14/3/94. If
this is the case it follows that they have issued false
information
to myself and their insurers.

1/3/01 The Council as far as I can establish, based on ownership
and possession by others, have no liability or indemnity in regard
to any damage to my property at any time after 14/3/94. If this is
the case it follows that they have issued false information to
myself and their insurers the purpose of which appears to
constitute maladministration and an attempt to cover up
wrongdoing.
It also means that indemnity would not be provided to me (if
claimed) by their insurers.

Will you please keep me informed of what the Councils response to
my complaint is and give me the opportunity to check their
response
with evidence I possess?

28/3/01 I do feel there are things in SMBC's letter to you that are
incorrect and require clarification but they may become academic
if
the period of SMBC's legal liability and indemnity does not extend
beyond 14/3/94 when the developer who was also the site owner,
took
possession. My complaint is that SMBC issued claims to their
insurers about damage to my property which contained information
known to SMBC, at the time they issued these claims, to be untrue
and that they did this with the knowledge that they had no legal
liability to do so on either one or both of the occasions they did
so.

Clearly my complaint that the Council issued a claim based on
information known to them to be false at the time they issued the
claim has not been addressed. Do you intend to do so ?

I also refer you to Mr Oxleys statement in his letter to me dated
11/4/01 that "It is also a matter for the insurers to decide
whether any time limitation applies to your claim".

This statement is factually and legally incorrect on the basis that
the claim referred to was issued on the false information that it
was for damage caused to my property for which the Council had no
liability for and was allegedly linked to a previously false claim
for unspecified damage to my property.

You are of course aware that status barring is statute law and as
such cannot be affected by an insurance company, this is in fact
confirmed by the insurers themselves.

The fact that the Council assert they had no involvement with the
site concerned after 1/4/94 means that the alleged claim made by
myself for damage occurring after 21/4/94 was a false claim.

The assertion that ownership of the land was stated by the Council
to be unknown to the Council on 30th June 2000 is unlikely, the
ensuing claim by the Council to their insurers could not have been
made if the ownership on the land was not theirs as liability goes
with the ownership of the land. As you and the Council know.

It appears that the claim was issued either with the knowledge that
the land was not owned by the Council or that the claim was made
without the ownership of the land being established or that the
Council did in fact own the land.

The matter of ownership of the land, with regard to compensation,
was first raised on 31st May 2000 by the surveyor who conducted a
survey at my property on 19th May 2000. The Council then wrote to
me on 30th June 2000 to assert the ownership of the land was not
known to them. The Council had at that time, had a month to
ascertain the ownership of the land and yet had not done so,
implying they did not know that the land had been owned by
Maritime
Housing since 21st January 1994. The knowledge of ownership would
have also made a claim to their insurers impossible as liability
goes with ownership.

On 3rd October 2000 I wrote to the Land Registry requesting details
of ownership of the land concerned. On 6th October 2001 I received
the information that since 21st January 1994 the land had been in
the ownership of Maritime Housing.

The tactic employed by the Council is to ignore facts and
information supplied by myself, this tactic, it appears, is being
employed by your office as there seems to be no credibility given
to my complaint that the Council have and still are lying to me.
Nor is the fact that you clearly avoid revealing that the Council
have not provided the information that they were not liable or
insured for any damage to my property occurring after 14th March
1994 which is proven to be the period when damage occurred. To do
this you are ignoring the law, which I assert is irrational.

The Council asserted that I was told to write my letter of
complaint to them to re-open an insurance claim and this would
suspend time limitation. If this were true time limitation would
have been suspended. After consultation with the insurance section
of the Council Mr Williams stated that time limitation would be
decided by the insurers. The insurers state time limitation is a
matter for the courts. Is it credible that Mr Oxley and yourself
do
not know about time limitation ? With respect, I think not.

I refute the assertion that the letter I wrote to the Council
on18th April 2000 was a claim, it was written as a complaint as
the
result of being told by Mr Williams it would stop lime limitation.

I ask you to respond to all the above facts and explain why you
have not taken them into consideration before rejecting my
complaint.

THEN:

In March 2003 I obtained my personal data from Sefton Council which
revealed to me the basis of the fraudulent "Insurance Claim" I had
supposedly made against the Council in 1993 referenced W215732 and
its alleged "reopening of claim RR98XN dated April 18th 2000
which,
has been the subject of Sefton Council's letter to the Ombudsman
on
March 15th 2001, Clearly the situation had changed and I wanted
the
Ombudsmans decision reversed. I had enlisted my MP's help in this
matter and he had contacted the Ombudsman on my behalf:

ON JUNE 24TH 2003, MRS BELLWOOD OF YOUR OFFICE WROTE TO ME
REGARDING A "FURTHER COMPLAINT AGAINST SEFTON METROPOLITAN
COUNCIL"...and stating ...WE NEED INFORMATION TO HELP US ACHIEVE
THIS."

I NOW REFER YOU TO A FURTHER LETTERS TO MR BARHAM AT YOUR OFFICE
REGARDING THE OMBUDSMANS DECISION ABOUT SEFTON COUNCIL'S
"INSURANCE
CLAIMS":

Letter to Mr Barham dated June 26th 2003:

Your Ref:03/C/04380/PIB

Probably in 1993 or 1994 Sefton MBC (SMBC) invented a claim against
themselves and credited it to myself. This claim was referenced
W215732.

In October 1999 I became aware of this claim when Maritime Housing
Association told me that SMBC had informed them that I had made
this claim in 1993. This claim was declared by SMBC to have been
for damage to my gable wall. When I challenged this assertion SMBC
refuted it by declaring that it was legitimate information
supplied
to Maritime under a contractual agreement and that it had been
supplied to them in "good faith."

On obtaining my data via the IC in March this year I discovered
that this claim is declared to be for damage to my property -
especially the gable wall - caused by the demolition of 21 Lime
Grove which SMBC declare was adjoined to my property at the time
it
was demolished in the 1960's.

As you see from the OS map I have sent you 21 Lime Grove was a
detached house and never adjoined number 19. My wife and I
purchased 19 Lime Grove in 1972 when 21 Lime Grove had been
demolished and maisonettes built in its place.

I ask that you have claim W215732 investigated and inform me of the
result as a matter of urgency, given the clear evidence that it
could not exist.

Letter to Mr Barham June 26th 2003

I refer to your telephone call on July 7th 2002.

Due to the long standing and serious nature of my compliant I do
not consider it appropriate to discuss it by telephone.

This matter requires that all the parties understand what has been
said to whom and, I must stress to you that part of the problem is
that in the past the lack of written confirmation has allowed this
matter to be manipulated by Sefton Council and others.

I regret this situation has arisen but had the matter been fully
investigated in the past, this would not be the case.

ON JULY 11TH 2003 MR BARHAM WROTE THE FOLLOWING TO ME:

"YOUR COMPLAINT AGAINST SEFTON...HAS BEEN PASSED TO ME...I HAVE
SEEN A COPY OF A LETTER FROM THE OMBUDSMAN TO MR J BENTON MP DATED
29 JANUARY 2002IN WHICH SHE SAID THAT IT HAD BEEN DECIDED NOT TO
INVESTIGATE YOUR COMPLAINT BECAUSE OF THE LENGTH OF TIME THAT HAD
PASSED...AND BECAUSE THERE WAS A LEGAL REMEDY AVAILABLE TO
YOU...AS
FAR AS I CAN SEE, THE ISSUES YOU ARE NOW BRINGING TO THE
OMBUDSMANS
ATTENTION APPEARS TO BE TO BE ABOUT THE SAME CONCERNS WHICH THE
OMBUDSMAN CONSIDERED TWO YEARS AGO...YOUR RECENT LETTER DOES NOT
GIVE THE OMBUDSMAN ANY REASON TO BEGIN AN INVESTIGATION INTO A
FURTHER COMPLAINT...I APPRECIATE THE INFORMATION YOU HAVE SENT MAY
ONLY RECENTLY HAVE COME TO LIGHT BUT THAT DOES NOT ALTER THE FACT
THAT YOU COULD HAVE MADE A COMPLAINT TO THE OMBUDSMAN WITHIN THE
NORMAL TWELVE MONTHS REQUIRED BY THE LOCAL GOVERNMENT ACT 1974.
NOR
DOES IT ALTER THE FACT THAT THERE WAS A LEGAL REMEDY AVAILABLE TO
YOU. IT DOES NOT APPEAR THEREFORE THAT THE OMBUDSMAN HAS REASON TO
OPEN A NEW INVESTIGATION.

AND

July12th 2003:

Thank you for your letter dated 11th July 2003.

SMBC declared that by the demolition of an adjoining building in
the 1960's the former party wall between 19 and 21 Lime Grove
became the gable wall of 19 Lime Grove. This is untrue.

In October 1999 SMBC declared to Maritime Housing Association that
I had made a claim against SMBC with regard to the damage in 1993,
i.e. damage to my gable wall caused primarily by this demolition
in
the 1960's. This claim is referenced W215732 and is declared by
SMBC to Maritime to be for "cracking and deterioration to my gable
wall." This is untrue.

With regard to claim W215732, SMBC's insurance brokers wrote to me
on August 19th 2002 and declared that claim W215732 was with
regard
to an incident on January 1st 1994. This is untrue.

The misinformation regarding this alleged claim - W215732 - which
was supplied to Maritime by SMBC became the basis of my compliant
to SMBC on November 4th 1999 and to yourselves on January 30th
2000.

Clearly the determination of that complaint by yourselves was based
on deceitful information provided to Maritime and myself by SMBC.
Dated January 1994 - not 1993.

I would also point out to you that as no damage to my property was
caused by claim W215732 dated 1st January 1994, no legal remedy
could have been in existence regarding it.

I request that you copy all the evidence - including that sent
today - I have sent to you since June this year and return the
originals to me.

Enclosed. Maritimes Letter dated October 22nd 1999. Aon's Letter
dated August 19th 2002.

ON JULY 23RD 2003 MR BARHAM WROTE THE FOLLOWING TO ME:

"I NOTE WHAT YOU SAY ABOUT THE DISPUTE AS TO WHETHER YOU HAD MADE
AN INSURANCE CLAIM...THE ONLY SUBSTANTIVE COMPLAINT I CAN SEE, IS
THAT WHICH THE OMBUDSMAN HAS ALREADY CONSIDERED AND HAS DECLINED
TO
PURSUE FURTHER...I AM SENDING A COPY OF THIS LETTER TO THE CHIEF
EXECUTIVE OF SEFTON METROPOLITAN BOROUGH COUNCIL TO LET HIM KNOW
THE POSITION."

AND

Mr Barham July 24th 2003

Thank you for your letter dated July 23rd 2003.

I wish to point out to you that your assertion that my complaint
has been dealt with and that the means to resolve it was to take
legal action is incorrect.

My complaint has never been dealt with as I had no knowledge of
claim W215732 until March this year.

SMBC clearly state that this claim was made by myself in 1993.

This is prior to any other alleged claim made by myself regarding
damage to my property on 1994.

Claim W215732 is in no way linked to any further claim as it
regarding alleged demolition in the 1960's which is proven could
have not damaged my property in the manner SMBC declare.

There is no legal action I can take regarding claim W215732 for
there is no damage to my property to claim for, nor any reason for
SMBC to deal with it.

My former solicitors confirm this and therefore your assertion that
my current complaint is "whether you had made an insurance claim"
is in error.

The fact is that I did not , nor could have made a claim regarding
W215732 as W215732 is an invention of SMBC which was then reported
to Maritime Housing Association in February 1999.

I enclose Mr Barrs assertion that primary damage was caused to my
property and is clearly false as is his assertion that my property
was formally mid terrace.

To be clear. I wish to make a complaint that this false claim
W215732 has nothing to support it in fact, and its invention is a
deliberate act of maladminisration, which despite my best efforts
was withheld from me for many years in the furtherance of claim
W215732 to my disadvantage.

Enclosed: Letter to MHA from Barr. Dated February 1999 Letter from
SMBC's CEO date May 1st 2002 Letter to SMBC's Legal Department.
Dated 26 November 2002 RSVP"

ON AUGUST 7TH 2003 MR HOBBS THE ASSISTANT DIRECTOR WROTE THE
FOLLOWING TO ME:

"MR BARHAMS LETTER OF 23 JULY GAVE THE REASON WHY THE OMBUDSMANS
DECIDED NOT TO PERUSE YOUR COMPLAINT. I HAVE READ THE PAPERS, AND
SEE NOTHING TO SUGGEST THE DECISION WAS WRONG...THE OMBUDSMAN
REMAINS UNABLE TO HELP YOU AND MR BARHAMS DECISION MUST STAND

On August 7th 2003 Aon, Sefton's Claims Managers wrote the
following to me in a letter headed "Our Ref: W215732

Our Client: Sefton Council

Re: Public Liability Claim:

Incident: 01 January 1994,

We would respectfully reiterate that you refer this matter to your
legal advisor."

I WROTE THE FOLLOWING TO MR HOBBS ON AUGUST 8TH 2003

Thank you for your letter dated August 7th 2003.

I note your position regarding the false claim W215732 and your
evident support of it, will you affirm this is the case.

I regard this as irrational and point out to you that claim W215732
is still being dealt with by SMBC as if it exists, it does not ,
nor ever has.

I request that you return to me all the copies of documents I have
sent to you over the past months and copies of my own letters to
yourselves.

On August 18th 2003 Aon, Sefton's Claims Managers wrote the
following to me in a letter headed Our Ref: W215732:

"Our Client: Sefton Council

Re: Public Liability Claim:

Incident: 01 January 1994,

We can merely reiterate that you refer this matter to your legal
advisor."

ON AUGUST 26TH 2003 SEFTON COUNCILS FINANCE DIRECTOR (with
constructive knowledge of my letters to the Ombudsman), WROTE (pp
Ms Swale), THE FOLLOWING TO ME:

"Further your letter dated 14th August 2003 regarding clarification
of claim W215732. I attach photocopies of the letters from your
solicitors dated 26th January 1995 and 29th November 1995 which
clearly state they are making a claim pon your behalf."

On September 1st 2003 Aon, Sefton's Claims Managers wrote the
following to me in a letter headed Our Ref: W215732:

"Our Client: Sefton Council

Re: Public Liability Claim:

Incident: 01 January 1994,

We can only reiterate that you refer this matter to your legal
advisors as before."

ON AUGUST 21ST 2003 MERSEYSIDE POLICE WROTE THE FOLLOWING TO ME IN
A LETTER HEADED, ALLEGATIONS AGAINST SEFTON MBC EMPLOYEES:

"THE ABOVE MATTER HAS BEEN EXAMINED BY A SENIOR DETECTIVE FROM THIS
AREA...AND OUR FORCE SOLICITOR. IT IS AND WILL REMAIN A CIVIL
MATTER. I WILL NOT ENTER INTO ANY MORE CORRESPONDENCE WITH YOU IN
RESPECT OF THIS CASE. THE COUNCIL IN THE FORM OF MR WILLIAMS
(TECHNICAL SERVICES DIRECTOR) CONFIRMS THAT HE HAS BEEN DEALING
WITH YOUR CASE AND ACCEPTS THERE HAS NEVER BEEN A FORMAL CLAIM IN
YOUR NAME. I SUGGEST THAT YOU REFER THE MATTER TO A SOLICITOR AND
THE DOCUMENTATION WE HAVE WILL BE KEPT FOR SIX YEARS PENDING ANY
CIVIL ACTION YOU MAY TAKE."

ON SEPTEMBER 2ND 2003 I WROTE THE FOLLOWING TO MR HOPE AT AON:

As you know from 2 unanswered letters to yourselves dated May 19th
and July 12th 2002, (both copied to Merseyside Police as this
letter will be) several senior members of SMBC, have affirmed to
me
that claim W215732 is a claim made by my solicitors in relation to
a letter from my solicitors dated January 26th 1995 regarding
damage to my property. The damage my solicitors refer to was that
caused by the demolition of the maisonettes at Kepler Street,
Seaforth, Liverpool between March 14th and April 6th 1994 and
notified by me to SMBC on April 6th 1994. This alleged damage was
acknowledged pp by Mr Barr on April 15th 1994 and is affirmed by
both SMBC and Royal & SunAlliance to be the responsibility of
Fawley.

On February 27th 1996 Ms E Smith Senior Claims Officer SMBC
contacted you by Fax regarding claim W215732. She sent you a memo
referenced W215732 sent to her by Mr Barr dated February 27th
1996.

In his memo Mr Barrs affirms that.

"Mr Robinson did not claim that his problems had been caused by
either the demolition or redevelopment contract," and that. "The
problem occurred sometime before either the demolition or
redevelopment contract" and that the problem was related to. "Work
carried out on what was presumably a former party wall and is now
the gable wall of the dwelling."

You formulated a series of questions from and, based on Mr Barrs
memo to be sent to my solicitors

On March 8th 1996 you wrote to Ms Smith in a letter headed, Claim
No W215732 Robinson, and enclosing your proposed reply to my
solicitors - W215732/TSH/BN/lt7 March 20th 1996 - your letter
clearly refers to the alleged damage to my property caused when
the
party wall was transformed into a gable wall -

"the work carried out on what is now the gable wall of 19 Lime
Grove"

- and therefore, claim W215732 is with regard to the alleged
transformation of the party wall between 19 and 21 Lime Grove into
a gable wall - which neither Fawley or GTB Demolition Ltd were
involved in as it never occurred - and not the damage caused by
the
demolition of the maisonettes

I formally ask that you confirm claim W215732 was not with regard
to damage to my property caused by the demolition of the
maisonettes at Kepler Street in March 1994 but damage allegedly
caused by the transformation of the party wall between 19 and 21
into a gable wall at some earlier time and, evidently was made in
1993 based on letters I wrote to SMBC at that time. I also request
that you inform me if claim W215732 was a formal claim against
SMBC.

I enclose an OS map of 19 and 21 Lime Grove from the 1960's proving
unequivocally that no such transformation of a party wall into a
gable wall could have occurred, and Mr Barrs affirmation to my
Solicitors dated March 7th 1995 declaring survey information about
this damage (which was, and never could have been taken) indicated
this damage had occurred prior to 1994.

ON SEPTEMBER 3RD 2003 MR BARHAM WROTE THE FOLLOWING TO ME:

"THANK YOU FOR YOUR LETTER RECEIVED ON 11 AUGUST. WHEN I WROTE TO
YOU ON 23 JULY I SENT YOU COPIES OF ALL THE PAPERS YOU HAD SENT US
SINCE JUNE WHICH WAS YOUR FIRST CONTACT WITH US THIS YEAR. I AM
NOW
ENCLOSING COPIES OF ALL THE LETTERS AND OTHER PAPERS YOU HAVE SENT
US SINCE 23 JULY 2003."

ON SEPTEMBER 4TH 2003 IN A LETTER REFERENCED W215732, AON'S MR HOPE
WROTE THE FOLLOWING TO ME FROM AON,S MANCHESTER ADDRESS:

"I UNDERSTAND THAT THIS MATTER IS NOW BEING DEALT WITH BY OUR
OFFICE IN SHEFFIELD AND THEY WROTE TO YOU ON 1ST SEPTEMBER 2003."

ON SEPTEMBER 5TH 2003 MERSEYSIDE POLICE WROTE THE FOLLOWING TO ME:

"I HAVE FULLY INVESTIGATED YOUR ALLEGATIONS OF POSSIBLE CRIMINAL
CONDUCT BY SEFTON MBC'S EMPLOYEES AFTER OUR MEETING ON 22 JULY.
YOUR ALLEGATIONS SURROUND THE FACT THAT REFERENCE HAS BEEN MADE BY
THEN TO A 'CLAIM' THAT THEY ALLEGE YOU HAVE MADE AGAINST THEM. YOU
DISPUTE EVER HAVING MADE ANY CLAIM. AS A RESULT OF OUR MEETING I
CONTACTED MR WILLIAMS FROM SEFTON MBC. HE INFORMED ME THAT LETTERS
THAT YOU HAD WRITTEN TO THEM HAVE BEEN TREATED AS A CLAIM AGAINST
THEM. I AM SATISFIED THAT THERE IS NO CRIMINAL CONDUCT IN THIS
MATTER AND I TELEPHONED YOU THE FOLLOWING DAY AND LEFT A MESSAGE
ON
YOUR ANSAPHONE, AS YOU REQUESTED, TO THAT EFFECT. THIS IS THE END
OF THE POLICE INVESTIGATION. I WILL NOT ENTER INTO ANY FURTHER
COMMUNICATION WITH YOU IN REGARD TO THIS MATTER AND I SUGGEST YOU
CONTACT A SOLICITOR IF YOU REQUIRE FURTHER ADVICE:

ON SEPTEMBER 25TH 2003 I WROTE THE FOLLOWING TO MRS THOMAS THE LGO:

On December 18th 2000 I wrote the following to you:-

"There is now another issue that I wish to make a complaint about,
this is that the Council have issued a 'claim' or 'potential
claim'
to their insurers in regard to my property, based on information
known by then to be false."

This was acknowledged on December 21st 2000.

This became formal complaint: 00/C/17558/PAT/pmc - then
00/C/17558/CSO/pmc, which was rejected by your office.

The only reason for this rejection - that I was ever informed of -
was contained in a letter, written to Mr Oxley by Sefton Councils
Legal Director, Mr Bownes on March 15th 2001, which I contested,
but was evidently not considered by yourselves, i.e. on March 27th
2001 I wrote the following to Mr Oxley:-

"My complaint is that SMBC issued claims to their insurers about
damage to my property which contained information known to SMBC,
at
the time they issued these claims, to be untrue."

Will you please confirm, as a matter of urgency, that this letter
from Mr Bownes to Mr Oxley of March 15th 2001, confirming that
these claims had been made, was the only reason for the rejection
of complaint 00/C/17558/CSO/pmc - 00/C/17558/PAT/pmc.

The matter of false claims is now in the hands of the court and I
need to confirm that I have had complaint 00/C/17558/CSO/pmc
rejected on the basis of Mr Bownes letter.

ON OCTOBER 6TH 2003 MRS THOMAS WROTE THE FOLLOWING TO ME:

"I CANNOT SEND YOU ANY INFORMATION IN ADDITION TO THAT WHICH HAS
ALREADY BEEN SENT TO YOU. NOR CAN I ALLOW ANY MORE OF MY OFFICERS
TIME TO BE SPENT ON THIS MATTER. FURTHER CORRESPONDENCE FROM YOU
MAY NOT RECEIVE A REPLY."

ON OCTOBER 15TH 2003 ROYAL & SUN ALLIANCE WROTE THE FOLLOWING TO
'STEVE', AND COPIED TO SEFTON'S MS SMITH UNDER THE REFERENCE'S
W215732 (JANUARY 1ST 1994) AND RR98XN (JANUARY 17TH 1994)."

"I ENCLOSE A COPY OF MR ROBINSONS LATEST LETTER WHICH WE RECENTLY
RECEIVED TOGETHER WITH OUR RESPONSE ON 10 OCTOBER. IN VIEW OF THE
LONG STANDING CIRCUMSTANCES WE WILL NOT ACKNOWLEDGE ANY FURTHER
CORRESPONDENCE FROM MR ROBINSON,"

ON OCTOBER 30TH 2003 MY SOLICITORS WROTE THE FOLLOWING TO ROYAL &
SUNALLIANCE N MY BEHALF:

"WE WOULD BE MOST GRATEFUL IF YOU WOULD CLARIFY WHETHER YOUR
REFERENCE RR98XN, IS IN FACT A REFERENCE TO A CLAIM WHICH ALSO HAS
THE CLAIM NUMBER RR98XN."

ON NOVEMBER 25TH 2003 ROYAL 7 SUNALLIANCE WROTE THE FOLLOWING TO MY
SOLICITORS:

"in response to your query "W215732" is the reference used by our
insureds brokers, Aon to identify this particular matter. our
reference for the same matter is "RR98XN". there was a previous
reference or claim number that was used in connection with this
matter by ourselves and that was "31/AT01939/96".

ON NOVEMBER 25TH 2003 SEFTONS DATA PROTECTION OFFICER RECEIVED THE
FOLLOWING IN A LETTER TO HER FROM THE INFORMATION COMMISSION
REGARDING MY DATA SUBJECT APPLICATION FOR MY PERSONAL INFORMATION
FROM1994 REFERENCED 03_36590/06/AD, WHICH HAS NOT BEEN PROVIDED TO
ME IN MARCH 2003, AD STATED:

"MR ROBINSON HAS ALLEGED THAT HE HAS NOT RECEIVED A COMPLETE
RESPONSE TO HIS SUBJECT ACCESS REQUEST///MR ROBINSON CONTENDS THAT
HE HAS NOT BEEN PROVIDED WITH ANY INFORMATION FROM 1994...MR
HUFF'S...RESPONSE TO MR ROBINSON CONCERNS THAT MISSING INFORMATION
FROM 1994...A NUMBER OF INFERENCES COULD BE TAKEN FROM MR HUFF'S
RESPONSE. THESE INCLUDE:

THE COUNCIL HOLDS NO PERSONAL DATA ABOUT MR ROBINSON RELATING TO
1994.

THE PERSONAL DATA ABOUT MR ROBINSON RELATING TO 1994 IS COVERED BY
AN EXEMPTION GRANTED BY THE DPA.

ANY PERSONAL DATA HELD RELATED TO 1994 IS NOT HELD AS PART OF A
RELEVANT FILING SYSTEM."

I WOULD BE GRATEFUL, THEREFORE, FOR YOUR CLARIFICATION AS TO WHY MR
ROBINSON HAS NOT BEEN PROVIDED WITH ANY PERSONAL DATA HELD ABOUT
HIM FROM 1994..I WOULD BE HELPFUL IF YOU COULD PROVIDED ME WITH
CLARIFICATION...HE IS ENTITLED TO A RESPONSE WITHIN THE NEXT 28
DAYS."

ON NOVEMBER 26TH 2003 MR BENTON MP WROTE THE FOLLOWING TO ME:

"Correspondence that I have copied to Council Officers was in an
effort to work with them to try to resolve your ongoing
problems...it-is only by copying your letters to the Council that
the gist of your complaints and queries could be adaquatly relayed
to them."

ON DECEMBER 8TH 2003, WITH REGARD TO A COMPLAINT I HAD MADE TO MY
SOLICITORS REGARDING THE CONDUCT OF THE POLICE, THEY WROTE THE
FOLLOWING TO ME REGARDING AN HOUR LONG TELEPHONE CONVERSATION I
HAD
HAD WITH THEM:

"YOU WILL RECALL...I ADVISED YOU TO WRITE TO ROYAL & SUN ALLIANCE
AND SEFTON REQUESTING CONFIRMATION AS TO WHETHER THEY ARE PREPARED
TO PROVIDED YOU WITH DETAILS OF ANY CLAIM WHICH MAY HAVE BEEN
BROUGHT BY YOURSELF AND DOCUMENTARY EVIDENCE IN SUPPORT OF
THIS...IF YOU DID NOT RECEIVE A RESPONSE WITHIN 14 DAYS THEN YOU
WOULD ASSUME THAT NO SUCH ACTION EXISTED AND FURTHERMORE YOU WOULD
RELY UPON THOSE LETTERS WHEN ATTENDING BEFORE A DISTRICT JUDGE."

THESE LETTERS WERE WRITTEN AND NO EVIDENCE OF WAS, OR EVER HAS BEEN
PROVIDED BY SEFTON TO JUSTIFY CLAIM W215732 DATED 1993, JANUARY
1ST
AND 17TH 1994 (RR98XN).

ON JANUARY 28TH 2004 ROYAL & SUNALLIANCE WROTE TO ME, WITH REGARD
TO CLAIM RR98XN DATED JANUARY 17TH 1994, STATING:

"WE HAVE SENT YOU ALL OF YOUR PERSONAL INFORMATION DATA IN NOVEMBER
2003 IT IS THEREFORE THERE IS NO WITHHELD 'DATA' TO SEND TO YOU."

SUBSEQUENTLY BOTH SEFTON (ON MAY 1ST 2002) AND ROYAL & SUNALLIANCE
(ON AUGUST 7TH 2001) VERIFIED SEFTON CEASED TO BE INDEMNIFIED BY
THEM ON DECEMBER 14TH 1993 WHEN THEY "LOST CONTROL OF THE LAND TO
MARITIME HOUSING ASSOCIATION."

ALL THESE FACTS ARE WELL KNOWN TO THE OMBUDSMAN.

Yours sincerely,

fred robinson

Dear HIARY POOK

FOR YOUR INFORMATION REGARDING WHAT SEFTON KNEW IN FEBRUARY 2003:

LETTER TO SEFTONS LEGAL DIRECTOR JANUARY 24TH 2003

Will you please send me ALL information held by yourselves to which
I am entitled to request under the Freedom of Information
legislation now in force. I request copies of ALL my correspondence
to the Council to check what you have and have not received to
compare it with the information you send. I request ALL information
you hold on any claims and settlement of claims held by your
Finance Department and allegedly made by myself.

LETTER TO SEFTON COUNCIL 1ST FEBRUARY 2003

Will you please send me ALL information held by yourselves to which
I am entitled to request under the Data Protection legislation now
in force. I request copies of all my correspondence with regard to
claims and settlement of claims held by your Finance Department,
also information of how the alleged settlement of a claim,
regarding my gable wall in 1997, referred to by Mr Barr on January
2000, (Ref: GRB/JBJ/HSG1187) was made and to whom ? I have none of
this correspondence. I also request a copy of a letter from the
Council to Maritime Housing stating I had made a claim for damage
to my gable wall in 1993.

LETTER TO MS ELWOOD SEFTONS FEBRUARY 8TH 2003

With regard to my request for ALL information I am entitled to
under the DATA PROTECTION ACT I enclose a cheque for £10 which I
believe is the correct fee. I especially request that ALL
information regarding claims against the Council and their
settlement be forwarded to me with any correspondence regarding
these claims that was sent to third parties and any notes which
were added to files or computer records.

LETTER TO SEFTON FEBRUARY 14TH 2003

Will you write to me and confirm that you have received both my
application and payment of £10 for information under the DATA
PROTECTION ACT, dated February 8th 2003.

LETTER TO SEFTONS LEGAL DIRECTOR FEBRUARY 20TH 2003

I asked not only for information held by the finance department. I
asked for ALL information I was entitled to under the data
protection act to be provided. This means All information not only
that held with regard to claims held by the Finance Department as
you appear to believe. I have been told by the Finance department a
summons was issued against me regarding Council Tax;- Summons No
2340104 at - The Law Court, Albert Road, Southport. I have written
to the court and they state "the summons No you have quoted does
not relate to one of our cases". Consequently I will not be
attending court.

LETTER TO SEFTONS LEGAL DIRECTOR FEBRUARY 22ND 2003

I formally request that SMBC's letter to MHA, dated between 1st and
10th February 1999, be provided to me as part of my request, and
payment, for information under the Data Protection Act. I believe
that the Council has committed breaches of The Data Protection Act
and ask that you give a reasoned respond to the following to
explicate the matter.

Background

1. In about June 1993 I visited Sefton Councils (SMBC) Planning
department and saw plans for a proposed development of a new
housing estate on land adjacent to my property. This was proposed
to occur after the demolition of buildings adjoining my property
then in situ on the land. These plans show the gardens of the
proposed houses extending to my gable wall - evidently after the
removal of a nib wall and footings.

2. In August and September 1993 I expressed concern in writing to
SMBC I stated it appeared, from the plans, a nib wall and old
footings abutting my gable wall were to be removed during the
forthcoming development. On October 1st 1993, SMBC (Mr Barr) told
me the nib wall and footings abutting my gable wall should not be
interfered with during the development. This fully resolved the
matter.

3. On March 7th 1994 SMBC (Mr Barr) arranged to survey and
photographed my property. The nib wall is shown on some of these
photographs. This survey does not record any damage, cracking or
deterioration to my gable wall. At the outset of demolition of
buildings adjoining my property - [which occurred between March
14th and April 6th 1994] - the nib wall and footings were
photographed in situ.

4. On April 6th and 21st 1994 I reported to SMBC that my property
had been damaged during the demolition of the adjoining buildings -
[It was acknowledged on April 15th 1994 (pp Mr Barr), the one dated
April 21st 1994 was not.] There was no mention of demolition of a
nib wall in this correspondence. - [The nib wall was witnessed by
SMBC's contractors in situ on April 21st 1994.]

5. On July 4th 1998 I wrote to my solicitors reporting latent
damage to my property due to the demolition of the nib wall. This
damage was located at the point where the nib wall had been.

6. On January 27th 1999 I wrote to Maritime Housing Association
(MHA) regarding my property.

7. On February 1st 1999: MHA's Director of Development and Property
Services. (Mr Quayle) wrote to me that MHA's records showed the
land had been transferred to them in "mid 1995" and, citing SMBC as
their consultants, stated he would write to SMBC regarding the nib
wall. - [Between February 1st and 10th 1999 SMBC had clearly
responded to MHA.]

8. On February 10th 1999 MHA (Mr Quayle,) after receiving
correspondence from SMBC, wrote to me with regard to the nib wall,
that. "Matters surrounding this particular wall began as early as
1993."

9. On March 4th 1999 MHA (Mr Quayle) wrote to me that ;- It was
Fawley Construction Ltd - MHA's building contractor. - "Who was
responsible for our development at Kepler Street."

We (MHA and Fawley) are "all convinced that the "nib" wall was not
in existence when we took possession of the site." - [Possession
has been given by MHA, Fawley and SMBC as March 14th 1994.]

That I should be aware that MHA. "Were not responsible for the
demolition of the maisonette blocks which previously occupied the
site, following demolition by Sefton Council."

That "On the evidence I have it would appear, therefore, that the
"nib" wall was removed during the demolition contract." - [This
evidence would appear to be, based on SMBC\s letter of February
1999 to MHA attesting that SMBC were responsible for the damage to
my property caused by the demolition of the nib wall and, had
demolished it and the adjoining buildings in 1993 and, had owned it
until "mid 1995."]

That "I am taking the opportunity of copying this letter to Mr G
Barr at Sefton Council, so that he is fully aware of the
correspondence that has passed between us."

10. On March 10th 1999 MHA (Mr Quayle) confirms that; "The
demolition of the maisonette blocks was carried out, under contract
by Metropolitan Borough of Sefton. I have previously confirmed that
this Association took possession of a cleared site."

"I am aware now of the nature of your enquiry, in that you are
alleging the "nib" wall was demolished after the site was cleared."

"Once again I am taking the opportunity of copying both your letter
and my response to George Barr at Sefton and also to Fawley
Construction." - [Thus SMBC (Mr Barr) knew in March 1999 that I was
alleging the nib wall was not demolished during the demolition of
buildings adjoining my Property in 1993 and, MHA were holding SMBC
responsible for its demolition prior to their possession.]

11.On October 22nd 1999 MHA (Mr Quayle) wrote stating he had.
"Found a letter from Sefton, written to me in February 1999 in
which it is stated;" - [From the above it was apparently written by
Mr Barr.]

"The whole issue of damage to your gable wall appears to go back to
1993."

"That you had a claim against Sefton Council at that time." [i.e.
In 1993.]

That this claim was due to. "Cracking and deterioration of your
gable wall" which had occurred due to. "Demolition of adjoining
buildings".

This letter from MHS to myself quotes verbatim from my
correspondence with SMBC dated August and September 1993. This
correspondence was written solely regarding SMBC's apparent
proposal to demolish the nib wall and remove the footings. - [There
was no demolition adjoining my property in 1993. No mention of the
nib wall is made between 1994 and 1998.]

12. On November 24th 1999 SMBC's Director of Technical Services (Mr
Williams, Mr Barrs superior) states, regarding SMBC's
correspondence to MHA of February 1999 that;

"As the appointed agents of Maritime Housing in respect of the
redevelopment scheme we have a contractual obligation to provide
information to them in respect of work carried out on their behalf;
and also in respect of any matter material to their interest in the
land being developed."

"Mr Barr had, on behalf of Sefton merely complied with his
contractual obligations."

That this information was supplied by SMBC to MHA in "good faith."
- [I also refer you to correspondence to Messrs Barr, Williams and
Heywood, SMBC's CEO, dated respectively; Barr
16/10/99-30/10/99-6/12/99. Williams 29/11/99. Heywood 18/1/00.]

Conclusions

With regard to the above it appears that the Council have breached
the following Principles of "The Data Protection Act 1998." The
reference numbers I use in brackets below are from the December
2001 issue of the "Legal Guide to the Data Protection Act". I
presume you are is au fait with the above1998 Legal Guide.

First Principle: (3.1) (i) SMBC did not obtain my consent (3.1.5)
to disclose to MHA the personal date (2.2) contained in my letters
of 1993 to them.

(ii) That it was known to SMBC that the provision of this personal
data to MHA was regarded by myself as being prejudicial to me.

(iii) The data was not provided to MHA in a fair and lawful manner
(3.1 and 3.1.4) and, did not protect my vital interests, in fact it
worked against them. This I stated to SMBC in November 1999.

(iv) That the data provided to a third party (MHA) was not provided
within a reasonable timescale (3.1.7.7)

Second Principle: (3.2) (i) SMBC had obtained the data in 1993 for
the sole purpose of resolving the matter of their apparent proposed
demolition of the buildings adjoining my property. This matter was
fully resolved by Mr Barrs letter to me dated October 1st 1993.

(ii) The data was used for a different, incompatible, unfair and
unlawfully purpose (3.1. 4) when it was stated by SMBC to MHA in
February 1999 to have been the basis of a claim for damage to my
property in 1993 which had not occurred in 1993.

Third Principle: (3.3) That the data supplied to MHA by SMBC was
irrelevant and excessive in relation to the purpose it was provided
to MHA for.

Forth Principle: (3.4) The data supplied to MHA by SMBC was
incorrect and misleading with regard to the reason stated by SMBC.
i.e. that it was a claim. This incorrect and misleading assertion
was not withdrawn by Mr Williams in November 1999 (3.4 [b].)

Fifth Principle: (3.5) The data was kept for longer that it was
necessary for the purpose it was provided for. - i.e. 6 years.

Sixth Principal: (3.6) The data was not processed with regard to my
rights (3.6.b[ii]) and has caused damage and distress to me.

Seventh Principle: (3.7) The data which was passed to MHA by SMBC
was done so in an unauthorised and unlawful manner.

LETTER TO MS ELWOOD SEFTONS LEGAL DIRECTOR FEBRUARY 26TH 2003

I write with regard to my letters to you dated 1st, 8th and 22nd
February 2003 concerning my request for ALL data I am entitled to
under the Data Protection Act. This letter should be read in
conjunction with my previous letters on the matter and deals with
SMBC's insurance managers AON.

Background 1. I have been notified by AON. (Mr Pearson, Claims
Adjuster) that, with regard to an "incident" dated January 1st
1994, a "public liability claim" (My Ref: W215732) was issued to
AON by SMBC. It is evident that this claim contained data which
caused AON to write to me advising me that I "seek legal advice in
connection with the same". This claim would appear to be connected
with damage to my property.

2. As January 1st 1994 was a bank holiday it is extremely unlikely
that any work was carried out on that day by SMBC - or anybody else
on its behalf - that would have given SMBC the legitimate reason to
send data, which identified me to AON, regarding the "incident"
alluded to and on which I should take - "legal advice."

3. Regarding the date of January 1st 1994, again, as it was a bank
holiday, there would have been no post that day and, therefore, it
may be that the claim for the "incident" had been delayed in the
Christmas post and, was the alleged claim notified to MHA in
February 1999 by SMBC as damage to my "gable wall," caused by the
"demolition of building adjoining my property in 1993".

4. If the "incident" reported to AON occurred on the land adjoining
my property, i.e. the Kepler Street site, and was that which
damaged my "gable wall" and was caused by the demolition of
"adjoining building in 1993" by SMBC. It is abundantly clear that,
that "incident" occurred prior to December 24th 1993 because, for
SMBC to make a legitimate public liability claim. This claim would
have had to have been made prior to SMBC's public liability
indemnity and any contractual obligation to AON - e.g. for any
claims regarding the land, a nib wall or my gable wall - ceasing on
December 24th 1993 and liability passing from SMBC to MHA on
[allegedly] December 24th 1993. [See letters to me from; MHA dated
February 1st 1999, Mr Williams dated September 26th 2000, Ms Swale
dated June 19th and August 8th 2001 and Mr Heywood dated May 1st
2002.]

I request that the data supplied to AON, which established January
1st 1994 being applied to the above claim, is sent to me as part of
my request and payment for information under the Data Protection
Act.

Conclusion With regard to data supplied by SMBC to AON, which
clearly allowed AON to identify me, SMBC appear to have breached
The Date Protection Act as follows. References to the Act are again
in brackets.

First Principle: (3.1) (i) SMBC did not obtain my consent
(3.1.1-3.1.5) to disclose to AON the personal data (2.2) [whether
true or false] to them.

(ii) This personal data SMBC provided to AON [whether true or
false] was prejudicial to me.

(iii) The data [whether true or false] was not provided to AON by
SMBC in a fair and lawful manner (3.1 and 3.1.4) and, did not
protect my vital interests, in fact it worked against them.

(iv) the data supplied to AON by SMBC [whether true or false,] was
not fair (3.1.7-3.1.7.1-3.1.7.2-3.1.7.3)

Second Principle: (3.2) (i) If SMBC had obtained the data in 1993
for the sole purpose of resolving the matter of their apparent
proposed demolition of the buildings adjoining my property. This
matter was fully resolved by Mr Barrs letter to me dated October
1st 1993.

(ii) If (i) above is true. The data was used for a different,
incompatible, unfair and unlawfully purpose (3.1.4) when it was
stated by SMBC to AON to have been the basis of a public liability
claim, which may have been for damage to my property in 1993. NB,
SMBC have not given me a reason for this claim.

Third Principle: (3.3) That the data supplied to AON by SMBC was
irrelevant and excessive in relation to the purpose it was provided
to SMBC for, i.e. the resolution of SMBC's intentions regarding the
nib wall and footings.

Forth Principle: (3.4) The data supplied to AON by SMBC was
incorrect and misleading with regard to the reason stated by SMBC.
i.e. that it was a public liability claim.

Sixth Principal: (3.6) The data was not processed with regard to my
rights (3.6.b[ii]) and has caused damage and distress to me
(4.2-4.2.1)

LETTER TO MS ELWOOD SEFTON’S LEGAL DIRECTOR MARCH 1ST 2003

I write with regard to my letters to you dated 1st, 8th 22nd and
26th February 2003 concerning my request for ALL data I am entitled
to under the Data Protection Act. This letter should be read in
conjunction with previous letters on the matter and deals with
SMBC's insurers Royal SunAlliance (RSA.)

Background

1. I have been notified by RSA of a "public liability claim" (Claim
Number RR98XN,) with regard to an "incident" dated January 17th
1994 and told it was being handled by RSA on behalf of SMBC. RSA
gave me no indication what this claim was for. It is evident that
this claim contained data which allowed RSA to write to me asking
me to advise them if I was "represented in this claim". This
"incident", i.e. event or occurrence, would appear to be connected
with damage to my property on January 17th 1994.

2. As January 17th 1994 was, and still is, given by RSA as the
"incident" date regarding a public liability claim against SMBC, it
would appear the data that was supplied to RSA came from SMBC and
allowed RSA to identify me from it.

3. The reason for this public liability claim to RSA is not known
to me, however, It is abundantly clear that, the "incident" - which
occurred on January 17th 1994 - could not be the subject of a
legitimate public liability claim by SMBC because, for SMBC to make
a legitimate public liability claim. The "incident" which caused
the claim would have had to have been made prior to SMBC's public
liability indemnity ceasing on December 24th 1993 and, as you know,
liability passing from SMBC to MHA on December 24th 1993. [See
SMBC's (Mr Heywood, CEO) letter to me dated May 1st 2002.]

I request that the data supplied to RSA, identifying me and,
causing January 17th 1994 being applied to the above claim, is sent
to me as part of my request and payment for information under the
Data Protection Act.

Conclusion

With regard to data supplied by SMBC to RSA, which clearly allowed
RSA to identify me, SMBC appear to have breached The Date
Protection Act as follows. References to the Act are again in
brackets.

First Principle: (3.1) (i) SMBC did not obtain my consent
(3.1.1-3.1.5) to disclose to RSA my alleged personal data (2.2)
[whether true or false] to them, i.e. that I had made a claim.

(ii) This personal data SMBC provided to RSA [whether true or
false] was prejudicial to me.

(iii) The data [whether true or false] was not provided to RSA by
SMBC in a fair and lawful manner (3.1 and 3.1.4) and, did not
protect my vital interests, in fact it worked against them.

(iv) The data supplied to RSA by SMBC [whether true or false] was
not fair (3.1.7-3.1.7.1-3.1.7.2-3.1.7.3)

Second Principle: (3.2) (i) SMBC had not obtained the data
regarding an incident dated January 17th 1994 from myself or
anybody representing me, therefore by that virtue it could not be
used in a compatible, fair and lawfully manner (3.1.4) when it was
stated by SMBC to RSA to have been the basis of a public liability
claim.

Third Principle: (3.3) That the data supplied to RSA by SMBC was
irrelevant and excessive.

Forth Principle: (3.4) The data supplied to RSA by SMBC was
incorrect and misleading.

Sixth Principal: (3.6) The data was not processed with regard to my
rights (3.6.b[ii]) and has caused damage and distress to me
(4.2-4.2.1.)

LETTER TO MS ELWOOD SEFTONS LEGAL DIRECTOR MARCH 5TH 2003

I write with regard to false and misleading and damaging
information supplied by the Council (SMBC) to Fawley Construction
Ltd and my former solicitors Canter Levin & Berg (CLB) between
January and March 1995 and Mr Benton MP on January 12th 2000.

1. In November 1991 a survey was conducted on my property by a
structural surveyor. This survey found no damage whatsoever to my
gable wall. He noted the gables structural fragility due to it
being free standing.

2. On February 7th and 16th 1994 I wrote to SMBC noting that
"demolition has now started on the development" and warning SMBC -
with regard to 1 above - of the problems demolition of adjoining
building may cause to my property especially my gable wall. This
demolition was the commencement of the first phase of the
development of the Kepler Street site. SMBC acknowledged my letters
on February 28th 1994.

3.On March 7th 1994 SMBC - as a result of 2 - above conducted a
survey of my property. This survey found no damage whatsoever to my
gable wall. - The above proves incontestably that SMBC knew the
development of the Kepler Street site had commenced prior to March
7th 1994 and at that time their own survey proved that there was no
damage to my gable wall.

4. Between March 14th and April 6th 1994 my property was damaged by
the demolition of buildings adjoining my property. On April 6th and
21st 1994 I notified and described this damage to SMBC's Technical
Services. - The above proves incontestably that SMBC's Technical
Services knew that my property was damaged by the demolition of
adjoining buildings between March 14th and April 6th 1994.

5. On April 15th 1994 SMBC's Technical Services acknowledged the
damage in 4 above. On October 24th 1994 I had this damage
quantified by a structural surveyor. Using SMBC's survey, taken on
March 7th 1994 during the development, he found some 30 changes for
the worse in my property. He recommended, in order to prevent a
claim, SMBC be contacted to ask them to provide a grant to repair
my property.

6. On January 26th 1995 my solicitors wrote to SMBC solely
regarding my structural surveyors report and my correspondence of
April 1994. Both regarding damage caused by the demolition of
buildings adjoining my property between March 14th and April 6th
1994. They suggested meeting to discuss the matter.

7. On February 17th 1995 SMBC (Mr Waddelow) wrote to CLB stating
that "damage if attributable to development is essentially a matter
between Householders and the developer concerned" The matter was
then passed to Technical Services. At this time Technical Services
had constructive knowledge my property had been damaged during
development due to my letters of April 1994.

8. Technical Services referred the matter to Fawley, MHA's
builders. Mr Fawley visited me on March 1st 1995 and states that
his visit was prompted by "a letter Sefton Council had received
from your solicitors dated 26th January 1995 regarding the
condition of your gable wall." He also states that I had told him
regarding my gable wall that "considerable worsening had occurred
during the demolition of the adjoining buildings." - There is no
mention of cracks to my gable wall in CLB's letter to SMBC of
January 26th 1995.

9. On March 7th 1995 Mr Barr stated to CLB that survey information
was taken of the property before redevelopment. In effect Mr Barr
is stating the survey by SMBC - taken on March 7th 1994 - had
occurred prior to development. - Mr Barr states that a claim for
damage to my gable wall was "settled off" in 1997.

11. On March 4th 1999, in a letter copied to Mr Barr, MHA (Mr
Quayle) states they have evidence that the demolition of buildings
adjoining my property occurred prior to their possession of the
site. - This evidence, which is clearly untrue, is confirmed by
MHA's CEO as being obtained by discussions with SMBC and Fawley and
from MHA's, SMBC's and Fawleys records. It will not be confirmed by
SMBC or Fawley.

Under 4.2 and 4.2.1 of the Data Protection Act - Date Subject
Notice. I request that SMBC ceases to process any information you
have obtained from Fawley Construction Ltd regarding myself as it
is untrue and misleading and has, and is likely to, cause me damage
and distress. I request that you notify all the other parties it
has been passed to that it is misleading and untrue. I also request
that SMBC ceases to process the information that a claim by me
regarding my gable wall was settled off in 1997 as it is untrue and
misleading, and inform my MP Mr Benton and any other parties it has
been passed to of this fact.

I request that you send me details of any further rights of access
to information under the Freedom of Information Act which may have
come into effect in March 2003, or where I may obtain a copy of
them.

LETTER TO MS ELWOOD SEFTONS LEGAL DIRECTOR MARCH 6TH 2003

I write regarding correspondence between Fawley Construction Ltd
and the Council (SMBC) between January and March 1995. This
correspondence resulted in SMBC making false unjustified and
unsupported assertion to their insurance representatives regarding
a claim against SMBC. I refer you to my letters of February this
year to yourself related to the matter.

Background

1. On January 26th 1995 SMBC received a letter from my solicitors,
Canter Levin & Berg (CLB). This letter requested that SMBC indicate
- by reference to my previous correspondence with SMBC dated April
6th and 21st 1994 - whether they would consider funding repairs to
my property solely for alleged damage caused during the demolition
of building adjoining my property. What this alleged damage was,
and its cause, was known to SMBC from my correspondence to
Technical Services of April 1994. To resolve the matter CLB
suggested a meeting between my surveyor and SMBC. SMBC did not, as
requested, indicate if they would be prepared to fund repair to my
property or not but, state that this letter was a claim holding
SMBC responsible for "crack fractures" to my property which
allegedly only became known on receipt of this letter. [See above]

2. After telling my solicitors that the matter of damage to my
property was not essentially SMBC's responsibility but that of the
developers. SMBC contacted Fawley Construction Ltd. Fawley,
Maritime Housing Associations (MHA - the developers) building
contractors who, are said by SMBC's insurers, to be the ones
responsible for the alleged damage to my property between March
14th and April 6th 1994. In a letter copied to Mr Barr from MHA
dated March 4th 1999 it is clearly stated by MHA that. "The
Associations building contractor who was responsible for our
development at Kepler Street." This responsibility was stated by
MHA to have begun on possession by Fawley. Possession is given by
MHA, Fawley and SMBC as March 14th 1994. MHA have also stated to me
that. In March 1994 "Fawley took possession of the site." SMBC
assert the site was "handed back" to MHA on April 1st 1994. By whom
this handing back was done they will not say, however, it is
abundantly clear it was not "handed back" by SMBC as SMBC were
neither the owners or in possession of the site on April 1st 1994.
[See 2 above and SMBC's (Mr Heywood CEO) letter to me of May 1st
2003.]

3. On March 1st 1995 I was visited by Mr D Fawley, he did not
identify himself or give his name to me. He did however refer to my
solicitors letter to SMBC of January 26th 1995. Based on this
reference to SMBC I assumed he was a representative of SMBC. When
Mr Fawley - with regard to a "report" he stated he was to make -
began to ask me what I considered inappropriate questions about my
property I referred him, under my solicitors advice not to answer
verbal questions, to my solicitors for the answers. He then left.

4. On the day of the above visit by Mr Fawley, March 1st 1995, I
telephoned my solicitors and reported to them that a member of SMBC
had visited me and I had referred him to them. This message clearly
records that I did not wish SMBC to make the "report" referred to
by Mr Fawley. There is no mention of me arranging a meeting and,
given SMBC had already been asked to attend a meeting in my
solicitors letter, no logical reason why SMBC would ask Fawley to
arrange one to include SMBC.

5. On March 7th 1995 SMBC (Mr Barr) wrote to my solicitors
confirming that Mr Fawley had visited me "with a view to arranging
a meeting so the property could be inspected by all relevant
parties." Mr Barr states that (undated and unknown to me) survey
information was taken "before the redevelopment works" i.e. prior
to January 17th 1994, and it indicates that the "primary cause" of
damage to my property occurred "before the redevelopment works
commenced" i.e. prior to January 17th 1994. What this damage was or
what caused it is not mentioned. It appears to be damage SMBC state
to MHA, occurred in 1993.

6. In a letter to myself dated May 25th 1999 MHA state that,
"particular issues" over the matter of the nib wall, had been
"resolved." Clearly this is in line with Mr Barrs assertion of
January 12th 2000 when he refers to "damage to your gable wall
arising from the removal of the nibwall." And, confirms that SMBC's
Finance Department has a record of the "settling off" of a claim
for damage to my gable wall in August1997.

To better understand the reason why SMBC would refer my solicitors
letter (said by SMBC to be a claim against SMBC,) to Fawley. I
request that all correspondence regarding this matter and causing
Mr Fawley to visit me in 1995 are included in my request for
information under The Data Protection Act. It may transpire that
SMBC have breached The Data Protection Act by providing data to
Fawley regarding a claim against SMBC which identified me.

Letter to Ms Elwood Seftons legal Director March 6th 2003

I write regarding correspondence between Fawley Construction Ltd
and the Council (SMBC) between January and March 1995. This
correspondence resulted in SMBC making false unjustified and
unsupported assertion to their insurance representatives regarding
a claim against SMBC. I refer you to my letters of February this
year to yourself related to the matter.

Background

1. On January 26th 1995 SMBC received a letter from my solicitors,
Canter Levin & Berg (CLB). This letter requested that SMBC indicate
- by reference to my previous correspondence with SMBC dated April
6th and 21st 1994 - whether they would consider funding repairs to
my property solely for alleged damage caused during the demolition
of building adjoining my property. What this alleged damage was,
and its cause, was known to SMBC from my correspondence to
Technical Services of April 1994. To resolve the matter CLB
suggested a meeting between my surveyor and SMBC. SMBC did not, as
requested, indicate if they would be prepared to fund repair to my
property or not but, state that this letter was a claim holding
SMBC responsible for "crack fractures" to my property which
allegedly only became known on receipt of this letter. [See above]

2. After telling my solicitors that the matter of damage to my
property was not essentially SMBC's responsibility but that of the
developers. SMBC contacted Fawley Construction Ltd. Fawley,
Maritime Housing Associations (MHA - the developers) building
contractors who, are said by SMBC's insurers, to be the ones
responsible for the alleged damage to my property between March
14th and April 6th 1994. In a letter copied to Mr Barr from MHA
dated March 4th 1999 it is clearly stated by MHA that. "The
Associations building contractor who was responsible for our
development at Kepler Street." This responsibility was stated by
MHA to have begun on possession by Fawley. Possession is given by
MHA, Fawley and SMBC as March 14th 1994. MHA have also stated to me
that. In March 1994 "Fawley took possession of the site." SMBC
assert the site was "handed back" to MHA on April 1st 1994. By whom
this handing back was done they will not say, however, it is
abundantly clear it was not "handed back" by SMBC as SMBC were
neither the owners or in possession of the site on April 1st 1994.
[See 2 above and SMBC's (Mr Heywood CEO) letter to me of May 1st
2003.]

3. On March 1st 1995 I was visited by Mr D Fawley, he did not
identify himself or give his name to me. He did however refer to my
solicitors letter to SMBC of January 26th 1995. Based on this
reference to SMBC I assumed he was a representative of SMBC. When
Mr Fawley - with regard to a "report" he stated he was to make -
began to ask me what I considered inappropriate questions about my
property I referred him, under my solicitors advice not to answer
verbal questions, to my solicitors for the answers. He then left.

4. On the day of the above visit by Mr Fawley, March 1st 1995, I
telephoned my solicitors and reported to them that a member of SMBC
had visited me and I had referred him to them. This message clearly
records that I did not wish SMBC to make the "report" referred to
by Mr Fawley. There is no mention of me arranging a meeting and,
given SMBC had already been asked to attend a meeting in my
solicitors letter, no logical reason why SMBC would ask Fawley to
arrange one to include SMBC.

5. On March 7th 1995 SMBC (Mr Barr) wrote to my solicitors
confirming that Mr Fawley had visited me "with a view to arranging
a meeting so the property could be inspected by all relevant
parties." Mr Barr states that (undated and unknown to me) survey
information was taken "before the redevelopment works" i.e. prior
to January 17th 1994, and it indicates that the "primary cause" of
damage to my property occurred "before the redevelopment works
commenced" i.e. prior to January 17th 1994. What this damage was or
what caused it is not mentioned. It appears to be damage SMBC state
to MHA, occurred in 1993.

6. In a letter to myself dated May 25th 1999 MHA state that,
"particular issues" over the matter of the nib wall, had been
"resolved." Clearly this is in line with Mr Barrs assertion of
January 12th 2000 when he refers to "damage to your gable wall
arising from the removal of the nibwall." And, confirms that SMBC's
Finance Department has a record of the "settling off" of a claim
for damage to my gable wall in August1997.

To better understand the reason why SMBC would refer my solicitors
letter (said by SMBC to be a claim against SMBC,) to Fawley. I
request that all correspondence regarding this matter and causing
Mr Fawley to visit me in 1995 are included in my request for
information under The Data Protection Act. It may transpire that
SMBC have breached The Data Protection Act by providing data to
Fawley regarding a claim against SMBC which identified me.

Yours sincerely,

fred robinson

Dear Hilary Pook,

For your information

FRAUDULENT INSURANCE CLAIMS AND THE OMBUDSMAN 2001

ON FEBRUARY 23RD 2004 SEFTON’S LEGAL DIRECTOR FILED A DOCUMENT AT
COURT in claim LV306271, ROBINSON V SEFTON MBC: IT STATED:

“The defendant is not prepared to satisfy the Claimant that he has
a valid and bona fide claim number W215732, RR98XN and AT01939 as
these claims are now statute barred having been raised in 1995 and
again in 1996.”

THE OMBUDSMAN:

ON FEBRUARY 23RD 2001 MR OXLEY AN OMBUDSMAN INVESTIGATOR WROTE THE
FOLLOWING TO ME:

“I write following your letter of 6 February…your complaint can be
summarised in the following statement:- that the Council issued a
claim to its insurers on your behalf without your knowledge or
permission…I have sent a copy of the above statement with your
complaint to the Council’s Chief Executive…I will not be
investigating any of the matter relating to your complaints about
the matters relating to the removal of the nib wall.”

IN A LETTER TO THE LOCAL GOVERNMENT OMBUDSMAN ON MARCH 15TH 2001,
SEFTON'S LEGAL DIRECTOR, MR BOWNES ALTERED AND ELABORATED THE
WORDING OF A LETTER DATED APRIL 18TH 2000 REGARDING AN ALLEGED
CLAIM(S) REFERENCED W215732 AND RR98XN AGAINST THE COUNCIL FOR
LATENT DAMAGE TO MY PROPERTY CAUSED BY THE DEMOLITION OF A ‘NIB
WALL’ BETWEEN MARCH 14TH AND APRIL 6TH 1994 -

FROM:

”It is my belief that during the development of the Kepler Street
site carried out by Sefton MBC, Maritime Housing Association and
Fawley Construction, a nib wall that abutted my gable end was
demolished and has caused damage to my property…I hold any one or
all three of the above named responsible for the demolition and any
resulting damage.”

INTO:

“This matter…as you will observe commenced in January 1995 with a
letter from Mr Robinsons solicitors…it is clear from that letter
and from the letter from [them] dated 29th November 1995 that Mr
Robinson was seeking to make a claim against the Council.
Furthermore, in his letter dated 18th April 2000, Mr Robinson
specifically states that he holds the Council (together with
Maritime Housing Association and Fawley Construction) “responsible
for the demolition and any resulting damage.” Thus it is abundantly
clear that Mr Robinson is pursuing a claim against the Council. Mr
Robinson’s claim was forwarded to the Council’s Public Liability
Insurers…Mr Robinson appears to believe that his permission is
required before the matter could be referred to the Council’s
insurers…I am sure that you will appreciate that, as a matter of
law…it is entirely a matter for the Council to decide whether or
not it should refer a claim that has been made against it, to its
insurers.”

ON APRIL 11TH 2004 MR OXLEY WROTE THE FOLLOWING TO ME:

“The Council’s letter of 15 March states that your claim was
forwarded to its insurers because it is a condition of its policy.
It is also a matter for the insurers to decide whether any time
limitation applies to your claim… it is my view the Council has
acted according to normal procedure concerning this type of claim…I
have not considered your claim from 1995-6…it is out of time and
you had put the matter in the hands of your solicitors at that
time.”

ON MARCH 2ND 2001 MR WILLIAMS, A STRUCTURAL ENGINEER AND SEFTON’S
TECHNICAL SERVICES DIRECTOR - WHO WITH COUNCILLOR DAVE MARTIN, THE
LABOUR LEADER OF SEFTON COUNCIL, HAD ATTENDED A MEETING WITH ME ON
APRIL 18TH 2000 AND ASKED ME TO WRITE A COMPLAINT TO THE COUNCIL
REGARDING THE DEMOLITION OF THE ‘NIB WALL’ -WROTE THE FOLLOWING
COVERT LETTER TO MR OXLEY:

“Mr Robinson contends that “the Council issued a claim to its
insurers on Mr Robinsons behalf without his knowledge or
permission”…Mr Robinsons allegations that the Council caused the
removal of the ‘nib wall’ adjacent to the gable of his
property…came to my personal attention in October 1998 some months
before the retirement of the General Manager (Property) [Mr Barr]
who had been dealing with the issue…Mr Robinson who was concerned
that liability for removal of the said nib-wall and the potential
effects on his property had not been resolved and was concerned
that his ability to claim against the Council would become time
expired…a meeting was arranged between the Leader [Mr Martin],
myself and Mr Robinson…on 18th April 2000 during which Mr Robinson
asked how we may ‘stop the clock’ on this issue before expiry of
the six year period…given it was almost six years since the date of
the alleged removal of the nib-wall, he would be best advised to
submit a claim setting out his allegations…Mr Robinson wrote on
18th April 2000, copy enclosed, clearly alleging that the Council,
Maritime Housing Association demolished a nib-wall and caused
damage to his property…the Council naturally referred the matter to
its Insurers with a view to meeting Mr Robinson’s objective of
avoiding the expiry of the period of limitation…the Council were
treating Mr Robinsons letter as a formal submission of a claim and
taking the matter forward, as agreed with Mr Robinson, via
Independent Structural Survey. You will appreciate that it is the
council’s right to refer matters of this nature to its insurers…I
note with interest from Mr Robinsons letter to you of 6th February
2001…that he accepts that the Council had no liability for removal
of the nib wall and alleges consequential damage.”

THE LETTER REFERRED TO ABOVE BY MR OXLEY AND MR WILLIAMS MR
WILLIAMS DATED FEBRUARY 6TH 2001 WAS WRITTEN TO MR RA HARRISON
DEPUTY OMBUDSMAN STATING:

I refer to your acknowledgement postmarked 30th January 2001 and my
letter to you of 24th January 2001.

My letter to you of 24th January 2001 you required more than an
acknowledgement, in it I asked it you were accepting that Sefton
MBC had committed an act of maladministration by issuing an
insurance claim to their insurers based on information they knew to
be incorrect.

A letter Ref: 94/0195/S/RJW/MNG written by Mr R J Waddelow of
SMBC's planning department on 17th February 1995, states "In our
opinion, damage if attributable to development is essentially a
matter between householders and the developers concerned..."

This clear and unequivocal statement of the position of SMBC
precludes the need for SMBC to have any further involvement with
the issue owing to the fact that the damage clearly occurred, not
during the demolition phase, not during SMBC's ownership, not
during the possession of the site by SMBC or their contractors, but
during the development phase of the project. Evidence proves this
to be true.

As requested on 24th January 2001, will you answer the question of
whether you are accepting the complaint of maladministration in
regard to the insurance claim based on false information submitted
by SMBC to their insurers in regard to my enquiries about the nib
wall that formally abutted my gable. If you are not, will you
accept that I am making a formal complaint that this matter is not
being dealt with in a fair and impartial manner by the Ombudsman's
office. I make this accusation on the grounds that;-

According to evidence they have provided, SMBC had no liability for
damage caused to my property after 14/3/94 however caused. Evidence
proves this to be true.

SMBC have stated damage during development is a matter between the
developer and the householder and indicate no difference in my
case. Evidence proves this to be true.

The basis of the false claim is that the nib wall was demolished at
the same time as the maisonette blocks, formally adjacent to my
house. Evidence proves this to be untrue.

SMBC have falsely asserted that the demolition of the nib wall was
part of a claim for damage during the demolition contract. Evidence
proves this to be untrue.

According to written and photographic evidence the nib wall
remained in situ after SMBC's demolition contract was completed.
Evidence proves this to be true.

According to SMBC the false claim in regard to the nib wall was a
re-opening of an existing claim, there is no evidence to support
this assertion in fact there is evidence that proves that apart
from the initial queries by my solicitors no action was taken by
them. Evidence proves this to be true.

SMBC claim not to know when the nib wall was demolished, they do
know it was not demolished by their contractors who were given
'special instruction' to protect it. Evidence proves this to be
true.

Over the past months I have provided you time and again with the
evidence and references that confirms the above. The overwhelming
evidence is that SMBC have without a doubt acted in a manner
calculated to pervert the facts and conceal their misdeeds at my
expense. This has been done by the calculated use of
misinformation, lies and failure to provide answers to my
legitimate and justifiable questions.

c.c. Sharan Bhogal DETR London

On MARCH 2ND 2001 IN A LETTER HEADED, “SEFTON MBC RR98XN” - A CLAIM
REFERENCE FOR AN ALLEGED INCIDENT ON JANUARY 17TH 1994 AGAINST
SEFTON BY MYSELF - RSA WROTE THE FOLLOWING TO ME:

“We have not seen any evidence to suggest that Sefton MBC had any
involvement with the removal of the nib wall…and we cannot see that
a legal liability rests with them in respect to any damage which
may have occurred to your property…it may be that any claim you
wish to make is statute barred.”

ON APRIL 12TH 2001 MY SOLICITORS OBTAINED COUNSELS ADVICE FROM
JOHNATHAN DALE FOR A ‘PROPOSED CLAIM’ AGAINST SEFTON COUNCIL: MR
DALE STATES:

“The position is no clearer in terms of who did what and when in
relation to the removal of the nib wall.”

ON MAY 2ND 2001 I WROTE THE FOLLOWING LETTER TO MRS THOMAS

I further refer to my letter to you dated 12/ 17/ 21/ 26 of April
2001, these letter seem to have been ignored in your consideration
of the validity of my claim against SMBC.

The matter is a very simple one, if Sefton had liability to issue a
claim to their insurers in regard to the damage caused by the
removal of the nib wall at some time after 21st April 1994, and the
right to link this claim to alleged damage to my property caused by
the demolition which occurred at some time prior to 21st April
1994, they must have had insurance cover to do so.

If they were not liable for damage on either occasion they had no
liability to issue a claim. This will be clarified by the release
of the date their insurance cover ended in relationship to the
demolition period as this is the period that is being used for
their claims.

The revealing of the date of SMBC’s insurance liability can at a
stroke resolve this issue.

SMBC cannot issue a claim if they are not liable to do so. – I
believe I have provided evidence SMBC were not liable, if you
ignore this you are being unfair.

SMBC cannot alter the law on statute barring.

SMBC’s insurers cannot alter the law on statute barring therefore
Mr Williams lied to me and as a result I have lost the right to
make a claim against anyone in regard to damage to my property. –
the evidence this is true is freely available to you, for some
reason you ignore it and seem unwilling to consider it.

You state I have not suffered loss, I disagree.

SMBC had no liability to offer me £1000 in settlement for damage to
my property.

Why was this done and on what authority.

If you are not prepared to consider this complaint and my evidence
further and investigate to clarify the allegations I am making,
please regard this letter as a formal complaint that you are not
dealing with the matter impartially and fairly and forward
information of how I must now proceed.

cc Joe Benton MP

ON MAY 30TH 2001 MRS THOMAS, WROTE THE FOLLOWING TO ME:

“From the information which you and the Council have provided I can
see no evidence of maladministration…whether or not the Council
should refer a matter to its insurers is a matter for the
Council…the correspondence which you have sent makes it clear that
this is to a degree a continuation of your original allegation of
neglect on the part of either the council or other parties which
dates back to the early 1990’s…you had the opportunity of taking
legal action at the time… the only rout now available to you is to
seek a Judicial review.”

LETTER TO MRS THOMAS JUNE 7TH 2001

Thank you for your letter of 30th May 2001.

You say that the only route now available to me is to seek a
judicial review, can you tell me how to go about this ? Is it
possible that to aid me in that course you can provide me with the
information you have from Sefton MBC that leads you to your
conclusions ?

Will you please respond to the above question with an answer or
write and tell me that you will not give me this information.

SMBC by the act of constructing the nib wall from the remains if
the former screen wall that ran from my gable to the gable of the
former maisonette blocks, also created a right of support for my
property.

During their demolition contract they issued special instructions
to their contractors to protect the nib wall, this I am reliably
informed created a duty of care in respect of the right of support,
in the light of this it seems highly unlikely they would then
demolish the nib wall.

I can find no evidence that either SMBC or their insurers can
affect time limitation in any way, therefore I am convinced Mr
Williams lied to me to deceive me into thinking time limitation had
been suspended.

This conviction is the result of obtaining several legal opinions.

If SMBC had a legitimate responsibility to issue a notice to their
insurers for a potential claim by myself it is only common sense
that to do so they would have to be insured for the period that the
alleged damage occurred. - SMBC's insurers tell me that SMBC have
no legal liability for any damage to my property this is,
presumably, based on the fact that they did not insure SMBC for
damage to my property at the time the damage occurred.

SMBC have strenuously denied responsibility for demolition of the
nib wall.

SMBC had received accusations from myself of them damaging my
property on other occasions which did not regard as claims worthy
of their insurers attentions.

It is not credible that SMBC's insurance section, as a matter of
course, would not check their liability to answer a claim for
damage made to them, nor is it credible Mr Williams would be
unaware that there was no mechanism to suspend time limitation by
the writing of a letter to SMBC - no matter what the letter said.

As I have stated. the disclosure of the date SMBC's insurance cover
in regard to their demolition contract is the one item that will
resolve the matter of SMBC's liability at a stroke. Both they and
their insurers have given me the date when this cover commenced
(17/1/94) but both have, despite many requests to do so, not given
me the date it ended.

It seems counter to common sense that this date is being withheld
as it is at the heart of the matter and would prove SMBC right and
me wrong. I enclose copies of documentation which I consider prove
my complaint to be valid. I would be grateful for the return of
these documents.

ON JUNE 19TH 2001 SEFTONS MS SWALE WROTE THE FOLLOWING TO ME:

“In January 1995 your solicitors made a claim on your behalf for
alleged damage to your property in 1994. This claim was therefore
forwarded to Royal & SunAlliance the Councils insurers…in April
2000 you attended a meeting with Mr Williams where the mater was
reopened. In order to be helpful and to ensure the exact nature of
your complaint were identified, Mr Williams asked you to put these
in writing. He mentioned the six year limitation period in order to
instil a sense of urgency, but he is not an insurance expert and
did not know that only the court can suspend this. The insurance
cover for Sefton Council has been with Royal & SunAlliance since
September 1992 and remains with them to date. The cover is for the
Council’s legal liabilities. With regard to the Kepler Street site,
the Council ceased to have any involvement on April 1st 1994 when
it was handed over to Maritime Housing Association.”

ON JUNE 21ST 2001 MRS THOMAS WROTE THE FOLOWING TO ME:

“The Information from Sefton MBC which led to Mr Oxley’s decision
was sent to you with his letter of 23 March. In case you do not now
have a copy of the Council’s letter of 15 March, I enclose a
further copy.”

LETTER TO MRS THOMAS JUNE 26TH 2001:

I write to query the basis of the information your office have used
to reject my complaint that "Sefton MBC have used information which
they knew to be false, some of which was obtained by deception, to
issue an insurance claim".

Before I consider a Judicial Review I need the decision clarified
in light of what follows.

The reason that Mr Cowley's letter gives as the basis of my
complaint is incorrect.

1. The letter of 29/11/9 not that of 26/1/95 is the basis of the
claim to SMBC's insurance brokers see the enclosed letter to my
solicitors. There is no link with a previous claim. DO YOU ACCEPT
THIS ?

On 6/11/00 in a letter from the Councils insurers I was told that
it is a condition of the Councils insurance policy with them that
they "advise the insurers of any potential claim against them,
irrespective of any ongoing enquiries".

2. This clearly is not an optional condition. DO YOU ACCEPT THIS ?

3. In Mr Cowleys words, "It is entirely a matter for the Council to
decide whether or not it should refer a claim that has been made
against it", DO YOU ACCEPT THIS ?

4. While this is essentially true, in terms of their contract of
insurance it would clearly be difficult if not impossible to
justify that the insurers met such a claim. DO YOU ACCEPT THIS ?

5. If I did believe that SMBC required my permission to issue a
claim against them it seems that their letter to me ARM/ES/MC
on13/10/00 stating "...it is the responsibility of the claimant to
pursue the claim", would fully justify this belief. DO YOU ACCEPT
THIS ?

At an early stage in my correspondence with Maritime Housing
Association they told me that their records showed that the land at
Kepler Street was transferred to them in "mid 1995", (see
enclosure) on the basis of this information it was my belief that
the Council were the owners of the land, and therefore liable for
damage to my property occurring until "mid 1995".

In a letter to Mr Barr at SMBC on 30/10/99 in answer to his comment
that he had "no authority to carry out work on privately owned
property" and that " the demolition of your nib wall is not
something that I would have been capable of authorising" I
responded:-

6. "…as far as I am aware the property the nib wall was on was
Council owned land - according to Maritime up until ' mid 1995'
when it was transferred to them". This was not refuted and
confirmed my belief that the Council were liable. DO YOU ACCEPT
THIS ?

To clarify the matter I wrote to Mr Williams, in a letter dated
18/1/00 I stated that based on the information that Maritime had
provided that the land was not transferred to them until "mid
1995", the nib wall and the land it stood on were Council owned.
This was not refuted. SMBC did not provide a date for transfer of
the land until 11th December 2000. They have never acknowledged the
ownership of the land being Maritimes.

Clearly from the above any claims I or those informed by me, made
against the Council, were based on the belief that the land and the
nib wall were in the ownership of the Council, making them liable.
It was not until Mr Williams claimed in a letter to me dated
30/6/00 Ref: PAW/RR/rob9 that the ownership of the nib wall was
unknown at the time of its demolition that I took steps to clarify
the matter, the result, as you know was that I discovered Maritime
to have been the owners from 21/1/94.

In the same letter of 30/6/00 Mr Williams states "If the wall was
still standing at the time of the disposal of the land to Maritime
Housing, it would have become their property". Clearly it would be
as easy for SMBC to establish ownership as it was for me.

7. Prior to the claim to SMBC's insurers in July 2000 and since
October 1999 Mr Barr and Mr Williams were aware of my assertion
that Maritime were not the owners the nib wall and the land it
stood on, my belief is the Council were the owners and that they
deliberately withheld this information DO YOU ACCEPT THIS ?

8. The Council always knew they had no liability to issue a claim
for demolition which had occurred after the land and nib wall were
transferred to Maritime on 24/12/93. DO YOU ACCEPT THIS ?

9. The Council were not insured with regard to my property at the
time the nib wall was demolished, nor when the maisonette blocks
were demolished after 14/3/94. DO YOU ACCEPT THIS ?

10. From the above it follows that a claim for damage caused by the
demolition of the nib wall could not be linked with that caused by
the demolition of the maisonettes as is alleged by the Council
unless the Council were liable at the time of both events. DO YOU
ACCEPT THIS ?

SMBC's insurers state in a letter to me dated 2/3/01 that SMBC have
had no involvement in the removal of the nib wall and see no
liability by the Council for any damage to my property, they do not
make it clear if this covers damage caused both by the alleged
linked demolition of the maisonette blocks and the demolition of
the nib wall or only that caused by the demolition of the nib wall.

If the demolition of the nib wall and the demolition of the
maisonette blocks are linked together there is liability by the
Council only if the link exists and is valid.

11. On 18/4/00 there was no evidence of damage to my property
caused by the removal of the nib wall, which was at that time in
situ, this is proven beyond doubt. DO YOU ACCEPT THIS ?

On Friday 30/6/00 Ref: PAW/RR/rob9 the Council claimed not to know
who owned the nib wall or the land it stood on at the time of its
demolition and he would write to me 2 working days later on Tuesday
4/7/00 Mr Williams wrote to me stating the matter was to be placed
in the Councils insurers hands.

On 27/7/00 Councillor Martin, informed by Mr Williams, wrote to me
stating the ownership of the nib wall was still under
consideration.

12. The facts of this matter are still in need of clarification by
the provision of exact dates, but it appears that SMBC issued the
alleged claim to their insurers before the ownership of the land
the nib wall stood on was established, or that on Monday or Tuesday
3-4/7/00 when Mr Williams stated the matter of the alleged claim
had been passed to SMBC's insurers, the ownership of the land and
nib wall had been established and due to this SMBC felt it was
their liability because the nib wall had been demolished causing
damage to my property during their ownership.. DO YOU ACCEPT THIS ?

13. It is the ownership of the land and nib wall which establishes
legal liability, not the conditions of SMBC's insurance policy. DO
YOU ACCEPT THIS ?

I wish to correct an error in the assertion that the Councils
insurers have the power to determine time limitation which Mr Oxley
stated on 11/4/01.

14. The insurers refute their power to effect time limitation and
state the matter is one that a court will decide, this is also the
opinion of several solicitors and a barrister. DO YOU ACCEPT THIS ?

15. Mr Oxley states, apparently based on the obligation they place
on SMBC. "It is a matter for the insurers to consider whether or
not there is any claim to consider". This appears to remove SMBC
from the consideration of any claim against them on the basis that
they are obliged, as a means to obtain indemnity, to fulfil that
obligation. DO YOU ACCEPT THIS ?

According to legal opinion I have obtained the Council established
a duty of care toward my property by issuing the "special
instructions" to their demolition contractors, during the
demolition period, at the end of which the duty had been observed
in relation to the nib wall which remained in situ on 21/4/94 and
according to SMBC passed from their ownership on 24/12/93 and from
their possession on 14/3/94 and from 1/4/94 they claim, Ref:
AD/VS/cb/13.6/robinso, "With regard Kepler Street site, the Council
ceased to have any involvement on 1st April 1994 when it was handed
over to Maritime Housing Association".

I have numbered my questions and am prepared to accept a simple yes
or no response to them. As I am in receipt of benefit and cannot
easily afford to send you copies of the letters from the Council
that I refer to, if you feel it is necessary for you to obtain them
from the Council I have given you their reference numbers. You will
find the Council have deliberately, apparently to justify the lies
of Mr Williams, linked the demolition of the nib wall to the
demolition of the maisonette blocks. The facts refute this.

I asked you to find the date that SMBC's insurance liability ended
in regard to damage to my property, the stated date of 1/4/94 as
the end of their involvement with the site proves that SMBC
knowingly issued a claim to their insurers with regard to damage
caused by the removal of the nib wall, based on false information
as they "most specifically" deny the nib wall was demolished by
their contractors Ref: GBR/AMc/KEPLER 5/10/99, as do their
contractors, GTB demolition Ltd, who cite their foreman as a
witness.

ON JULY 17TH 2001 MR WILLIAMS WROTE THE FOLLOWING TO THE LABOUR
LEADER OF THE COUNCIL, MR MARTIN:

“Mr Robinsons claim is being dealt with by the Council’s insurers
and Ms Viv Swale, the Claims and Administration Manager in the
Finance Department…as you are aware, Mr Robinson has previously
complained to the Ombudsman…the Ombudsman concluded there was no
evidence that Mr Robinson had been caused any injustice by
maladministration on the Council’s part. The Ombudsman decided that
the Council has acted reasonably in terms of the way in which his
claim had been dealt with.”

LETTER TO MRS THOMAS JULY 7TH 2001

“Please find enclosed some of the correspondence with regard to the
complaints I have sent to you against SMBC. My observations are on
the reverse

You must see that my complaint to the Council as well as to
yourself has not been addressed and I ask you to treat the enclosed
evidence to close scrutiny and if you find no reason to reconsider
your dismissal of my complaint please write and tell me why. The
one letter to you from the Council you offer as the reason for your
conviction that the Council have acted correctly, as the basis of
you decision, is clearly wrong as it does not address my complaint.
Both you and the Council have had my correct complaint and it is
not that I am complaining that the Council issued a claim, but that
they did so based on information that they knew was false at the
time they issued it and had been obtained by deception.

As you see from the most recent correspondence from the Council
they are now asking me questions that they already have the answer
to.

I keep stressing the point that my complaint, which I consider has
not been addressed, is that the Council have used information they
know to be false to issue 2 insurance claims, the matter can be
resolved by revealing the date that the Councils legal liability
ceased in relation to the Kepler Street site. This will prove at a
stroke who is right and who is wrong.

Clearly the contents of the letters from the Council to myself
don't stand up to scrutiny, especially when compared with those of
Maritime Housing.

Throughout this matter I have been stonewalled by your office when
I point out the above, is there no way you can obtain this
information or no will to do so.

As you see from the enclosed letters I have written to the Council
and their insurers to obtain information, my efforts have been met
with the same tactics your office uses. Silence.

I am providing a stamp addressed envelope for the return of my
documents, you may copy them and send me the originals back.”

ON JULY 18TH 2001 MR YATES, THE COUNCIL’S FINANCE DIRECTOR, SENT A
‘MEMO’ TO MR WILLIAMS STATING:

“Mr Robinson…claims we were still on site to September 1994,
whereas I say (based on your memo of 1 March 2001) we ceased to be
involved from 1st April 1994 when we handed over to
Maritime…Maritime Housing have told him we had control of the site
until September 1994, please let me know if in fact we did do
anything, and the details. I am aware that Peter Cowley [Sefton’s
Senior Solicitor] is involved with this matter so I am not sure if
you want me to respond or if it should come from the insurers or
even Peter.”

ON JULY 19TH 2001 MR WILLIAMS SENT A ‘MEMO’ TO MR YATES STATING:

“[I] will endeavour for the last time to research the papers…as
there appears to be conflicting evidence from our own records,
those of our demolition contractors, and those of Maritime Housing
in relation to the completion of demolition works on the Kepler
Street site. In terms of response to Mr Robinson’s latest letter…it
should merely be acknowledged…but that in future correspondence on
the matter should be dealt with through our Insurers.”

ON JULY 19TH 2001 MR WILLIAMS WROTE TO COUNCILLOR MARTIN STATING:

“Thank you for your fax of 2nd July enclosing correspondence from
Joe Benton MP…Mr Robinson is again raking over old coals…and is
embellishing and distorting statements made in our meeting with
him. His central allegation is that his allegations of damage to
his property have been referred to our insurers…the Ombudsman was
of the opinion that the Council had acted properly in dealing with
Mr Robinson…you may wish to enclose a copy of his report in your
response to Mr Benton. Mr Robinson has recently written to the
Council’s Insurance Section and raised queries about the dates when
Sefton were undertaking work adjacent to his property during 1994.
I have arranged for a thorough examination of our archive
records…once I have this information I will pass it to the insurers
and leave it in their hands…all my future dealings with him will be
through our insurers.”

ON JULY 24TH 2001 MS SMITH, SEFTON’S SENIOR CLAIMS MANAGER SENT A
‘MEMO’ TO RSA’S M LOADER HEADED, SUBJECT:- MR ROBINSON W215732 –
RR98XN, STATING:

“I attach the latest letter from Mr Robinson. I note that his of
21.6.01 was copied to G Phillips [RSA]. Given his latest of 20.7.01
and his question of legal liability and compensation I feel that
you ????? matter for yourselves to answer. Please advise.”

ON JULY 26TH 2001 MR BOWNES, SEFTON’S LEGAL DIRECTOR WROTE THE
FOLLOWING TO ME:

“The Ombudsman has fully investigated your compliant…the Council’s
response to your complaint was contained in my letter dated 15th
March 2001.”

ON AUGUST 7TH 2001 GTB, SEFTON’S DEMOLITION CONTRACTOR WROTE THE
FOLLOWING TO ME:

“We started on site at Kepler Street on 17th January 1994…I have no
special instructions in respect of your nib wall…we were not aware
that Maritime Housing Association became owners of the land on 21st
January 1994.”

ON AUGUST 7TH 2001 RSA’S MRS CONNER WROTE THE FOLLOWING TO ME IN A
LETTER HEADED RR98XN:

“It appears to be accepted by both yourself, ourselves and Sefton
MBC that they ceased to have control of the land at Kepler Street
prior to the alleged damage to your property occurring. As such it
would be logical to assume that Sefton Council were not involved in
the removal of the nib wall and consequently cannot be the party
responsible for any alleged damage to your property that resulted
from its removal. Furthermore as no formal claim has been made
against Sefton MBC in respect of the alleged damage and the claim
would now appear to be statute barred I intend taking no further
action in this matter

ON AUGUST 8TH 2001 MS SWALE WROTE THE FOLLOWING TO ME:

“It is my belief that the final day the Council was responsible for
the site was 31st March 1994 and therefore with effect from 1st
April 1994 we ceased to be liable for anything that happened on the
land.”

ON AUGUST 16TH 2001 GTB WROTE TO ME STATING:

“Our Certificate of completion received from Sefton Council on May
3rd 1994 states that the works were completed on the 21st April
1994. If any further demolition was carried out at Kepler Street
after this time it was not done by GTB Demolition Company.”

Yours sincerely,

fred robinson

Dear Hilary Pook,

FOR YOUR INFORMATION

Claim W215732 January 1st 1994

In 1893: 19 Lime Grove was built on the North side of Lime Grove,
as the end terrace house of nine standing next to a large detached
house numbered 21 Lime Grove.

19 Lime Grove was a three bedroom end of terrace house with an
outside toilet. This toilet was situated some 4 metres from the
rear of its kitchen and attached to the Rear Boundary Wall of 19
Lime Grove. This rear boundary wall ran east to west along an
alleyway between Lime Grove and Hawarden Grove.

Looking at 19 Lime Grove from the front, its gable wall ran North
to South and formed its boundary wall with 21 Lime Grove - the
large detached House.

In the 1960's: Numerous streets to the east of 19 Lime Grove,
including 21 Lime Grove were demolished, the land cleared, and
maisonettes and high rise flats built on it. In lieu of 21 Lime
Grove, maisonette block 21 to 39 Lime Grove was built some 5 metres
from the gable wall of 19 Lime Grove. To achieve this, as Lime
grove runs downhill, the level of the land along 19 Lime Groves
gable wall was reduced to level the site and build the adjacent
maisonette block.

The support this land had previously given to 19 Lime Groves gable
wall appears to have been considered important enough to replaced
it with two Party Boundary Structures in the form of what are known
as 'the screen wall' and 'old footings' these were constructed
abutting the gable wall of 19 Lime Grove, presumably by Sefton’s
contractor Messrs Mathews and Mumby Ltd.

The 'old footings' (a misnomer as they 'footed' nothing) extend the
length of the gable wall between The 'screen wall' that extended
between and abutted (around the centre) the gables of 19 Lime Grove
and (to the front of) the maisonettes 21 to 39.

Prior to 1972: The outside toilet in 19 Lime Groves yard was
demolished and the soil pipe to the underground drains, within the
yard of 19 Lime Grove that had served the outside toilet was sealed
off and buried some 250mm below ground level.

In 1983 I applied for a grant from Sefton and a surveyor from 'The
Vis Johnson Partnership' inspected.

Regarding the gable wall this surveyor noted it had a bulge in it
and was not sure if it required rebuilding or not. He recommended
the gable wall be investigated by a structural engineer and
recommended Mr Kevin Smith, a structural engineer, to me.

I engaged Mr Smith and Mr Smith surveyed the gable wall on June 5th
1983, his report states:

“The Property…the end house of a terrace block…there are cracks
visible to the gable and the movement appears to be horizontal
only… there are cracks visible at the junction of the ceilings and
the gable at both ground and first floor levels…the problem would
appear to be a lack of horizontal restraint to the tall and slender
gable wall. The original construction made no provision to tie the
gable wall to the structure at floor and roof levels…the gable wall
itself appears sound…there are no signs of cracked bricks…it is not
possible to determine whether any movement is still taking place…it
is unlikely that any movement will continue once the strapping work
has been done…there is no indication of vertical movement as a
result of inadequate foundations.”

There is a gully that drains surface water into the sewers leading
from the alleyway that runs along the length of the rear boundary
walls of Lime Grove with grids situated in it. A grid leading to
these drains is located some 500mm from the rear gateway to 19 Lime
Grove abutting my boundary wall.

As the land is unadopted this gully and drains are not maintained
and this had caused subsidence in the alleyway which, in turn had
caused the boundary walls of 15, 17 and 19 Lime Grove to lean into
the rear alleyway.

Around March 1985 Sefton, in the form of Mr McDonnagh notified me
Sefton had ordered the demolition of the rear boundary walls of 15,
17 and 19 Lime Grove - due to their 'condition'.

This notification, on a small green card was posted through my
front door [Wednesday] when I was out.

Two days after Mr McDonnaghs notification to me of Seftons
intentions [Friday]. Sefton performed the demolition of the
boundary wall by pushing it over into the yard of 19 Lime Grove.
This demolition was done when I was not at home and resulted in the
locked gate of the rear boundary wall into the alleyway being torn
from its hinges and the lid of my refuse bin being destroyed.

With regard to the damage caused to the rear gate and bin lid, I
made an insurance claim against Sefton and was paid some £37.00 by
their then Manchester based insurers M & M.

This creates an insurance claim record of a claim by myself
concerning, but not for, the demolition of a boundary wall due to
its condition.

It also acknowledges the liability of Sefton for damage caused by
the demolition of the rear boundary wall. I subsequently had the
rear boundary wall rebuilt at no cost to Sefton.

The demolition of this boundary wall had ruptured the underground
drains under the yard of 19 Lime Grove by impacting on the shallow
soil pipe from the demolished outside toilet and caused damage that
remained latent until 1987 when the drains began to 'back up' and
eventually partially collapse, this caused subsidence to the rear
yard, principally at the boundary wall. In 1987 I had the drains
repaired at no cost to Sefton. The boundary wall was unaffected.

In 1984/5 Sefton revamped the maisonettes and proposed to demolish
the party boundary structure the 'screen wall'.

After I had enquired to Sefton on site about their evident
intention to demolish the screen wall Sefton reduced the screen
wall from some 5 metres long to a 'nib wall' some 1.5 metres long
and built a pier on its end.

In Early 1991 A claim against Sefton was contemplated by myself and
I engaged solicitors, David Phillips and Partners who obtained
legal aid for me and, with regard to:

A letter of instruction:

Preliminary advice from counsel:

A statement from myself:

Instructed and had my property surveyed by Mr Alan Jones, a
chartered surveyor. Mr Jones noted in his report:

“Mr Robinson explained that at some time after the Improvement
grant work there was a difficulty at the back of his home in that
part of the boundary wall was demolished. Thereafter, difficulties
were found with the drainage system and drains were re-laid. The
rear yard boundary wall was reconstructed. I regard those incidents
as quite important in the catalogue that has effected 19 Lime
Grove…other incidents have occurred during the history of this
house…when it was first constructed it butted up to but, clearly
did not form part of a bigger and more substantial house which was
immediately to the right or along the east side of Lime Grove. That
house has long since been demolished and in lieu there is now a
development of flats and maisonettes owned by Sefton MBC. The gable
wall of 19 Lime Grove faces toward those properties. In part there
is a screen wall running between the gable of No 19 and the corner
of the maisonettes. Evidently, Sefton, in a renovation process for
their properties, intended to demolish that screen wall. However at
Mr Robinson’s request a nib was left, for it was giving some
support and stability to the gable wall. I have to say a sensible
proposition. One can see at low level toward the rear, that is
beyond the screen wall, where there is a concrete upstand and
concrete apron against the gable wall…those concrete sections
evidently shield and shelter stepped footings to the rear section
(beyond the cellar area. The exposure might well have come about at
the time the maisonettes were constructed by the winning of the
land and change in levels, that would of course be before the
purchase by Mr Robinson and his interest in No 19…between the front
right hand corner of the house and the footwalk there is a boundary
wall. That is in 225mm brickwork rising to a height of about 2
metres and capped by heavy concrete coping. It seems the wall
probably replaces and had been extended from an earlier wall. There
is block bonding between the red brick quoin of the original front
elevation of the house and the common brick gable wall. One can see
where this boundary has dragged away from the main structure. In
effect, it has rotated on its axis at the point of intersection
with the quoin to the front right hand corner. In so doing, it has
dragged away and opened up at joints there…Mr Robinson has
discovered that fractures are beginning to appear, (hairline
fractures), in particular to the outrigger portion of the
property…notwithstanding the bow which one can clearly see to the
gable wall and notwithstanding the presence there of various plates
and ties that pass through, one cannot see anything sinister
occurring at this moment to the main portion of the gable…however,
there is an old tie which shows in the end of the terrace to the
right of the masonry and thee is a pronounced bow of the brickwork
at the front quoin. How old is that bow? I would suggest it has
been there many years…it would have been ideal in 1983 or 1984 to
suggest that the gable wall be reconstructed in a truly vertical
plane and upon new foundations. It is not necessarily the case of
course that underpinning of that gable wall for the outrigger would
have been considered necessary at the time. That could be the case
whether or not the bulge in the gable wall was as great as it is at
this moment. A bulge does not necessarily denote defective
foundations. Moreover a situation obtains where there must be
different levels of foundation. The cellar section has walls which
go down some 1500mm below the remainder and it is highly unlikely
that because of the change of levels, there would have been deep
foundations to the back section of the gable or indeed the
outrigger. (for it is borne out by the presence of the concrete
apron to part of the rear section of the gable / flank wall

On May 14th 1992: Mr Jones rang my solicitors’ Mr Skinner,
regarding his report of November 8th 1991 and a conversation they
had had previously. Mr Jones stated to him:

“Mr Robinson forwarded to me direct a copy of Kevin Smith
Associates report…dated 5th June 1983. I also received (directly
from Mr Robinson), an account for repairing a broken drain which
account is dated 23rd February 1987 and is in the sum of £290.
Thereafter you kindly took up with Sefton MBC whether or not the
authority could make its file available. Sefton has now replied to
indicate the file was destroyed some time ago…the situation remains
whereby movement seems to be continuing to the house. The only
source of finance that seems likely to be available to put right
any difficulties would be that of Mr Robinson’s own pocket, for I
cannot see on the basis of the present evidence contributions might
be received from any other source.”

Around January 9th 1993: David Phillips and Partners, my
solicitors, obtained a second counsels advice from Mr Graham Woods
whose advice states:

“I was first instructed in this matter in the early part of 1991,
proceedings were contemplated against Metropolitan Borough of
Sefton, who had supervised grant – aided repair work to Mr
Robinson’s terrace dwellinghouse…I indicated in my preliminary
advice that it was impossible to give any opinion as to the merits
of the proposed claim in negligence, assuming an duty of care could
be established without the benefit of a detailed history and an
engineers report. Mr Jones has subsequently provided that
report…and a further short report in May of this year. I am
required to consider the merits of the proposed claim for the
purpose of the Legal Aid Authority…when Mr Jones first reported he
did not have the benefit of Kevin Smiths report Mr Smiths liability
was limited to the provision of restraint to all walls…undoubtedly
Mr Robinsons property is suffering from subsidence. It is
ongoing…ultimately, remedial works by means of underpinning will be
required. The issue of any negligence action is a simple one. Was
such subsidence evident to a significant degree in 1983/1984…it
would seem that Mr Jones has considered this aspect
comprehensively, and is unable to advise that the present condition
did not obtain when works were undertaken in 1983/1984 and that
they could not have been speculate by Sefton.”

On January 15th 1993: My legal aid was discharged on the basis of
the above advice.

On June 10th 1993: Sefton informed me of a proposed development on
the land adjacent to my property known as 'The Kepler Street site'.
I went to Seftons Planning Department and viewed the ‘layout
drawings’ for the proposed development

This work was seemingly to include the demolition of the Party
Boundary Structures. No other party connected with the development
was mentioned in the letter of June 10th 1993 and I took it that no
other party was involved and that it was a Sefton Council project.

On August 3rd 1993: I wrote to Sefton stating:

"Re my recent visit to your planning Department about the existing
nib wall and old footings at the side gable of my property, can you
inform me of any action the Council would take about the above,
should the development go ahead."

On August 10th 1993: Sefton’s Mr Louhran responded stating:

“From your letter it is not possible to ascertain the reason behind
your enquiry. Please contact my assistant Mrs P Carruthers in my
development and control section who will be able to assist you
further.”

On September 8th 1993 I wrote to Sefton, clearly under the
impression it was they who were to develop the land, stating:

"I refer to your letter dated 10 August 1993. Your plans show no
nib wall or old footings adjacent to my gable wall, do you intend
to remove these when you develop the site or do you intend to alter
your plans to show their presence."

On September 16th 1993: The above letter was sent to: the Director
of Property Services, Pavilion Buildings, Southport, marked for the
attention of Sefton’s Mr Barr who was the Principle Architect on
the project at Kepler Street.

On October 1st 1993: Sefton’s Mr Barr wrote to me stating:

“I appreciate your concern about your gable wall, ‘nib’ wall and
associated footings. May I reassure you that when the site is
redeveloped adjacent to your property, there should be no
interference with these features. The layout drawing which was
provided for consultation purposes is of such a small scale that
the details to which you refer would not be shown.”

On March 22nd 2006: In claim 5LV55490, Robinson v Aon Corporate Mr
Craig Sayer, a lawyer employed by Sefton’s Claims Managers, the Aon
Corporation, in claim 5LV55490, Robinson v Aon sent, to the
Liverpool County Court, and copied to me a letter in response to my
application for details of the basis of claim(s) W215732 dated 1993
from Aon for “the demolition of none existent buildings in the
1960’s” and, for an “incident” dated January 1st 1994. Mr Sayer
verified and stated the following:

“The incident date of 1 January 1994, which is a referred to is
used for Aon’s and the insured’s (Sefton’s) purposes to ascertain
which policy year any claim attaches to or may attach to at a later
date. There is no specific incident that took place on the 1st
January 1994 and this may account for the claimant’s confusion.
Similarly, the date of 1st January 1994 does not refer to a
specific claim as it is an internal date used by Aon and Sefton.

Correspondence was received prior to 1st January 1994 from the
claimant, i.e. his letters of 3 August and undated letter received
by Sefton on 9 September 1993…it is not clear why the date of 1
January 1994 should be amended in the light of the information set
out above or why the Claimant wishes to have the date amended.”

NB This document is an amendment of a document entitled “Report of
Crime by Sefton MBC” dated July 17th 2006 that was hand delivered
to Merseyside Police, Filed at Liverpool county court, and
delivered by hand to Sefton Council at Balliol House Bootle, who,
stamped each page of it as received on July 17th 2006.

Yours sincerely,

fred robinson

Dear Hilary Pook,

I REFER YOU TO THE APHORISM:

“IF YOU WISH TO FIND THE CRIMINALS, DON’T FOLLOW THE CRIMINALS,
FOLLOW THE MONEY.”

FOR THE MONEY READ THE LAND

In 1962: Crosby Council, initiated a compulsory purchase order to
buy a plot of land to the south of Lime Grove consisting of Maple
Grove, Willow Grove, Bangor Street and Beaumaris Street which is
shown on OS SJ3396.

This land was subsequently filed under title LA45343 at the Land
Registry.

In December 1964: Land to the north of Lime Grove, bought under a
compulsory purchase order by Crosby Council, was registered under
title LA45086 at the Land Registry using OS SJ3396 dated 1955.

By 1968: Numerous streets to the north of 19 Lime Grove, including
21 Lime Grove, had been demolished, the land cleared, and
maisonettes built on it. This land became known as the Kepler
Street Estate.

One of the maisonette blocks, 21 to 39 Lime Grove, was built some 5
metres from the gable wall of 19 Lime Grove.

The level of the land adjacent to 19 Lime Grove was consequently
lowered by Crosby Council’s contractors to accommodate the building
of these maisonettes, and the support that this land had previously
given to 19 Lime Groves gable wall was removed and, in so doing,
exposed the shallow footing of part of 19 Lime Grove’s gable wall.

Crosby Council’s building contractors, Mathew and Mumby,
subsequently replaced the former support with two Party Boundary
Structures in the forms of what are known as, the ‘screen wall' and
the 'old footings' some 700mm square which were constructed
abutting the gable wall of 19 Lime Grove around 1968.

The first and most significant of these structures being the ‘old
footings.’ The term 'old footings' a misnomer as they 'footed'
nothing and were in fact a ‘buttress.’ They remain in place today
and, with the land they stand on, are, and have been since 1994,
the property of Maritime Housing Association.

The second was a wall built abutting the gable wall of 19 Lime
Grove around its centre, and extending to abut the gable wall of
the maisonette block, 21 to 39 Lime Grove near its front elevation.

The location of this wall is of some significance as it was
constructed at the point where the footings of the gable wall
descend into a cellar and thus obviate the need for support beyond
that point.

Clearly those structures belonged to Crosby Council.

This is borne out by the fact that the brick cladding of the gable
wall of the maisonettes was, the same brick as used to construct
the screen wall, and obviously, both structures stood on Crosby
Council’s land.

The structure the ‘screen wall’ was first shown on OS SJ3396 in
October 1969, and by October 1989, (according to a ruling in the
House of Lords) 19 Lime Grove had obtained a legal right to the
support it gave.

Beyond the rear of the screen wall where, the footings were exposed
by the excavation of the land, is where the old footings abutted
it, and from there commenced, it is abundantly clear that no other
purpose can be attributed to this constructions other than to give
support to the gable wall of 19 Lime Grove and, that purpose, in
the absence of any other, would be obvious to an engineer,
architect, surveyor or any competent builder.

This contention is borne out by the fact that the old footings
extend beyond the gable wall and continue to give support not only
to the gable wall but also to the boundary wall which, extends some
four metres from the gable wall.

The ‘old footings’ are still in situ but, have never been recorded
on an OS map. They could not be removed at any time after 1984
without causing structural damage to my property.

In 1973: A new version of OS SJ3396 was drawn which did not
included the Star of the Sea Junior School, built in 1974, but did
included the maisonettes 21 to 39 Lime Grove with the boundary
structure, the 'screen wall' still shown running at right angles
between the respective gable walls of 19, and 21 to 39 Lime Grove.

In 1978: A new version of OS SJ3396 was drawn which included the
Star of the Sea Junior School, the maisonettes 21 to 39 Lime Grove
with the boundary structure, the 'screen wall' still shown running
at right angles between the respective gable walls of 19, and 21 to
39 Lime Grove.

In March 1977: The land, known as the Kepler Street Estate, filed
at the Land Registry in 1964 under the title number LA45343 using
the 1969 OS SJ3396 map: had removed from it a parcel of land
re-registered under title MS351603 which included the maisonettes
21 to 39 Lime Grove with the boundary structure, the 'screen wall'
still shown running at right angles between the respective gable
walls of 19, and 21 to 39 Lime Grove.

In April 1977 The land filed at the Land Registry under title
number LA45343 using OS SJ3396 dated 1966: had removed from it two
parcels of land that were also re-registered under title MS351603.
The 1966 OS SJ3396 did not include the maisonettes 21 to 39 Lime
Grove with the boundary structure, the 'screen wall' shown running
at right angles between the respective gable walls of 19, and 21 to
39 Lime Grove, because in 1966 they had not been built.

In 1984/5 Sefton Council revamped the maisonettes including 21 to
39 Lime Grove and reduced the screen wall from some 5 metres long
to a 'nib wall' some 1.5 metres long and built a pier on its end.

Clearly Sefton Council also attached some significance to the
screen wall’s role of support to my gable wall, and just as
clearly, their actions prove that they owned it by virtue of them
reducing and strengthening it, something Maritime Housing
Association seemed unaware of, because when they wrote to me on
October 5th 1999 - in response to a photograph of the nib wall in
situ, taken by Sefton Council (their appointed agents) on March
14th 1994 during a survey which, in June 2000, Maritime did know
about and, which they also (then, if not before) knew was prior to
the demolition of the maisonette block 21 to 39 Lime Grove - they
stated:

“Sefton as our agent, are responsible for controlling building
operations on our behalf, but as I have already said, demolition
was still taking place up to September 1994, which had nothing to
do with Maritime…looking at the photograph you have sent me I
notice what appears to be either a newly built brick pier attached
to your wall, or an old pier that has been repointed…I would
question who constructed, or repointed, the brick pier. ”

In 1989: A new version of OS SJ3396 was drawn showing no screen
wall between 19 and 21 to 39 Lime Grove.

On August 13th 1993: Planning Permission for:

“Erection of single story and 2 storey dwellings after demolition
of the existing maisonettes.”

Was granted to Maritime Housing Association.

On September 25th 1992: The three titles, taken from Titles LA54086
and LA45343, and filed under MS351603, were Registered separately
to Sefton MBC at Bootle Town Hall, and Southport Town Hall.

On October 28th 1993: Sefton Council’s Housing Standing Sub
Committee resolved, that:

“Demolition of maisonette blocks at Kepler Street prior to
development by Maritime Housing Association. (1) That the
appropriate officer be authorised to implement the demolition works
by acceptance of the tender of GTB Demolition company…in the sum of
£95,693 subject to the land being acquired by Maritime Housing
Association by December 31st 1993. That subject to (1) above the
Borough Property Services Officer be authorised to issue a letter
of intent in advance of formal contract documentation.”

On December 16th 1992: Sefton Council’s Housing Standing Sub
Committee considered the report of the Borough Property Services
Officer recommending the transfer of land for two new build sites
to Maritime Housing Association.

On December 13th 1993: A new version of OS SJ3396 was drawn showing
no screen wall between 19 and 21 to 39 Lime Grove.

On December 24th 1993 Sefton Council and Maritime Housing
Association, after taxation, signed and sealed the transfer
documents for the sale of 3.5 acres of land under titles 1. (a)
LA45086 and (b) LA45343.

This land consisted of the three plots filed in March and April
1977 with the Land Registry under the title numbers LA45086 and
LA45343 re-referenced to Sefton on September 25th 1992 which, the
transfer document shows were to be given a new title number with
another two parcels of land, i.e.:

(c) the land comprised in an agreement dated 7 August 1967 made
between Liverpool Roman Catholic Archdiocese & Trustees
Incorporating (1) and the Mayor Aldermen and Burgesses of the
Borough of Crosby.

(d) the land comprised in a Statutory Declaration dated December
16th 1993 made by Michael Scott.

There were on December 24th 1993, to my knowledge, five distinct OS
SJ3396, maps of the Kepler Street estate available, they were:

The first dated October 1969 – showing the screen wall

The Second dated 1973 - showing the screen wall

The third dated 1978 – showing the screen wall

The fourth dated 1989 – showing no screen wall

The fifth dated December 13th 1993 – showing no screen wall

Bound with the transfer documents was a ‘cut and pasted’ version of
OS map SJ3396 comprising of: an ‘outer section’ being OS SJ3396
dated 1978 showing the Star of the Sea School and,

an ‘inner section’ depicting the land filed under titles MS351603,
united by a section of public highway named Maple Close.

The screen wall, despite being on both of the versions of OS SJ3396
used in the forgery, had been erased from this transfer map.

The altered OS map SJ3396 provided for sale of the land is a forged
instrument under s.8. (1) (a) and 9 (2) of the Forgery and
Counterfeiting Act 1981 as it does not depict the presence of the
party Boundary Structure 'the screen wall' and is clearly
calculated to deceive.

This document also breaches s. 183 (1) of the Law of Property Act
1925 as neither Sefton or Maritime showed "due diligence" in the
sale of the land in breach of s. 2 of the Property Misdescriptions
Act 1991.

At 2, of the transfer document it is stated:

“It is agreed between the Council and the Association that any
boundary structure now or hereafter constructed within 80 years of
the date herein between the property herby transferred and the
adjoining land of the Council are party boundary structures and are
maintainable and repairable as such.”

This land is identified at 3, of the transfer documents as land
referenced by Planning Permission as 93/03897/S. this reference was
given to me by Sefton Council’s Planning Department as land
provided for: “Erection of single story and 2 storey dwellings
after demolition of the existing maisonettes.”

This permission was the permission granted on August 13th 1993.

The above dwellings are all now in situ on the land registered to
Sefton Council under title MS351603 on September 25th 1992, taken
from title LA43086 1977.

These dwellings are also identified in a ‘memo’ from Sefton’s Mr
Barr, to Sefton’s Mr Williams: Referenced HSG 1188/2, and dated
November 12th 1999 in which Mr Barr states, with regard to 19 Lime
Grove – with a twist as to responsibility:

“This particular dwelling lies within an area which was redeveloped
by the Council in conjunction with Maritime Housing Association
during the period January 1994 to September 1995. The work
basically involved the demolition of 7 blocks of 4 storey
maisonettes and the construction of 49 new 2 storey traditionally
built houses as part of the City Challenge program relating to
relocation of residents of the former Rimrose Housing Estate.”

And further, with another twist:

On November 16th 1999, Fawley Construction, Maritime’s Building
contractor, wrote the following to me:

1. “Our site plan 417/01 was adapted from Sefton Council’s drawing
HSG 1187.1A which did not show a nib wall attached to your
property, therefore one was not included on our drawing submitted
for planning approval.”

2. Drawing HSG 1187, a used as part of the transfer map, and is
marked as a Sefton Planning Department drawing based on OS SJ3396
dated 1978, which has had the screen wall erased from it.

3. This clearly shows that Sefton and Fawley, if not Maritime, had
a drawing, and knowledge, at the planning stage of the development
in August 1993 that showed no nib wall abutting my gable wall. All
three had contractual obligations to each other.

On August 31st 1994 the land shown on the forged OS map used to
transfer the land at both Kepler Street, shown on title LA45086,
and Maple Grove, shown on LA45343 which was united by the public
highway, Maple Close, was registered by the Land Registry under
title MS351603 to Maritime Housing, at 2, of the office copy of the
Property Register dated February 3rd 2006, it states:

“2. (21.01.1994) A transfer of the land in this title dated 24
December 1993 made between (1) The metropolitan Borough of Sefton
and (2) Maritime Housing Association Limited contains the following
provision:-

2, It is agreed between the Council and the Association that any
boundary structure now or hereafter constructed within 80 years of
the date herein between the property herby transferred and the
adjoining land of the Council are party boundary structures and are
maintainable and repairable as such.”

The title map that accompanies this title is a forgery which again,
like the transfer map is composed of two versions of OS SJ3386 cut
and pasted together, this time, the outer section is that of OS
SJ3396 dated 1984 showing the Star of the Sea junior school, and
the inner section, that of OS SJ3396 dated 1969, clumsily overlaid
on it which has, amongst other things, removed the pavement between
Seaforth Road and 19 Lime Grove and the entire pavement from
Seaforth Road and the opposite side of Lime Grove through to Maple
Close from it.

This title map is marked: Crown copyright 1975.

The altered OS map SJ3396 draw by the Land Registry for
registration of the land is a forged instrument under s.8. (1) (a)
and 9 (2) of the Forgery and Counterfeiting Act 1981 as it does not
depicts the presence of the party Boundary Structure 'the screen
wall' and is clearly calculated to deceive.

This document also breaches s. 183 (1) of the Law of Property Act
1925 as the Registry did not show "due diligence" in the production
of this title map and also breach of s. 2 of the Property
Misdescriptions Act 1991.

Yours sincerely,

fred robinson

Dear HILARY POOK

Sefton Council from the evidence below did not have sufficient
legal interest over the land to instruct Fawley Construction to
grant me a one metre strip of land along my gable wall and alter
the boundary of the land between my property and that of Maritime
housing Association: Consequently, it is for Maritime to establish
that Sefton was given that interest in the strip of land to give it
to me on their behalf.

It is common ground between Maritimes contractor Fawley
Construction and Sefton that Sefton’s instructions to Fawley in
April 1994 for the alteration of the boundary based on Sefton’s
mapping, was supported by Maritime at the Planning stage of the
development granted on June 29th 1994 under reference’s: 417/02 -
417/04 - 417//04 – 417/05, 417/06 plus revised layout plan, and
417/07 revision E.


It is also common ground between Sefton Council, myself and its
insurers, Royal & SunAlliance that the Council had no insurable
interest in the land from December 24th 1993 when Sefton
transferred the land title to Maritime.

However, the minutes from a ‘pre site meeting attended by Sefton,
Fawley and Maritime on July 28th 1994 state “NO HANDOVER WILL BE
ACCEPTED WITHIN 10 DAYS PRIOR TO CHRISTMAS DAY.”

Maritime at that time were averring that their ‘RECORDS’ showed the
land was transferred to them from Sefton in “MID 1995.”

The registration for this land under tile MS351603 is recorded as
August 31st 1994. The Land Registry say that from December 24th
1993 Maritime were the owners of the land, the Registry also say in
an office copy dated February 3rd 2006, that, due to the transfer
of the land, the title absolute of the freehold land was Maritime’s
from January 21st 1994.

There is no common ground between Maritime and Sefton as to who had
‘CONTROL’ over the land from December 24th 1993 until September
1994.

Sefton’s CEO states that from December 24th 1993 Maritime were
RESPONSIBLE for the land, however, the Council’s insurance section
and the CEO’s officers state that Council had an interest in the
property until is was “HANDED BACK TO MARITIME ON APRIL 1ST 1994”.
This brings Sefton within the Occupiers Liability Act between
January and September 1994.

However, Maritime say that Sefton were “IN CONTROL OF THEIR
CONTRACTORS ON THE LAND DURING THE CONSTRUCTION OF THE HOUSES ON
IT” which was until: so Sefton’s Principle Architect says,
SEPTEMBER 1995. This brings Sefton within the Occupiers Liability
Act between January 1994 and September 1995. Fawley, who did not
start their building activities on the land until September 1994,
aver in a WITNESS STATEMENT to the court they were under the
‘VERBALLY AGREED’ control of Sefton in February 1995.

However, Sefton say that they were LICENCED by Maritime to be on
the land to effect demolition of the existing maisonettes between
JANUARY 21ST AND MARCH 31ST 1994 when their interest in the site
ceased. This removes them from the Occupiers liability Act.

However, Sefton also say [PAW/RRROB6 MAY 8TH 2000] that, to the
best of their knowledge, “MARITIME HOUSING TOOK POSSESSION OF THE
SITE ON MARCH 14TH 1994.” This means that whoever Maritime took
possession from on March 14th 1994 had POSSESSED the site until
March 14th 1994.

However, Maritime say as far as they were aware [DV/PQ A4345
SEPTEMBER 28TH 1999] that, “UP UNTIL SEPTEMBER 1994 THE SITE WAS
UNDER THE CONTROL OF SEFTON COUNCIL WHO WERE NOT ACTING ON THE
BEHALF OF THIS ASSOCIATION BETWEEN JULY AND SEPTEMBER 1994…THEY
WERE APPOINTED BY US TO OVERSEE AND LOOK AFTER OUR INTERESTS WHILST
THE HOUSES WERE BEING BUILT” This brings Sefton under the Occupiers
Liability Act ‘up to September 1995.
However, Sefton say [PAW/RRROB6 MAY 8TH 2000] that “FROM DECEMBER
24TH 1994 THE RESPONSIBILITY FOR THE LAND PASSED TO MARITIME AND
ANY WORK OF DEMOLITION BY SEFTON WHICH MAY HAVE STILL BEEN UNDERWAY
AFTER THAT DATE WOULD HAVE BEEN SANCTIONED BY MARITIME”. This
asserts that Sefton were acting “ON BEHALF OF THIS ASSOCIATION
BETWEEN JULY AND SEPTEMBER 1994”.
However, Maritime say [DV/PJQ/A2983 MARCH 2ND 1999] that “I am sure
you will appreciate that there are many departments in Sefton
Council that could have carries out the demolition, if, in fact the
demolition was carried out by Sefton Council.”

However, Maritime state [DV/PQ/A2302 MARCH 4TH 1999] “THIS
ASSOCIATION WAS NOT RESPONSIBLE FOR THE DEMOLITION OF THE
MAISONETTE BLOCKS WHICH PREVIOUSLY OCCUPIED THE SITE. THIS
ASSOCIATION TOOK POSSESSION [ON MARCH 14TH 1994] OF A CLEARED SITE,
FOLLOWING DEMOLITION BY SEFTON COUNCIL.”

However Royal & SunAlliance say on November 16th 200 [in a claim
for an incident on January 17th 1994 referenced:
RR98XN/conner/TPPZ] that ”ANY CLAIM FOR DAMAGE TO YOUR PROPERTY
RESULTING IN THE DEMOLITION WORKS CARRIED OUT BETWEEN 14 MARCH AND
6 APRIL 1994 SHOULD BE REDIRECTED TO FAWLEY CONSTRUCTION WHO WERE
THE DEMOLITION CONTACTORS RESPONSIBLE FOR CARRYING OUT THE WORKS.”
– “Work’s” is defined as including demolition works under the
Building Act.

However, Maritime say [DV/PQ/A3054 MARCH 17TH 1999] “THE SITE
CLEARANCE WAS NOT CARRIED OUT BY THE SAME CONTRACTOR WHO UNDERTOOK
THE REDEVELOPMENT OF THE SITE FOR THIS ASSOCIATION.” Which was a
reaffirmation of a statement by Maritime and copied to Sefton
[DV\PQ\A2302 MARCH 4TH 1999] regarding “THE ASSOCIATIONS BUILDING
CONTRACTOR WHO WAS RESPONSIBLE FOR OUR DEVELOPMENT AT KEPLER
STREET.” Which was again reiterated by Maritime’s statement
[PJQ\DV\C3019 SEPTEMBER 8TH 1999] that “THE STRICT LEGAL POSITION
IS THAT WHEN A CONTRACTOR TAKES POSSESSION OF A SITE HE IS
RESPONSIBLE UNTIL THAT SITE IS HANDED BACK TO THE OWNER…SEFTON MBC
WERE EMPLOYED AS THIS ASSOCIATION’S AGENTS, AND AS SUCH WERE
RESPONSIBLE FOR TAKING SUCH ACTION AS WAS NECESSARY TO ENSURE THE
COMPLETION OF THE NEW HOUSES. THEY WERE, THEREFORE, EFFECTIVELY IN
CONTROL OF THE SITE ON OUR BEHALF.” This brings Fawley within the
Occupiers Liability Act.

However, the minutes from a ‘pre site meeting attended by Sefton,
Fawley and Maritime on July 28th 1994, some months after the
demolition of the maisonettes on the land had been completed, give
the dates for contract COMMENCEMENT OF THE BUILDING CONTRACT WITH
FAWLEY AS COMMENCING ON MARCH 14TH 1994 WITH A COMPLETION DATE OF
APRIL 21ST 1995.

However, Fawley Construction says that they took POSSESSION of the
land on March 14th 1994.

However, there is a document “PASSAGE OF OWNERSHIP” dated March
14th 1994, accompanied by an undated deed TRANSFERRING the land
from Fawley to Maritime to meet their stage payments for work under
the ‘City Challenge Scheme’ sponsored by the Government.
The law is that: If A and B are in dispute about ownership of a
piece of land, the only question for the court is which of the two
of them has the better title to the land.
From the above it appears that Maritime contest the date on which
they themselves owned the land by the transfer of it to them from
Sefton being dated by them as either December 24th 1993 [a witness
statement to the court, verified by a statement of truth states
Maritime, ”obtained legal title to the land on the 24th December
1993] which is contradicted by the statement on February 1st 1999
that Maritime’s records showed the land was transferred to them in
“MID 1995.”
It is not common ground with anyone that the land was registered or
unregistered on December 24th 1993.
Section 3 (2) of the Land Registration Act 2002 deals with the
circumstances in which a person may apply to be registered as the
proprietor of what had hitherto been an unregistered legal estate.
Section 3(2) provides as follows:
Section 11 (11) of the Land Registration Act deals with the effect
of registration of a person as the proprietor of a freehold estate,
and provides: "THE ESTATE IS VESTED IN THE PROPRIETOR TOGETHER WITH
ALL INTERESTS SUBSISTING FOR THE BENEFIT OF THE ESTATE."


It is clear there was a delay of over seven months between the
possesessory title of the land and its registration on August 31st
1994, this registration should have been completed within two
months and. by virtue of that fact, and there must have been
something ‘special’ to account for this delay.

Section 11(7) deals with the special case of possessory title and
provides that: "REGISTRATION WITH POSSESSORY TITLE HAS THE SAME
EFFECT AS REGISTRATION WITH ABSOLUTE TITLE, EXCEPT THAT IT DOES NOT
AFFECT THE ENFORCEMENT OF ANY ESTATE, RIGHT OR INTEREST ADVERSE TO,
OR IN DEROGATION OF, THE PROPRIETOR'S TITLES SUBSISTING AT THE TIME
OF REGISTRATION OR THEN CAPABLE OF ARISING."


It is common ground [by evidence] between Sefton and Maritime and
the Land Registry that on January 21st 1994 Maritime became the
owners of the land by way of a forged certified transfer document
and forged mapping composed of two versions of OS SJ3398 dated 1978
and 1969 cut and pasted together. It is also common ground [by
evidence] that the Registry ALTERED the mapping used in the
transfer with a forged title map for this same land composed of two
versions of OS SJ3396 dated 1969 and 1884 cut and pasted together.

The reasons allowed by the Land Registry Act allow the registrar to
alter the registrar; “FOR THE PURPOSE OF:
 (A) CORRECTING A
MISTAKE,
 (B) BRINGING THE REGISTER UP TO DATE,
 (C) GIVING EFFECT
TO ANY ESTATE, RIGHT OR INTEREST EXCEPTED FROM THE EFFECT OF
REGISTRATION, OR
( D) REMOVING A SUPERFLUOUS ENTRY.”

I HOPE THIS ASSISTS

Yours sincerely,

fred robinson

Dear Hilary Pook,

FOR INFORMATION:

COVERT MEANS SECRET OR HIDDEN.

OVERT MEANS OPEN.

RECIPIENT MEANS SOMEONE WHO RECEIVES SOMETHING.

DATA SUBJECT REQUEST IS SOMETHING SENT TO THE RECIPIENT OF IT.

CONFIRM OR DENY MEANS TO GIVE A CONSTRUCTIVE ANSWER TO A REQUEST
UNDER THE FOIA.

Overt correspondence from the IC to me - 2002:

May 7 – 14 – 22

July 15

August 6 - 22

Covert correspondence to Sefton Council from the IC January 5 2004.

ON FEBRUARY 23RD 2004 IN CLAIM LV 306271 ROBINSON V SEFTON MBC,
SEFTON COUNCIL'S LEGAL DIRECTOR FILED AN UNVERIFIED DOCUMENT IN
COURT WHICH THE COURT SAYS WAS A 'DEFENCE' (THE FIRST DEFENCE)
REGARDING FRAUDULENT INSURANCE CLAIMS W215732, RR98XN AND AT01939
STATING:

"These claims are now statute barred having been raised in 1995 and
again in 1996...there is no obligation on the Council to notify
third parties that any information is unreliable or unfounded...any
claim that the Claimant may have in respect of his wall affecting
his property is now statute barred...any claim in relation to data
should be addressed to the Data Protection Registrar and is a
matter of which the court has no jurisdiction"

Covert correspondence to Sefton Council from the IC March 1st 2004.

Overt correspondence from the IC to me - 2004:

March 3

April 8 – 14

ON APRIL 14TH 2004, ADDLESHAW GODDARD, A FIRM OF SOLICITORS - NOT
ON THE COURT RECORD - SENT A "VERIFIED DEFENCE" TO THE COURT SIX
DAYS OUT OF TIME IN CLAIM 4LV11339 ROBINSON V ROYAL & SUN ALLIANCE
PLC STATING:

"ON OR ABOUT 20 FEBRUARY 1996 THE SUN ALLIANCE WAS NOTIFIED BY
ROLLIN HUDIG HALL...OF A POSSIBLE CLAIM AGAINST SEFTON BY THE
CLAIMANT [REFERENCED] W215732. SUN ALLIANCE'S REFERENCE RELATING TO
THAT CLAIM WAS AT01939...ON OR ABOUT 13 JULY 2000 THE DEFENDANT WAS
NOTIFIED BY AON CLAIMS MANAGEMENT...OF ANOTHER POSSIBLE CLAIM BY
THE CLAIMANT [WHICH] AROSE OUT OF A LETTER DATED 18 APRIL 2000
WRITTEN BY THE CLAIMANT TO MR WILLIAMS, TECHNICAL SERVICES DIRECTOR
OF SEFTON. THE DEFENDANTS REFERENCE IN RELATION TO THE SECOND CLAIM
WAS RR98XN. THE DEFENDANT FIRST WROTE TO THE CLAIMANT IN RELATION
TO THE SECOND CLAIM ON 7 SEPTEMBER 1994 STATING IT WAS NOW HANDLING
THE MATTER ON BEHALF OF SEFTON...THERE FOLLOWED VOLUMINOUS
CORRESPONDENCE BETWEEN...VARIOUS INDIVIDUALS WORKING FOR SEFTON,
VARIOUS COUNCILLORS OF SEFTON, THE ASSOCIATION OF BRITISH INSURERS,
THE LOCAL GOVERNMENT OMBUDSMAN, MERSEYSIDE POLICE, MR J BENTON MP,
THE DEPARTMENT OF THE ENVIRONMENT AND THE PRIME MINISTER. SOME OR
ALL OF THIS LATTER CORRESPONDENCE WAS COPIED TO THE DEFENDANTS."

June 4

ON JULY 19TH 2004 SEFTON COUNCILS LEGAL DIRECTOR FILED AN
UNVERIFIED 'DEFENCE' IN COURT (THE SECOND DEFENCE) STATING:

"The Claimant is a Local Authority who in 1993 were owners of the
land...between January and April 1994, demolition took place of
existing Council housing at that site culminating in redevelopment
work on the site being completed on 26th September 1994...a claim
was received from solicitors acting for the Claimant on 29th
November 1995...and a claim number was allocated being claim number
W215732...that claim is now statute barred...the Councils Technical
Services Director met with the Claimant on the 18th day of April
2000 and advised him to seek independent legal advice in relation
to his claim as at that date it was close to becoming statute
barred...the Council paid for a survey to be carried out on the
Claimants property...the Claimant has inundated the council with
correspondence to its Technical Services Department, its Insurance
Section,its Planning Department, its Chief Executive, its Legal
Department, its Data Protection Officer its Councillors and the
local member of Parliament in relation to a number of allegations
against the Council in respect of claim number W215732 which the
claimant has stated is a claim he did not make...a full
investigation has been carried out by the Information
Commission...the Information Commission have held that in respect
of Mr Robinson's access request data held by the Council is not
part of a "relevant filing system"...the Information Commission
refers to the "Durant" case on the interpretation of the Data
Protection Act 1998."

THE OVERT PURPOSE GIVEN TO ME BY THE IC WAS THAT THE ONLY PERSONAL
INFORMATION OF MINE BEING DISCUSSED WITH SEFTON COUNCIL WAS
INFORMATION FROM 1994 WHICH, THE COUNCIL TOLD THE IC, CONSISTED OF
SOME 700 DOCUMENTS.

THERE ARE AND NEVER WERE 700 DOCUMENTS PRODUCED IN 1994, I.E 14
DOCUMENTS A WEEK FOR A WORKING YEAR AND THEREFORE THEY DID NOT FALL
UNDER "DURANT" AS THEY ARE FALLACIOUS.

Yours sincerely,

fred robinson

Dear Hilary Pook,

I REFER YOU TO CORRESPONDENCE BETWEEN JULY 5TH 2006 AND JULY 12TH
2007.

ON JULY 5TH 2006 I WROTE AND FILED AT COURT A LETTER TO THE OFFICE
OF THE DEPUTY PRIME MINISTER ENTITLED “REPORT OF FALSIFIED LAND
RECORDS.” DETAILING WITH COPIES, HOW THE MAPPING OF THE LAND SOLD
TO MARITIME HOUSING ASSOCIATION AS KEPLER STREET SEAFORTH, HAD BEEN
CONVEYED AND REGISTERED USING FORGED MAPPING.

ON JULY 11TH 2006 THE COURT WROTE THE FOLLOWING TO ME:

“District Judge Fitzgerald has asked me to write to you and
acknowledge receipt of the document that you filed on 5th July
2006, i.e. Report of Falsified Land Records and a letter from the
Information Commission dated 25th November 2003.”

SHAYNE BROWN, FROM THE DEPARTMENT OF COMMUNITIES AND LOCAL
GOVERNMENT ACKNOWLEDGED MY REPORT ON JULY 12TH 2006 STATING:

“Thank you for your letter regarding the Report of Falsified
Records…the Department for Communities and Local Government has
considered your letter but unfortunately it does not have
responsibility for the issue raised. However, we have forwarded
your letter today to the Department of Constitutional Affairs.”

I FILED THIS LETTER AT COURT

ON JULY 17TH 2006 I FILED AND SERVED ON MARITIME HOUSING
ASSOCIATION AND SEFTON COUNCIL A “CRIME REPORT” TO MERSEYSIDE
POLICE REGARDING THE FORGED MAPPING USED TO REGISTER THE LAND AT
KEPLER STREET SEAFORTH, AND COPIED IT TO THE DEPUTY PRIME MINISTER,
MR PRESCOTT FOR FORWARDING TO THE DEPARTMENT OF CONSTITUIONAL
AFFAIRS.

ON JULY 24TH 2006, MS FOX, THE LAND REGISTRIES ASSISTANT TO LAWYERS
FROM LONDON, WROTE THE FOLLOWING TO ME:

“Your complaint has been forwarded to the Land Registry by the
Office of the Deputy Prime Minister as the matter falls within its
remit.”

ON JULY 27TH I WROTE TO SHAYNE BROWN AT THE DEPARTMENT OF
COMMUNITIES AND LOCAL GOVERNMENT SENDING HIM MORE EVIDENCE.

ON AUGUST 4TH 2006, MRS WEAVER FROM THE LAND REGISTRIES COVENTRY
OFFICE WROTE THE FOLLOWING TO ME REGARDING MY “LETTER TO THE OFFICE
OF THE DEPUTY PRIME MINISTER” STATING:

“My understanding from your letter…is that there has been some
fraudulent alteration of one or more of the title plans and that
the Land Registry has conspired to make these alterations…some
background…may prove useful. The boundary that you are querying is
between your property, number 19, and what was formally number 21
Lime Grove. Number 21 was purchased by The Mayor Aldermen and
Burgesses of the Borough of Crosby on 2 September 1960…the
application for registration of the Council was lodged on 10 August
1964…it was included in title LA45086. It was included in that
title from that time until it was sold again…to Maritime Housing
Association on 24th December 1993. At that time it was removed from
title LA45086 and registered under title MS351603.”

THIS STATEMENT NEGATES THE TWO FILED PLANS OF TWO TITLES FILED AS
MS351603 THAT HAD BEEN TAKEN FROM TITLES LA45086 AND LA45343 IN
MARCH AND APRIL 1977.

ON AUGUST 17TH 2006 I FILED AT COURT THE FORGED MAPPING OF THE LAND
SOLD AT KEPLER STREET AND COPIED TO:

SEFTON MBC

MARITIME HOUSING ASSOCIATION

THE LAND REGISTRY BIRKENHEAD

THE OFFICE OF THE DEPUTY PRIME MINISTER

WILLIAM ELSBY, SOLICITOR FOR FAWLEY CONSTRUCTION

AND ASKED JUDGE FITZGERALD THE FOLLOWING QUESTION:

“The party boundary structure ‘the nib wall’ was, was according to
you demolished between March and September 1994, from the above,
how do you determine this.”

ON AUGUST 16TH 2006, MR WILLIAMS, SEFTON COUNCILS TECHNICAL
SERVICES DIRECTOR, WROTE THE FOLLOWING TO ME:

“I can confirm that the Council will not have provided any
information which contributed to the production of the Ordnance
Survey plan referred to, nor any other Ordnance Survey plan.”

ON AUGUST 17TH 2006, MR JOHN POWELL, FROM THE DEPARTMENT FOR
COMMUNITIES AND LOCAL GOVERNMNET WROTE THE FOLLOWING TO ME:

“Thank you for your letter of 21 July with enclosures copied to
this Department about structural defects regarding your property. I
am sorry to read about the problems you are currently experiencing
and appreciate this must be a difficult situation for you.
Unfortunately, this Department cannot get involved in individual
cases or questions of possible court decisions. I would suggest
that you continue to seek legal advice.”

ON AUGUST 17TH 2006, MS ELWOOD, SEFTON COUNCILS LEGAL DIRECTOR,
WROTE THE FOLLOWING TO ME:

“The Council is unable to confirm any detail in relation to the
party boundary structure “the nib” as requested…Mr George Barr, the
property manager referred to in Maritime Housing Association
Limited’s letter of March 4th 1999, is now deceased and therefore I
am unable to take this matter any further.”

ON AUGUST 21st 2006, MR JOHN POWELL, FROM THE DEPARTMENT FOR
COMMUNITIES AND LOCAL GOVERNMNET WROTE THE FOLLOWING TO ME:

“Thank you for your letter, received on 15 August, about
difficulties encountered with the boundary wall of your property.
This has been passed to this Department because of our
responsibility for housing…this Department has no power to
intervene in private property disputes of this nature…planning
functions, such as formulating development plan policies,
determining planning applications and enforcing planning control
are best carried out by the democratically elected district and, in
certain cases, county councils…if you are unhappy with the conduct
of the local authority, you may wish to complain via their own
complaints procedure. If you are not satisfied…you might wish to
take your case to the Local government Ombudsman can investigate
whether there has been maladministration.”

ON AUGUST 21ST 2006. MR IAN FLOWERS OF THE LAND REGISTRIES LONDON
OFFICE WROTE THE FOLLOWING TO ME:

“The Department of Constitutional Affairs (DCA) has referred your
copy letter of 17 July to this office. However, I regret that the
issues you have raised do not fall within the jurisdiction of the
Land Registry. I will send a copy of this letter to the DCA for
their reference.”

ON AUGUST 30th 2006, MR JOHN POWELL, FROM THE DEPARTMENT FOR
COMMUNITIES AND LOCAL GOVERNMENET WROTE THE FOLLOWING TO ME:

“Thank you for your further letter of 25 August with enclosures
about maps affecting your property…this Department cannot get
involved with private property disputes. I would suggest that you
seek legal advice in order to resolve this matter.”

ON AUGUST 31ST 2006, MS ELWOOD, SEFTON COUNCILS LEGAL DIRECTOR,
SENT ME A TERRIER MAP, REFERENCE LA076317 2005, PREPARED BY THE
COUNCILS ON SEPTEMBER 4TH 2006 AND WROTE THE FOLLOWING TO ME
REGARDING LAND, DONATED TO ME IN APRIL 1994 BY MARITIME HOUSING
ASSOCIATION, (BUT SUBSEQUENTLY FENCED OFF ALONG MY GABLE WALL AFTER
THE PLANNING APPLICATION STAGE OF THE DEVELOPMENT – ON THE WRITTEN
INSTRUCTION OF THE COUNCIL) WHICH IS NOT SHOWN ON THE TERRIER MAP:

“I thank you for your letter 31st August 2006 in which you sought
information regarding a 1 metre strip of land. I am enclosing a
plan from which you can clearly be seen the area in which you are
interested.”

ON SEPTEMBER 4TH 2006 MR WILLIAMS, SEFTONS TECHNICAL SERVICES
DIRECTOR WROTE THE FOLLOWING TO ME:

“I refer to your letter of 21st August 2006 and would advise that I
will not enter into any further correspondence in the matters
raised in this letter.”

ON SEPTEMBER 8TH 2006 I WROTE, AND FILED AND SERVED A FREEDOM OF
INFORMATION REQUEST TO MS ELWOOD FOR INFORMATION REGARDING THE
COUNCIL’S POWERS TO CHANGE THE BOUNDARIES OF MARITIMES LAND IN
1994, AND COPIED IT TO:

FAWLEY CONSTRUCTION
MARITIME HOIUSING ASSOCIATION
THE LAND REGISTRY BIRKENHEAD

ON SEPTEMBER 18TH 2006 I WROTE THE FOLLOWING IN A FOURTEEN PAGE
VERY DETAILED LETTER TO MR POWEL FROM THE DEPARTMENT FOR
COMMUNITIES AND LOCAL GOVERNMNET STATING, INTER ALIA, THE FOLLOWING
FACT REGARDING THE TITLES OF THE LAND:

False Land Records

“With regard to your letter dated September 12th 2006 and the
transcripts of telephone conversations with The Land Registry in
Birkenhead (The Registry) which I presume you have received by
recorded delivery.

As of today I do not know who owned the land registered at Kepler
Street and Maple Grove Seaforth (the land MS351603) between
December 24th 1993 and August 31st 1994, nor evidently do Sefton
MBC (Sefton) or Maritime Housing Association (Maritime). I present
the following conflicting fact which I have been given and compare
them with the actual facts of the matter. I give letter references
in square brackets, and where appropriate print in bold what I
consider to be pertinent points. While the purpose of this letter
is to highlight the matter of land ownership, it cannot be done
without reference to the demolition of the party boundary structure
or the supposed insurance claims made by myself. I will keep these
to a minimum. What follows is only a small percentage of the events
begun in 1977 or earlier.

The Information

Maritime are averred to have become the "owners" of 'the land
MS351603' on December 24th 1994 by Maritime, Sefton and The
Registry, Fawley Construction. On October 19th 2005 District Judge
Bellamy made the following statement regarding the 'land MS352603'.

"On 6th September 2000 Mr Robinson, by virtue of a Land Registry
search ascertained the Maritime Housing Association were the
registered proprietors of the above land from January 1994."

The ownership by Maritime is stated by The Registry to have been
triggered by the transfer document dated December 24th 1994 but,
the title number MS351603 is not recorded on that document,
instead, a title number is said to be awaiting designation. The
title numbers of LA45343 and LA45086 are used to identify 'the
land' that is sold to Maritime by Sefton…

The Titles

Title LA45086 was filed in March 1977 using OS SJ3396 dated 1969.

Title LA45343 was filed in April 1977 using section B of OS SJ3396
dated 1966. Section A of this map would show the land as it was
prior to the demolition of the area of land comprising; Peach
Grove, Birch Street, Alder Street, Vine Grove, Vine Street, Plum
Street, Date Street and Kepler Street circa 1966.

On January 21st 1994, by virtue of the transfer documents The
Registry aver that Maritime, the owners of the land from December
24th 1993, became the "registered proprietors" of the land 'greened
out', i.e. outlined in green and, stated by The Registry to have
been carried out on January 21st 1994 from the filed title plans of
titles LA45343 and LA45086.

Title LA45086

On February 3 2006 I obtained the Property Register from The
Registry. At 1 of this document it is recorded that 'the land'
inter alia is:

"The freehold land shown edged in red on the plan of the above
title...being...Lime Grove 1 to 27 (odd numbers) "

Numbers 1 to 27 Lime Grove are shown on OS SJ3396 dated 1966 and
comprise of the terrace 1 to 19 Lime Grove, a large detached house
numbered 21 Lime Grove and a further three house terrace numbered
23 to 27 Lime Grove.

The proprietary register records that on September 9th 1992.

"The land edged in green on the filed plan has been removed from
this title and registered under the title number or numbers shown
in green on the said plan."

This 'greening out by The Registry is recorded on Section B of OS
SJ3396 dated March 1975 and the new title number is recorded as
MS351603 [edged in red on the title plan] which pre dates the filed
plan of March 1977 and clearly uses a different version of OS
SJ3396 than the 1966 version. The registered proprietors are
recorded as Sefton MBC at The Town Hall, Orial Road Bootle on May
12th 1976.

Fact

By September 25th 1992 two separate parcels of land were registered
as owned by Sefton under the same 'unique' title number MS351603 -
from different versions of OS SJ3396 - at two separate Council
locations. These being those 'greened out' of OS SJ3396 dated 1966,
and OS SJ3396 dated 1967, and both filed and recorded under the
same title number on May 12th 1976.

Registration of MS351603

On February 4th 2003, The Registry sent me a filed plan of MS351603
dated August 31st 1994. This plan comprises of; the amalgamated
title plans of LA45343 dated May 12 1976 and; the amalgamated title
plans of LA45086 dated May 12 1976 as recorded above.

It appears that Maritime may not have filed the August 31st 1994
registration - another fact withheld from me by The Registry - and
did in fact have the completed site registered to them in 'mid
1995'. The Registry refuse to disclose any detail about this
registration.

I look forward to a constructive response from you, or better,
someone with more authority, i.e. The Deputy Prime Minister.

ON SEPTEMBER 25TH 2006 THE ASSISTANT LOCAL GOVERNMENT OMBUDSMAN
ROSEMARY AGNEW WROTE THE FOLLOWING TO ME UNDER REFERENCE
06/C/07976/RA/DH:

“The Local Government Ombudsman has asked me to consider your
complaint against Sefton Council and write to you…after checking
with the Council it appears that your complaint has not yet been
dealt with through the Council’s complaint procedure. So: I will
send a copy of your complaint to the Council and ask the Chief
Executive to put it through the Council’s own complaint procedure,
to keep you informed of the progress, and to let you know the
outcome.”

ON OCTOBER 3RD 2006, LYNN ROWLAND FROM THE REGISTRY IN BIRKENHEAD
WROTE THE FOLLOWING TO ME IN A LETTER HEADED “21 LIME GROVE,
SEAFORTH:

“In order for us to deal with your query, could you please provide
us with the reference on the letter sent to you by the Coventry
Land Registry. This will enable us to call up any previous
correspondence.”

ON OCTOBER 12TH 2006 MR GIBSON, SEFTON’S PRINCIPLE LEGAL ASSISTANT
WROTE THE FOLLOWING TO ME IN A LETTER HEADED “REFUSAL NOTICE
(VEXATIOUS REPEATED REQUESTS).”: [CAPITALISATION ADDED)

“Further to your numerous letters regarding YOUR NIB WALL and the
title to your property AND ADJOINING PROPERTY. I write to inform
you that your request for information will not be processed. I have
decided that your request is vexatious and repeated requests have
been responded to over the years…the reason I have concluded your
request is vexatious and that repeated requests have been received
and responded to is that the council has spent hundreds of man
hours dealing with your requests REGARDING YOUR PROPERTY 17 LIME
GROVE, and the INSURANCE CLAIM WHICH YOU ALLEGE WAS NOT MADE.”

ON OCTOBER 17TH 2006, SALLY WALKER, PERSONAL ASSISTANT, FROM THE
LOCAL GOVERNMENT OMBUDSMANS OFFICE WROTE THE FOLLOWING TO ME UNDER
REFERENCE O6/100048/SPC/sw:

“Please note you complaint has been allocated the above new
reference number…we have at the moment more complaints than we can
give our investigators but will allocate your complaint as soon as
we can…we will contact you again when your complaint has been
allocated…please note we may copy to the council any papers you
have sent us about your complaint. This is to inform the Council
that your complaint has been brought to our attention

ON OCTOBER 18TH 2006, CATHY HOWKINS, CASEWORKER AND ADVICE OFFICER
FROM THE INFORMATION COMMISSION WROTE THE FOLOWING TO ME, REGARDING
MY LETTER TO SEFTON COUNCIL DATED JULY 5TH 2006, USING THE RFERENCE
END0124895 STATING: (CAPITALISATION ADDED):

“Your letter refers to a request for assessment (REFERENCE:
03-36599/06/AD) THAT YOU SUBMITTED TO THIS OFFICE A NUMBER OF YEARS
AGO WHICH FOCUSED ON THE PROCESSING OF PERSONAL DATA BY SEFTON MBC.
WE WERE UNABLE TO TAKE ACTION IN RESPECT OF YOUR REQUEST FOR
ASSESSMENT AS WE CONCLUDED THAT THE INFORMATION IN QUESTION DID NOT
FALL UNDER THE SCOPE OF THE DATA PROTECTION ACT 1998. WE REACHED
THIS DECISION BECAUSE WE WERE OF THE OPINION THAT THE INFORMATION
THAT THE COUNCIL DID NOT PROVIDE TO YOU DID NOT FORM PART OF A
RELEVANT FILING SYSTEM. YOU HAVE ASKED US TO PROVIDED FURTHER
INFORMATION ABOUT THE INFORMATION THAT IS NOT HELD UNDER A RELEVANT
FILING SYSTEM. I can only repeat the Information that MR DAMMS, the
caseworker who completed the assessment, provided to you. During
the course of our investigations, SEFTON MBC CONFIRMED THAT THE
‘MISSING DOCUMENTATION (THE INFORMATION THAT WAS NOT PROVIDED TO
YOU IN RESPONSE TO YOUR DATA SUBJECT ACCCESS REQUEST) WAS NOT HELD
IN A RELEVANT FILING SYSTEM…we can only confirm that it is OUR
UNDERSTANDING THAT THE ‘MISSING’ DOCUMENTS WERE NOT HELD IN A
RELEVANT FILING SYSTEM.”

ON OCTOBER 23RD 2006 MERSEYSIDE POLICE WROTE THE FOLLOWING TO ME
HEADED “COMPLAINT AGAINST THE POLICE.:

“It is my role on behalf of the Chief Superintendent…to conduct
investigations into such matters…I would be grateful if you would
contact me…in order to arrange a suitable appointment to discuss
the matter in detail,”

ON OCTOBER 24TH 2006 I FILED AND SERVED A LETTER I HAD WRITTEN TO
MERSEYSIDE POLICE ASKING FOR CLARIFICATION OF WHICH “COMPLAINT
AGAINST THE POLICE” THEY REFERRED TO.

ON OCTOBER 25TH 2006, PATRICK BROUGH, THE LAND REGISTRAR AT
BIRKENHEAD WROTE THE FOLLOWING TO ME IN A LETTER HEADED “21 LIME
GROVE.” (CAPITALISATION ADDED):

“We have on file a full copy of the comprehensive letter written to
you on 4 August by Mrs D M Weaver, the Land Registry at our
Coventry office. As Mrs Weaver made clear in the final paragraph of
that letter, it contained Land Registries definitive response on
the issues you had raised in respect of titles LA45086, LA45343 and
MS351603. I do not therefore propose to enter into any further
correspondence regarding the matter. It would NOT in any event be
appropriate for the Land Registry to comment on QUESTIONS THAT YOU
HAVE ASKED IN CORRESPONDENCE WITH SEFTON BOROUGH COUNCIL AND WHICH,
THEY HAVE, FOR REASONS STATED IN THEIR RECENT LETTER TO YOU,
REFUSED TO ANSWER.”

ON NOVEMBER 2ND 2006, CATHY HOWKINS FROM THE INFORMATION COMMISSION
WROTE THE FOLLOWING TO ME UNDER EFERENCE ENO124895.”:

“I refer to your letter of 30 October…the Information Commission’s
Office conducted an assessment in respect of Sefton Council
following a complaint that you submitted to us in 2003. However, in
the course of our investigations we were not supplied with any of
your personal data. We based our of our assessment on the
correspondence that both you and Sefton provided to us in the
course of our investigation. However, Sefton Council never provided
us with any of the documents that you had requested from them…you
have enclosed a print out of your council tax account with your
letter. You have asked us to confirm whether this document will not
be personal data…because it is not part of a relevant filing
system…it appears that the council holds your council tax records
on computer. For the purpose of the DPA this information is likely
to be your personal data and as such you have a right of access to
this data…if the Council held a paper copy of this information at
the time of your request, and this document was not held in a
relevant filing system, you would not have been entitled to a copy
of this information under the DPA.”

ON NOVEMBER 10TH 2006 I RECEIVED THE FOLLOWING FROM MERSEYSIDE
POLICE under the reference TK/ih/6VDDW ACKNOWLEDGEING MY LETTER
DATED NOVEMBER 9TH 2006:

“I have forwarded your letter to Chief Superintendent XXXX, Area
Commander for Sefton…Constable xxxx will reply to you directly.”

ON NOVEMBER 9TH 2006, CATHY HOWKINS FROM THE INFORMATION COMMISSION
WROTE THE FOLLOWING TO ME UNDER REFERENCE ENO124895.” IN ANSWER TO
MY LETTTER OF NOVEMBER 6TH 2006 COPIED TO (CAPITALIATION ADDED):

LIVERPOOL COUNTY COURT

SEFTON COUNCILS LEGAL DEPARTMENT

CHIEF CONSTABLE MERSEYSIDE POLICE

BOOTLE MAGISTRATES COURT

“ The advice that we provided to Sefton Metropolitan Borough
Council following the assessment we conducted IN 2004 regarding the
COMPLAINT that you submitted to our office about Sefton Council.
The outcome of OUR ASSESSMENT was explained to you when we
concluded our investigation…I can confirm that the Freedom of
Information Act does not provided an individual with the right to
have INACCURATE DATA amended…I can confirm that we have now closed
this case and that the large volume of correspondence that you have
enclosed with your last letter will be HELD ON FILE for information
only…we will be in touch with you shortly regarding the subject
access request that you made to this office on 21 October 2006.”

ON NOVEMBER 16th 2006, FAYE SPENCER, SENIOR CASEWORK AND ADVICE
MANAGER FROM THE INFORMATION COMMISSION WROTE THE FOLLOWING TO ME
UNDER EFERENCE FOII/486SAR/310.” (CAPITALISATION ADDED):

“You first of all asked us for copies of all the correspondence
and, if any, faxes emails and telephone conversations regarding
[your] REQUESTS to the Commission…given that your letter of 21
October 2006 was only concerned with…case reference 03/36599/06…we
have supplied you with the communications WE EXCHANGED WITH SEFTON
COUNCIL in relation to 03/36599/06.”

03/36599/06 WAS A “REQUEST” REGARDING THE INFORMATION WITHHELD BY
SEFTON COUNCIL DATED BETWEEN JANUARY 1ST AND DECEMBER 31ST 1994
WHICH, HAD NO CONNECTION WITH ANY OTHER DATA OF FORGED MAPPING.

ON NOVEMBER 24TH 2006 I RECEIVED TWO ACKNOWLEDGEMENTS FROM THE
LOCAL GOVERNMENT OMBUDSMAN DATED NOVEMBER 22ND 2006, THE FIRST
REFERENCED 06/C/10048.SPC3: THE SECOND REFERENCED 06/C/10048/RA.

ON NOVEMBER 22ND 2006, CATHY HOWKINS FROM THE INFORMATION
COMMISSION WROTE THE FOLLOWING TO ME UNDER EFERENCE ENO124895.”:

“It would appear that you are in dispute with the council over
whether you owe, or have ever owed, council tax payments…it is not
the role of the Information Commissioners Office to assess whether
or not an individual is liable for council tax payments and we have
neither the resources or expertise to do so…the amount of money
that you owe in council taxes has been considered by the
Magistrates Court and you have been issued with two liability
orders. The Information Commissioner’s Office would be unable to
overturn a decision that has been made by the courts…you have
indicated that you have made a subject access request to access
your computer records, but that you have ‘been unable to obtain
them’…you could consider a complaint if you felt the council had
not responded to your request in accordance with the Data
Protection Act 1998. However, you would need to provide us with a
copy of your request letter …and any other correspondence from the
council relating to your request…it would appear that the Local
Government Ombudsman is better placed to consider your complaint
about whether the council has correctly assessed your council tax
liability.”

ON NOVEMBER 24TH 2006 I SENT MS HOWKINS THE INFORMATION SHE HAD
REQUESTED AND COPIED IT TO:

LIVERPOOL COUNTY COURT FOA JUDGE FITZGERALD AND HH JUDGE STEWART

BOOTLE MAGISTRATES COURT

THE CHIEF CONSTABLE MERSEYSIDE POLICE

MR SPARROW AS THE ipcc

MS SEEKS LOCAL GOVERNMENT OMBUDSMAN

ON NOVEMBER 29TH 2006, CATHY HOWKINS FROM THE INFORMATION
COMMISSION WROTE THE FOLLOWING TO ME UNDER REFERENCE ENO124895.”:

“It would appear that you have pursued the matter through the
courts…before we can take any action in respect of your complaint
to this office we need you to provide us with details of the courts
response to your claim against the council…we would be grateful if
you could provide details of the outcome of your court case,
including copies of any correspondence that you have received from
the court in respect of this matter. Once we have received this
additional information from you we will consider how best to
progress your complaint.”

ON DECEMBER 4TH 2006 I WROTE AGAIN TO THE DEPUTY PRIME MINISTER
ENCLOSING 22 ITEMS OF EVIDENCE REGARDING THE FALSE LAND RECORDS AND
FORGED MAPPING AND COPIER TO:

LORD FALCONER

THE LOCAL GOVERNMENT OMBUDSMAN

And with part of the evidence to:

LIVERPOOL COUNTY COURT FAO HIS HONOUR JUDGE MACKAY

CHIEF CONSTABLE MERSEYSIDE POLICE

ipcc

THE LAW SOCIETY

LEGAL DIRECTOR SEFTON COUNCIL

MARITIME HOUSING ASSOCIATION

CEO HALIFAX BUILDING SOCIETY

THE HOUSING CORPORATION

ON DECEMBER 5TH 2006, TED POWELL, RESEARCH ASSISTANT TO THE DEPUTY
PRIME MINISTER WROTE THE FOLLOWING TO ME:

“Thank you for your letter to John Prescott MP to which I am
replying on his behalf…the matters you have raised are the
responsibility of the Department of Communities and Local
Government. I have therefore passed your correspondence to that
Department so that your concerns may be addressed in more detail.”

ON DECEMBER 8TH 2006 THE LOCAL GOVERNMENT OMBUDSMAN ACKNOWLEDGED MY
CORRESPONCE UNDER 06/C/10048/SPC3.

ON DECEMBER 14TH 2006 I WROTE THE FOLLOWING TO LORD FALCONER,
ENCLOSING SEVENTY FOUR PAGES OF EVIDENCE, AND COPIED TO:

THE LAW SOCIETY

SEFTON COUNCILS LEGAL DIRECTOR

MARITIME HOUSING ASSOCIATION

“The court and the Government appear not to be able to deal with
the deceit which over the years have escalated to the present
state, absorbing tens of thousands of pounds of public money, and
occurred seemingly centered on the unlawful sale of land by Sefton
Council to Maritime housing Association in 1993/4. It is quite
clear that some parties in this matter should be sent to prison
rather than the threat of prison, loss of my home and massive
unfounded costs and fallacious liability orders for Council Tax,
obtained by perjury, being used against myself in full view of the
authorities…the matter now needs to go to the Court of Human Rights
as a matter of great urgency and not be passed around like a bad
smell. Please note it is the duty of senior members of the
Government to keep the courts independent and not let them become
subverted from within, or from without.”

ON 13TH DECEMBER MERSEYSIDE POLICE WROTE THE FOLLOWING TO ME
REFERENCED Misc AND HEADED “COMPLAINT ABOUT THE POLICE”:

“I refer to the above matter in relation to your on-going issues
and various correspondences…I have reviewed the matter once again
and would refer you to the letter sent to you by D/I xxxv.”

THE ENCLOSED LETTER DATED DECEMBER 1ST 2005 HEADED “LETTERS OF
COMPLAINT” STATED:

“I have indicated on several occasions there are no criminal
offences committed by any party against you or your property in
relation to your claim for damages. This is a civil matter between
yourself and other parties. The allegation of perjury against
members of staff of Sefton Council was investigated and there were
no offences committed. As indicated by Superintendent xxxx in his
letter to you we are not prepared to communicate with you any
further. You should refer all of your future correspondence to
those parties you hold responsible for damage.”

ON DECEMBER 19TH 2006, NATALIE JADE HOLE, CUSTOMER LIASON UNIT, FOR
THE DEPARTMENT OF COMMUNITIES AND LOCAL GOVERNMENT WROTE THE
FOLLOWING TO ME:

“Thank you for your letter of 7 December addressed to the Rt Hon
Ruth Kelly MP regarding false land records. The Department of Local
Government does not have responsibility for the issue you have
raised. Your letter has therefore been sent to the Department for
Constitutional affairs.”

ON December 21st 2006, CATHY HOWKINS FROM THE INFORMATION
COMMISSION WROTE THE FOLLOWING TO ME UNDER EFERENCE ENO124895.”:

“Thank you for your letter of 5 December 2006 in response to my
request of 29 November 2006…you are seeking access to your council
tax records …we will only consider whether or not the council
responded to your subject access request of 15 November 2005 in
accordance with the provisions of the Data Protection Act 1998…I
have therefore written to the council to ask it to confirm whether
it has provided you with the information that you requested. If the
council has not provided you with this data, I have asked it to
confirm whether it will now do so, if the council does not intend
to provide you with the information that you have requested, I have
asked it to clarify the exemption within the Act upon which it is
relying to withhold this data.”

ON JANUARY 10TH 2007, MR DANNY O’ SULLIVAN, OF HMSC’S CUSTOMER
SERVICES UNIT, WROTE THE FOLLOWING TO ME UNDER REFERENCE CSU/20492:

“Thank you for your letter of 14 December 2006 addressed to the
Department for Constitutional Affairs. We will send you a reply by
30 January 2007…if we decide your letter is best answered by
another office, we will write and tell you where your letter has
been transferred.”

ON JANUARY 11TH 2007 I WROTE TO THE HOME SECRETARY, JOHN REID
REGARDING THE REFUSAL OF MERSEYSIDE POLICE TO ACCEPT EVIDENCE OF
FORGED TITLE MAPS BY THE LAND REGISTRY.

ON JANUARY 11TH 2007, BELINDA DAWKINS, OF THE LAND REGISTRIES
CUSTOMER SERVICE TEAM IN LONDON WROTE THE FOLLOWING TO ME UNDER
REFERENCE CSG 38 – 07 IN RESPONSE TO “COPY LETTERS AND DOCUMENTS”
SENT TO THE LAND REGISTRY:

“An inspection of our system indicates that 19 Lime Grove is not
registered therefore we would not have any documents relating to
the property on our files.”

ME ON JANUARY 15TH 2007 WITH REGARD TO FURTHER COPY CORRESPONDENCE
AND A ‘FEEDBACK FORM’ MERSEYSIDE POLICE WROTE THE FOLLOWING TO
UNDER REFERENCE YV000098:

“Your letter will be forwarded to the Area Commander at Sefton for
his attention. You should receive a response within 21 days.”

ON JANUARY 17TH 2007, JEREMY DONALDSON, HEAD OF THE LAND REGISTRY
AGENCY CASE REVIEW TEAM WROTE THE FOLLOWING TO ME, ON BEHALF OF
PETER COLLIS, CHIEF REGISTRAR, IN RESPONSE TO MY LETTER OF JANUARY
12TH TO MS DOWKIN IN A LETTER HEADED “TITLE NUMBER MS361603 LAND AT
KEPLER STREET AND MAPLE CLOSE, SEAFORTH” UNDER REFERENCE
ACRT/700/06/118/JRD”

“I refer you to the letter dated 4 August 2006 from Mrs Weaver…I
have nothing to add to what Mrs Weaver said.”

ON JANUARY 26TH 2007 KERRRY LOCK, OF THE HOME OFFICE DIRECT
COMMUNICATIONS UNIT WROTE THE FOLLOWING TO ME ON BEHALF OF JOHN
REID UNDER REFERENCE T1944/7:

“Thank you for your letter…regarding your wish to formally report a
crime to the police…the Chief Constable of Merseyside Police is
responsible for the day to day operational management of the force
and not the Home Secretary…Ministers do not have the authority to
intervene in operational matters. If you wish to make a
complaint…contact their Professional Standards
department…alternatively you can make your complaint through the
Merseyside Police Authority…or the …ipcc.”

ON JANUARY 29TH 2007, DINESH BHATT,FROM THE CUSTOMER SERVICES UNIT
OF HMCS WROTE THE FOLLOWING TO ME IN A LETTER REFERENCED CSU/20492:

“We are the third tier in Her Majesty’s Court Service…we
investigate complaints concerning the administration of HMCS. We
cannot investigate complaints concerning judicial fraud…I note that
you have already reported the matter of fraud to Merseyside
Police.”

ON FEBRUARY 1ST 2007, LEIGH TAPPIN, OF THE MINISTERIAL
CORRESPONDENCE UNIT OF THE DEPARTMENT FOR CONSTITUTIONAL AFFAIRS
WROTE THE FOLLOWING TO ME IN A LETTER HEADED “TRANSFER LETTER”
UNDER REFERENCE 83360:

“The issue raised is outside of the remit of this department.
Consequently, I have forwarded your letter to the HM Land Registry,
so that they can consider its contents.”

ON FEBRUARY1ST 2006, ANGELA ELLISON FROM THE INFORMATION COMMISSION
WROTE THE FOLLOWING TO ME UNDER REFERENCE ENDO124895.:

“We have now received a response from the council’s Data Protection
Officer. He states that the Revenue Manager has indicated that your
request was answered at the time…the Revenue Manager has also
stated that the council hold hard copies of the documents if
required and, in view of this…I shall ask for them to be copied to
you again.”

ON FEBRUARY 2ND 2007 I WROTE TO THE CHIEF CONSABLE OF MERSEYSIDE
POLICE REGARDING THE FORGED MAPPING USED IN THE SALE OF THE LAND AT
KEPLER STREET / MAPLE CLOSE, SEAFORTH AND COPIED TO:

JOHN REID, HOME SECRETARY

LORD FALCONER

MERSEYSIDE POLICE PROFESSIONAL STANDARDS

ipcc

LEGAL DEPARTMENT SEFTON COUNCIL

MARITIME HOUSING ASSOCIATION

THE LAW SOCIETY

ON FEBRUARY 6TH 2007 MERSEYSIDE POLICE WROTE TO ME IN A LETTER
REFERENCED SI/lh6VDDW THANKING ME FOR MY “COMPLAINT” OF FEBRUARY
2ND 2007 AND STATING:

“I have forwarded your letter to Chief Superintendent xxxx, Area
Commander for the Sefton area, as he is the officer who has been
dealing with your investigation.”

ON FEBRUARY 16TH 2006, ANGELA ELLISON FROM THE INFORMATION
COMMISSION WROTE THE FOLLOWING TO ME UNDER REFERENCE ENDO124895.”:

“There is no evidence that the Council have concealed records.”

ON FEBRUARY 16TH 2007, MRS S HACKNEY, SECRETARY, WROTE TO ME FROM
THE LOCAL GOVERNMENT OMBUDSMANS OFFICE UNDER THE REFERENCE
006/C/10048/CSO/SH STATING:

“Your complaint has now been allocated to Mr Oxley.”

ON FEBRUARY 16TH 2007, MR OXLEY A LOCAL GOVERNMENT OMBUDSMANS
INVESTIGATOR WROTE THE FOLLOWING TO ME UNDER THE REFERENCE
06/C/10048/CSO STATING. (CAPITALISATION ADDED):

“I RECALL that you submitted a complaint about the issue of YOUR
NIB WALL to the Ombudsman IN 1995…I have considered what you have
submitted with your current complaint and it is my view that this
concerns basically THE SAME ISSUE…I understand that the Police…are
no longer prepared to communicate further with you on this matter…I
can see no benefit in investigating your complaint [because] this
is a PRIVATE MATTER and not one of public administration.”

ON FEBRUARY 27TH 2007, SUSAN HOLLERAN WROTE THE FOLLOWING TO ME
FROM THE ROYAL COURT OF JUSTICE UNDER REFERENCE 0375/02/07
REGARDING A LETTER I HAD WRITTEN TO THE LORD CHIEF JUSTICE:

“The contents of your letter concerning Maritime Housing
Association have been noted…if you wish to take the matter further
you may like to consider seeking legal advice. I am afraid that
this office nor the Lord Chief Justice is in a position to offer
such advice.”

ON FEBRUARY 28TH 2007, ANGELA ELLISON FROM THE INFORMATION
COMMISSION WROTE THE FOLLOWING TO ME in answer to a letter to her
dated February 28th 2007 UNDER REFERENCE ENDO124895.”:

“There is nothing further that I can add to my previous comments.”

ON MARCH 12TH 2007, MR OXLEY A LOCAL GOVERNMENT OMBUDSMANS
INVESTIGATOR WROTE THE FOLLOWING TO ME UNDER THE REFERENCE
06/C/10048/CSO REGARDING MY ALLEGED COMPLAINT DATED 1995, AND THE
LIABILITY ORDERS OBTAINED BY SEFTON FOR NONE EXISTENT COUNCIL TAX
LIABILITIES, STATING. (CAPITALISATION ADDED):

“You have asked in your latest letter for RECORD OF YOUR COMPLAINT
which you say was not made at that time because the OWNERSHIP of
the nib wall was not at that time established…there are NO RECORDS
of the decision on your compliant…are RECORDS of the complaint
numbers your complaints…these are 95/C/04896…I DO RECALL the
complaint about the OWNERSHIP of the nib wall…I informed you that
YOU had made complaint on this subject AT THAT TIME…writing to you.
There was no decision on the OWNERSHIP of THE WALL as that was NOT
RELEVANT, what WAS relevant was that this was A PRIVATE MATTER
between you and the Council OR the housing association…I note that
you complained that the council officers COMMITTED PERJURY…and that
you complained about this CRIMINAL OFFENCE to Merseyside Police.
You also challenged the competency of the Magistrates Court and
APPEALED TO THE CROWN COURT which was unable to help you…I am
sending a copy of this letter and the letter of February 19th to
the Council’s Chief Executive.”

THERE WAS NO APPEAL TO THE CROWN COURT.

ON MARCH 13TH 2007, BELINDA DAWKINS, OF THE LAND REGISTRIES
CUSTOMER SERVICE TEAM IN LONDON WROTE THE FOLLOWING TO ME REGARDING
TITLE MS 351603 UNDER REFERENCE CSG 38 – 07 ON BEHALF OF PETER
COLLIS, HEAD REGISTRAR, IN RESPONSE TO A LETTER SENT TO THE LAND
REGISTRY ON MARCH 8TH 2007. (CAPITALISATION ADDED):

“ON THE FIRST POINT I can confirn that the Land Registry was
supplied with the August 1994 version of Ordnance Survey map OS
SJ3396NW which CORRESPONDED with title MS351603 – 21 Lime Grove…on
the second point…if you want a response…please contact the
appropriate land registry office which deals with your area.”

ON MARCH 12TH 2007, MS ANNE SEEEKS THE LOCAL GOVERNMENT OMBUDSMANS
WROTE THE FOLLOWING TO ME UNDER THE REFERENCE 06/C/10048/CSO
REGARDING A LETTER DATED MARCH 16TH 2007:

“I have asked Mr Corney, an Assistant Ombudsman to review the file
on your complaint on my behalf. Mr Corney does not manage Mr Oxley
and has not previously been involved with your complaint. He will
complete the review and write to you as quickly as possible. His
decision will be final.”

ON MARCH 22ND I WROTE A COMPLAINT TO MS SEEKS REGARDING MR OXLEY
HEADED “MALICIOUS MIS-STATEMENT – BREACH OF DUTY”, POINTING OUT TO
HER THERE WAS NO COMPLAINT BY ME TO THE OMBUDSMAN IN 1995
REFERENCED 95/C/03824.”

ON MARCH 22ND 2007, MR CORNEY, ASSISTANT OMBUDSMAN WROTE THE
FOLLOWING TO ME UNDER REFERENCE 06/C/10048/RJC/jm. (CAPITALISATION
ADDED):

“ I have read the PAPERS and see nothing to suggest that the
decision was wrong, the only point I would accept is that complaint
95/c/03824 WAS NOT MADE IN 1995, as it was IN FACT received in this
office on 10 January 1996…Mr Oxley is also quite correct…about the
LIABILITY ORDER for NONE payment of Council Tax…there is no way in
which the Ombudsman can overturn the decision of a Magistrates
Court, which has been REINFORCED IN TURN BY THE CROWN COURT. ”

ON MARCH 26TH 2007, LEIGH TAPPIN, OF THE MINISTERIAL CORRESPONDENCE
UNIT OF THE DEPARTMENT FOR CONSTITUTIONAL AFFAIRS WROTE THE
FOLLOWING TO ME IN A LETTER HEADED “TRANSFER LETTER” UNDER
REFERENCE 154306:

“Thank you for your letter dated 16/3/07 addressed to Lord
Falconer…the issue raised is outside the remit of this department.
Consequently, I have forwarded your letter to the DCLG.”

ON MARCH 27TH 2007, MR PATRICK BROUGH THE REGISTRAR AT BIRKENHEAD
WROTE THE FOLLOWING TO ME, WITH REGARD TO A LETTER AND DOCUMENTS
DATED MARCH 20TH 2007, UNDER THE REFERENCE CL145/03.
(CAPITALISATION ADDED):

“I have nothing to add to the COMPREHENSIVE INFORMATION which Mrs
Weaver gave you except to say…title MS351603 was FIRST registered
on 21 January 1994 and not on 25 September as YOU SUGGEST.”

ON MAY 4TH 2007, KELLY TOMLIN, OF HMSC’S CUSTOMER SERVICES UNIT,
WROTE THE FOLLOWING TO ME UNDER REFERENCE CSU/20492:

““Thank you for your letter of 14 April 2007 addressed to Lord
Falconer…if we decide your letter is best answered by another
office, we will write and tell you where your letter has been
transferred.”

On May 8TH 2007, ANNE SEEKS, THE LOCAL GOVERNMENT OMBUDSMAN WROTE
THE FOLLOWING TO ME, REGARDING A LETTER DATED APRIL 23RD 2007,
UNDER REFERENCE 06/10048/AS/CRB and changing the date for the 1995,
1996 complaint C/04896 to 1999:

“Both Mr Oxley and Mr Corney have explained why your complaint will
not be investigated. Their decisions are correct…I have to tell you
that the file relating to complaint 99/C/04896 was destroyed some
time ago and I cannot therefore comply with your request.”

ON MAY 14TH 2007, SUSAN HOLLERAN FROM THE JUDICIAL OFFICE OF THE
ROYAL COURT OF JUSTICE WROTE THE FOLLOWING TO ME REGARDING EVIDENCE
I HAD SENT TO THE LORD CHIEF JUSTICE OVER THE “LAST MONTHS”
REFERENCED 0160/05/07. CAPITALISATION ADDED):

“The contents of those letters concerning damage to YOUR WALL have
been noted……if you wish to take the matter further you may like to
consider seeking legal advice. I am afraid that this office nor the
Lord Chief Justice is in a position to offer such advice.”

ON MAY 18TH 2007 PAULA MULLIN OF HMCS WROTE THE FOLLOWING TO ME IN
A LETTER HEADED ”CLAIM NUMBERS 5LV53314 & 6L50690 UNDER REFERENCE
CSU21318 AND, REGARDING “LETTERS OF 14 APRIL, ADDRESSED TO LORD
FALCONER. LORD GOLDSMITH & LORD PHILLIPS WHICH HAD BEEN PASSED TO
HMCS BECAUSE:

“This office is responsible for dealing with all correspondence in
relation to the administration within the courts in England and
Wales.”

ON MAY 31ST 2007, KAREN ROUSE, OF THE HOME OFFICE DIRECT
COMMUNICATIONS UNIT WROTE THE FOLLOWING TO ME REGARDING MY LETTER
OF MAY 31ST 2007:

“The matters raised in your letter are now the responsibility of
the Ministry of Justice. Your letter has therefore been transferred
to the new Ministry of Justice.”

ON MAY 31ST 2007, SARAH MASTERSON, OF THE HOME OFFICE DIRECT
COMMUNICATIONS UNIT WROTE THE FOLLOWING TO ME UNDER REFERENCE
T16299/7 REGARDING “YOUR POLICE COMPLAINT.”:

“I can see from your letter that you have raised a complaint with
the Chief Constable and the…IPCC and are not satisfied with the
response you have received…the IPCC is an independent body and
therefore, if you are not satisfied with their investigation, you
will need to seek independent legal advice.”

ON JUNE 12TH 2007 I WROTE A ‘ROUND ROBIN’ LETTER REGARDING THE
FALLACIOIUS INSURANCE CLAIMS W215732 AKA RR98XN AKA AT01939, TO:

LORD FALCONER

LORD PHILLIPS

THE HOME SECRETARY

THE LOCAL GOVERNMENT OMBUDSMAN

THE INFORMATION COMMISSION

THE LAW SOCIETY

ON JUNE 26TH 2007, HIESH DARJEE, FROM THE DEPARTMENT OF COMMUNITIES
AND LOCAL GOVERNMENT WROTE THE FOLLOWING TO ME IN A LETTER
REFERENCED 070626/J24 – 54/018673/07”

“Thank you for your letter concerning council tax. As the issues
you have raised is the responsibility of this Department…I have
been asked to reply…I am afraid that the administration and
collection of council tax is the responsibility of the local
authority and it would not be appropriate for ministers or
officials from this Department to intervene in individual cases
between a local authority and its taxpayers.”

On June 27th 2007, BERNARD McNALLY FROM THE CUSTOMER SERVICES TEAM
OF THE INFORMATION COMMISSION WROTE THE FOLLLOWING TO ME UNDER
REFERENCE INFO166270:

“Thank you for your “round robin letter” regarding Sefton Borough
council. The information you have provided will be kept on our
files for information only.”

ON JUNE 28TH 2007, H JARMAN FROM THE CASE RECEPTION UNIT OF THE
INFORMATION COMMISSION WROTE THE FOLLLOWING TO ME UNDER REFERENCE
INFO166461:

“Thank you for your correspondence received at this office on 14th
June 2007 regarding your information request to Sefton MBC. The
information you have provided will be kept on our files for
information only.”

ON JULY 9TH 2009 LANDSEARCH LIMITED EMAILED ME CONFIRMING THEIR
CONTRACT WITH ME TO SUPPLY ME WITH TITLES LA 45086, LA 45343 AND
TITLE MS351603.

JUST OVER A YEAR SINCE MY LETTER TO JOHN PRESCOTT REGARDING THE
FORGED MAPPING, MARY ROSE MULLINER,LAWYER FROM THE LAND REGISTRY,
TELFORD, WROTE THE FOLLOWING TO ME IN A LETTER HEADED “TITLE NUMBER
LA45086.”:

“The point made by you in your letter of 13 June 2007 as to the
erasure of the Crown copyright date. The 1977 title plan for
LA43086 is based on more than one edition of the Ordnance Survey.
The first sheet within which former LA45086 is to be found, is
based on a 1966 edition, and the second and third sheets, within
which second sheet your property is found, is based on a 1970
edition. Where more than one edition is being used it would be
inappropriate to refer a crown copyright date.”

Yours sincerely,

fred robinson

Dear Hilary Pook,

SEFTON COUNCIL SAY I AM VEXATIOUS FOR REQUESTING THEY CONFIRM OR
DENY THEY OWNED TWO PARCELS OF LAND WITH THE SAME "UNIQUE" TITLE
NUMBER MA351603.

WHAT IS VEXATIOUS ABOUT CONFIRMING THAT THE COUNCIL HAD OWNERSHIP
OF TWO PARCELS OF LAND UNDER THE SAME TITLE NUMBERS ?

THE ANSWER IS BECAUSE THAT IT IS THE COUNCIL THAT HAS AN OBSESSION
WITH CONCEALING WHAT IT HAS ON RECORD AND IS THEREFORE VEXATIOUS
BY, ITS AND THE INFORMATION COMMISSIONS DEFINITIONS.

THE COPIES OF THE REGISTRATION OF THIS LAND I HAVE ARE AVAILABLE TO
THE COUNCIL FROM THE LAND REGISTRY AT LESS THAN THE STATUTORY LIMIT
FOR THE COUNCIL TO CONFIRM MY REQUEST. THIS CAN BE DONE ON LINE IN
A FEW MINUTES.

MY LONG HISTORY OF SIMILAR REQUESTS IS DUE TO THE FACT THAT THE
COUNCIL HAS BEEN CONCEALING ITS INVOLVEMENT WITH THE REGISTRATION
OF THIS LAND SINCE I FIRST QUESTIONED ITS OWNERSHIP WITH THE
COUNCILS CEO, GRAHAM HEYWOOD, IN THE YEAR 2000.

MR HEYWOOD, WHO IS A BARRISTER AND KNOWS BETTER, AT THAT
TIME,CONCEALED ITS OWNERSHIP AND COLLUDED WITH OTHER COUNCIL
OFFICERS OVER THE NEXT TWO YEARS TO PREVENT THE OWNERSHIP BEING
CONFIRMED DUE TO THE COUNCIL HAVING TO KEEP UP THE DECEPTION THAT
THE COUNCIL WERE INDEMNIFIED FOR IT.

IN FACT THE COUNCIL HAD BEEN AWARE THAT IT HAD TRANSFERRED THE LAND
TO MARITIME HOUSING ASSOCIATION AT THE TIME OF MY INITIAL REPORT OF
DAMAGE TO MY PROPERTY IN 1994, SOME FOUR MONTHS AFTER ITS TRANSFER
AND, WHILE THE MAISONETTES ON THE LAND WERE STILL BEING DEMOLISHED
BY THE COUNCILS CONTRACTOR.

MR HEYWOOD THEN BECAME INVOLVED WITH THE DECEPTION OF THE DATE OF
CONTRACT COMPLETION OF THE DEMOLITION CONTRACT.

IN FEBRUARY 1995 THE COUNCIL KNEW WHEN IT SENT MR FAWLEY TO VISIT
ME THAT IT DID NOT OWN THE LAND AND, IN FEBRUARY AND MARCH 1996,
WHEN AON QUESTIONED THE OWNERSHIP OF THE LAND WITH REGARD TO A
"POSSIBLE INSURANCE CLAIM" FOR "WHAT IS NOW THE GABLE WALL OF 19
LIME GROVE", THE COUNCIL KNEW THAT CLAIM SHOULD BE DIRECTED AT
MARITIME HOUSING ASSOCIATION OR ITS CONTRACTOR FAWLEY, SOMETHING
THAT WAS STATED BY THEIR INSURERS IN MARCH 1996.

THE COUNCIL ALSO KNEW THAT THE DAMAGE REFERRED TO IT BY MY
SOLICITORS IN 1995 COULD NOT BE A CLAIM FOR THE DEMOLITION OF NONE
EXISTING BUILDING AS STATED BY MR BARR TO OFFICERS OF THE COUNCIL
AND MARITIME HOUSING ASSOCIATION, BUT WAS IN FACT DAMAGE CAUSED BY
THE DEMOLITION OF THE MAISONETTES.

IN FACT THE COUNCIL HAD BEEN AWARE OF ITS OWNERSHIP OF THE TWO
PARCELS OF LAND AT KEPLER STREET AND MAPLE GROVE SINCE 1977, UNLESS
THE TITLE MAPS AND OFFICE COPIES OF ITS REGISTRATION TO THE COUNCIL
AT BOOTLE AND SOUTHPORT TOWN HALLS, ARE ALL FORGERIES

I REMIND YOU THE COUNCIL PRETENDED TO BE INDEMNIFIED FOR THIS LAND,
FROM APRIL 6TH 1994 WHEN I REPORTED DAMAGE TO MY PROPERTY TO THE
COUNCIL CAUSED BY THE DEMOLITION OF THE MAISONETTES, AND AFTER THIS
DAMAGE WAS QUANTIFIED BY MY SURVEYOR, WHICH THEY ALSO KNEW.

THEN, ON MAY 1ST 2002 AFTER ROYAL & SUN ALLIANCE WITHDREW THE
PRETEND INDEMNITY AND WHEN IT BECAME CLEAR TO ROYAL & SUNALLIANCE
THAT I HAD REPORTED DAMAGE TO THE COUNCIL IN APRIL 1994 THAT THEY
HAD NOT REPORTED TO ROYAL & SUNALLIANCE IN BREACH OF THEIR
CONTRACT, AND ROYAL & SUNALLIANCE MAY HAVE HAD TO PAY ME
COMPENSATION.

MR HEYWOOD WAS FORCED TO ADMIT THAT THE CLAIM I HAD ALLEGEDLY MADE
IN 1993 WAS UNFOUNDED AND THE LAND WAS NOT OWNED BY THE COUNCIL AT
THE TIME OF THE DAMAGE, NOR HAD IT BEEN SINCE JANUARY 24TH 1993
WHEN OWNERSHIP PASSED TO MARITIME WITH THE TRANSFER
DOCUMENTS,DESPITE THE COUNCIL PROCESSING MY ALLEGED CLAIMS WITH
ROYAL & SUNALLIANCE DURING ALL OF THAT NINE YEAR PERIOD.

A BIGGER QUESTION MARK HANGS OVER THE LAND REGISTRY WHO, AFTER
ROYAL & SUNALLIANCE AND MR HEYWOOD CONFIRMED THE COUNCIL DID NOT
OWN THE LAND, WROTE TO ME TELLING ME THAT THE NONE EXISTENT
BUILDINGS "ADJOINING" 19 LIME GROVE - HAD IN FACT BEEN "ATTACHED"TO
19 LIME GROVE.

THE STATEMENT TO THE OMBUDSMAN BY MR BOWNES, THE COUNCIL'S LEGAL
DIRECTOR, AND MR WILLIAMS, THE COUNCILS TECHNICAL SERVICES DIRECTOR
REGARDING AN "ABUNDANTLY CLEAR CLAIM, AND A FORMAL CLAIM" MADE BY
THE ALTERATION OF THE CONJUNCTION 'OR' TO 'AND' TO 'TOGETHER WITH',
ARE FALLACIOUS.

Yours sincerely,

fred robinson

Dear Hilary Pook,

AS SOON AS A FACT APPEARS THAT THEY CANNOT FACE, LIKE MAJOR MAJOR,
DATA PROTECTION OFFICERS LEAVE THEIR OFFICES IN DROVES.

Yours sincerely,

fred robinson