Dear Mr. Clarke,
We refer to your e-mail of 6th December 2011.
Our professional indemnity insurers are Zurich Insurance PLC, The London underwriting centre, 3 Minster Court, Mincing Lane, London, EC3R 7DD, and the cover relates to services provided from our offices in England.
It is noted that you have attempted to serve the members of this firm with a document on 9th December.
The document does not comprise a Claim Form or Particulars of Claim. The document, which you call a "commercial lien", is no more than an affidavit which can be sworn on oath (the document e-mailed this morning is not in fact so sworn). In the absence of this document being produced in the context of formal legal proceedings and in support of a properly pleaded claim, the document has no value other than to comprise a record of the facts of this matter as you understand them.
For the avoidance of any doubt, such affidavit does not amount to a claim against this firm for damages. Such affidavit further does not give you a right to enforce your alleged claim for damages against this firm. No bailiffs will accept instructions from you to proceed with such enforcement.
If you believe you have a claim against this firm for damages, we suggest you take legal advice and issue a proper and valid claim at court in respect of the same.
Until you do so, we do not propose to correspond with you any further in relation to your threats, save to reserve the right to rely on the same as evidence of your harassment of this firm, and (if necessary) in respect of an application for an injunction to ensure any unlawful conduct on your part going forwards is restrained.
Further, should you publish to any third party, including this firm's insurer, untrue statements which defame this firm, we reserve the right to rely on such publications as further acts of harassment and in respect of an additional claim against you in defamation.
Hugh A S Jones
Head of Private Client and Court of Protection Groups
For and on behalf of Pannone LLP
"Excellent in every way"
- Legal 500 2011
|Pannone LLP is a limited liability partnership registered in England
and Wales under number OC317202 and is authorised and regulated by the Solicitors Regulation
Authority (SRA) and authorised and regulated by the Financial Services
Authority. Registered office: 123 Deansgate Manchester M3 2BU where a list
of Members and Partners is open for inspection. We use the word 'partner'
to refer to a member of the LLP, or an employee or consultant with
equivalent standing and qualifications.|
This email and any attachments are confidential and legally privileged. If you are not the intended recipient you must take no action based on them, nor must you copy or show them to anyone. Please contact the sender if you believe you have received this email in error. The contents of this email may be intercepted, monitored and/or recorded. We accept no responsibility for viruses and it is your responsibility to scan the email and any attachments. If this message is transmitted over the internet be aware that it may be intercepted by a third party for which we exclude any liability in negligence or otherwise.