Dear Hugh
 
Your email below has been referred to our legal advisors.
Trust me, this document will be sworn on oath and the then sworn copy forwarded, but regardless, the contents are likely to be the same.
 
We would advise dialogue on the very subjects within that document.
Not least of all the sufferings, also, you are currently engaging in today, with an earlier email sent by reply in reference to your email sent via Margaret last week.
 
Our sufferings continue with what can only be described by myself as “financial blackmail”.
You seem to provide sweeteners with regard to funds to use as negotiators to try and significantly reduce the risk of our continued commitment to proceed with a claim against you, but one broken Mercedes, registration document and £1000 sweetener will most definitely not cut it HUGH.
 
Wake up, smell the coffee, start to take responsibility for what you have done. STOP dragging all your partners into the affray and get down to the business of settling our indifferences.
 
You are responsible and will be held accountable for your actions.
You can make our Christmas as miserable as you like as it will only serve to make us more determined to get accountability.
 
You are responsible for the death of my dog. A pet I loved and was only weeks from bringing back to the UK. Your sole actions have been the cause of our personal & financial sufferings.
One way or another you are going to pay.
 
Mike Clarke
 
 
 
From: Hugh Jones
Sent: Monday, December 12, 2011 10:30 AM
 

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.

 

Yours sincerely,

 

Hugh A S Jones

 


Hugh Jones
Head of Private Client and Court of Protection Groups
For and on behalf of Pannone LLP
 

Email: Hugh.Jones@pannone.co.uk
Direct: +44 (0) 161 909 1554
Office: +44 (0) 161 909 3000
Mobile: +44 (0) 7879891010
Fax: +44 (0) 161 909 4444
Web: www.pannone.com

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