Friday, November 4, 2011

SUBMISSION OF SOLICITOR DAVID TAYLOR RESPONSIVE TO SUBMISSION OF MAURICE LAW IN VR 158 OF 2011

6 comments:

  1. NATURE OF COMPLAINT IN THE SCHEDULE OF THE LPCC LETTER TO SAT DATED 7.10.2011 IN VR 158 OF 2011. THE SUBJECT OF THE SUBMISSIONS OF BOTH DTS DATED 3.11.2011 AND ML DATED 14.10.2011 PURSUANT TO ORDERS 2 AND 3 OF JUDGE SHARP
    1.DTS failed to file a Writ Civ 1131 of 2006 on 10.2.2006 according to Orders of Jenkins J dated 20.1.2006.
    2. DTS failed to advise ML about the caveatable interests in NH two properties.
    3. Delay of DTS in enforcing default judgment in DCA 2509 OF 2002.
    4. DTS incorrectly advised ML to pursue REGISTRAR POWELL 'S costs order against Mr. Chin.
    5. DTS GOADING ML to pursue REGISTRAR POWELL COSTS ORDER against Mr. Chin.
    6. DTS misled ML about date of filing Civ 1131.
    7. DTS swore a false Affdavit about filing Civ 1131 on 10.2.2006.
    8. DTS demanding outstanding fees from ML in aggressive manner.

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  2. LPCC SUGGESTED THAT COMPLAINTS 5, 6 AND 7 REQUIRES LEAVE ON THE GROUNDS THAT THEY ARE PERCEIVED TO BE TRIVIAL, UNREASONABLE, FRIVOLOUS AND VEXATIOUS AND THAT ML DOES NOT HAVE A DIRECT PERSONAL INTERESTS IN THEM.

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  3. WITH REFERENCE TO PARAGRAPH 3 OF DTS SUBMISSIONS, THE REGISTRY RECORDS SHOW THAT CIV 1131 WAS FILED ONLY ON 16.2.2006 BUT NEVER ON 10.2.2006. BESIDES THE DATE STAMP OF 10.2.2006 WAS CORRECTED TO REFLECT THAT PAYMENTS OF THE FEES OF $654.20 WAS PAID BY DTS ONLY ON 16.2.2006. THE STAMP DATE 10.2.2006 IS THEREFORE INCORRECT. THIS WAS PICKED UP BY JUSTICE SIMMONDS WHO GAVE THE CORRECTED COPY OF THE WRIT WHICH INDICATES PAYMENTS ON THE LATTER DATE TO MS. NANCY HALL WHO IN RETURN GAVE IT TO MR. NICHOLAS N CHIN FOR SAFEKEEPING AND LATER REFERENCE.

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  4. CONTRARY TO THE ARGUMENT IN PARAGRAPH 6 BY DTS, THE TEST IN THE CASE CITED IS MET AS SUBSTANTIAL INJUSTICE WOULD BE CAUSED TO BOTH ML AND MR. CHIN IF THE CASE WERE NOT REVERSED. BERSIDES THERE WAS FRAUD AND IT MUST BE UNRAVELLED BY THIS SAT.

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  5. CONTRARY TO PARAGRAPH 7 BY DTS, OWEN JA DID NOT DECIDE THE ISSUE OR HAD AVOIDED THE ISSUE. IF THE ISSUE WAS DECIDED IT WOULD HAVE BEEN INDICATED IN THE REASON FOR HIS HONOUR'S DECISION.

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  6. LOOK AT THE RECORDS OF THE SUPREME COURT REGISTRY PERTAINING TO RECEIPTS OF THE FILING FEES FOR CIV 1131 OF 2006 OBTAINED BY ML PERSONALLY AT:
    http://nicholasnchin.blogspot.com/2011/06/invoices-and-receipt-obtained-from.html
    ALSO LOOK AT THE EXPLANATIONS OF NICHOLAS N CHIN IN HIS FOURTEEN COMMENTS AT THAT SITE AS INDICATED ABOVE.

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