Church and State blog: Has the Central London County Court ignored Declan's request for time to reply to the Mayor of London-commissioned St Mungo's fabrication of false claims and misleading information? (UPDATED 11/12/2019)

Saturday, December 07, 2019

Has the Central London County Court ignored Declan's request for time to reply to the Mayor of London-commissioned St Mungo's fabrication of false claims and misleading information? (UPDATED 11/12/2019)

6/12/2019

Your courage and persistence are inspirational to Sally and me and all our associates!!

Donald A. Collins
Founder, International Services Assistance Fund, Washington DC

Our Church and State website has no less than 57 Nobel Laureates on it; for details, see this blog's sidebar under "Church and State" (updated today).

County Court at Central London, Royal Courts of Justice

Mayor of London Sadiq Khan

11 December (newer post): St Mungo's: Declan has filed in court his reply to an outrageous witness statement from this Mayor of London-commissioned charity. We are threatened with insurmountable debt just to get them to vouch over the phone that we are clients of theirs

Paragraph 1 of Declan's reply to the St Mungo's witness statement reads as follows:

1. The Defendant's witness statement dated 27 November 2019, written by its Tenancy Sustainment Team (TST) Service Manager Ilyas Hussein, contains a series of false claims and omits and misrepresents key facts pertaining to its tenancy sustainment support. This in itself would indicate that the Claimant has a pleadable case against the Defendant which has some real prospect of success, and that the Defendant's request for costs is abusive and unjustified.

On Thursday of last week Declan asked the Court for time to reply to a whole series of false claims upon which costs have been sought. And that's not to mention a stack of misleading information.

The Court Manager
County Court at Central London
Royal Courts of Justice

Address removed for email

BY EMAIL AND RECORDED POST

28 November 2019

Dear Sir,

Claim Number: F03CL589
Claimant: Declan Heavey
Defendant: St Mungo's

I hereby ask that the Court allow me time to file and serve my reply to the Defendant's Defence, which I received mid-afternoon today.

The Defendant has invented a series of false claims and left out key evidence because it would undermine the negative portrayal of me that it is seeking to give the Court.

Furthermore, the Defendant's website makes it very clear that clients have to be ready to move on and that Tenancy Sustainment Teams (TSTs) offer "critical support" to help tenants "access training or employment opportunities". All I have most recently requested is the most basic support to this end through learning disability volunteering (meaning the willingness of my TST caseworker to vouch over the phone that I am a client of his).

The Defendant has provided the Court with no reasonable explanation for the denial of this most basic support. In fact, the Defendant completely ignores in its Defence this simple request of mine.

I ask for 21 days from the date of service of the defence to file my reply.

Yours faithfully,

Declan Heavey

cc: Batchelors LLP

EU freedom for rough sleepers infringed - shock horror. https://t.co/RuJKrSEiTm
— Andrew Martin (@devonprof) May 14, 2018

'Let me recommend an important web site churchandstate.org.uk. Operating out of London this well-designed and exciting web site covers church-state, population, climate change and other issues. Check it out.' Edd Doerr, President, Americans for Religious Liberty

Church and State

MAYOR OF LONDON RSI PROPERTY
DAY 406 IN A WEEKLY PERIODIC TENANCY
SUBJECT TO A SECTION 21 NOTICE

(SEE PARA. 3 BELOW)

1. Our 308 Honorary Associates include 20 Nobel Prize laureates. Declan and I are engaged in a project that deals with the publication of issues significant to social policy in a number of key areas, e.g., climate change, population, futurism, atheism, and free speech. Established as Network for Church Monitoring, a non-profit company limited by guarantee, our main publication, found at the website, Church and State, calls attention to subjects, not the least which have been critical of the interaction between religious and secular institutions. We have been the target of numerous threats and actions, e.g., the former resulting in threats to Declan's life, and the latter, which have led to vandalism. The various incidents are on record with the police and other official agencies.

2. There are no less than 63 Nobel Prize laureates on the Church and State website from 20 Honorary Associates, eight articles, nine book excerpts and 33 petition signatories. (For example, one Nobel laureate signed our Nobel petition in support of human embryonic stem cell research and gave us permission to excerpt from one of his books.) Our list of associates also includes 18 US National Medal laureates, and six Turing Award laureates (the equivalent of the Nobel Prize in computer science). We have published one article and excerpted from the books of seven members of the British House of Lords. And there are 31 knighted professors on the site from 13 Honorary Associates, one book excerpt and 21 petition signatories. These figures are despite the never-ending assault on our email (this link reveals the targeting of our emails to, among others, a close colleague in Washington, DC as well as space advocates and Nobel laureates).

3. This is Day 406 for us living under the threat to life of a 'no fault' eviction by Peabody Trust.[1] We live in a Mayor of London's Rough Sleepers Initiative (RSI) property. Peabody's appalling new terms of tenancy have forced us into an unstable weekly periodic tenancy that poses a threat to Declan's life and inhibits our ability to exercise our rights. Declan accumulated quite a history with the Housing Ombudsman Service before he received the Ombudsman's decision not to investigate a referral from Lyn Brown MP on jurisdictional grounds. The Ombudsman was asked to consider whether or not our tenancy has been renewed like for like; and whether, if not, it should be in light of the landlord having accused us of not signing a like-for-like agreement. The Equality and Human Rights Commission will not accept a referral of discrimination from Ms Brown, the Commission's helpline (EASS) having grossly distorted the complaint against Peabody. We no longer have pro se access to the courts (see next paragraph).

4. This eviction matter came before District Judge Ruth Fine at the Central London County Court on 30 June 2020, when both counsel for St Mungo's (the charity in effective control of our tenancy) and Declan presented their positions. Declan lost the case and was ordered to pay £1,850 in costs. A publishing colleague in America cleared these costs within 24 hours of my blog post about this hearing for strike out on a related issue that was the essence of the claim, i.e., that St Mungo's would take a phone call to confirm that we are clients of the Mayor of London's RSI programme. Within a week of the hearing, St Mungo's had agreed to take this phone call for us both, the Court having ruled that they were not obliged to do so despite our circumstances. This time we escaped bankruptcy (counsel for St Mungo's asked for £3,407.50 in costs), but consider that to seek pro se access to justice in the courts has become far too dangerous for us. Declan currently has before the Parliamentary and Health Service Ombudsman the decision of the Information Commissioner that allows St Mungo's to continue processing coercive support plans without our knowledge or consent and that also poses a threat to his life.

5. When it comes to traffic, we have had 10.7 million hits in the past three years on Facebook; however, I left the platform on 13 March 2021 for one year rather than risk being banned for life. It is indisputable that with any sort of level playing field Church and State would have far exceeded 2.5 million hits last year. In addition to a large variety of blocks without explanation, Facebook had so severely restricted our Page's distribution by October 2020 that it was almost as good as an unpublished page.[2] Currently, we are up to their 85th block since 1 December 2015, and as usual without an explanation. This block records as one half of their 3rd double block in the first five weeks of this year that lasted 60 days. Our traffic has also been curtailed by over 2.5K blocks on access to Church and State since 26 July 2016, including 29 full distributed denial-of-service (DDoS) attacks since 17 May 2019 that have lasted for as long as 54 hours at a time.[3] About 70% of our hits are from Americans.

"This is precisely the hard hitting kind of response needed to clarify the unfair way Facebook is treating your highly reputable site." Don Collins, Founder, International Services Assistance Fund, Washington DC

Last updated: 26/06/21

_________________________

[1] Once a fixed term has elapsed, the landlord has the option to seek eviction even if the tenant has upheld their obligations in full (though of course the landlord must still apply for and obtain a county court order).

[2] 17/10/20: We have permission to publish this ISAF letter of 30 September to Facebook COO Sheryl Samberg. Facebook has so severely restricted our Page's distribution since 4 September that it's almost as good as an unpublished page

[3] Since October 2019, we have been defining a full DDoS attack as having such a high volume of up to 4-minute blocks on access to Church and State that we don't bother recording them all.

Church and State blog

Saturday, December 07, 2019

Has the Central London County Court ignored Declan's request for time to reply to the Mayor of London-commissioned St Mungo's fabrication of false claims and misleading information? (UPDATED 11/12/2019)

About me

My Picks

Church and State

Blog Archive