TABLE OF EXHIBITS Part one. Essential reading is
shown with. +++
___________________________________________________________________________________________________
EXHIBIT 1 MicroDirect orders, delivery
prices, plus Amtrak's promises, assurances of reliability and standard prices.
EXHIBIT 2 Confirmation of the order.
EXHIBIT 3 PROOF claimant was in residence at relevant
times to take in delivery. +++
EXHIBIT 4 EVIDENCE Driver had not returned to re-deliver that day.
EXHIBIT 5 Claimant advises a variation of time window for
re-delivery until
EXHIBIT 6 Claimant could see no attempt and gives notice to issue a formal claim. Suddenly goods arrive next day???
EXHIBIT 7 Negotiations between claimant and 1st
defendant on second part of settlement (£15.28 carriage refunded by 1st
defendant already)
EXHIBIT 8 1st defendant case dismissed, case proceeds for 2nd defendant in the sum of £30 court costs for the taxpayer.
EXHIBIT 9 Details of telephone call, 1st defendant
& claimant, advising claimant the £30 cannot be settled, claimant
states it can. +++
EXHIBIT 10 The determination of AMTRAK on
refund of carriage, and or court costs, ADAMANT they were reasonable??? +++
EXHIBIT 11 Amtrak advises they
will rely on “privity rule” and the refund
cannot be settled. +++
EXHIBIT
12 After 1st hearing, claimant VERY sceptical of defendant’s behaviour. Demeanour of defendant, shows contempt for court. +++
EXHIBIT 13 Claimant commences serious
interrogatories, proves that from E12 defendant is inventing stories to cover
tracks.
EXHIBIT 14 Should be after E 17, Critique of exchange between
three parties on
EXHIBIT 15 Following E 12, defendant calls claimant with STORY, that
explains mens rea of
actions, Confirms contempt of court (E23) +++
EXHIBIT 16 Follow up of email concerning what was
advised to court in anticipation of willful design in filing the N150 (AQ)
EXHIBIT 17 Follow up of unsatisfactory resolution of
exchange where Bachu And her MD call claimant.
EXHIBIT 18 Preparation for second hearing showing a
list of all emails of
importance.
EXHIBIT 19 Defendant, under pressure, provides very
late evidence of driver’s scan history proving claimants chronology was true. +++
EXHIBIT 20 Claimant already had E19 and E20 showing
demeanor of driver previously, combined with sworn affidavit. +++
EXHIBIT 21 Affidavits and miscellaneous, the first affidavit is important, confirming re-delivery normally should occur same day +++
EXHIBIT 21a The N150. (Allocation questionnaire) PART A (SETTLEMENT) is the undertaking to the court, please read. +++
EXHIBIT 21b The N150. Showing the amount in dispute (backdated
from
EXHIBIT 21c The N150. Showing a time window of exclusion between
EXHIBIT 21d The N150. Showing date of signing same date as third party call to establish true amount of claim at £255 + £30. +++
EXHIBIT 22 Email concerning standard disclosure
documents. Attempting to convince that EX
19, was sent. +++
______________________________________________________________________________________
__________________________^^^^^^^__________________________
Please note the link FROM
Micro-Direct, to Amtrak's web site, indicating this Web Seller acts as AGENT
for the carrier.
Click on this link above and
the
buyer is referred to the
following pages by Amtrak.
Text reproduced from above
-------
"The Reputation- As a high-calibre player in the nation's overnight delivery industry, Amtrak Express Parcels is a company whose name is synonymous with quality and reliability. Established in 1987 and built up by a comprehensive, franchised nationwide network, Amtrak's unique strength lies in being able to offer customers a local and individual level of service unequalled in the industry."
Text reproduced from above
------- next day delivery, the least expensive of daily carrier's costs,
"0 Service Code…..The
next working day
This is Amtrak's standard
service to a nominated address. You can rely on it to get your
parcel to the right place at the right time - Monday to
Friday."
From: WebSales
Sent: 2004-09-23 12:19 PM
To: general
Subject: Information on Micro Direct
Order (MICR054450)
Dear
Mr. Winter
Thank you for your order with Micro Direct Ltd.
Your order contents are as follows:
1 x 17" LG L1715S 16ms Silver-Grey TFT slim bezel monitor (3yrs Onsite) @
£179.99(211.49) each.
1 x 160 GB Maxtor DiamondMax Plus9
8MB Cache 7200rpm ATA133 @ £48.99(57.56) each.
1 x DELIVERY @ £13.00(15.28) each.
OrderTotalEXVATis.£241.98
OrderVATis…………………….£42.35.
Order Total INC VAT is £284.33.
Comment on itemised bills below,
Carriers telephone and fax
numbers.
..................is the fax number confirming
the faxed letters, and
................. is
the telephone number.
The two bills above are from BT, originals, as
the claimant's calls to
Under construction please
revisit fortnightly
Some masking of Tel, Email,Fax and address details has
taken place.
From: Anthony Winter [general"" "]
Sent: 2004-09-24
To: chris"" ".readnotify.com
Subject: Here is a copy of the letter to Amtrak,
DEAR CHRIS,
At 4.40 I guess they will not deliver today, (this will confirm that their behaviour is 'WILLFUL') and I will not know when they will attempt again, so this can possibly cause another failure due to my not expecting them. If they wish to be professional, they need to advise me by telephone of an impending ETA. I guess they will not!
All will be up in the air now, and I suggest I leave the matter with you to arrange either another time, or another courier.
Please advise.
Thank you.
Tony Winter
Micro Direct Ltd
Sales Fax: " " AMTRAK" "
I am prepared to give this between
9 and
Yours Faithfully,
A.H. Winter.
From: Anthony Winter <general"" ">
To: chris"" ".readnotify.com
Subject: Notice of intention to issue proceedings if buyer's (my) instructions are not carried out. Within 7 days
Date:
Notice of intention to issue proceedings if buyer’s (myself) instructions are not carried out.
Micro Direct Ltd
Also - Sales Fax: " " AMTRAK" "
Dear Chris,
Further to the two emails sent and read on Sunday, also to several to Amtrak read also, without replies.
I now instruct as follows:
I formally cancel and reject the goods on the above order reference numbers, on grounds of breach of contract the relevant section in the sale of goods act as aforementioned in performance and delivery. No deliver having been received today, having given a variance of the arrangement and no reply thereof.
I ask you to refund the amount to the credit card immediately, and if this is not actioned within 24 hours, I shall report the breach to the credit card issuer, and request they block the transaction.
Yours Faithfully, A. H. Winter.
|
From: romeen [romeen"" "] Sent: 2004-11-08 11:57 AM To: Anthony Winter [general"" "] Subject: Re: MICR054450 |
Dear Sir,
I can confirm that the offer made is from Micro Direct rather than both parties. Do you accept the offer made on do you wish to discuss this further. If so, I can give you a call?
Regards
Romeen " "
Customer Services Manager
Micro Direct Ltd,
From: Anthony Winter <general"" ">
To: romeen <romeen"" >"
Subject: Re: MICR054450 case number 4CL07994
Date:
Dear Romeen,
I confirm that the payment of £70 has been received at the visa card centre, and the case is withdrawn between ourselves. The court were advised yesterday in writing.
Thankyou
Tony Winter
From: Anthony Winter [general"" "]
Sent: 2004-11-23
To: Nicky Bachu [nicky."" ]"
Subject: re last friday
COPY FOR THE COURT 4Cl07994
FAO. Legal Department Ms. N. Bachu.
Reference CASE Nr: 4Cl07994.
Dear Ms. Bachu,
Following the recent letter and hour-long exchange we had last Friday. I confirm as follows: You probed a number of issues. The resolution of the matter out of court, was discussed cordially. There was a suggestion I (as plaintiff) would be happy if your company merely settled the court fees, and that they resolved the issue between themselves and the first defendant on the settlement already made.
You made it clear that your position disables you legally from being able to meet that requirement, but it was left that you may make a positive attempt. I felt there were many ways in which this might be achieved with a will.
I consider that the weekend plus one day, has now expired, and your absence of
any indication that the matter would be resolved in the sum of £30 for the court fees (to be paid to the court direct) places clause 3) of letter Ref:AW / 16112122 back in vigour.
While I respect your continued argument, that you made all reasonable attempts to deliver, I note a similitude between the approach referred to by Micro-Direct concerning your being adamant in respect of reasonable delivery, and that of a reasonable settlement for £30 court fees now, out of court, and lack of resolve in that direction. I find the pairing of any text or demeanour concerning “adamant” on being “reasonable” unusual; I am permitted to make such comment. £30 is in my view reasonable, and I should have personally shown eagerness and promptitude in resolving that small amount were I in Amtrak’s position, but I am not! It is just my opinion!
As a duty of honour, I advised you of the financial circumstances relating to the need for exemption of the court fees.
You stated that you intend to have the case set aside, on the grounds that the first defendant’s settlement clears you. I shall clarify to the court the basis on which the settlement had been reached with particular note that it was settled between the first defendant and the plaintiff, on unequivocal grounds that treated the claim in two parts, leaving a small amount for Amtrak, to be continued. I shall await the court ’s notice if your application is to be successful.
You stated that the rules for affidavits are considerably relaxed from former times, and I take the view that any party in a claim, prepared to make testimony under oath, is less likely to have their propositions tested in truth-value. You should consider all my testimony as plaintiff, under oath, and not of the weaker form, concerning “truth the whole truth”, but including “and nothing but truth.”
The proposition that your company and its contracted parties made all reasonable attempt to deliver the goods on time, remains to be considered by the court for its quality of reasonableness, where the Plaintiff paid in advance, for a next day delivery, and did not receive the goods until six days later, with no re-delivery attempts recorded.
I shall make an exhibit for the court, in respect to the exchanges resulting in the settlement reached with the first defendant.
Yours most respectfully, and a particular thank you for your call.
A .H. Winter (For the plaintiff.)
FAO. Legal Department
Amtrak Express Parcels Lt
Date:
Ref: AW / 16112122
Dear Sir or Madam,
Reference CASE Nr:
4Cl07994.
I enclose by way of copy, an update on the status of the claim above, part settlement completed.
I also detail several extracts from the exchanges between the first defendant (Microdirect Ltd) and the Plaintiff. Their settlement is in the sum of £70, plus a previous credit of £13+vat for the delivery costs.
I understand they approached you to split the costs, and your response was in the nature of:
”As per your recent County Court claim form, Micro Direct have looked in to
this matter with Amtrak and they are adamant that there delivery driver
made
a reasonable amount of effort to deliver the consignment on time.”
And you did not
wish to share any costs, which one can respect.
A few extracts of the plaintiff’s reply follows at the end
of this letter as footnotes 1 & 2.
If your defence concerning “reasonable effort” is to rely on statements from either
your driver, or the depot manager, or both, I respectfully request that you ensure that the testimony provided
shall be in the form of affidavits, upon which a test of the veracity
may be conducted, unless you intend to have the parties aforementioned be
present at the hearing and be sworn in for questioning. Footnote 1)
The costs being sought for the plaintiff at today’s date, are:
The court
fees of £30 to be paid to the court.
The plaintiff
would wish, if the court finds against Amtrak, that
they be ordered to pay at least 50-60 percent towards Microdirect’s
out of court settlement, to the first defendant.
A sum of
£32, Plaintiff’s costs shall be written off, if the matter ends by this
weekend.
Otherwise in the event of a hearing, The plaintiff shall be asking for 3) plus costs in the week prior, which shall be advised.
All may regard the matter at this stage, as having been settled financially in favour of the Plaintiff. Costs on Items 1) and 2) are for third parties. The Plaintiff would only become financially interested again, seven days prior to a hearing.
End of partial
extracts, too long otherwise.
|
From: Nicky Bachu [nicky."" ]" |
Dear Mr A. Winter,
Thank you for email dated
I on behalf of Amtrak have endeavoured to explain the legal status to you. You have confirmed that you fully understand that your contract is between
Micro direct and not with Amtrak. (inaccurate) You have explained to me that you have settled your personal loss with Micro direct Limited
and are now perusing Amtrak for the taxpayers loss on their behalf . (inaccurate)
I can only re-iterate we have no contract with you but we do with Micro direct Limited.
We believe this matter cannot be settled and do not believe that any further correspondence or
dialogue can at this stage resolve matters any further.
Yours sincerely
Nicky.Bachu
Extracts (too long). Full pages Batch 1 exhibits all
correspondence P129, P130
FAO Mr. " ", Customer Services Manager, Ext 5000.
Copy please to Her Honour, Judge F, to attach to my letter after the hearing, and original allocation questionnaire.
Case
4CL 07994 A.H.Winter V Amtrak Ltd.
Dear Mr. "T ",
This appears to be an opportune moment to examine and compare reasonable demeanour. I shall keep a meticulous record of any approach made by the defendant to settle this case as expressed in their choice of settlement on the form.
The primary point is that I shall wish to make a direct and corroborative comparison between the defendant's making a delivery under a contract of 18 hours, reluctantly 7 days later, and their express wish to reach a settlement within 30 days from 21st Inst.
Without wishing to appear misanthropic, their sense of timing may indicate an intention to cause a further delay for a hearing until probably August or September, to be borne out by their demeanour.
To: Ms N. Bachu,
Amtrak Ltd, Direct Dial:"" " Fax: "" "
Per Email and or fax: nicky.bachu"" "
Dear Madam,
An
application for the case to be re-listed, has been
confirmed by the court.
For you information I enclose several relevant copies of extracted texts sent to the Court, on receipt of your N150 with comment.
1) As
anticipated from your filing the allocation questionnaire on
2) It is noted that you make a clear distinction between your respect for the court, and your clients.
The defence and N150 forms have all been returned to the court precisely within time for the last day permitted. Elsewhere under contract for performance and time you and your agents are content with breaches, and denial. With the expression of a velleity in response that you require an extension of time; 30 days in order to resolve the issue 'out of court', you have shown the court and those in witness, that you pursue quite another policy; apart from being well out of the extension time, you equivocate, subtract, and prolong. In anticipating this in the letter A)*** to the court, you also have shown a disesteem to the court and its function in respect for truth, and civil procedure, by requesting such extension of time, merely to take the case forward into a short window and holiday that would achieve this anticipated end of further delay. The first question the claimant shall request permission of the trial judge is that you explain coherently, the purpose of signing such a request where there was no volition to carry out the expressed wish. And it should be stated that on your side you have wilfully failed throughout to conduct: 'genuine and reasonable negotiations with a view to settling the claim economically and without court proceedings.' Precisely analogous to your agents' conduct on delivery.
3) The claimant is of the view that it is not unreasonable to expect you may respond to this question, that you did make every effort to deliver a recorded letter, telephone or fax in support of that declared wish; just as your agent did in the delivery of the goods under contract. To which, of course you will be likewise expected to corroborate it by showing records of the aforesaid attempts, even with perhaps a back-dated recorded letter to show you tried, and the claimant was 'out.' As you have done in the past and placed on record in your defence.
Too extensive for this part, see full texts BATCH 1 p153,154,155. Extract hereunder.
e) Identify which claims the claimant has made, that you specifically admit in your
"Save as specifically admitted below the defendants deny each and every allegation contained in the claim form (and particulars) as though the same were set out herein and traversed seriatim."
6.
On what do you rely for the truth of, "the
defendant collected a consignment from the Customer on
7.
On what do you rely for the truth of, "The
Delivery was attempted the following date" meaning
8. On what do you rely for the truth of, "nobody there to accept the delivery."
On what do you rely for the
truth of, "The defendants would assert that they have fulfilled their
contractual obligation." Bearing in mind you admit -i)
leaving a card on 24th, and not the goods. -ii) your
company failed to attempt a re-delivery by
Too extensive for this part, see full texts BATCH 1 p132,133,134, 135. Extract hereunder.
Letter to Managing Director of
Amtrak Ltd.
End 1st para.
Your MD did say of my claim that your call of the 6th Inst; to retro-actively establish that cheque and letter had been sent, and a further repeat will be re-sent, was pure speculation This takes no account of the grounds on which I rely for such an assertion.
Clause 13)
13) For any further exchanges to be realistic, you will need to state unequivocally that "without prejudice" if a settlement were reached, it will include the costs to date of £285 which are not negotiable; as a part of a total where the other part is to cover all other aspects of pursuing this disgraceful case of on an initial just and trivial claim. I require, this prior to any further debate to establish whether further exchanges are at all likely to be meaningful, sincere and genuine enough to be relied on
Too extensive for this part, see full texts BATCH 1 p135,136,137. Extract hereunder.
Email
sent
2) It is noted that you make a clear distinction between your respect for the court, and your clients.
The defence and N150 forms have all been returned to the court precisely within time for the last day permitted. Elsewhere under contract for performance and time you and your agents are content with breaches, and denial. With the expression of a velleity in response that you require an extension of time; 30 days in order to resolve the issue 'out of court', you have shown the court and those in witness, that you pursue quite another policy; apart from being well out of the extension time, you equivocation, subtraction, and prolongation. In anticipating this in the letter A)*** to the court, you also have shown a disesteem to the court and its function in respect for truth, and civil procedure, by requesting such extension of time, merely to take the case forward into a short window and holiday that would achieve this anticipated end of further delay. The first question the claimant shall request permission of the trial judge is that you explain coherently, the purpose of signing such a request where there was no volition to carry out the expressed wish. And it should be stated that on your side you have wilfully failed throughout to conduct: 'genuine and reasonable negotiations with a view to settling the claim economically and without court proceedings.' Precisely analogous to your agents' conduct on delivery.
_________________________________________________________
Case 4CL 07994 A.H.Winter V Amtrak Ltd.To: Ms N. Bachu,
Amtrak Ltd, Direct Dial:"" " Fax: "" "
Per Email and or fax: nicky.bachu"" "
Dear Madam,
Further
to your call today
Here is a copy of the preliminary to the 6 points sent to the court last month the day the N150 was received. It relates to the details of that conversation, and predates the receipt of the N150 by a day, indicating you were aware the costs had moved on since the n150 was sent out. Now 6 weeks later they have moved on again.
The defendant called "without prejudice" on the 20th Inst, to ascertain what might be their likely costs if a settlement were reached out of court. I stated that I was seeking settlement of all of the court fees to date of £170, plus compensation to the dismissed First Defendant's costs in settling which in my view were not theirs to carry (up to a maximum of £85). I also stated that with regards to my own costs, I had originally no pretensions whatsoever, when the request was merely a refund of £15 in delivery costs, they wilfully delayed as to punish me for a further 6 days, and then after legal action it became £30. In seeking those trivial and perfectly reasonable early costs, the policy of the defence has been a prime cause in their increase to the present day. With this minimal settlement amount of £255 in mind, they filed and served the form meeting the deadline. I comment:
Yours Most respectfully,
A. H. Winter
Copy FAO Customer Services Manager, and Trial Judge.
Too extensive for this part, see full texts BATCH 1 p141,142,143.144. Extract hereunder matching italics from these pages.
Email
sent
To Ms Bachu.
"Without prejudice"
Case 4CL 07994 A.H.Winter V Amtrak Ltd.
To: Ms N. Bachu,
Amtrak Ltd, Direct Dial:"" " Fax: "" "
Per Email and or fax: nicky.bachu"" "
Dear Sir / Madam,
The claimant affirms "That the defendant did NOT; in seeking an extension of time be granted for the purpose of a resolution out of court, make any attempt to fulfill that purpose within the extended period." Therefore the request became an instrument of further delay, continued contempt for the claimant, and a new contempt for the due process of the court.
Proof of delivery pages.
Relating to a reference set of documents BATCH 3
Emails.
Proof of
delivery pages.
12-Oct nicky.bachu *** documents Last two pages
12-Oct nicky.bachu *** final email Last
two pages
Relating
to a reference set of documents Identical with the batch of emails sent:
29-Jul 
nicky.bachu
list of served
documents to date,
plus a further 7 added since that date.
Post MAIL
26th Sept Post Notice to admit.
Emails.
02-Sep msadmin @amtrak Re: AutoNotify: Re: case 4CL07994 for Sept 7t P183
02-Sep nicky.bachu Re: case 4CL07994 for Sept 7th P183
03-Aug nicky.bachu *** Nice meeting you. P183,[p61]
02-Aug sue.price FAO ms Bachu. Full text sent to her E' address P182
02-Aug nicky.bachu Re: section b missing items P180,[p60]
02-Aug nicky.bachu Re: section b missing itemsP180,[p59]
01-Aug
nicky.bachu
revision to one secti of b) on prev email.
[p57]
01-Aug
nicky.bachu *** privileged
evidence? P132,179,[p65]
31-Jul
nicky.bachu
prev' list with B & C parts now incl. P178,[p56]
29-Jul
nicky.bachu list of served
documents to date,
All
emails and faxes from
26-Jul nicky."" " 
tidying
up P177,[p55]
26-Jul nicky."" " Revision of
draft1 P176,[p54]
22-Jul nicky."" " You are reminded [2] P175,[p53]
22-Jul nicky."" " You are reminded! P173,[p52]
22-Jul nicky."" " Subject: Re: Further disclosures [1] 2ndrequest
for acknowledgement.[p50]
21-Jul nicky."" " Further disclosures [1] P172,[p49]
21-Jul
sue.price"" " Re:[1] Cs 4CL 07994 Wint V Amtra P172 ,[p48]
20-Jul nicky."" " Re: emails yesterday P171,[p46]
20-Jul nicky."" "s election of relevant exchanges, part 1,
posted version will be batched in groups of exhibits.P67,[p44]
20-Jul nicky."" " notification of documents ??
09-Jul nicky."" " Interrogatories. part 1 P153,169,[p43]
29-Jun nicky."" " Case 4CL 07994 documents
(1) P168,[p42]
29-Jun
sales""
" Case 4CL 07994 docuents(1)
P168,[p40]
22-Jun
sales""
" correction to court hearing P167,[p38]
22-Jun nicky."" " hearing date notification P166,[p37]
16-Jun
sales""
" *** Please forward to your MD P162,[p33]
16-Jun nicky."" " *** Re:further'case convers' 15th Ju 2005 P160,[p32]
12-Jun nicky."" " *** update on exchanges 12th June P151,[p31]
09-Jun nicky."" " *** Re: further'case convers' to' 6th June P151,[p30]
06-Jun nicky."" " *** further to case conversation today 6th juP152,[p25]
05-Jun nicky."" " *** Case 4CL 07994 P135,[p24]
20-Dec nicky."" " Copy of last before Xmas P108,[p22]
20-Dec nicky."" " Re: Request for proper pre-action protocol
procedures copied to the court. P109,[p21]
17-Dec nicky."" " Request for proper pre-action protocol procedures
copied to the court. P110,113,39,[p20]
23-Nov nicky."" " Re: Case Number 4C107994 P108,[p19]
23-Nov nicky."" " re last friday P158,
[p17]
01-Oct nicky."" " answer '' H.Parsons and
Nicky Bachu P34,125,[p15]
01-Oct nicky."" " Re: AW/29091908 P82,126,[p13]
29-Sep melaine."
""" " VERY
IMPORTANT URGENT P90, [p12]
COMMUNICATION, Please read if you wish me to cease court action intended for Monday.
28-Sep melaine."
""" " Re:
your quality office is on holiday. and the delivery
treatment is appalling. P107,[p9]
24-Sep
quality""
" *** Re: your quality office is on holiday. and the delivery treatment is appalling. P87,
[p3]
24-Sep sales""
" your quality office is on holiday. and the delivery treatment is appalling. P87,88,107,[p2]
24-Sep quality""
" You are not living up to your represented
description on delivery. P90.94,95,99,100,104,105, [p1]
EXHIBIT 21 next page p18,19,20,21.
Copy Ray Jone's
affidavit (1) = p18
AFFIDAVIT 1,2,3,exhibit1
Copy M.C. Winter's affidavit (2)
Copy Claimant's affidavit
To: Amtrak
Express Parcels Ltd.
Aldridge,
WS9 8ST
Winter V Amtrak
Case 4CL07994.
_______________________
Mr. Winter Claimant.
Micro-Direct Ltd 1st
defendant (case dismissed)
Amtrak Express Parcels
Ltd. Defendant (Formerly 2nd Defendant)
Copied to the court.
Dear Ms. Bachu,
Thank you for this!
May I respectfully point out that your belief, below, would appear to be inconsistent with your actual defence, sworn for truth and belief.
As you will know by re-traversal of your clauses 3, 4 and 12, you will find that at that time you only refer to THREE items you intend to rely on. Since I have been asking for a coherent explanation (for nearly a year) of your thesis in clauses 5 and 6, and the 4th item copied here (4. Copy of the scan history for the consignment in question), would appear to be what you relied on for them. I am interested to see this non-disclosed item to unravel the logic contained therein, and I should very much be grateful if you could inform me of the relevant references you may have for the theory of logic and epistemology that enables you to explain empirical facts in such a manner.
Whatever it contains, I will enclose an analysis of these clauses shortly before the hearing, for you to examine and attempt a logical rebuttal.
I never received from you item 4 on this list.
I do not intend to bar emails from you BUT,
Since you have chosen NO email communication, rejecting mine, I would most courteously request that in future you reciprocate by sending me communications via recorded post, as a simple reciprocal protocol.
yours respectfully,
A.H. Winter
Text below from Ms. Bachu. (italics are by Claimant)
__________________
1. Application for account facilities dated 15th Janary 1997
2. Terms and Conditions of Carriage
3. Emails dated
4. Copy of the scan histroy for the consignment in question. PLEASE FORWARD
Nicky
Bachu <nicky.bachu > wrote:
Dear Mr Winter,
In accordance with the court order dated
Yours sincerely
Nicky Bachu
Company Solicitor
Amtrak Express Parcels Limited
(the above statement of belief is
false, and confirms the ethic of inventing stories where prior willful
omissions have been made, this is particularly offensive since it compounds
breaches in pre-action protocol, (despite repetitious requests) and the defence document clearly
lists that a total of only 3 attachments were included, whereas
suddenly the defendant believes the
claimant received four where she
knows that has to be false. After all she is the author of the defence document, and no matter how many readings it
sustains, it cannot imply a fourth attachment. The third being the one referred
to in the penultimate clause. (C12)