“1. Declaration the11 June 2018 and4 November 2016 Wills are invalid, and any new wills and codicils the Defendants suddenly claim are invalid. 2. Full Disclosure of the8 December 2006 Will and the earlier family wills and documents listed above. 3. Declaration that Sheila's (the Deceased) three children: Karen, David and Adrian are the three main beneficiaries of the entire Estate, as well as the residuary, and everything else that comes down through Sheila, from Sheila's father Ephraim. That Karen is entitled to receive one third or more, as always intended since a child. For Defendants to account for and rectify, everything they have taken and or control, so Karen receives her full entitlement. 4. Full Disclosure and response to a) the four Larke v Nugus requests: i) Jaffe Porter Crossick ii) Osbornes iii) IM Sheffield iv) Attwells. b) Requests in the5th November 2024 warning refused. That followed 27th August Sealed Appearance,14th June 2024 warning and prior letters. 5. Provide signed Authorisation for Claimant to access mother’s full medical records. 6. Full Disclosure of Estate Accounts 7. Declaration that earlier intergenerational Wills known about for decades must be taken into account (see listed in this document). In the alternative, intestate entitlement. That should include all properties above, those bought and or sold, and other assets in this estate, inter alia. 8. Specific return of: ii) Second Floor Flat at 56 Parliament Hill and turret above it + Freehold of building. iii) One third of 2024 value of 56 Redington Rd and other properties bought with the proceeds. iv) Box of her Mum’s and Gran’s jewellery due to Karen, investments, shares, policies, oil paintings, art, rare first edition illustrated books, inter alia, worldwide holdings. 9. Legal costs: Order that non-beneficiaries desist from using funds from the estate for legal costs, under cover of Adrian, and that estate pays the claimant’s legal costs. Unfair for Adrian and David to charge legal costs to the estate, and not ensure their sister Karen’s legal fees are paid. 10. Further or other relief, including for 45 years of deprivation.”
“The Claimant was told since childhood that she would receive one third or more of the entire estate. The Claimant is a main beneficiary, the only daughter of the Deceased, and grand-daughter of late maternal Grandfather and Grandmother. Entitled to and told very clearly and unambiguously she will receive one whole storey and the turret room above it of four-to-five storey 56 Parliament Hill NW3, and Freehold of whole building. Entitled also to one third or more of detached 56 Redington Road, Hampstead NW3, plus what family on the other side has made by investing the proceeds of 56 Redington Road in other properties, such as those listed above. Entitled under earlier Wills and within the intergenerational structure. Daughter also entitled under intestacy. Sealed Appearance was issued27th August 2024 (accompanied by sixth page, a cover letter).”
“The purpose of a pleading or statement of case is to inform the other party what the case is that is being brought against him. It is necessary that the other party understands the case which is being brought against him so that he may plead to it in response, disclose those of his documents which are relevant to that case and prepare witness statements which support his defence. If the case which is brought against him is vague or incoherent he will not, or may not, be able to do any of those things. Time and costs will, or may, be wasted if the defendant seeks to respond to a vague and incoherent case. It is also necessary for the Court to understand the case which is brought so that it may fairly and expeditiously decide the case and in a manner which saves unnecessary expense. For these reasons it is necessary that a party’s pleaded case is a concise and clear statement of the facts on which he relies…”