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    • My defence was standard no paperwork:   1.The Defendant contends that the particulars of claim are generic in nature. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 2. Paragraph 1 is noted. The Defendant has had a contractual relationship with MBNA Limited in the past. The Defendant does not recognise the reference number provided by the claimant within its particulars and has sought verification from the claimant who is yet to comply with requests for further information. 3. Paragraph 2 is denied. The Defendant maintains that a default notice was never received. The Claimant is put to strict proof to that a default notice was issued by MBNA Limited and received by the Defendant. 4. Paragraph 3 is denied. The Defendant is unaware of any legal assignment or Notice of Assignment allegedly served from either the Claimant or MBNA Limited. 5. On the 02/01/2023 the Defendant requested information pertaining to this claim by way of a CCA 1974 Section 78 request. The claimant is yet to respond to this request. On the 19/05/2023 a CPR 31.14 request was sent to Kearns who is yet to respond. To date, 02/06/2023, no documentation has been received. The claimant remains in default of my section 78 request. 6. It is therefore denied with regards to the Defendant owing any monies to the Claimant, the Claimant has failed to provide any evidence of proof of assignment being sent/ agreement/ balance/ breach or termination requested by CPR 31.14, therefore the Claimant is put to strict proof to: (a) show how the Defendant entered into an agreement; and (b) show and evidence the nature of breach and service of a default notice pursuant to Section 87(1) CCA1974 (c) show how the claimant has reached the amount claimed for; and (d) show how the Claimant has the legal right, either under statute or equity to issue a claim; 7. As per Civil Procedure Rule 16.5(4), it is expected that the Claimant prove the allegation that the money is owed. 8. On the alternative, as the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974. 9. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.
    • Monika the first four pages of the Private parking section have at least 12 of our members who have also been caught out on this scam site. That's around one quarter of all our current complaints. Usually we might expect two current complaints for the same park within 4 pages.  So you are in good company and have done well in appealing to McDonalds in an effort to resolve the matter without having  paid such a bunch of rogues. Most people blindly pay up. Met . Starbucks and McDonalds  are well aware of the situation and seem unwilling to make it easier for motorists to avoid getting caught. For instance, instead of photographing you, if they were honest and wanted you  to continue using their services again, they would have said "Excuse me but if you are going to go to Mc donalds from here, it will cost you £100." But no they kett quiet and are now pursuing you for probably a lot more than £100 now. They also know thst  they cannot charge anything over the amount stated on the car park signs. Their claims for £160 or £170 are unlawful yet so many pay that to avoid going to Court. When the truth is that Met are unlikely to take them to Court since they know they will lose. The PCNs are issued on airport land which is covered by Byelaws so only the driver can be pursued, not the keeper. But they keep writing to you as they do not know who was driving unless you gave it away when you appealed. Even if they know you were driving they should still lose in Court for several reasons. The reason we ask you to fill out our questionnaire is to help you if MET do decide to take you to Court in the end. Each member who visited the park may well have different experiences while there which can help when filling out a Witness statement [we will help you with that if it comes to it.] if you have thrown away the original PCN  and other paperwork you obviously haven't got a jerbil or a guinea pig as their paper makes great litter boxes for them.🙂 You can send an SAR to them to get all the information Met have on you to date. Though if you have been to several sites already, you may have done that by now. In the meantime, you will be being bombarded by illiterate debt collectors and sixth rate solicitors all threatening you with ever increasing amounts as well as being hung drawn and quartered. Their letters can all be safely ignored. On the odd chance that you may get a Letter of Claim from them just come back to us and we will get you to send a snotty letter back to them so that they know you are not happy, don't care a fig for their threats and will see them off in Court if they finally have the guts to carry on. If you do have the original PCN could you please post it up, carefully removing your name. address and car registration number but including dates and times. If not just click on the SAR to take you to the form to send to Met.
    • In order for us to help you we require the following information:- [if there are more than one defendant listed - tell us] 1 defendant   Which Court have you received the claim from ? County Court Business Centre, Northampton   Name of the Claimant ? LC Asset 2 S.A R.L   Date of issue – . 28/04/23   Particulars of Claim   What is the claim for –    (1) The Claimant ('C') claims the whole of the outstanding balance due and payable under an agreement referenced xxxxxxxxxxxxxxxx and opened effective from xx/xx/2017. The agreement is regulated by the Consumer Credit Act 1974 ('CCA'), was signed by the Defendant ('D') and from which credit was extended to D.   (2) D failed to comply with a Default Notice served pursuant to s87 (1) CCA and by xx/xx/2022 a default was recorded.   (3) As at xx/xx/2022 the Defendant owed MBNA LTD the sum of 12,xxx.xx. By an agreement in writing the benefit of the debt has been legally assigned to C effective xx/xx/2022 and made regular upon C serving a Notice of Assignment upon D shortly thereafter.   (4) And C claims- 1. 12,xxx.xx 2. Interest pursuant to Section 69 County Courts Act 1984 at a rate of 8% per annum from xx/01/2023 to xx/04/2023 of 2xx.xx and thereafter at a daily rate of 2.52 to date of judgement or sooner payment. Date xx/xx/2023   What is the total value of the claim? 12k   Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) ? Yes   Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? No   Did you inform the claimant of your change of address? N/A Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? Credit Card   When did you enter into the original agreement before or after April 2007 ? After   Do you recall how you entered into the agreement...On line /In branch/By post ? Online   Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? Yes, but amount differs slightly   Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. DP issued claim   Were you aware the account had been assigned – did you receive a Notice of Assignment? Not that I recall...   Did you receive a Default Notice from the original creditor? Not that I recall...   Have you been receiving statutory notices headed “Notice of Sums in Arrears”  or " Notice of Arrears "– at least once a year ? Yes   Why did you cease payments? Loss of employment main cause   What was the date of your last payment? Early 2021   Was there a dispute with the original creditor that remains unresolved? No   Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? No   -----------------------------------
    • Hello CAG Team, I'm adding the contents of the claim to this thread, but wanted to open the thread with an urgent question: Do I have to supply a WS for a claim with a court date that states " at the hearing the court will consider allocation and, time permitting, give an early neutral evaluation of the case" ? letter is an N24 General Form of Judgement or Order, if so, then I've messed up again. Court date 25 May 2024 The letter from court does not state (like the other claims I have) that I must provide WS within 28 days.. BUT I have recently received a WS from Link for it! making me think I do need to!??
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    • Hello,

      On 15/1/24 booked appointment with Big Motoring World (BMW) to view a mini on 17/1/24 at 8pm at their Enfield dealership.  

      Car was dirty and test drive was two circuits of roundabout on entry to the showroom.  Was p/x my car and rushed by sales exec and a manager into buying the mini and a 3yr warranty that night, sale all wrapped up by 10pm.  They strongly advised me taking warranty out on car that age (2017) and confirmed it was honoured at over 500 UK registered garages.

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      I’m not happy to do this, drive the car or with the after care experience (a sign of further stresses to come) so want a refund and to return the car asap.

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    • Housing Association property flooding. https://www.consumeractiongroup.co.uk/topic/438641-housing-association-property-flooding/&do=findComment&comment=5124299
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    • We have finally managed to obtain the transcript of this case.

      The judge's reasoning is very useful and will certainly be helpful in any other cases relating to third-party rights where the customer has contracted with the courier company by using a broker.
      This is generally speaking the problem with using PackLink who are domiciled in Spain and very conveniently out of reach of the British justice system.

      Frankly I don't think that is any accident.

      One of the points that the judge made was that the customers contract with the broker specifically refers to the courier – and it is clear that the courier knows that they are acting for a third party. There is no need to name the third party. They just have to be recognisably part of a class of person – such as a sender or a recipient of the parcel.

      Please note that a recent case against UPS failed on exactly the same issue with the judge held that the Contracts (Rights of Third Parties) Act 1999 did not apply.

      We will be getting that transcript very soon. We will look at it and we will understand how the judge made such catastrophic mistakes. It was a very poor judgement.
      We will be recommending that people do include this adverse judgement in their bundle so that when they go to county court the judge will see both sides and see the arguments against this adverse judgement.
      Also, we will be to demonstrate to the judge that we are fair-minded and that we don't mind bringing everything to the attention of the judge even if it is against our own interests.
      This is good ethical practice.

      It would be very nice if the parcel delivery companies – including EVRi – practised this kind of thing as well.

       

      OT APPROVED, 365MC637, FAROOQ, EVRi, 12.07.23 (BRENT) - J v4.pdf
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Should we trust Sunak or the next PM to fix the Country's problems? (title revised 24/10/22)


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5 hours ago, tobyjugg2 said:

Leaver baiting? - You mean 'the Truth'

Well, we cant help it if someone considers Truth as 'baiting

 

 

Oh yea careless of me I completely forgot that lefties don’t possess a sense of humour 🤣
could have saved you a tirade 

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Be laughing with/at you as soon as the next general election tosses the Tories on the scrap heap ..

I wont say flushes them away as we really dont want those lumps adding to the pollution in our waterways eh


Cheer up:

WWW.THELONDONECONOMIC.COM

Rwanda has agreed to take just 200 people after originally agreeing to take up to 1,000 migrants from the UK.

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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It seems Rwanda doesn't want to sign the treaty that is supposed to get round the Supreme Court ruling on whether Rwanda is a safe country.

They're objecting to loss of sovereignty.

Edit: Link added.

INEWS.CO.UK

Kigali is refusing UK Government demands to place British officials in the east African nation.

 

  • Haha 1

Illegitimi non carborundum

 

 

 

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seems to me that the 'delay (kick into the long grass) is what the UK taxpayer is actually paying vastly in excess of £140M+ for

.. or do the Tories really want to trash the good friday agreement and their really crappy trade deal with the USA along with many other of the UK's international agreements which rely/refer?

 

Hmmm - all those downsides, with the 'upside (sic) of maybe 200 migrants at a million quid each trafficked?

vs

a million quid each for 200 migrants not to be trafficked, issue kicked into long grass,  - and some dog whistles for the shallow end

(bargain - its only taxpayer money after all)

Edited by tobyjugg2

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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hey Tossries - I'll take some migrants  - just a £100 million quid up front - we'll sort out details later eh?

 

.. £50M+ cheaper than Rwanda .. can you get a refund? No? ah well .. Not my problem ..

Edited by tobyjugg2

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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(True) soundbite of the day, especially presented in tinsel for the right wing supporters of the utter cobblers that is the Rwanda farce

'Even if ministers had somehow managed to turn around every single dinghy leaving a French beach last year, legal migration would still have hit record levels.

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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I wouldn't suggest anyone attempt to through the seemingly deliberate attempts of the UK guv (or even ONS) to munge and camouflage the stats - through terms such as 'irregular. regularised etc etc

.. but the sky report is a relatively easy start:

NEWS.SKY.COM

Former home secretary Suella Braverman calls the numbers "a slap in the face to the British public" after the Office for National Statistics details the...

 

or

 

BLOG.ONS.GOV.UK

Net migration to the UK has been running at record levels. Driven by a rise in people coming for work, increasing numbers of students and world events...

 

WWW.GOV.UK

This series brings together documents relating to Home Office statistics on migration.
MIGRATIONOBSERVATORY.OX.AC.UK

This briefing examines irregular migration – also called ‘illegal immigration’ – in the UK, including the difficulties in defining and measuring it, and...

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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A crucial stat .. that continues to Sept

 

"The increase in non-EU immigration in the YE June 2023 was mainly driven by migrants coming for work (up to 33% from 23% in YE June 2022), largely attributed to those coming on health and care visas;

in contrast, those arriving on humanitarian routes decreased from 19% to 9% over the same period. "

 

- read the above carefully

I'm loath to explain as there are some aspects which fly in the face of the Tory right-wing dog whistles - LOL (let their hate shine and shoot themselves)

 

Hint

The Tory right can hardly admit they need experienced workers and dont want to invest 'locally eh?

Edited by tobyjugg2

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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Not many right wingers actually support the Rwanda plan which was always going to be a non starter due to leftie lawyers 
Far better to have built secure detention centres here, decided the applications for asylum within a few days and deported those failing immediately ( not too many genuine asylum seekers lob their ID into the channel prior to arrival)
As for allowing in extended families to “support “ students is quite ludicrous 
Can only hope the Tories are reduced to a handful of MPs and a new party emerges that actually delivers what the overwhelming silent majority actually want and what they voted for on three separate occasions only to be ignored 

PLEASE HELP US TO KEEP THIS SITE RUNNING

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1 hour ago, theoldrouge said:

 

Only a few of the most loathsome right wingers actually support the Rwanda plan which was always going to be a non starter due to being incompetent, illegal, breaching far too many other agreements and quite simply 'not fit for purpose' let alone worth wasting the best part (other costs included) of a couple hundred £million taxpayer money on - as anyone with even a modicum of competence immediately saw

Far better to have decided the applications for asylum within a few days and deported those failing immediately and integrate the others swiftly

 - apart from being unable to deport people to places where there are no agreements in place thanks to Brexitish incompetence - I hope you are not advocating just throwing them in the sea as you seemed to be excusing the mass murder of Palestinians ?

As for allowing in extended families to “support “ students is quite ludicrous 

+1

Can only hope the Tories are reduced to a handful of MPs

+1

... Corrected

weren't you shouting support for Braverman on this and related matters @theoldrouge  ?

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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Good to see Mr Gove agreeing with the head of the FBI that the virus was indeed man made
and escaped from the lab in Wuhan
Debunking Juggs following of the science that it originated in a batcave 1000 miles from Wuhan🤣
 

DAILYSCEPTIC.ORG

Michael Gove has told the Covid Inquiry he became convinced lockdown was needed to counter the "man-made" coronavirus...

not to mention the fact that it now emerges that Moderna were developing a vaccine against the virus before it was even leaked from the lab
 

Still not to worry the enquiry has already concluded that Boris was guilty of Brexit🤣

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Any help I am able to give is from my own experience only. Should you have any doubt you should contact a qualified professional.

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Reuters don't agree about the vaccine being developed early on, unless this has been superseded

WWW.REUTERS.COM

Social media users are sharing a document from 2019 about an mRNA vaccine to claim baselessly that the U.S. government knew about COVID-19...

Going back to Rwanda, here are Rafael Behr's thoughts on Sunak's current problem.

WWW.THEGUARDIAN.COM

A brave leader would admit he is cornered and set out a new direction to his party and the public. He’s not that guy, says Guardian columnist Rafael Behr

 

Illegitimi non carborundum

 

 

 

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Gove says 'its a Novel virus so its ok to make up stories like 'its man made and 'we were prepared for the wrong or indeed prepared for any virus and 'How could we know spreading respiratory virus would spread and infect people.

Head of inquiry and everyone who isnt a nut and/or dog whistling says 'stop talking water company pollution Gove

and the incompetent self serving corrupt idiots didnt even follow the flu virus 'plan' ephemeral as it was anyway - just read it to see

Gove makes note for later claim he was just testing everyones' eyesight by trying to pull the wool over their eyes.

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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just change a few of the names of the references

 

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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I think that more than that - the linked 'question time shows the issues we are seeing are a core Tory issue, which gets 'forgotten'.

Britain doesn't boom under the Tories - it bombs - they are just better liars and better at blaming others for their failures

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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Fact of the day

Michael Gove’s flagship bill to end leaseholds on newly built houses in England and Wales

contains no provision to end leaseholds on newly built houses in England and Wales

 

- Kiran Stacey Political correspondent

 

What the ... ?

1. Downing street didn't want it - but didnt want the flack from not including it - so farcically include it without the headline bit

2. Torys want it done via amendments so they can drop some huge  lumps of poop in with it that only they want passing and hope to slide it through without an immediate uproar in parliament

 

WWW.THEGUARDIAN.COM

Rush to write legislation means clauses to ban the leaseholds will be added via amendments

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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Gove says 'its a Novel virus so its ok to make up stories like 'its man made and 'we were prepared for the wrong or indeedprepared for any virus and 'How could we know spreadingrespiratory virus would spread and infect people.”

 

it’s OK Jugg Mr Icke will see you shortly 
you’ll be telling me next The King and Kate were members of the EDL all along 🤣

PLEASE HELP US TO KEEP THIS SITE RUNNING

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Any help I am able to give is from my own experience only. Should you have any doubt you should contact a qualified professional.

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Israel knew of Hamas plot more than a year ago

Israeli officials obtained Hamas’s battle plan for the devastating Oct. 7 terrorist attack more than a year before it happened, according to documents, emails and interviews, but they dismissed it as aspirational, considering it too difficult for Hamas to carry out. In fact, Hamas followed the blueprint with shocking precision.

Over about 40 pages, a document code-named Jericho Wall by the Israeli authorities outlined exactly the kind of devastating invasion that led to the deaths of about 1,200 people. It did not set a date, but it described a methodical assault designed to overwhelm the fortifications around the Gaza Strip, take over Israeli cities and storm key military bases.

Last year, shortly after the document had been obtained, officials in the Israeli military said that Hamas’s intentions were unclear. Then, in July, just three months before the attacks, a veteran Israeli intelligence analyst warned that Hamas had conducted an intense, daylong training exercise that appeared similar to what was outlined in the blueprint. Those concerns were brushed off.

Concessions: Israeli security officials have already acknowledged that they failed to protect the country, and the government is expected to assemble a commission to study the events leading up to the attacks. The Jericho Wall document lays bare the missteps that culminated in what officials now regard as the worst Israeli intelligence failure in five decades.

More from the war:

-NYT

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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The above does need careful consideration of all aspects but

 

WWW.TELEGRAPH.CO.UK

Civilians could be heard shouting ‘get out of here’ as public anger at the government mounts
 
 
 

 

Edited by tobyjugg2

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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and the UK guv is doing the decent thing - at last - better late than never - although the lateness of the 'secret' actions and leak'ness of the 'secret' plans leaked to newspapers does raise some questions on the reasons

BUT - better late than never

 

WWW.INDEPENDENT.CO.UK

Exclusive: James Heappey lifts the lid on a military operation to airlift Afghans who fought with Britain out of Pakistan

 

The Tory Legacy

Record high Taxes, Immigration, Excrement in waterways, energy company/crony profits

Crumbling Hospitals, Schools, council services, businesses and roads

 

If only the Govt had thrown a protective ring around care homes

with the same gusto they do around their crooked MPs

 

10 years to save the Vest

After Truss lost the shirt off the UKs back in 49 days

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All in black and white for you Jugg 
 

Any notion that this novel coronavirus arose from contaminated bat meat sold in the wet market at Wuhan is a fairytale for the credulous, a juvenile explanation that insults the intelligence of every serious virologist.

The Chinese are to blame for the Covid pandemic and the deaths (estimated at seven million globally) and long-term illnesses it caused, as well as the incalculable damage to the world's economy - to the extent that it would not be inappropriate for nations to demand substantial reparations from Beijing.”
 

 

WWW.DAILYMAIL.CO.UK

PROFESSOR ANGUS DALGLEISH: If the Covid Inquiry was genuinely interested in discovering the truth behind the...

 

PLEASE HELP US TO KEEP THIS SITE RUNNING

EVERY POUND DONATED WILL HELP US TO KEEP HELPING OTHERS

 

 

 

 

Any help I am able to give is from my own experience only. Should you have any doubt you should contact a qualified professional.

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