Specific questions.
Across the whole case.

Did you personally draw the plan sent to Mr Mayo on 28 April 2025? If not, who prepared it?

Why it matters: A plan should be traceable to its author and source material. That allows its reliability and limitations to be checked. Identify who prepared the plan, as well as who sent it.

Which apparatus and which title did “the apparatus on your title” refer to? What supported that wording, and how does it relate to your later description, “not any particular title”? Did you carry out the Bodmin records check you proposed on 13 March 2025 before sending the April plan? If so, what did it establish? Was this intended as the plan accompanying a particular wayleave agreement? What could it establish about BH68, and what could it not establish? Identify any agreement to which it was attached.

Why it matters: A general apparatus map and a statement about a particular title do not necessarily establish the same thing. Integrity requires the wording to match what the underlying records can support, so those relying on it understand its limits.

What agreement or other basis supports the claimed BH68 wayleave rights connected with Mr Mayo? Produce the agreement, its date, parties and plan. Identify the land and apparatus covered. If an older agreement is relied upon, what establishes its continued application after any ownership change or subdivision, and how does it relate to Miss E’s signed 2024 agreement?

Why it matters: Miss E’s signed agreement provides a specific record against which the claimed BH68 rights can be compared. A transfer assertion should identify the relevant agreement or other basis, the land and apparatus, and why an older arrangement is said still to apply. Without those records, the family cannot test the competing claim.

Mr J says the April 2025 plan was introduced late in the proceedings and relied upon in court to support Mr Mayo’s claimed BH68 rights. Why was it introduced at that stage, and what exactly was it presented as proving? Given Mr Shackson’s later description of a general-area map, “not any particular title”, what justified relying on it for that purpose? Identify the document and the assertion it supported. Where is the executed BH68 wayleave agreement in Mr Mayo’s name and its accompanying plan that the family says it repeatedly requested? If your position rests on an older agreement or another instrument, identify it and explain how it applies to the relevant land and BH68. Identify the accompanying statement of truth, its signatory and the precise assertions it verified, including which email version was exhibited.

Why it matters: On Mr J’s account, the plan was relied upon in court despite not being suitable as a wayleave-agreement plan. The integrity issue is the gap between what a document was presented as proving and what it could support. Producing the filing, the agreement and the explanation for the late introduction would allow that gap to be tested. Identify the agreement’s terms, parties and scope.

Did you send the 15 April 2024 message saying “Your wayleave will be paid annually in advance in September” in response to the displayed 9 April request naming BH67 and BH68? Was BH68 in the email National Grid actually received? Produce the retained request, reply, full headers and attachments. For each pole, identify the agreement or other instrument behind “your wayleave” and the record linked to reference 2624773. If any displayed wording is not what you received or sent, identify it, when you became aware of it and what correction or notification followed. Miss E’s verification requests began in February 2025: why do the supplied replies still contain no authentication answer? If you have answered, identify the dated reply. If you cannot verify the exchange, explain what prevents you, who is checking it and when an answer will be provided.

Why it matters: The reply can be read as confirming the request about two named poles. If the request was altered, or the reply concerned different records, the apparent confirmation could convey a materially different meaning. Authenticating both sides of the exchange and identifying the instrument for each pole tests that connection directly.

Which agreement or other instrument did “your wayleave” refer to, for BH67 and for BH68? Identify the land, apparatus and recipient linked to reference 2624773. What payment records were updated, by whom and on what documents? Produce the archived plan and completion letter referred to in the April 2024 request and explain whether the stated £25 annual amount concerned one pole, both poles or different apparatus. How does that position relate to Miss E’s June 2024 BH68 agreement, its signed plan, 14-year term and one-off £2,000 payment provision?

Why it matters: An assertion that payment records were changed should be traceable to the documents and apparatus it concerns. Integrity requires explaining whether the records describe the same pole and rights, rather than treating an administrative payment entry as proof of an agreement or of the disputed boundary.

On 7 May 2026 you promised a substantive response to the recent Shackson correspondence. Where is that response? Separately, which dated answer resolves the Skea email-authentication and BH68 agreement questions? Produce the answers and supporting records. If these points remain unanswered, why, what prevents an answer, and when will you provide one?

Why it matters: A promise of a substantive response gives the family a concrete commitment against which to ask what happened next. An acknowledgement leaves the underlying verification work unfinished. Accountability requires the promised answer, its supporting records or an explanation of what prevents it.

The 31 January 2025 header names you as both sender and recipient: why did you self-forward the exchange attributed to Amelia Skea and Mr Mayo? The family’s Annex E specifically alleges insertion of BH68 into correspondence originally about BH67. Was the phrase “The pole numbers are BH67 and BH68” present in the message received from your source? Produce that message and the native exchange, including attachments, and compare them with the self-forwarded and court-filed versions. Identify every addition, removal or change, who made it and when. If you removed material on privilege grounds, identify the dated written notice or disclosure-list entry under CPR 31.19, its recipients and the grounds for withholding. Where is the unaltered original preserved under PD 31B paragraph 35? If no notice exists, explain why and identify any relevant direction. Paragraph 42 of the second amended claim relies on MJM2 pages 20–25: what checks supported that verified assertion? Identify the first redaction explanation and any hearing record addressing Mr J’s reported objection. Mr J says the emails were relied upon while the requested agreement and Ms Skea’s authentication remained outstanding: what checks supported that reliance, and which agreement supported the claimed BH68 rights? Provide the dated explanation and version comparison with appropriate protection for genuinely confidential information.

Why it matters: The family’s concern is that the disputed copy carried the weight of an agreement they say was never produced, without a checkable confirmation from the attributed sender. The integrity test connects provenance, meaning and reliance: which words were actually sent, what changed, what verified them and what justified the use made of them in court?

Is this handling of a wayleave-holder’s verification requests consistent with National Grid’s standards? Identify who took responsibility after the February and March 2025 requests, the referral and the April 2026 office visits. Who checked the disputed emails and agreement records, what did they conclude, and where is the written outcome? Will a senior officer review BH68-03, BH68-05 and BH68-06, explain any unresolved delay and give a date for a document-supported response?

Why it matters: Responsibility should remain traceable when a wayleave-holder’s concern passes between departments and external solicitors. Integrity requires a checkable outcome: who investigated, which records they examined and what answer the company stands behind.

Seldons’ letter of 28 October 2025 acknowledges the 27 October correspondence and attachments and reserves the firm’s position. What action followed that notice? Who was responsible, which records were preserved and where is the substantive review outcome? Cornwell had rejected the tampering allegations on 24 October and supplied copies said to have been printed by Mr Mayo and delivered personally: what comparison established that their content matched the originals? Will a partner identify the received, self-forwarded and court-filed versions, each change, the written withholding notice and grounds under CPR 31.19, and the preserved original under PD 31B paragraph 35? Who checked the version relied on in paragraph 42 of the amended claim? Identify the first redaction explanation and any response to the reported objection in court. Was verification sought directly from Amelia Skea or National Grid? Identify the supporting record and any correction required.

Why it matters: A firm-level answer should explain how evidence bearing its solicitor’s name was handled and checked. The integrity test is whether the disclosed copy preserved the original meaning and made its changes traceable, including the action taken if a problem is found.

Which agreement or other instrument do you rely on for rights concerning BH68? Identify its date, parties, plan, apparatus and the land to which it applies. If you rely on an older agreement rather than one in your name, identify the record establishing its continued application to your land. Explain how that position relates to Miss E’s signed June 2024 agreement. If the family has misstated your position, provide the precise correction and supporting document. Did your 9 April 2024 email contain the words “The pole numbers are BH67 and BH68” as shown in the disputed copy? Provide your sent message, its attachments and the reply you received, and identify the agreement or other instrument relating to each pole.

Why it matters: A claim about particular land and apparatus should identify the instrument and reasoning that support it. Naming the agreement and its scope lets readers compare competing accounts against documents rather than implications.

What N260 or equivalent signed costs statement was before you when costs were assessed following the 10 March 2025 hearing? Identify the document, its date and where it is held, and provide the available copy through the court. If no such statement was available, what other material supported the assessment and why did the court proceed on that basis?

Why it matters: A financial order must be capable of explanation by reference to the material and reasoning used. Identify the costs evidence and reasoning on which the assessment was based.

Identify when and how the costs statement was filed with the court and served on Miss E. Produce the filing and service record. If it was not filed or served within the applicable time, how was that addressed, and what opportunity was Miss E given to examine and challenge the costs sought? Mr J reports that Mr Mayo stated under oath that the N260 was sent to all parties on 17 March 2025, and the family disputes that claim. What record establishes the asserted service, and what costs material was available at the earlier 10 March hearing?

Why it matters: The person facing a financial demand needs to know its basis and have a meaningful opportunity to challenge it. Filing with the court and serving the other party are separate matters.

The published correspondence challenges an assessment of £3,500 and a £1,750 payment requirement. What work, hours, rates, fees and adjustments produced those figures? Identify the recorded reasoning, the operative order and the payment deadline. Explain the basis for the payment timing that Miss E describes as immediate.

Why it matters: The amount assessed, the amount payable and the time for payment each require a clear explanation. Which items of work beyond attendance at the hearing, if any, were claimed and allowed, and where are they recorded?

Where are the reasons explaining the costs assessment and payment requirement recorded? Identify any judgment, order, hearing recording, transcript or contemporaneous note that contains them, and explain how Miss E can obtain the relevant record. What costs submissions were considered, and what objections by Miss E were addressed?

Why it matters: A party cannot meaningfully understand or challenge a decision if its reasoning cannot be located. Which order, written reasons or transcript passage explains the decision?

What substantive response addresses the requests repeated in the 29 April 2026 final notice? Identify the date, recipient and supporting records for any response already given. If the requested documents or reasons have not been provided, explain what remains outstanding, who is responsible for responding and how the request will be resolved.

Why it matters: Repeated requests for the basis of a financial order should lead to a traceable outcome. The continuing reported gap matters because it leaves the affected party unable to check the decision against its supporting record.

Which employee-conduct, customer-communication, wayleave-record, complaint and document-integrity policies applied to the identified BH68 events during 2024–2026? Provide the policy titles, effective dates and relevant provisions, identifying the responsible National Grid legal entity. Which requirements applied to external solicitors, and through what instruction or contractual arrangement? If a document cannot be shared in full, provide the applicable provisions and explain the restriction.

Why it matters: A company’s public commitments should lead to identifiable standards against which particular conduct can be reviewed—not a general assurance that leaves the substance unchecked.

Will you appoint a reviewer not previously involved in the disputed handling, with authority to obtain the relevant records and require corrections? Name the responsible office, provide a case reference and a secure route for the indexed correspondence and letters before action. Confirm preservation of original emails, headers, attachments, plans and version histories. Which route will examine authenticity and staff conduct if the wayleave-rights dispute is being handled through legal proceedings?

Why it matters: A concern passed between staff, departments and solicitors needs an identifiable owner able to reach the underlying records and give a reasoned outcome.

Will the review authenticate the complete BH67/BH68 exchange attributed to Amelia Skea against National Grid’s originals, including headers and attachments, and explain any difference from the self-forwarded copy? Identify the instrument, parties, land and apparatus supporting “your wayleave” for each pole, and reconcile that position with Miss E’s signed June 2024 BH68 agreement. What record supported the April 2025 plan’s “on your title” wording, given Mr Shackson’s later general-area explanation?

Why it matters: The agreement, email and plan must be connected by records that can be checked. An executive assurance cannot replace authentication of the very material in dispute.

Which substantive authentication and agreement issues raised in the documented February–March 2025 correspondence remain unresolved, and why? For each point, identify the request, responsible person, checks made and dated answer with its supporting document. Account for the 10 March referral, the May 2026 letters before action and the 7 May promise of a substantive response concerning Mr Shackson. If the company considers the questions answered, show exactly where—not merely that correspondence took place.

Why it matters: Miss E and Mr J need to verify the records affecting their rights. Beyond the recorded referrals and acknowledgements, where are the supporting agreement and authenticated email?

Who held responsibility for checking Amelia Skea’s and Nick Shackson’s handling of the disputed records and the ensuing requests? Identify the non-privileged scope of Geldards LLP’s role, who retained complaint ownership after referral to the firm, and what process ensured the factual questions were investigated and answered. If information is withheld, identify the category and reason, and what non-privileged factual outcome can still be provided.

Why it matters: Use of external advisers should leave the company able to explain who owns a concern and which factual checks underpin its response.

Will you provide a dated written outcome against each question, setting out the records examined, applicable standards and findings, and identifying any corrections required? Explain the relevant agreement terms, notice provisions, contractual protections and review or escalation routes for Miss E. Give a realistic completion date and arrangements for progress updates. Where a point cannot be resolved, identify the missing record and the steps being taken to obtain it.

Why it matters: Give Miss E and Mr J a written account of what was checked, the findings and any resulting changes. The result should answer the material questions, not simply close the correspondence.

Did Torridge issue, supply or authorise the smaller sheet displayed beside the “KEEP OUT / NO PLANNING” sign? Once the legible photograph is available, identify its author, date, reference, recipient and legal status. Is it advice, correspondence or a formal notice? Was any officer involved in its display or in communications about displaying it during the sale?

Why it matters: A private sign and an official notice carry different authority. Prospective purchasers should not be left to guess which they are seeing.

How was the express investigation request of 24 June 2025 handled after the 27 June acknowledgement said the whole email had been passed on? Why did the July response state that no enforcement request had been received? Supply the complaint and enforcement references, referral dates, assessment and reasons for any decision not to open a case. Address the renewed September request too.

Why it matters: A request acknowledged by one part of a council must have a traceable outcome in the service responsible for acting on it.

Identify the planning basis, evidence and enforcement assessment applied separately to the shed, the dwelling, the concrete surfacing and the proposed forestry track. Ian McIver’s 6 September 2024 email to Mr Mayo reports a Community Protection Warning issued on 31 August concerning access. Supply that warning, its initiating complaint, supporting assessment and mapped route; identify any referrals between community safety and planning. Provide relevant dated communications with the applicant or his representatives about those issues and the sale-related sign, with lawful redactions. What conflict-of-interest checks or declarations were relevant to the officers handling these matters?

Why it matters: Planning, community-safety action and private access rights are different matters. The records should identify which powers and evidence were used, and whether any relevant communications connected the separate decisions or recent display.

The 19 August 2025 consultation letter allowed later representations while the application remained undecided. Your 23 September email gave a 26 September cut-off and said later comments would not be accepted. Was the detailed objection sent on 29 September considered before the recorded 14 October decision? Identify its registration, the report passages addressing it and the basis for the different deadline wording.

Why it matters: A resident must be able to establish whether a material objection reached the decision-maker and how it was addressed.

Identify the applicant’s heritage statement or equivalent material and the Council’s assessment for 1/0589/2025/FUL. Point to the analysis of the existing concrete driveway, proposed construction access and effects on the listed building’s setting. How was the request for a fresh assessment addressed? If the conservation note was the sole assessment, confirm that and identify its author, date and evidential basis.

Why it matters: A conclusion about heritage harm needs a visible route from the proposal and site evidence to the assessment. Naming a document is not the same as showing that it addresses the disputed impact.

Provide the decision notices, reports and approved drawings for 1/0638/2024/AGR and 1/0640/2025/AGR. What changes in the proposal, forestry need, route or evidence addressed the 2024 refusal? How was the family’s 29 September 2025 boundary-plan submission considered? Explain the exact legal effect of the later decision.

Why it matters: A different outcome should be understandable from the changed proposal, evidence and reasons, rather than inferred from a decision code alone.

Your 24 September 2025 response inferred driveway works in 1989–1994. Which document dates the particular concrete surface challenged by the family, who say it was laid around 2018–2019? Supply the completion correspondence relied upon, identify the stretch of route, and distinguish original construction from later surfacing, widening, drainage or other works.

Why it matters: Evidence of an old access does not, by itself, date each later alteration. The same physical works must be compared before their planning position can be explained.

Supply the 1989 decision, approved site and curtilage plans, conditions and relevant compliance records, including the status of the two drawings stamped in 1991. What resolved the earlier curtilage-plan request? Identify the basis relied on for the present concrete works: an express permission, a specified permitted-development provision, or an enforcement time limit. How was the cottage’s listing between submission and determination considered?

Why it matters: The existence of a permission, its geographical scope, compliance with its conditions and immunity from enforcement answer different questions. The Council’s explanation should identify which answer it relies upon.

Mr J’s 19 August 2025 objection challenged the existing house’s design and the effect of a similarly styled extension on the listed cottage’s setting. He contrasts it with a timber kit shed which he describes as screened behind the cottage in a rural plot approaching an acre. Identify the relevant assessments and approved drawings for each development, distinguishing existing works from the extension proposal. What significance, scale, materials, siting and views did officers assess? Supply the original conservation note challenged on 29 September as finding “no greater harm”, its author and date, photographs and any site-visit record. Where were the driveway, construction access and the earlier design objection addressed?

Why it matters: The family’s concern is unequal scrutiny of the same historic setting. The answer should show the separate evidence and applicable tests, explain any different conclusions, and identify the response to the recorded design objection.

Mr J reports reassurance during a planning-department telephone call and a site visit by an officer he identifies as Grant, who he says photographed the proposal and raised no objection to its position behind the house. Identify the officer and supply the call notes, visit record, photographs and advice recorded. How does that account relate to the January 2024 enquiry and the 12 April written advice that planning permission was required? Were the same structure, location and uses considered? Identify any subsequent application, decision or enforcement action, and whether the displayed material accurately represents the current position. If further action has been considered, what actual harm, complaint or new evidence prompted it, when was it received, and how was proportionality assessed?

Why it matters: A requirement to apply for permission is not itself a finding of heritage harm or a decision to enforce. The Council should reconcile the advice and explain the evidence, timing and public-interest basis of any further action.

Identify the date, extent and contractor for the disputed concreting and the planning permission or other planning basis relied upon. Separately, what landowner consent or deed-based right authorised those works? Mr J says the previous owners of Lower Barley Hayes confirmed they did not consent: address that account and identify the document and clause relied upon if you say their consent was unnecessary. Did the concreting coincide with tree felling, excavation or clearance, and was timber transport an intended use? Supply the relevant dates, location plans, felling licence or claimed exemption, and contemporaneous contractor or timber-transport records. Distinguish those works from the activities considered in the 2024 and 2025 forestry applications.

Why it matters: Planning status, private authority to alter the land and the purpose of the works are separate questions. Matching dated records can test the family’s allegation that unconsented concreting was linked to timber operations rather than ordinary residential access.

Mr J says a neighbour confirmed your involvement and that security-camera footage shows you putting up signs outside the property. The family alleges that their purpose was to prevent the sale. What is your response? Identify which signs you erected, when, and for what purpose. What record supports the planning statements displayed? Who supplied the smaller sheet? Did you obtain Council material or advice for the display, and from whom? What is your response to the estate agent’s report that the sign put the first viewers off?

Why it matters: The agent reports an effect on prospective purchasers. Establishing who erected each sign, its purpose and the source of its claims will test the family’s sale-obstruction allegation and whether any official involvement existed.

Identify the author, date and complete version of the conservation note for 1/0589/2025/FUL quoted in the 29 September objection as saying “It is only when you visit the site…”. Was a visit undertaken for that assessment? State who attended, when and what was inspected, and supply the contemporaneous visit notes. Supply the original image reproduced by the objectors as Photo B, its source, capture date, available metadata and original caption. Was it described as taken during that visit, or used as an older illustration? Explain why it shows an entrance without the gate/fence arrangement visible in Photo A, which bears a 4 May 2025 timestamp. Distinguish this ground-level image from the separate 2006 aerial photograph discussed in the objection.

Why it matters: Readers need to know whether the assessment represented current observation accurately. The photograph’s date and the visit’s date are separate, verifiable facts; if a claimed new-visit photograph is older, that specific representation requires correction and explanation.

The 29 September 2025 email addressed to you and Planning Support enclosed the nine-page objection. Pages 6–8 challenged the conservation note’s visit wording as reproduced in the objection and included Photos A and B. Identify when the objection was logged, whether you reviewed that challenge, to whom it was referred and what response was obtained before the permission recorded on 14 October. Which version of the conservation advice informed your report? Point to the passage addressing the disputed photograph, or explain why it was not addressed.

Why it matters: A specific challenge to the evidence behind an assessment should have a traceable outcome. The key issue is not merely whether a letter was uploaded, but what happened to its material photographic challenge before determination.

You were copied into the 29 September 2025 objection and are identified as Planning Manager in the 2025 Council record. What management review, if any, followed its challenge to the photograph and site-visit account? Identify the officer responsible for checking it, the findings, any corrected advice and the approval or review trail before determination. If it was not reviewed, explain the recorded reason. Who will now examine the original note, image provenance and visit record independently of its author?

Why it matters: The public-interest issue includes supervision: who took ownership of a documented challenge to information potentially relied upon in a planning decision?

You were copied into the 29 September 2025 objection and are identified as a Torridge Conservation Officer. Did you write, review, approve or supply material for the particular conservation note challenged in that objection? If so, identify your contribution, any visit you made and the source and date of the photograph. If not, identify the responsible officer or team and any referral you made after the objection. What response or correction, if any, followed the photographic comparison?

Why it matters: Authorship must be established, not guessed from a job title. A clear account of who supplied the advice and who handled the challenge is necessary to test its reliability.

You were copied into the 29 September 2025 email after corresponding with the family about the planning history. Identify the registration and upload timestamps for the objection and its nine-page attachment, any internal referral of the photograph/site-visit allegation, and the response or decision recorded. Was the attachment available in full to the case officer and decision-maker before 14 October? If this was handled by another officer, identify that officer and the relevant case or complaint reference.

Why it matters: An objection can be sent without its central point reaching the person making the decision. The registration and referral trail should show what was actually available and acted on.

The family alleges that an older photograph was used to give a misleading impression of a current inspection for 1/0589/2025/FUL. Produce the original conservation response, its authorship/version history, photograph and provenance, recorded visit details, and the handling of the 29 September objection. That email also copied Martin Setherton, Steve Hearse, Staci Dorey and Building Control. Identify any referrals or review arising from that distribution and who now owns the response. Preserve the originals and metadata. If the photograph was historical, explain how that was made clear; if any representation was inaccurate, identify its correction and whether the assessment or decision requires review.

Why it matters: The Council can resolve the central issue with primary records. The question is both whether the evidence was accurately represented and whether a specific warning about it received a documented answer.

The family’s letter dated 17 September 2025 quotes a historic warning that, without the requested garden/curtilage plan within 14 days, “the application will have to be returned with a recommendation for refusal”. Mr J also recalls a handwritten requirement on a plan published on the register. Produce the complete annotated plan, identify its author and date, and establish whether it is the same request attributed in the letter to 7 November 1988. Supply the amended plan or response, its receipt date and the record of acceptance. What resolved the requirement before the conditional approval which the Council dates to 13 April 1989? If the relevant records cannot be located, identify what was searched and what evidence supports the Council’s explanation.

Why it matters: A deadline and a later approval leave a specific question between them: what information or decision resolved the outstanding requirement? A traceable answer is necessary to assess the reliability of the planning history now relied upon.

Your 24 September 2025 response discussed missing or unscanned historic papers, no additional curtilage plans and two drawings stamped in 1991. Which document establishes the garden/curtilage accepted for application 1/0313/1988? Identify its number, revision, receipt date and approval status. Explain how the two 1991 drawings relate to the conditional approval dated 13 April 1989: approved amendments, later submissions or another status? If the requested plan is not held, what records support your conclusion about the permission’s scope, and how was the family’s quoted 14-day warning addressed?

Why it matters: The Council’s later assurance needs an identifiable documentary basis. A drawing received later is not self-explanatory evidence of what was approved earlier; its status and connection must be shown.

The family’s September 2025 correspondence raised the historic garden/curtilage request before the decision on 1/0589/2025/FUL. Which historic decision notice, conditions and approved drawings informed your assessment of that application? Did you investigate the quoted 14-day warning and the question of which amended plan satisfied the request? Identify any referral, answer and relevant passage in the assessment. If you considered the issue immaterial to the 2025 decision, explain why and identify where that reasoning was recorded.

Why it matters: The issue is your later assessment, not responsibility for the 1988–1991 file. Readers should be able to see whether the specific historic-record objection was examined and what effect, if any, it had on the decision.

As Planning Manager in the 2025 record, will you arrange a documented review reconciling the quoted 1988 request and reported handwritten deadline, the conditional approval dated 13 April 1989, and the drawings stamped in 1991? Identify the officer responsible, the records examined and the findings. Explain whether any outstanding requirement affected the Council’s later conclusions about approved scope or development, and correct any earlier explanation that the surviving evidence does not support. If records are missing, state what can and cannot be established from the remaining file.

Why it matters: Management oversight should turn repeated requests into a documented answer. The public-interest test is whether the Council can explain its conclusions, acknowledge gaps accurately and correct unsupported statements.

Your letter of 28 October 2025 acknowledges the correspondence and attachments sent on 27 October, and reserves the firm’s position. Who was assigned to assess the notice? Identify the documents received, preservation steps, checks undertaken and the dated substantive response, if any. Was the reservation a holding response or your final position? What allegations do you dispute, for what reasons, and what further information is needed?

Why it matters: A receipt identifies a point at which the firm had the notice. What review followed receipt of the specified records, who undertook it, and where is the outcome recorded?

Paragraph 42 of the second amended Particulars of Claim relies on MJM2 pages 20–25 as evidence of transfer. Was the version supplied edited or redacted? Identify every substantive change, its author and date, and the written notice or disclosure-list entry recording the withheld material and grounds under CPR 31.19. If no such notice exists, explain why and identify any relevant direction. Where is the original preserved for comparison under PD 31B paragraph 35? Was BH68 present in the original incoming request? Identify the checks supporting paragraph 42, the first redaction explanation, and any hearing record addressing Mr J’s objection. How do the replacement copies described in your 24 October denial resolve these points?

Why it matters: The chain was relied on for a specific pleaded proposition. Identifying the original, the notice and the exact reliance makes the alleged concealment testable without requiring public disclosure of genuinely privileged content.

Identify the instrument and land relied on for the claimed BH68 rights, and explain the asserted transfer of the 1963 and 1975 wayleaves described in the 24 October correspondence. Separately identify the historic boundary agreement referred to in Annex E and the evidence relied on for it. Distinguish the wayleave instrument, the claimed boundary arrangement and the later court determination; they are not the same document.

Why it matters: The factual basis should remain traceable even where a court has subsequently determined a boundary. A reference to one document should not silently substitute for another.

Annex E alleges that disputed email copies were supplied to Mr Dennis Venn while Miss E’s executed National Grid material was omitted. Identify the instruction dates, document index, versions supplied and any later supplementary material. Was her agreement and plan provided, and where does the report address them? Identify which propositions were instructions, disputed assumptions or the expert’s own observations, and any judgment passage resolving this challenge.

Why it matters: Which instruction letters, document index and report passages show what Mr Venn received and how he addressed the competing material?

Annex E section A challenges the two N260 schedules for 19 January 2026 and identifies different time entries, components and subtotals. Provide the exact filed and served versions, explain the entries and arithmetic, identify any correction and the assessment or order that dealt with the objection. Keep this separate from the family’s request for the underlying statement for the March 2025 costs hearing.

Why it matters: For each hearing, identify the exact schedule, reconcile its entries and totals, and show the court’s treatment of the disputed items.

For Annex E sections B, C and G, identify the joinder order and transcript passages relied upon, the operative amended pleadings, and the provenance of the disputed conveyancing versions. Explain any relevant corrections or redactions and identify the court’s findings on these issues. Provide non-privileged records, with personal financial details protected; if inspection is withheld, identify the category and the applicable ground.

Why it matters: This separates a pleading disagreement, a document-version concern and a court ruling. It seeks relevant evidence without treating private finances or privilege as proof of wrongdoing.

Authenticate the retained request and reply attributed to Mr Mayo and Amelia Skea, identify the apparatus and underlying agreement for each pole, and reconcile them with Miss E’s signed 2024 BH68 agreement and Nick Shackson’s plan correspondence. Which of these matters has the company already answered, with what records? Refer any unresolved items to the responsible reviewer and give a dated outcome.

Why it matters: The original company records are the direct way to test the email-insertion allegation and the competing descriptions of rights. The executive review requested elsewhere should lead back to those records.

Annex E alleges that woodland correspondence was used to misrepresent compliance with an access order. Identify the original request, visit notes, report and any revisions or communications about use in court. Distinguish what the officer observed from information supplied by Mr Mayo. Did the report purport to determine compliance with a civil access order, and if so on what material?

Why it matters: A forestry observation, a party’s account and a finding about compliance with a court order have different evidential roles. The original report and correspondence can show whether those roles were kept separate.

Following your 30 October 2025 closure decision, will you examine the identified pleading and MJM2 exhibit, obtain the original/edited versions and establish whether written notice and preservation complied with CPR 31.19 and PD 31B paragraph 35, subject to the applicable directions? Will you assess whether the court or opponent was misled under Code 1.4 or evidence was misused under 2.1–2.2, including who prepared, checked and knew about any changes? Identify which judicial reasons or additional records would justify further assessment and whether any later submission has been assessed.

Why it matters: The question is not simply whether the family lost the civil case. It is whether a distinct, evidentially supportable conduct issue was assessed, and what record would resolve it. The earlier closed file and later court outcome must form part of that assessment.

In assessing any further report following the 30 October 2025 closure decision, will you assess the allegations concerning Luke Cornwell and Seldons LLP against each stage of your Assessment Threshold Test? Identify the potential conduct issue, its seriousness if established, and whether the evidence supplied or realistically obtainable can prove it. If a stage is not met, explain which one and why.

Why it matters: A reasoned assessment should address the specific conduct and the available evidence, rather than treating the complaint simply as dissatisfaction with the result of a civil dispute.

Will you obtain the original messages, the self-forwarded or edited copy, MJM2 pages 20–25 and the first redaction explanation? Identify the written notice or disclosure-list entry recording any withholding and its grounds, and whether the original was preserved. Assess compliance with CPR 31.19 and PD 31B paragraph 35 against the applicable directions. What did paragraph 42 of the verified amended claim represent, and what did the signatory know? Will you assess whether an undisclosed change or omission misled the court or opponent under Code 1.4, or involved evidence misuse under 2.1–2.2? Identify any transcript or ruling addressing Mr J’s reported objection and any additional evidence needed.

Why it matters: The pleaded reliance and exhibit are now identified. The unresolved questions concern changes, notice and knowledge. A later explanation should be tested against the contemporaneous record, not substituted for it.

Who within Seldons prepared and checked the supplied versions; what, if anything, was removed or changed; and who authorised and recorded that decision? Where are the withholding grounds and retained originals? After the challenge and the notice acknowledged on 28 October 2025, what comparison, supervision review or correction followed? Will you assess the firm’s own actions under its compliance duties and the litigation standards applied by paragraph 7.1(a), including whether its 24 October replacement-copy explanation was checked against the original messages?

Why it matters: Which records identify the firm’s responsibility for preparing, supervising and checking the disputed material, and what review followed the allegations?

If further evidence is submitted, will you confirm whether it is assessed under the earlier reference or a new reference and tell the reporter which concerns you will assess, which—if any—fall outside your role, and what further material is required? If you decide not to investigate, will you give the reasons for that assessment, subject to any lawful confidentiality limits? Please identify the available route for supplying new evidence and the circumstances in which the earlier closed assessment could be reconsidered.

Why it matters: The person raising a concern needs to understand whether it was assessed, what the decision addressed and what remains possible. This requests an accountable process, not disclosure of protected investigation material.

Laurence Price, as the Investigation Officer who signed the decision, and the SRA: identify the report, index and exhibit versions received through Mimecast and considered before 30 October 2025. Your 23 October email acknowledged receipt. Which allegations and documents were included in the assessment, and which were excluded or referred elsewhere?

Why it matters: Receipt is established. A document list would make the scope of the decision checkable and separate the October evidence from later expansions.

For the alleged email alteration, banking-record anomalies, conveyancing discrepancies and disclosure omissions, identify which stage of the Assessment Threshold Test was not satisfied and why. Did the assessment address each conduct allegation, or treat them together as a property dispute? Explain how evidence realistically obtainable was taken into account.

Why it matters: A general reference to disputed facts does not tell the reporter how distinct evidence-integrity concerns were assessed.

The 21 October submission offered native files, metadata and witness statements. What inquiries were made or considered to obtain the original utility messages, compare them with the court exhibits and establish any changes, redaction notice and preservation of originals? Why was a further discussion or evidence request considered unnecessary, if that was the decision?

Why it matters: The allegation concerns the relationship between originals and copies. Identifying the authentication steps would show whether that question was tested or left for someone else.

Your decision relied on the absence of judicial criticism or positive findings. Was that a case-specific evidential decision, or a requirement that the court must first establish misconduct? Identify its policy basis. Explain how the parallel-investigations guidance was considered, including any risk of prejudice, need to preserve evidence and reason to await the civil court.

Why it matters: The published policy allows regulatory work alongside other proceedings. The decision needs a case-specific explanation of why that route was not taken here.

What assessment was made of the banking, completion-record and disclosure allegations identified in the October report? Which required further originals or reconciliation, which were answered by the supplied documents, and which were deferred? Identify the non-confidential reasons and the further evidence that would make a difference.

Why it matters: The two-page decision does not separately discuss those documents. Which assessment records explain how those documents were considered and why the identified concerns did not lead to investigation?

On 4 November 2025 Mr J challenged the handling; on 8 November the Contact Centre said you or the Report Team would respond in due course. Who considered that challenge, when, and what substantive response was sent? If none was sent, explain the omission and identify who will now provide an answer.

Why it matters: The promise of a follow-up is documented. A substantive later answer has not been located in the correspondence searched for this review.

The closure decision allowed for possible reopening after judicial criticism. In light of the later July 2026 order and any further evidence, identify which issues have actually been determined, the relevant judgment passages and what additional evidence could justify reconsideration. Explain how a challenge to a solicitor’s handling of evidence would be distinguished from an attempt to reverse a property judgment.

Why it matters: A court outcome and a regulatory conduct assessment have different purposes. The answer should identify the actual findings and the remaining evidential route.

On 9 August 2024, did Henry Bexley try to lift or open the chain? Produce the contemporaneous notes and photographs showing whether it physically prevented access, and explain the difference between its appearance and any check actually performed.

Why it matters: An impression of obstruction can affect court proceedings. The physical check and its record are central to the family’s challenge.

Why did notes from a visit to check alleged felling and discuss a licence include Mr Mayo’s private access dispute? What independently supported the blocked-access account and his requested chain wording? Identify the original notes, any revisions and checks against the complainant’s evidence. Why seek Mr Mayo’s agreement, permit evidential use at 17:54 and reply “that’s fine” at 19:38 after his court-and-planning proposal? Explain what that reply authorised, the limits on use and how accuracy, objectivity and impartiality were protected.

Why it matters: An official account must distinguish the officer’s observations from the investigated person’s account. Readers need to see who supplied, checked and changed each material statement.

Identify the land, cutting periods, timber volumes, machinery and historic imagery assessed. Supply the decision and plan for application 018/2760/2024, any exemption relied upon for earlier work, and the evidence addressing the family’s photographs and complaint.

Why it matters: The response must address the particular work reported, not leave uncertainty about which area and period were examined.

Why did you ask a woodland officer checking alleged felling to include that the chain appeared locked at first glance? What evidence shows it was locked rather than resting on an open hook? At 19:29 you proposed discussing court use with your solicitor: what proposition did you intend the notes to prove, and how was the difference between appearance and verified obstruction explained?

Why it matters: The requested wording should be traceable to what happened at the visit.

Miss E’s account is that, during her cross-examination of you, you stated under oath that you cut only one tree and denied commercial felling. Mr J says she recorded the answers in contemporaneous notes and subsequently challenged them in writing. Identify the exact statements, the tree, land and period they concerned. What operations and purpose were covered by the denial of commercial felling? How does that account fit the 2019–2025 imagery, the photographed cut timber and machinery, and the cutting described in the inspection notes? Give a dated schedule of the work, who carried it out, the quantities removed and the licence or exemption relied upon. Mr J says timber and machinery used the driveway before later field access: identify the dates, loads and vehicle records that confirm or dispute that sequence, including when the field routes came into use.

Why it matters: The family alleges that understating the operations discredited a genuine safety complaint. The scale, purpose, vehicle movements and route matter to the protection sought for Miss E and her vulnerable Grade II-listed historic home.

Identify the exact Bexley correspondence filed, its exhibit reference, hearing and the proposition it was used to prove. The defendant’s rebuttal alleges reliance before Judge Gibbs to obtain a further injunction and costs exceeding £3,000: identify that application, dated order, costs decision and the submissions linking the notes to the relief sought. Did the court receive Mr Mayo’s wording request, the request for his agreement, the 19:29 court-use proposal and the 19:38 reply? Was an impression of a locked chain presented as verified obstruction or as a finding about lawful access? Identify the checks, qualifications and response to the hooked-chain evidence. Once the family alleged a contrived obstruction account, what did you investigate, correct or place before the court? Explain how the presentation complied with SRA Code 1.4 and 2.1–2.4.

Why it matters: The filed wording and the use made of it allow the alleged misrepresentation to be tested.

Identify the substantive response to the family’s photographs, the hooked-chain account and the forestry particulars in the strike-out submissions and Annex E. Preserve the original messages and identify any changes between the received chain, the 8 November 2024 self-forward and the filed exhibit.

Why it matters: The record must show how a specific evidential challenge was answered and which document version the court received.

Mr J says he presented the material before Judge Paul Mitchell. Miss E’s account of the later trial before Judge Timothy Walsh, relayed to Mr J, is that it was not meaningfully addressed. Where do the hearing record and reasons compare Mr Mayo’s reported one-tree account and denial of commercial felling with the dated images and machinery photographs? Mr J says he personally attended delivery of the judgment and heard Judge Walsh conclude that felling had not occurred on the scale alleged: what evidence supported that conclusion, and how was the photographic contrast addressed? For the trial and final judgment, where is Mr Folland’s reported evidence of losing control and swerving into a tree about five metres from the house addressed? Explain the treatment of clause 2(ii) of the 1987 conveyance and the earlier interim undertaking excluding agricultural vehicles. What reasons explain the later access outcome and the response to the risk of a recurrence? Where were the likelihood and possible severity of harm assessed, including a vehicle strike or falling material blocking the home’s only exit? What preventive safeguards were considered, and why was the final access outcome considered appropriate?

Why it matters: The family says that minimising the operations displaced a material safety complaint. The evidence, the care obligations and the reasoning about vehicle use must be examined together.

Mr J says timber and machinery used the right of way before the later change to field access, following the family’s objections to heavy vehicles. He points to field tracks in the May 2025 image and links the change to the residential-use undertaking recorded before Judge Offen. Identify when that change occurred, which vehicles and loads used the driveway beforehand, and the dated records that confirm or dispute his account. How did those movements relate to the interim undertaking excluding agricultural vehicles while permitting commercial vehicles for domestic purposes? The family’s March 2025 defence quotes application 1/0638/2024/AGR as describing the existing access as unsuitable for heavy or long loads. Identify the original wording, the loads contemplated, and when and why concrete was laid. What precautions followed the reported tractor collision, and how do you say the use complied with the due-care and damage-avoidance wording in clause 2(ii) of the 1987 conveyance? Identify the landowner consent and maintenance arrangements relied upon.

Why it matters: The application, work records, collision evidence and conveyance should be addressed together when explaining the burden and safety of the traffic beside Miss E’s home.

Mr J identifies Mr Folland as the driver and places the tree approximately five metres from the house. Miss E’s account of the trial, relayed to Mr J, is that Mr Folland said he lost control and swerved into the tree to avoid the house. Is that an accurate account of the incident and testimony? Identify the hearing passage, date, vehicle, equipment, load and purpose of the journey. Mr J says the visit concerned a basket for forestry logs from Mr Mayo. What contemporary records explain the loss of control, damage and precautions taken afterwards?

Why it matters: The family says this was an actual loss-of-control event beside an occupied home. Its cause, the driver’s testimony and the response to the risk of repetition are material to how the route was being used.

Richard Stanford and Anna Brown: identify the staff-conduct, case-record, inspection, evidence-sharing and supervision rules in force on 9–10 August 2024, with their effective dates and relevant provisions. Was this visit a complaint investigation, a licensing visit, or both? Did those rules permit the subject of the complaint to confirm the notes and obtain wording about a private access dispute for possible court use? Who supervised or authorised that handling? Explain, against the actual correspondence, whether Henry Bexley met the applicable requirements for accuracy, objectivity, impartiality and authorised use of official information.

Why it matters: Public authority lends weight to a document. The Commission should be able to identify the standard, the checks and the responsible decision-maker behind its own officer’s account.

Will you appoint a reviewer not involved in the visit or subsequent handling, preserve the original emails, headers, notes, photographs and revisions, and compare them with the court exhibit? Identify who will test the physical chain evidence, the requested wording, the court-use proposal and the response to the complainant’s photographs. Provide the reviewer’s remit, a case reference, the findings on each allegation and any correction or remedial action. If a review is declined, identify the decision-maker, reasons and applicable route for challenge.

Why it matters: The family alleges that the handling affected an injunction and costs against Miss E. A reasoned review must trace the official account through to its practical use, not simply repeat the disputed notes.

For Judge Paul Mitchell’s strike-out hearing: where were the Bexley allegation, hooked-chain evidence, request for the complete communications and request to review the injunction determined? Was Mr Mayo required to answer the particular allegation that an apparent-locking account was manufactured for court use? If the issue was deferred, identify the direction and how it was preserved for trial. For Judge Timothy Walsh’s trial: where were those outstanding points tested and resolved, and what findings addressed their alleged effect on the injunction, costs and portrayal of Miss E? Mr J says Judge Mitchell did not put the specific manipulation allegation to Mr Mayo at the earlier hearing; Miss E’s account of the trial, relayed to Mr J, is that Judge Walsh did not do so either. Identify the hearing passages, evidence and reasons that address that account.

Why it matters: A challenge alleging that misleading official material produced a court order requires a traceable procedural outcome. The family asks what was decided, on what evidence, and why—not merely whether a hearing took place.

Your 6 August 2024 email says you could not see a current felling licence, had referred the matter to the local Woodland Officer and would provide an update after review. Identify the referral date, case reference, records and imagery passed on, who received them, and the inspection or review outcome. When and how was the promised update communicated? If the work was treated as licensed or exempt, provide the decision, relevant land and dates, and the records supporting it.

Why it matters: The original complaint and referral should lead to an identifiable review and answer. This question seeks the administrative trail connecting the family’s report to the officer’s visit.

Mr J says the photographs were supplied long before trial and presented at the strike-out hearing. Miss E’s trial account, relayed to him, is that the one-tree account and denial of commercial felling were advanced while her safety concerns were discredited. Mr J says the solicitors have not disputed that Mr Mayo made the statement. Do you dispute Miss E’s account of the words used during her cross-examination, which she says she recorded contemporaneously? Identify the hearing record supporting your position. For each representative, identify the hearings attended, the dated images and forestry allegations received, when they were received and which were reviewed. What account of the scale, purpose and traffic did you advance, and in which submissions or exhibits? What instructions and records supported that account? How did you address the apparent photographic contradiction, the reported tractor collision, the only-exit concern and the conveyance’s care obligations? If you became aware of a material inaccuracy, what correction or clarification did you place before the court, and when?

Why it matters: The family alleges that a false account displaced a genuine safety complaint. The answer must identify each representative’s knowledge and actions: what was known, what was said, and what the court was asked to do about the risk.

What evidence answered the family’s safety concerns about heavy vehicles beside Miss E’s vulnerable Grade II-listed historic home, the reported tractor collision, the only-exit risk and the conveyance’s care obligations? Identify the exhibits, dated submissions and passages where you addressed them. If her concerns were characterised as exaggerated or obstructive, identify the words used and their evidential and legal basis. What steps avoided unfair advantage of a vulnerable or unrepresented opponent and ensured an accurate account reached the court? Explain compliance with individual Code 1.2, 1.4 and 2.4 for Cornwell, and Firms Code 1.2, 1.4 and 7.1(a) for Seldons. How did you apply the disputes guidance and protect duties to the administration of justice where those duties conflicted with your client’s interests? Identify any correction made, and when.

Why it matters: The family alleges that attacks on credibility displaced examination of danger. The professional-accountability question is whether the safety evidence was fairly and accurately addressed, with a proper basis for the assertions advanced—not merely whether the client obtained the outcome sought.