Refer to

The defendant’s response

DEVONSHIRES SOLICITORS LLP has rejected the claim.

Their defence

Why they disagree with the claim

Claim: 566MC567 and Claim: 570MC618 Mevelee Myers V Devonshires Solicitors The Defendant applies to have the following claims struck out in their entirety pursuant to CPR 3.4 (2)(a) – (c): 1. 566MC567 (1st Claim) 2. 570MC618 (2nd Claim) Together (the Claims). For clarity, the Defendant wishes to make it clear that, in accordance with CPR 3.4(7), it is has not filed Defences to either of the Claims as it is applying to strike them both out. MM Response: The Defendant did not file any response because they are in CONFUSION about how swiftly the Claimant is acting against their UNPROFESSIONAL CONDUCTS targeting VULNERABLE TENANS on behalf of their client Housing for Women. Background Both the 1st and 2nd Claim were issued by the Claimant via the Online Civil Money Claims Pilot (the Pilot) on 27 August 2024 and 6 September 2024 respectively. The 1st Claim was transferred by the Court of its own volition out of the Pilot to Mayor’s & City County Court on 23 September 2024 together with another claim (Claim No. 567MC716) the Claimant made via the Pilot but against a different defendant that is not the Defendant. The Court stated they were transferring these Claims out of the Pilot as they included allegations of ‘defamation’ and because Mayors & City was the Defendant’s local court. Upon being informed by the Court of the transfer of the 1st Claim, the Defendant wrote to the Court on 25 September 2024 and 26 September 2024 to request that the 2nd Claim also be transferred to the Mayors & City County Court to be heard together with the 1st Claim as the 2nd Claim is near-identical in form and content to the 1st Claim. The Defendant is awaiting confirmation that the 2nd Claim has been transferred to the Mayors & City County Court but applies now for both claims to be struck out. MM Response: I am putting on record the fact that District Judge Sterlini who labelled me a “VIOLENT NUISANCE” on 1st August 2023 was involved in the strike out of my claims against Winsome Duncan who stole my manuscript for IN HONOUR OF STRONG WOMEN EVERYWHERE with DJ Zimmel and Rand after reaching “Telephone Conciliation“. Devonshires is seeking that both the Claimant’s Claims are struck out in their entirety under CPR 3.4. Application to strike out Claims The Claimant’s Claims were brought improperly via the Pilot, disclose no reasonable grounds for bringing the Claims and have no merit as they fail to coherently or properly plead any genuine cause of action. MM Response: Must make the Court aware that District Judge Bell sent 7 cases from Clerkenwell and Shoreditch County Court including Barrister Ryan Clement judgement passed for him to pay me £9,455.00. I was not paid and 4 years later Court Enforcement Services LTD contacting me about payments for judgement I did not get my money. Further, the allegations contained therein are spurious and entirely unparticularised. Devonshires denies that it is liable to the Claimant for damages as claimed or at all. The Claims are an abuse of the court’s process given that it appears the Claimant is claiming damages relating to the fact that Devonshires have acted and continue to act for their client, Housing for Women (“H4W”), in relation to on-going injunctive committal (Claim No. K02CL827) and possession proceedings (Claim No. K05EC530) brought against the Claimant in the Clerkenwell & Shoreditch County Court. MM Response: When the facts are revealed about the role of Devonshires Solicitors LLP in the cases of Ms H. Presley and Mervelee Myers the world will be watching. Devonshires need to find out about Mervelee Myers contributions to “British Values” and whose photo was portrayed across ITV News for Windrush 70 ahead of Prime Minister Theresa May. Before DEFAMATION of my NAME and CHARACTER any further. Therefore, the actions the Claimant is complaining of are those of a firm of solicitors bringing entirely legitimate claims against her on behalf of their client. MM Response: No, this is/was not a legitimate claim and the world knows this to be a lie. Including my MP Neil Coyle and the Housing Ombudsman Service Richard Blakeway. If in doubt reference Complaints 2022000052 after which my data was removed from the Customer Panel. I had to do another complaint 2024000031 which was not upheld because by then Devonshires Solicitors LLP sent me POSSESSION letter in July 2023 on behalf of H4W. An injunction order was made against the Claimant on 1 August 2023 in Claim No. K02CL827, for the period of a year (“the Injunction”) in relation to proven incidents of anti-social behaviour, including incidents whereby the Claimant committed incidents of anti-social behaviour against members of both H4W staff and Devonshires staff. MM Response: This is where the DEFAMATION is applicable and Social Media will be my source of evidence leading up to the 1st of August 2023 when that INJUNCTION was issued by DJ Sterlini. The Reasonable Adjustment prepared by Trina Philbert in the BUNDLE is source of proof about Defendant’s depravity acting for H4W against tenants who raised concerns about our homes when asked via SURVEYS. The Claimant breached the Injunction order dated 01 August 2023 on multiple occasions in August 2023 and committal proceedings for contempt of court were subsequently brought against her on 31 August 2023. MM Response: There should be no INJUNCTION ORDER if the DEFENDANT had accepted my attempt at MEDIATION when I called to discuss the matter on receiving the letter from Narin Masera in July. Please check what was happening to me in July 2023. Then check my engagement with the Metropolitan Police at Elim House to meeting Sir Mark Rowley at the launch of “A New Met for London” on 2nd September 2023 where I was recorded asking to VOLUNTEER. He signed IN HONOUR OF STRONG WOMEN EVERYWHERE dedicated to a #Strong #Jamaican #woman. The committal hearing duly took place on 12 June 2024 at which the Claimant admitted breaching the terms of the Injunction and all the allegations against her contained in the contempt application. MM Response: The Court will have to take some RELEVANT factors relating to my Mental and Physical Impairments on board by H4W releasing my DATA wiped from the Customer Portal about who is guilty of ASB. Reference letter dated April 2019 detailing what the neighbour did to me and my husband from the time I moved to 16 Alma Grove December 2000. A copy of the order dated 12 June 2024 is enclosed. The is my source of proof. MM Response: My source of proof is linked to the Metropolitan Police handling of Concerns raised and their response from the 30th October 2017 to 9 August 2024. During that period attempts made to #section #murder #kidnap me. I was even beaten in my home on 30th November 2020 under cover of http://www.leyf.org.uk Margaret Horn Lecture by Holly Sweeney P255654 and Nikki Wright P240060 and Harry Stack P255641 and Ben Godfrey P255842. Claimant is therefore now awaiting sentencing for the same and the sentencing hearing has been scheduled to take place on 20 January 2025. MM Response: Since the Court failed to use any of the evidence provided after DJ Sterlini 2nd miscarriages of justice labelling me a VIOLENT NUISANCE during the time I was experiencin a personal CRISIS along with bereavement and losses I ask that the court take https://www.gov.uk/employment-tribunal-decisions/ms-m-myers-v-london-early-years-foundation-2300047-2016 into consideration as RELEVANT. Given that the Claimant’s Claims are vexatious and spurious, the Defendant considers that they also amount to further breaches of the injunction order dated 01 August 2023 granted to H4W against the Claimant which prohibits her from causing a nuisance, annoyance or distress, towards any member, employee, consultant, or agent of Devonshires or harassing or attempting to harass any of the above. MM Response: Is the Defendant hereby saying that the COURT in issuing my CLAIMS and allowing the Requested Judgement breaches of the IINJUNCTION that is open to SCRUTINY about the way it was obtained by failing to stop the NEIGHBOUR and others from TERRORISING me? Why did H4W failed to respond to any of the claims that were issued? The Claimant’s claims have caused a nuisance and annoyance to Devonshires as well staff members expressly named within the Claims, who are merely carrying out the requirements of their employment. MM Response: Is the Defendant aware of Complaint 20240000274 prepare by H4W staff for failures by their Contractor MCP. MCP was supposed to visit my home to carry out repairs on the toilet that was installed after a request was made. They have changed the appointment to 2/10/2024. My visitor and I are using the toilet without any seat. The water is not filling up so we have to catch water in container to flush the toilet when we use it. But to make matters worse both my visitor and I were left TRAUMATISED when her phone fell in the bowl. I had to borrow money to get the phone fixed at the shop. Further, a claim for possession was also issued by Devonshires on behalf of H4W against the Claimant on 7 November 2023 in relation to breaches of tenancy and/or anti-social behaviour. MM Response: The role of the Metropolitan Police will be considered by the Court as ROBERT.Lewsley@met.police.uk on behalf of DPSMailbox-.CRUTeam1@met is dealing the matter of HATE CRIMES by the Police. Let me put on record that Narin Masera on the advice of Stephen Agera who she coerced sent Police to my home on the 25th October 2023. Luckily I reached home from Tony Cealy Augusto Boal’s Theatre Of the Oppressed training to take husband out of the HYPO he was left in when a letter was delivered. My husband and I were robbed in Peckham PC/08721/24 for 3034363/24. I am still waiting for resolution. The claim for possession as originally issued relied on grounds 12 and 14 of Schedule 2 of the Housing Act 1988 and, following the committal hearing on 12 June 2024 and the finding of breach of the Injunction order, the claim was amended to include ground 7A, which is a mandatory ground for possession. MM Response: This will depend on the failures of H4W to address the concerns raised and Housing Ombudsman Service managing the COMPLAINTS. I was a member of the H4W Customer Scrutiny Panel as the minute taker in 2019. I am a member of the HOS Resident Panel. The possession hearing is scheduled to take place on 13 December 2024 and H4W expects to obtain an outright possession order against the Claimant at the same. MM Response: Can the Court consider Ms. H. Presley who has found herself a victim of H4W and the Defendant and bring her Case as evidence with mine, please. Proof that the Defendant is targeting VULNERABLE TENANTS for raising concerns. The Housing Department is recruiting volunteers from the HOS Resident Panel for RESEARCH into how Landlords communicate with tenants and empowering tenants to raise concerns. Given the facts that (i) the Court has made findings of fact that the Claimant engaged in anti-social behaviour when making the Injunction and (ii) she has admitted to multiple breaches of the Injunction, it is clear that H4W have acted entirely appropriately by issuing injunctive, committal and possession proceedings against her and, by extension, Devonshires have acted entirely appropriately by acting for H4W in those proceedings. MM Response: My “Experience of Multiple Discrimination” finding as a participant in Dr. Maria Hudson research paper recommended to ACAS made me the ideal tenant to shed light on how H4W coerced my neighbour to target me after the 13th December 2021 when she broke the glass to the communal door. The Court will have to accept that whatever ASB I was asked to accept were precepted by the need to SAFEGUARD my elderly husband who was TRAUMATISED at this point of TRANSITION in his life. The court refused to accept any of the argument that any ASB on my part was because of how the neighbour started MISTREATING us after Samantha Gibbs and Trina Philbert started working for H4W. Accordingly, it is our position that the Claimant’s claims disclose no reasonable grounds for bringing the same, have no merit and/or are an abuse of process and should accordingly be struck out forthwith. MM Response: The Defendant is the one abusing the system using my VULNERABILITY against me. Devonshires wrote to the Claimant on 12 September 2024, encouraging her to withdraw the 1st Claim. MM Response: This is another Barrister Samantha Jones case who took out ECRO against me after using a CONMAN John Fenton to represent LEYF as if he was a lawyer. I have the names of those involved to make public. A copy of the same is enclosed with this application for the Court’s information. MM Response: This is just another case of UNPROFESSIONAL CONDUCT like the judge who tried to trick me to take LEYF £58,000.00 NDA knowing I would be taking it in one hand and handing it back with the next. The Claimant responded with the attached emails dated 19 and 20 September 2024, indicating that she had no intention to withdraw the claim. MM Response: The Defendant in acting UNPROFESSIONALLY from the time I phoned Narin Masera to mediate and continued with the DEFAMATION will have to understand why I invested in https://fight4justiceadvocacy.business.site to share stories of cases like H4W. Devonshires subsequently were served with the 2nd Claim. In light of the above, Devonshires respectfully requests the Court to strike out both the Claimant’s claims in their entirety. Application for Civil Restraint Order Further, Devonshires also requests that the Court make a civil restraint order against the Claimant under CPR 3.4 (3), 3.3 (9), 3.4 (6) and 23.12 in order to restrict her from being able to bring any such further claims against Devonshires without the permission of the court. MM Response: I have already address the RESTRAINT ORDER by Barrister Samantha Jones and repeat that I have not received the judgement from Barrister Ryan Clement. Devonshires aver that the history of the Claimant’s conduct to date makes it abundantly clear that she will continue to act as she has done to date by issuing further, vexatious and entirely unmeritorious claims against Devonshires and their staff unless she is formally restrained from doing so. MM Response: Once more I will bring to the Court’s attention the DEFAMATION by the Defendant. Let me know which JUDGE will perform the request by the Defendant to check if they are listed amongst those involved in the miscarriages of justice against me from Kings College Hospital NHS Foundation Trust 2003-2008 and the NEGLECT of my husband and ASSAULT of MM in April 2024. This will make headline news in the wake of Black History Month and Windrush Scandal and MM preventing a Grenfell at Alma Grove. Barrister Samantha Jones bragging to Michael Carter of BSB she was given a reference to be on the Grenfell Tower Inquiry Panel. Transfer to Clerkenwell & Shoreditch Country Court for consideration of applications. Lastly, the Defendant respectfully suggests that the Court may consider transferring the Claims to the Clerkenwell & Shoreditch County Court so that the applications laid out in this notice can be heard together with the possession claim (Claim No. K05EC530) at the listed hearing on 13 December 2024. District Judge Beecham sitting at Clerkenwell & Shoreditch County Court has reserved both the possession claim and the sentencing hearing for the committal application to herself so already has knowledge of this matter and the Defendant would aver that it makes practical sense for one Judge who has knowledge of this matter to hear all of the matters together.

Their evidence

Full response

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