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Your ref

our ref
COOPD346
31 /SGT /U72-828584 (AOC) Kennedys
Broomhay House
By DX Blackbrook Business Park
Taunton TA1 2PX
Unite.d.Kin,gdon;>
T +44 1823 692 600
Court Clerk F +44 1823 692 601
DX 97187 Taunton (Blackbrook)
Cardiff County Court
DX 99500 CARDIFF 6 www.kennedyslaw.com

Direct Dial
T +44 1823 624 396
Email
stuart.treadaway@kennedyslaw
.corn
Date
30 March 2017
, ,,, -,.,, >,,,M

Dear Sir

JONATHAN BISHOP V DR M REDDY


CLAIM NO: COOPD346

Please find enclosed an application for strike out/summary judgment, a supporting


witness statement, both in triplicate, and a cheque for the court fee.

We should be grateful if you would please issue and serve this on the claimant.

Yours faithfully

){ e11rc2cl:t3'
Kennedys

Encs.

Kennedys is a trading name of Kennedys law LLP.


Kennedys Law LLP is a limited liability partnership registered in England and Wales {with registered number 0(353214),

Kennedys offices, associations and cooperations: Auckland, Beijing, Belfast, Birmingham, Bogota, Brussels, Buenos Aires, Cambridge,
Chelmsford, Copenhagen, Dubai, Dublin, Edinburgh, Glasgow, Hong Kong, Karachi, Lima, Lisbon, London, Madrid, Manchester, Mexico
City, Miami, Moscow, Mumbai, New Delhi, Oslo, Paris, Rio de Janeiro, Santiago, Sao Paulo, Shanghai, Sheffield, Singapore, Stockholm,
Sydney, Taunton and Warsaw

A 11st of members' names is available far inspection at our registered office at 25 Fenchurch Avenue, London C3M 5AD. Kennedys Law LLP Is
authorised and regulated by the Solfcltors Regulation Authority, We use the word 'Partner' to refer to a member of Kennedys Law LLP, or an
employee or consultant who is a lawyer with equivalent standing and quaffffcatlans.

Legal\20295510, 1
N244 Name of court Claim no.
Cardiff County Court COOPD346
Application notice

For help in completing this form please read the


Fee account no. Help with Fees - Ref. no.
notes for guidance form N244Notes. (if applicable) (if applicable)

IHIWIFl-1 I I 1-1 I I I
Warrant no.
(if applicable)
Claimant's name (including ref.)
Jonathan Bishop

Defendant's name (including ref.)


Dr Mike Reddy
31 /SGT /U72-828584 (AOC)
Date 30 March 2017

1. What is your name or, if you are a legal representative, the name of your firm?
Kennedys Law LLP

2. Are you a D Claimant D Defendant 0 Legal Representative

D Other (please specify)


If you are a legal representative whom do you represent? loefendant

3. What order are you asking the court to make and why?
That the claim be struck out/sununary judgment be granted to the Defendant and the
claim be certified as totally without merit.

4. Have you attached a draft of the order you are applying for? LYes

5. How do you want to have this application dealt with? E at a hearing D without a hearing
D c1t a telephone hearing
6. How long do you think the hearing will last? 0 Hours DMinutes

Is this time estimate agreed by all parties? 0Yes E] No


7. Give details of any fixed trial date or period

8. What level of Judge does your hearing need? Circuit

9. Who should be served with this application? I Claimant


9a. Please give the service address, (other than details of the
claimant or defendant) of any party named in question 9.

N244 Application notice (06.16) Crown copyright 2016 Laserform International 6/16
Claim No COOPD346
IN THE CARDIFF COUNTY COURT

BETWEEN:
JONATHAN BISHOP
Claimant
- and-

MICHAEL REDDY
Defendant

ADDENDUM TO APPLICATION NOTICE

Introduction
I. The Defendant seeks an order that:

(I) The claim be struck out and/or the Defendant be granted summary judgment.

(2) The claim be certified as totally without merit.

(3) The Claimant pay to the Defendant the costs of this application and of the claim.

2. A draft of the order sought is appended to the application notice.

3. The Defendant seeks an order that the claim be struck out pursuant to CPR 3.4, on the
grounds that it discloses no reasonable grounds for bringing the claim and the
particulars of claim are an abuse of the Court's process and are likely to obstruct the
just disposal of the proceedings. Further or alternatively, the Defendant seeks summary
judgment on the claim pursuant to CPR 24.2, on the ground that the Claimant has no
real prospect of succeeding on the claim and there is no other compelling reason why
the case should be disposed of at trial.

4. In support of its application for strike out/summary judgment, the Defendant will rely
upon three main arguments, as follows.

I
(b) The particulars of claim are embarrassing
10. The paiticulars of claim are an abuse of the court's process because they are
embarrassing, uureasonably vague and incoherent. In particular, contraiy to CPR 16.4,
the particulars of claim do not comprise a concise and clear statement of the facts on
which the Claimant relies and it is impossible to discern what the Claimant's case is on
key elements of his claim.

(c) The claim is otherwise an abuse of process


11. The Claimant is pursuing his claim for an improper collateral purpose, in that rather
than genuinely seeking compensation for damage allegedly suffered by him, he is
seeking to use this litigation as a means by which to threaten to destroy the Defendant's
reputation "beyond repair" in order to intimidate the Defendant into withdrawing his
comments on the Claimant's application for a PhD.

Statements required by CPR PD24, paragraph 2(3) and (5)


12. This application for summary judgment is made because the Defendant believes that on
the evidence the Claimant has no real prospect of succeeding on the claim to which the
application relates and knows of no other reason why the disposal of the claim should
await trial.

13. The Claimant's attention is drawn to CPR 24.5(1), which requires that if the Claimant
wishes to rely on written evidence at the hearing of the application for summary
judgment, he must file the witness evidence and serve copies on the Defendant at least
7 days before the hearing.

3
ACrocombe
2' t Statement
Filed on behalf of the Defendant
Exhibit AC2

Claim No COOPD346
IN THE CARDIFF COUNTY COURT

BETWEEN:
JONATHAN BISHOP
Claimant
- and-

MICHAEL REDDY
Defendant

WITNESS STATEMENT OF
ANDREW CROCOMBE

I, ANDREW CROCOMBE, of Kennedys, Broomhay House, Blackbrook Business Park,


Taunton TAI 2PX, STATE as follows

1. I am a partner in Kennedys, solicitors to the Defendant, and I am the partner with


management responsibility for the Claimant's claim against the Defendant. I make this
witness statement in support of the Defendant's application to strike out the claim
and/or for summary judgment.

2. The facts stated within this witness statement are within my own knowledge and they
are true.

3. I have exhibited to this witness statement a paginated bundle of documents marked


"Exhibit AC2'' containing true copies of documents to which I refer. In this witness
statement, references in square brackets are references to page numbers of Exhibit AC2.

4. On or around 27 November 2016, Kennedys received what purported to be a "without


prejudice" letter from an organisation called Crocels News LLC, which is apparently
incorporated in Delaware in the United States [AC2, pp 1-2]. The letter threatened that,
unless the Defendant agreed to settle with the Claimant, Crocels News would publish
what purp01ied to be quotations from the Claimant. I understand that Crocels News is
under the sole direction of the Claimant (indeed the letter was signed by the Claimant
for and on behalf of Crocels News), and I took the view that the letter was a wholly
improper attempt to intimidate the Defendant under the cloak of without prejudice
conespondence. I replied to the letter (and letters before claim sent by the Claimant) on
12 December 2016 [AC2, pp 3-5).

5. On 2 March 2017, I received an e-mail from the Claimant stating that he had a number
of disabilities and as a result he wanted to serve documents electronically [AC2, pp 6].
For reasons which are unclear to me, this e-mail was also headed "without prejudice",
when it clearly was not. I replied on 3 March 2017 [AC2, pp 7], and this resulted in a
further message from the Claimant on 4 March 20 17 [AC2, pp 8], followed by a reply
from me on 7 March 2017 [AC2, pp 9]. On 7 March 2017, the Claimant e-mailed me
threatening that, if I did not observe the purported without prejudice privilege in the
conespondence, he would expose what he said was wrongful behaviour on the part of
partners at Kennedys in dealing with without prejudice communications [AC2, pp 1O].
I rejected the Claimant's threat by way of a further e-mail on 7 March 2017 [AC2, pp
11 ].

6. In response to that last e-mail, the Claimant threatened that, unless the Defendant agreed
to settle the claim, he would destroy the Defendant's reputation "beyond repair" using
his power as a member of the press [AC2, pp 12].

7. I am concerned that the Claimant's purpose in bringing the claim is not to seek
compensation from the Defendant for alleged negligent misstatement, but is part of a
campaign by the Claimant to intimidate the Defendant into withdrawing his negative
comments about the Claimant's PhD application so that the Claimant can achieve his
avowed aim of being awarded a PhD by May 2017.

3.t?..(.."?.,.'?.'?.1.:f..............................
Dated ............
IN CARDIFF COUNTY COURT Party: Defendant
Initials ft surname: A Crocombe
Claim No COOPD346 No. of statement: 2
Exhibits marked: AC2
Claimant(s) MR JONATHAN BISHOP Date made: 30.03.2017
(including ref)
(Ref: )

Defendant(s) DR MIKE REDDY


(including ref)
(Ref: 31 /SGT /U72828584 (AOC) )

EXHIBIT AC2

Page Nos Description of Document Date of Document

12 Croce ls News, LLC Letter to Kennedys 27 November 2016

3.5 Kennedys Letter to Claimant 12 December 2016

6 Claimant Email to Kennedys 2 March 2017

7 Kennedys Email to Claimant 3 March 2017

8 Claimant Email to Kennedys 4 March 2017

9 Kennedys Email to Claimant 7 March 2017 (11:18)

10 Claimant Email to Kennedys 7 March 2017 (15:48)

11 Kennedys Email to Claimant 7 March 2017 (16:02)

12 Claimant Email to Kennedys 7 March 2017 (17:01)

Legal\20289703.1
Page 1 of 1
~0C~l~ NEWS
Crocels News, LLC.
Ty Morgannwg, PO Box 674, Swansea, SA1 9NN, Wales, GB
Tel: + 1 302 394 9454 - Email: info@crocels.info - Web: http://news.crocels.com
WITHOUT PREJUDICE

27 November 2016

Kennedys LLP
Broomhay House
Blackbrook Business Park
Taunton
TA1 2PX

Dear Sirs,

Re: Defamation Act 2013 / Telecommunications Act 1996

This is to notify you that should your clients the University of South Wales, Doctor
Mike Reddy and Dr Daniel Cunliffe not agree to out of court settlements with Jonathan
Bishop then we will be running the news articles in the annex to this letter.

As you know, the Defamation Act 2013 allows Crocels News to publish accurate
reports of those proceedings. Jonathan Bishop has told us what he intends to say at
those hearings and we have agreed to publish them. As we are based in the United
States then we are protected by the Telecommunications Act 1996 and any concerns
you have must be taken up with Mx Bishop directly.

Our news is indexed by Thompson Reuters and Lexis Nexis and therefore accessible
by University of South Wales students and most major news outlets.

Yours faithfully,

Jonathan Bishop
FOR AND ON BEHALF OF CROCELS NEWS, LLC.

Registered in Delaware No. 5480920. VAT No. EU009469347. EIN No. 30-0837076

P1
Annex - WITHOUT PREJUDICE

University examiner 'stalked' student


An examiner appointed by the University of South Wales stalked a student, the
Administrative Court of Wales has been told. Councillor Jonathan Bishop alleges that
an examination report that included criticisms of him based on the examiner looking
up information about his personal and private life on the Internet amounts to an
unfair interference of his academic freedom. "Instead of just reviewing my academic
work the examiner went on my own website and then made criticisms about my
personal and professional life," Councillor Bishop said. "The report was not a fair
assessment of my work, it was a character assignation of me," he continued. "I
believe the examiner was appointed as a 'hired gun' in order to ensure I was not
awarded the qualification."

University examiner 'racist,' 'ageist' and 'classist'


An examiner appointed by the University of South Wales has been accused of 'racism,'
'ageism' and 'classism' by a higher doctoral candidate. The allegations form part of a
judicial review at the Administrative Court for Wales by Councillor Jonathan Bishop. "I
was denied a higher doctorate because the examiner was a bigot," Councillor Bishop
told the court in Cardiff. "They used my youthful age as a basis to deny me a
doctorate, said the fact I had papers at conferences held at the same time and thus
affordable was wrong, criticised me for attending conferences sponsored by British
professional bodies instead of American ones," he continued. "By accepting this report
and not giving the university watchdog the chance to investigate the University of
South Wales has acted in an unfair matter."

Gaming professor was 'negligent' in PhD assessment


A University of South Wales professor has be brought before Cardiff County Court
following a student saying that his assessment of his PhD was negligent. Doctor Mike
Reddy has been accused by Councillor Jonathan Bishop of negligence for claiming that
"augmentive technology" does not exist as a discipline and for promising to supervise
his studies in 2011, but then not doing so when given the opportunity in 2015 and
2016.

University appointed 'unfair' examiners


The University of South Wales is under fire for allegedly appointing examiners that
lacked the expertise to examine a thesis submitted to them. Councillor Jonathan
Bishop has alleged at the Administrative Court for Wales that two of the academics
who assessed his higher doctoral application did not have the appropriate expertise.
"One of the examiner's backgrounds was only incidental insofar as online communities
and e-learning and the other had no experience in IT, with only a limited background
in tort law, which was not the major aspect of my thesis," Councillor Bishop said. "I
am seeking a judicial review of the university's decision to on the one had give me
permission to go to the university watchdog and then to tell that body the degree was
not eligible, knowing I would be ineligible for a judicial review a year later when I
went to them."

Registered in Delaware No. 5480920. VAT No. EU009469347. EIN No. 30-0837076

P2
Your ref
our ref 31/SGT/072-828584 (AOC) Kennedys
-------
Broomhay House
Blackbrook Business Park
Taunton TA1 2PX
lll)~KJ."~dom __,_______

Mr Jonathan Bishop T +44 1823 692 600


Ty Morgannwg F +44 1823 692 601
PO Box 674 DX 97187 Taunton (Blackbrook)
Swansea www,kennedyslaw.com
SA1 9NN
Direct Dial
T +44 1823 624 396
-~~-~,-~~._,,.,..,.,.-,...__~--=--n-
Email
stuart, t~a5Law~@~pedy5law .corn
Date
12 December 2016 .,.. ---
Dear Sir

DR M REDDY AND DR D CUNLIFFE RE: JONATHAN BISHOP

We refer to your letter dated 18 October 2016 to Dr Mike Reddy and your letter dated
27 October 2016 to Dr Daniel Cunliffe. We also refer to a letter written by you,
purportedly on behalf of "Crocels News", dated 27 November 2016. We are instructed
by both Dr Reddy and Dr Cunliffe to respond to those letters.

The claim against Dr Reddy

Your letter to Dr Reddy purports to be a letter before claim in relation to a proposed


claim for negligent misstatement against Dr Reddy.

However, you have since informed us, fn letters written fn respect of a proposed claim
against the University of South Wales ("the University") dated 2 and 16 November 2016,
that you have already issued a claim against Dr Reddy in the county court. It is
disappointing that you have seen fit to issue a claim without waiting for a response to
your letter, and this is a matter that we shall draw to the attention of the court on the
question of costs should the need arise. Nevertheless, fn light of the fact that a claim
has now been issued, we consider that there fs little point in responding to your letter
unless and until we have been served with your claim and we have had the opportunity
to assess the exact nature of it.

Kennedys Is a trading name of Kennedys Law LLP,


Kennedys Law LLP Is a limited liability partnership registered In England and Wales (with registered number 0053214),
J(ennedys offices, a$Socia0om, and coaperatrons: Auckland, Beijing, Belfast1 Birmingham, Bogota, Brussels, Buenos Aires, Cambridge,
Chelmsford, Copenhagen, Dubai, Dublin, Edinburgh, Glasgow, Hong Kong, Karachi, Llma1 Usbon, London, Madrid, Manchester, Mexico
City, Miami, Moscow, Mumbai, New Delhi, Oslo, Paris, Rio de Janeiro, Santiago, Siio Paulo, Shanghai, Sheffield, Slngapore1 Stockholm,
Sydney, Taunton and Warsaw

A fist of members' names is available for lnspecttan at our registered office at 25 Fenchurch Avenue, London l:CJM 5AO, Kennedys Law LLP fs
authorised and regulated by the Solfcltors Regulatton Authority. We use the word 'Partner' to refer ta a member a{ Kennedys Law LLP, or an
employee or consultant who Is a lawyer with equivalent standing and quaUfft;atlons,

legal\19001685, 1

P3
Mr Jonathan Bishop
Kennedys
Accordingly, at this stage, Dr Reddy does not propose to take the action requested in
your letter.

The proposed claim against Dr Cunliffe

Your letter to Dr Cunliffe alleges that Dr Cunliffe made actionable negligent


misstatements in the context of your applications for a PhD by Publication in 2013 and
2015.

In our view, there are a number of fundamental difficulties with your proposed claim
as articulated in your letter. Most obviously, however, we consider that there is no
prospect of you demonstrating that the statements upon which you appear to rely were
made negligently.

In relation to your application for a PhD by Publication in 2013, the only comment on
that application that Dr Cunliffe made to the Graduate Research Office was in an e-
mail dated 15 October 2013, in which he merely stated that he did not wish to be
involved with your proposed PhD. As that statement reflected Dr Cunliffe's genuine
position at that time, we do not see how this statement could possibly found a claim
for negligent misstatement: the statement was entirely accurate.

In relation to your application for a PhD by Publication in 2015, you allege that Dr
Cunliffe made an inaccurate statement that he had no direct interest in the subject
matter of the proposed PhD (as reported to the Graduate Research Office in an e-mail
from Dr Reddy dated 2 September 2015). Again, however, as Dr Cunliffe's genuine
position at the time was that the subject matter was outside his direct field of interest,
it is entirely accurate and cannot found a claim for negligent misstatement.

For the avoidance of doubt, insofar as you allege that Dr Cunliffe "does not like your
autistic personality" and that he wanted to sabotage your chance of getting a PhD, this
is denied. We note that you have not referred to any evidence to support such an
allegation.

Accordingly, Dr Cunliffe does not agree to take the action requested in your letter.

The letter purportedly from Crocels News

Your letter dated 27 November 2016 purports to be from Crocels News LLC and
threatens that, unless Dr Reddy and Dr Cunliffe (and the University) agree to
compromise your claim and proposed claims, it will publish various statements
purportedly made by you. Although this letter purports to be written by you on behalf
of Crocels News LLP, it is clear to us that Crocels News is acting under your sole
direction and you are merely using it as a conduit to continue your campaign against Dr
Reddy, Dr Cunliffe and the University. Accordingly, as we have made clear to you in our
letter dated 1 December 2016 on behalf of the University, we do not propose to enter
into correspondence with Crocels News LLP separately.

L~ial\1900168S, 1 2 ofl

P4
Mr Jonathan Bishop
Kennedys

Again, as we stated in our letter dated 1 December 2016 on behalf of the University,
although the letter dated 27 November 2016 purports to be "without prejudice", we
do not consider that it is a genuine attempt to compromise proceedings, Rather, it
seems to us that it is a wholly improper attempt to intimidate Dr Reddy, Dr Cunliffe
and the University into giving into your demands under threat of what you no doubt
consider will be adverse publicity. The substance of the allegations referred to are
baseless and untrue, and we consider that your threats are improper. Accordingly, we
intend to draw the letter of 27 November 2016, and any subsequent publication of the
so-called "news items" referred to in It, to the attention of the court as further
evidence of the unreasonable approach that you have adopted in relation to Dr Reddy
and Dr Cunliffe.

Conclusion

Finally, we repeat the warnings that we have previously given on behalf of the
University. Both Dr Reddy and Dr Cunliffe will seek to recover from you their costs of
defending any claims. They will also seek to have any claims certified as totally without
merit and, in conjunction with the University, they will give consideration to seeking a
civil restraint order against you,

Yours faithfully
-,

/!A/
Kennedys

l.esul\1900168$, f 3 of)

PS
Andrew Crocombe
From: Jonathan Bishop
Sent: 02 Mar 2017 19:11
To: Andrew Crocombe
Subject: Equality Act 2010

WITHOUT PREillDICE

Dear Mr Crocombe,

I wish to serve your legal firm with an Equality Act 2010 Letter.

I have a number of disabilities that mean I need to be able to serve documents electronically.

To which address should I send this letter?

Regards,

Jonathan Bishop LLM

Jonathan Bishop
Mixter, Freeman, Councillor.
BSc(Hons), MSc, MScEcon, LLM,
FRSS, FRAI, FRSA, FlnstAM, FCLIP, FBCS,
SMIEEE, MIMarEST, MACM, MIET, MCIJ,
CITP, MarTech,
AACS.

Author of over 75 research publications.


Editor of: Examining the Concepts, Issues and Implications of Internet Trolling; Transforming Politics and Policy in the
Digital Age; Gamification for Human Factors IntegratiOn: Social, Educational and Psychological Issues; Psychological and
Social Implications Surrounding Internet and Gaming Addiction; and Didactic Strategies and Technologies for Education:
Incorporating Advancements.

Envoy6 par rnon ordinateur

This email has been scanned for viruses and malicious content by Kennedys email security service
provided by Mimecast. For more information on email security, visit http://www.mimecast.com

P6
Andrew Crocombe
From: Andrew Crocombe
Sent: 03 Mar 2017 10:02
To: 'Jonathan Bishop '
Subject: RE: Equality Act 2010 [KEN-Legal.FJD2402915]

WITHOUT PREJUDICE

Dear Mr Bishop,

Any letter can be addressed to me and I am happy to receive that electronically. I note your email is
addressed as being without prejudice. I am not clear why the request in your email or the provision of a
letter under the Equality Act should be under the cloak of privilege (as opposed to being in open
correspondence) and I would be grateful if you could clarify this point.

Yours sincerely,

Andrew Crocombe
Partner
for Kennedys

Kennedys
T +441823 624 381
M +44 7714 921 384
F +44 1823 692 601
www.kennedyslaw.com

From: Jonathan Bishop [mailto:jonathanbishop@jonathanbishop.com]


Sent: 02 March 2017 19:12
To: Andrew Crocombe <Andrew.Crocombe@kennedyslaw.com>
Subject: Equality Act 2010

WITHOUT PREJUDICE

Dear Mr Crocombe,

I wish to serve your legal firm with an Equality Act 2010 Letter.

I have a number of disabilities that mean I need to be able to serve documents electronically.

To which address should I send this letter?

Regards,

Jonathan Bishop LLM

Jonathan Bishop
Mixter, Freeman, Councillor.
BSc(Hons), MSc, MScEcon, LLM,
FRSS, FRAI, FRSA, Flns!AM, FCLIP, FBCS,
SMIEEE, MIMarEST, MACM, MIET, MCIJ,

P7
Andrew Crocombe
From: Jonathan Bishop
Sent: 04 Mar 2017 01:20
To: Andrew Crocombe
Subject: Re: Equality Act 2010 [KEN-Legal.FID2402915]

WITHOUT PREJUDICE

Dear Mr Crocombe,

It is my view that as I have disabilities that make working electronically simpler that yon should
work with me electronically.

Whenever you send correspondence to my PO Box it is scanned into electronic format for me in
any case as I cannot access it in print fonn.

Regards,

Jonathan Bishop

On 3 March 2017 at 10:02, Andrew Crocombe <Andrew.Crocombe@kennedyslaw.com> wrote:

WITHOUT PREJUDICE

Dear Mr Bishop,

Any letter can be addressed to me and I am happy to receive that electronically. I note your email is
addressed as being without prejudice. I am not clear why the request in your email or the provision of
a letter under the Equality Act should be under the cloak of privilege (as opposed to being in open
correspondence) and I would be grateful if you could clarify this point.

Yours sincerely,

Andrew Crocombe
Partner
for Kennedys

Kennedys
T +44 1823 624 381
M +44 7714 921 384
F +44 1823 692 601
www.kennedyslaw.com

From: Jonathan Bishop [mailto:ionathanbishop@ionathanbishop.com]


Sent: 02 March 2017 19:12

PB
Andrew Crocombe
From: Andrew Crocombe
Sent: 07 Mar 2017 11:18
To: 'Jonathan Bishop'
Cc: Stuart Treadaway
Subject: RE: Equality Act 2010 [KEN-Legal.FID2402915]

Dear Mx Bishop,

Thank you for your email. I am treating this chain of emails as being open as there is nothing contained
within your emails to which privilege could possibly attach.

We are happy to send you letters and documents (including service of Court Documents) to you
electronically (i.e. by email using your email address jonathanbishop@jonathanbishop.com) and to
receive correspondence and documents (including service of Court Documents) from you also. However,
in respect of the service of Court Documents by you, those documents must be served only using the
email address andrew.crocombe@kennedyslaw.com and on the basis that you agree that service is
deemed effective on the next business day after the email was sent.

Yours sincerely,

Andrew Crocombe
Partner
for Kennedys

Kennedys
T +44 1823 624 381
M +44 7714 921 384
F +44 1823 692 601
www.kennedyslaw.com

From: Jonathan Bishop [mailto:jonathanbishop@jonathanbishop.com]


Sent: 04 March 2017 01:20
To: Andrew Crocombe <Andrew.Crocombe@kennedyslaw.com>
Subject: Re: Equality Act 2010 [KEN-Legal.FID2402915]

WITHOUT PREJUDICE

Dear Mr Crocombe,

It is my view that as I have disabilities that make working electronically simpler that you should
work with me electronically.

Whenever you send correspondence to my PO Box it is scanned into electronic format for me in
any case as I cannot access it in print fonn.

Regards,

Jonathan Bishop

On 3 March 2017 at 10:02, Andrew Crocombe <Andrew. Crocombe@kennedyslaw .corn> wrote:

WITHOUT PREJUDICE

Dear Mr Bishop,
pg
Andrew Crocombe
From: Jonathan Bishop
Sent: 07 Mar 2017 15:48
To: Andrew Crocombe
Cc: Stuart Treadaway
Subject: Re: Equality Act 2010 [KEN-Legal.FID2402915]

WITHOUT PREWDICE

Dear Mr Crocombe,

You can treat this chain of emails that way if you wish, but the consequences would be that I would
tell the whole world that I have evidence of on at least two occasions a paiiner at Kennedys
Solicitors not honouring the "without prejudice" convention and that in my honest opinion this
means that no one should trust them to handle connnunications confidentially.

You would have no claim against me for serious financial loss if that were to occur, because what I
would say would be truth and honest opinion.

I'm happy for documents served on your electronically to be treated as served the day after they
were emailed.

Regards,

Jonathan Bishop LLM

On 7 March 2017 at 11: 18, Andrew Crocombe <Andrew.Crocombe@keunedyslaw.com> wrote:

Dear Mx Bishop,

Thank you for your email. I am treating this chain of emails as being open as there is nothing contained
within your emails to which privilege could possibly attach.

We are happy to send you letters and documents (including service of Court Documents) to you
electronically (i.e. by email using your email address jonathanbishop@jonathanbishop.com) and to
receive correspondence and documents (including service of Court Documents) from you also.
However, in respect of the service of Court Documents by you, those documents must be served only
using the email address andrew.crocombe@kennedyslaw.com and on the basis that you agree that
service is deemed effective on the next business day after the email was sent.

Yours sincerely,

Andrew Crocombe
Partner
for Kennedys

P10
Andrew Crocombe
From: Andrew Crocombe
Sent: 07 Mar 2017 16:02
To: 'Jonathan Bishop '
Cc: Stuart Treadaway
Subject: RE: Equality Act 2010 [KEN-Legal.FID2402915]

Dear Mx Bishop,

Thank you for your confirmation provided in the 3rd paragraph of your letter.

If you can explain to me on what basis the communications you have sent to me attract 'without
prejudice' privilege then I will consider that point. To assist, I paste below the Practical Law note on WP
communications which explains when the rule is engaged.

The without prejudice (WP) rule will generally prevent statements made in a genuine
attempt to settle an existing dispute, whether made in writing or orally, from being put
before the court as evidence of admissions against the interest of the party which made
them. One reason for having the WP rule is the public policy of encouraging parties (or
potential parties) to litigation to settle their disputes out of court. The rationale is that
settlement discussions (and, it is hoped, settlement itself) will be facilitated if parties are
able to speak freely, secure in the knowledge that what they have said and, in particular,
any admissions which they might have made to try to settle the matter, may not be used
against them should the settlement discussions fail. The inclusion of the words "without
prejudice" will not necessarily bring the communication within the ambit of WP privilege if
it is not, in substance, a communication made in a genuine attempt to settle an existing
dispute.

So far as I can tell, none of the emails you have sent to me in the chain below would fall within the scope
of the rule. Your threat to impugn my and/or my firms professionalism is noted but, with respect, any
such action would be wholly misguided.

Yours sincerely.

Andrew Crocombe
Partner
for Kennedys

Kennedys
T +441823 624 381
M +44 7714 921 384
F +44 1823 692 601
www. kennedyslaw .corn

From: Jonathan Bishop [mailto:jonathanbishop@jonathanbishop.com]


Sent: 07 March 2017 15:48
To: Andrew Crocombe <Andrew.Crocombe@kennedyslaw.com>
Cc: Stuart Treadaway <Stuart.Treadaway@kennedyslaw.com>
Subject: Re: Equality Act 2010 [KEN-Legal.FID2402915]

WITHOUT PREWDICE

Dear Mr Crocombe,
P11
Andrew Crocombe
From: Jonathan Bishop
Sent: 07 Mar 2017 17:01
To: Andrew Crocombe
Cc: Stuart Treadaway
Subject: Re: Equality Act 2010 [KEN-Legal.FID2402915)

WITHOUT PRElliDICE,

Dear Mr Crocombe,

From my point of view, attempting to resolve disability discrimination with you without prejudice
falls within that definition, as does asking your clients to settle in order to avoid me using the only
power I have over them which is as a member of the press, when it is them that has all the power to
stop me getting a PhD even though I am a more accomplished at research than them so they have
no credibility in attacking me in order to prevent me getting the title Dr before my name and/or
PhD after it.

Doctor Reddy for instance has less than 20 publications and less than 100 citations whereas I have
over 100 publications and over I OOO citations. I don't think Doctor Reddy has any credibility to
criticise my work when he is far less accomplished than me. All the criticisms he makes of my
application apply to his PhD.

Each hearing I am made to attend due to Doctor Reddy not settling will result in further press
coverage, so it would be best for all if he signed a consent order that I would withdraw the claim
and he would withdraw his criticisms.

IfI destroy Doctor Reddy's reputation beyond repair through my power as a member of the press,
then that is his problem for going to a protracted Part 7 Claim rather than a speedy Part 8 Claim,
which have only come about through him abusing his power over me by preventing me from
getting a PhD.

Regards,

Jonathan Bishop LLM

On 7 March 2017 at 16:02, Andrew Crocombe <Andrew.Crocombe@kennedyslaw.com> wrote:

Dear Mx Bishop,

Thank you for your confirmation provided in the 3rd paragraph of your letter.

If you can explain to me on what basis the communications you have sent to me attract 'without
prejudice' privilege then I will consider that point. To assist, I paste below the Practical Law note on
WP communications which explains when the rule is engaged.

The without prejudice (WP) rule will generally prevent statements made in a genuine
attempt to settle an existing dispute, whether made in writing or orally, from being put
P12