The following Formal Complaint was filed to the Appeal court in London and to the JCIO against Deputy Master Linwood for false statement regarding perjury evidence.
DEPUTY MASTER LINWOOD EXPRESSLY LIED AND MADE A FALSE STATEMENT IN COURT JUDGMENT TO COVER UP EVIDENCE OF PERJURY BY THE DEFENDANTS' WITNESS AND TO CREATE A FALSE REASON TO STRIKE OUT THE CLAIMANT'S CLAIM IN THE CASE BUMP v WIGGIN LLP, FOX WILLIAMS LLP.
At PARAGRAPH 85 of the transcript of his oral judgment Deputy Master Linwood lied about evidence of perjury by Wiggin's witness and stated: "There is no evidence before me which gets even near supporting these very serious allegations against Mr Millgårdh”. However he knew that BUMP put before him following evidence of perjury on page 2 of its Exhibit DB:
1) Written witness statement of 30 September 2016, paragraph 6, in which Wiggin’s key witness Millgardh provided following false statement to support Wiggin’s strike out application: “The show called "Minute Winner" was not presented at this meeting. If any other ideas had been presented I would have made notes of them. The conversation was only about the NDA and "Celebrity Birthday””. However, in the following evidence which BUMP also put before Deputy Master Linwood,
2) Email of 5 September 2011, Millgårdh himself and his CEO contradict Millgårdh’s witness statement of 30 September 2016 and cite not one but several TV show ideas which they recalled BUMP presented to Millgårdh and his colleague Mattias Olsson at the meeting they held with BUMP in Stockholm: “Thank you for your email. I have just talked to Jock and Mattias. When you met with them you presented Singing Mother, Singing brother and sister, Language school, Foreign eyes foreign lenses and Colonies. ... Best regards, Estelle”.
And BUMP also put following evidence before Deputy Master Linwood,
3) Written witness statement of 18 December 2015 on page 10 Exhibit DB in which Mr M. L. who was also present at that meeting in Stockholm between BUMP and Friday TV confirmed that BUMP presented a total of nine TV show ideas to Millgårdh and Olsson, including “Celebrity Birthday”, “Minute Winner - You got one minute to win it”, etc. All of the above was proof before Deputy Master Linwood that Millgårdh committed FRAUD and PERJURY when he LIED UNDER OATH that BUMP presented ONLY one idea, "Celebrity Birthday". Therefore, for the judge, Deputy Master Linwood, to lie in court judgment that “There is no evidence before me which gets even near supporting these very serious allegations against Mr Millgårdh...” is COMPLETELY DECEITFUL and cause of Wrongful Decision. Defendants Wiggin LLP and Fox Williams LLP can corroborate the fact that Deputy Master Linwood's declaration is a lie, because they put the bundle of documents before Deputy Master Linwood for the hearing of their strike out application, including the perjury evidence.
Deputy Master Linwood's entire court decision of 23 February 2024 is heavily geared towards protecting law firms Wiggin LLP and Fox Williams LLP against the Claimant's compelling evidence while undermining the Claimant's claim against the two law firms and attempting to discredit the Claimant, a black minority company.
BUMP has requested an investigation of Deputy Master Linwood’s conduct and appropriate sanctions.
FORMAL COMPLAINT
JUDICIAL CONDUCT INVESTIGATIONS OFFICE
5 April 2024
Regarding court Case No: CH-2024-000061
Before the APPEAL COURT - IN THE HIGH COURT OF JUSTICE
BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES
BUSINESS LIST
BETWEEN:
BANNER UNIVERSAL MOTION PICTURES LIMITED / BUMP
Appellant
-and-
(1) WIGGIN LLP
(2) FOX WILLIAMS LLP
Respondents
__________________________________________________________
COMPLAINT AGAINST DEPUTY MASTER LINWOOD FOR
FALSE STATEMENT IN COURT DECISION REGARDING PERJURY EVIDENCE
__________________________________________________________
Dear Sir / Madam,
I am Derek Banner, and I am the Appellant’s founder and director, and representative of the Appellant in the above claim.
I am filing this formal complaint against Deputy Master Linwood for his demonstrably false and UNTRUE statement in his oral judgement of 23 February 2024, a false, completely untrue, statement which the Appellant fears was made with the purpose to cover up fraud and perjury by Defendant Wiggin LLP’s witness, Jock Millgårdh.
Deputy Master Linwood presided over the case in lower court, case number BL-2023-001403, which was initially assigned to Master McQuail but Deputy Master Linwood took over for unknown reason. And although the Appellant has also addressed Deputy Master Linwood’s false statement in its Skeleton Argument of 2 April 2024 filed to the Appeal court, the Appellant finds that it is also important to submit this formal complaint since Deputy Master Linwood’s untrue statement was material to the court’s decision of 23 February 2024.
- At PARAGRAPH 85 of the approved transcript of his oral judgment of 23 February 2024, Deputy Master Linwood made the following statement / conclusion:
“In particular, he (referring to me, the Appellant’s representative) repeats allegations that Mr Jock Millgårdh of Friday TV perjured himself –“,
and he further concluded
"... There is no evidence before me which gets even near supporting these very serious allegations against Mr Millgårdh, …”.
- Deputy Master Linwood knew well that following evidence of perjury was submitted to the court and put before him by the Claimant / Appellant on page 2 of the Appellant’s Exhibit DB, (also on page 212 of Exhibit DB):
- A Written witness statement of 30 September 2016, paragraph 6, in which Mr Jock Millgårdh, who was Defendant Wiggin’s key witness, issued following false statement to the court to support Wiggin’s strike out and/or summary judgment application:
“The show called "Minute Winner" was not presented at this meeting. If any other ideas had been presented I would have made notes of them. The conversation was only about the NDA and "Celebrity Birthday””,
and following evidence
- An Email of 5 September 2011, in which Mr Jock Millgårdh himself and his CEO contradicted Mr Millgårdh’s above witness statement of 30 September 2016 and they cited not one but several TV show ideas which, according to themselves, I pitched and presented to Mr Jock Millgårdh and his colleague Mattias Olsson at the meeting I held with them in Stockholm:
“Dear Derek, Thank you for your email. I have just talked to Jock and Mattias. When you met with them you presented Singing Mother, Singing brother and sister, Language school, Foreign eves foreign lenses and Colonies. The only idea we continued talking to you about was Language school but also that idea we didn't move on with as you might remember. Best regards, Estelle”,
and following evidence
- A Written witness statement of 18 December 2015 on page 10 Exhibit DB, in which Mr (M. L.) , who was also present at that meeting in Stockholm, recalled that I pitched and presented a total of nine TV show ideas to Mr Millgårdh and Mr Mattias Olsson, including “Celebrity Birthday”, “Minute Winner - You got one minute to win it”, etc,
and also the fact that - “Celebrity Birthday” which Mr Jock Millgårdh alleged in his witness statement to the court was the only idea I presented to them at that meeting in Stockholm was not even mentioned in their email response of 5 September 2011 was further evidence before Deputy Master Linwood that Mr Millgardh was deceitful in his witness statement to the court in 2016, and the “Minute Winner” NDA which I submitted at the pitch-meeting showed the date of the meeting, full name of Mr Jock Millgårdh, and the full address of his company Friday TV, which were all proof that the document and TV show idea “Minute Winner” was also among the nine ideas I presented at that meeting.
- All of the above was put before Deputy Master Linwood and showed beyond a reasonable doubt that Mr Jock Millgårdh committed FRAUD and PERJURY when he LIED UNDER OATH to the court that I presented to him and his colleague ONLY one idea at our meeting in Stockholm, “Celebrity Birthday”.
- I also submitted the above on page 48 paragraphs 226 and 227 of my written witness statement of 18 December 2023 and I wrote specifically, “I also draw the court’s attention to the evidence of perjury in the written witness statement issued by Wiggin’s key witness Jock Millgårdh and which Wiggin and Ms Kean submitted to the court in 2016. This evidence has not been disputed by Wiggin, by Browne Jacobson, or by Ms Kean in her written statement of 30 November 2023 provided to this court. …Mr Millgardh’s perjury also gives grounds for setting aside the court decision of 19 October 2017”.
- Therefore, for the judge, Deputy Master Linwood, to lie and conclude in his judgment that “There is no evidence before me which gets even near supporting these very serious allegations against Mr Millgårdh...” is COMPLETELY DECEITFUL and cause of Wrongful Decision.
- The Defendants, Wiggin LLP and Fox Williams LLP, had the responsibility to provide to the court the bundle of documents for the hearing of 16 February 2024 with regard to their strike out and/or summary judgment application and therefore they can also corroborate the fact that Deputy Master Linwood’s conclusion in his judgment that “There is no evidence before me which gets even near supporting these very serious allegations against Mr Millgårdh…" is totally false.
- On the basis of the above, the Appellant hereby requests that the Judicial Conduct Investigations Office investigate Deputy Master Linwood’s conduct and issue appropriate sanctions.
STATEMENT OF TRUTH
The Appellant believes that the facts stated in this document are true and understands that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
Signed ............................................... Date: 5 April 2024
Full Name: DEREK BANNER Position: Appellant’s Founder and Director
PERJURY EVIDENCE PUT BEFORE DEPUTY MASTER LINWOOD
EMAIL OF 5 SEPTEMBER 2011
WITNESS STATEMENT OF 30 SEPTEMBER 2016
