"
In the High Court of Justice
1978 T No. 1641
Queen's Bench Division
Master
The Honorable Master Elton
Between Feng-ming TUNG (Thomas)
Plaintiff
and
Dr. David Owen and
Lord Goronwy Roberts
Defendants
Re: Concerning the attendance in Master's Chambers, in Room No. 110 at the Central Office, Royal Courts of Justice, Strand, Lon- don, on 18th day of June, 1979 at 10:30 a.m. on the hearing of an application on the part of the Defendants for an Order that the Plaintiff's Statement of Claim be struck out under Rules of the Supreme Court Order 18 Rule 19 and etc., the Plaintiff veri- ly and solemnly beg an application to this honorable Court for a ruling or an order on this same day, the 18th day of June, 1979, to dismiss or to strike out the above-mentioned applica- tion of the Defendants on the following grounds that:- (1) Plaintiff has very, very superbly reasonable cause of act- ion against the Defendants.
(2) This defamatory letter is a glaringly clear-cut and clean- cut prima facie nage of libe) por go. The Derendants have no right to apply for an Order that the Plaintiff's Statement of Claim be struck out and that the Plaintiff's action against the Defendants be dismissed and that the Defendants be at liberty to enter Judgment for their costs under the cloak of Rules of the Supreme Court Order 18 Rule 19 and under the inherent juri- sdiction on the grounds (1) and (2) which are apparently not applicable to a glaringly clear-cut and clean-cut prima facie case of libel per se in order to enable the Defendants to abuse the process of the Court, to delay the legal proceedings of the law, to avoid the answerings of the charges of Statement of the Claim and to evade the open Court trial.
(3) Plaintiff is not suing the British Government, nor suing the two Defendants, David Owen and Goronwy Roberts, as the Mini- -sters of the Crown. Plaintiff is suing the two Defendants, Mr. David Owen and ir. Goronwy Roberts, as two private and per- sonal individuals for their private and personal act in committ- ing a criminal offence of criminal libel per se by writing a private and personal letter in deliberate falsification of a record of phoney self-admission by way of phoney self-confession and phoney self-incrimination of a crime which is non-existing in the name of plaintiff without the knowledge and authorization of the plaintiff with the malicious intention purporting to be the official record undetected to banboozle the unsuspecting Parliament Members like Mr. Christopher Price into misunderstand- ing of the good character of the Plaintiff against the contents of their official letter of Foreign and Commonwealth Office of the 20th September, 1977. written by M.J.Upton, Hongkong Department. (4) As Plaintiff is not a lawyer and there is no lawyer to read and correct the defective areas of the Statement of Claim, so from the very beginning, Plaintiff has sincerely and frankly told the lawyer of Defendants, Mr. D.A. Watson that Plaintiff is willing to delete and amend any part of the Statement of Claim, if there is any word, sentence or paragraph which appears to his Honour as redundant or embarassing. Plaintiff has never seen an example of a British lawyer-written Statement of Claim. It is only after Plaintiff has received the Writ of Summons that the Plaintiff begins to know that there is a book called Supreme
LEONJA L. SAGASTA Notary Public, State of New York No. 31 8738165
Qualified in New York County
Commission Expires March 30, 1980
No comments yet.
Private notes are available after approval.