TNAG-0914-FCO40-1124-Allegations-of-bribery-and-corruption-in-Hong-Kong-1979 — Page 16

FCO40 Hong Kong Department Records 聯邦事務部香港部檔案 All

name, this is very unfair and unjust to all parties concerned. (13) The two defendants illegally plagiarize the perjury words of the perjury witnesses by artful insertion and by artful sub- stution of the untrue facts for the complaint of the plaintiff by artful excision, artful omission, artful concealment and art- ful distortion of the true facts of the complaint of the plain- tiff in a secret and insidious way without the knowledge of the plaintiff. The two defendants act as a lawyer on behalf of the disqualified magistrate by performing an ilegal maneuver to make the disqualified magistrate Lo Hinshing look like a bona fide magistrate by making the victim plaintiff look like a guilty man under the investigation. It is very unfair and unjust to let the defendants evade an open court trial without giving the victim plaintiff a chance to clear up the name under the cloak of Supreme Court Order 18 Rule 19.

(14) The defendants' application is a maneuver to bully plaintiff in exloitation of his no-lawyer situation in order to evade an open court trial under the cloak of Supreme Court Order 18 Rule 19. It is unfair and unjust to allow defendants escape by artifice. (15)The right to an open court trial is is a fundamental human right. If the court let defendants escape by artifice, it means to deprive plaintiff of his human right to put up a defence. (16)If defendants could escape by illegal artifice an open court trial, it means that the Court has validated the lying words of of perjury witnesses illegally plagiarized by the defendants as true record which would continually smear the good reputation of plaintiff. How unfair and unjust it would be!

17)If defendants could escape the liability to stand an open court trial, it means that the court has legalized the illegal libel of defendants into a legal official record of true facts to smear permanently the good reputation of plaintiff. How unfair and un- just it would be!

(18) The mere fact that the defendants have persistently refused to disclose the basis of their libel in answer to the precise and specific charges made by the plaintiff is a cogent evidence of the acceptance of their guilt. How could defendants abuse the Supreme Court Order 18 Rule 19 to escape an open court trial by illegal artifice of such an application. It is unfair and unjust. 19)In a highly civilized London society, a powerful high ranking officer and a low ranking education officer should be treated on equal footing before the law. If a powerful high ranking officer could escape and evade an open court trial by abusing the Supreme Court Order 18 Rule 19, then there is no equal footing before the law. How unfair and unjust it would be!

(20) The two defendants are trying to utilize the term "power politics" to create a 'power law" instead of "legal reasoning" by using such high sounding phrase "Minister of, the Crown" in order to bully the plaintiff and to overpower the Court in their favour for evading an open court trial for their private criminal act of libel. This is not only unfair and unjust to plaintiff. It will set a dangerous precedent in British legal history which will endanger the peace of British society in future.

(21)The defendants have no right to abuse the privilege by enjoying the service of Treasury Solicitor by making pretension as if the plaintiff is suing the British Government in order to mislead the Court in their favour to escape an open court trial for their personal crime of criminal libel per se. They cheat British Government. 122) The specious, invidious and tendentious arguments of the defendants are contriving and self-serving which are not in fact the genuine expression of the defendants' real views, but were written with vicious and dishonest intention of injuring the plaitiff, Solicitor for Defendants

r.D.A. Watson, Treasury Solicitor Matthew Parker Street, London SW1

Plaintiff (No Counsel) May 24, 1979

New York, N.Y.

Im Kung

Thomas Feng-ming TUNG

SPONI TO, AND SUBGORILED BEFORE ME

STHL

DAY OF marz

STATE OF HEW YORK COUNTY OF NEW YORK

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