EXHIBIT LISTReference No: HOL/00253Petitioner: Sharon-May and Richard Arthur MeanleyPublished to Collaboration Area: Thursday 20-Oct-2016

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1 P3842_01. Meanley_Local Map.pdf (P3842) 2

2 P3843_02. Meanley_Construction.pdf (P3843) 3

3 P3844_03. Meanley_Operation.pdf (P3844) 4

4 P3845_04. Meanley_Letter_20161003.pdf (P3845) 5 - 9

5 P3846_05. Meanley_Petitioner Letter to SC_20161012.pdf (P3846) 10 - 15

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HS2 Ltd accept no responsibility for any circumstances, whicharise from the reproduction of this map after alteration,amendment or abbreviation or if it is issued in part or issuedincomplete in any way.

High Speed TwoPetitioner Location Plan

Reference Drawing

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LONDON

BIRMINGHAM

Petition number

Petitioner

Registered in England. Registration number 06791686. Registered office: One Canada Square, London E14 5AB.

This material was last updated on [date] and may not be copied,distributed, sold or published without the formal permissionof Land Registry and Ordnance Survey. Only an official copy of atitle plan or register obtained from the Land Registry may be used forlegal or other official purposes. © Crown Copyright Ordnance Survey.This is not a copy of a title plan issued by LR.

© Crown copyright and database rights 2016.Ordnance Survey Licence Number 100049190.Sharon-May and Richard Arthur Meanley

SC-04-253

HS2-HS2-HY-PET-HOL-000253 Doc Number: PH1-HS2-HY-MAP-000-004568

Indicative extent of petitioner(s) propertyHybrid Bill Limits

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Petitioner(s) property

LegendPhase One SES3 and AP4 ES alignment October 2015

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Drawn Checked Approved

Drawing No.

Date Scale Size

Rev.

DrawnRev Description

Project/Contract

Discipline/Function

ZoneLegends/Notes:

Drawing Title

Design Stage

Ordnance Survey Licence number 100049190

© Crown Copyright and database right 2015. All rights reserved.

Registry under delegated authority from the Controller of HMSO.

© Crown Copyright material is reproduced with the permission of Land

may be used for legal or other official purposes.

Only an official copy of a title plan or register obtained from the Land Registry

sold or published without the formal permission of Land Registry.

This material was last updated on 2015 and may not be copied, distributed,

Scale with caution as distortion can occur.

Creator/Originator

Checked Con App HS2 App

or if it is issued in part or issued incompletely in any way.

the reproduction of this document after alteration, amendment or abbreviation

HS2 accepts no responsibility for any circumstances which arise from

London, E14 5AB

One Canada Square,

Registered office:

Registration No. 06791686

Registered in England

A330/10/2014

NOR

Country North

Environmental

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P00.1

DESIGN-FOR-PETITION

Capita Symonds Ineco JV

Country North Design

P00.1

Temporary material stockpile

Satellite construction compound

Engineering earthworks

Landscape earthworks

Rail alignment formation

during construction

Land potentially required

(PRoW)

Existing public right of way

PRoW

New, diverted or realigned

Construction traffic route

Main utility works

Stopped-up PRoW

Rail alignment

Main construction compound

MARSTON LANE

Leeds Spur

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Existing watercourse

C223-CSI-EV-DPL-030-522901-PETHOL0253

House of Lords Petitions HL:0253

property

Location of petitioner(s)

Construction

Sharon-May and Richard Arthur Meanley

AS SHOWN

Property

Petitioner(s) Existing Footpath M23

Overbridge Satellite Compound

A4097 Kingsbury Road

Road Overbridge

A4097 Kingsbury

Main Compound

Road Overbridge

A4097 KingsburyFootpath M13 Closed

Compound

Viaduct (South & Central) Satellite

Birmingham & Fazeley Canal Marston Lane Stopped Up

Satellite Compound

Cuttle Mill Underbridge

Satellite Compound

Seeney Lane Overbridge

Satellite Compound (Rail Systems)

(North) and Cuttle Mill MPATS

Birmingham & Fazeley Canal

For Sections Refer To Drawing No. C223-CSI-EV-DSE-030-000001-PETHOL0253

Main Construction Compound

Kingsbury Road Railhead CONSTRUCTION

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Drawn Checked Approved

Drawing No.

Date Scale Size

Rev.

DrawnRev Description

Project/Contract

Discipline/Function

ZoneLegends/Notes:

Drawing Title

Design Stage

Ordnance Survey Licence number 100049190

© Crown Copyright and database right 2015. All rights reserved.

Registry under delegated authority from the Controller of HMSO.

© Crown Copyright material is reproduced with the permission of Land

may be used for legal or other official purposes.

Only an official copy of a title plan or register obtained from the Land Registry

sold or published without the formal permission of Land Registry.

This material was last updated on 2015 and may not be copied, distributed,

Scale with caution as distortion can occur.

Creator/Originator

Checked Con App HS2 App

or if it is issued in part or issued incompletely in any way.

the reproduction of this document after alteration, amendment or abbreviation

HS2 accepts no responsibility for any circumstances which arise from

London, E14 5AB

One Canada Square,

Registered office:

Registration No. 06791686

Registered in England

A314/10/2016

KT

Country North

Environmental

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P00.1

DESIGN-FOR-PETITION

Capita Symonds Ineco JV

Country North Design

P00.1Balancing pond

Grassed areas

Sustainable placement

(scrub / woodland)

Landscape mitigation planting

Rail alignment formation

Landscape earthworks

Engineering earthworks

Ditches - new

Main utility works

Hedgerow habitat creation

Existing watercourse

PRoW

New, diverted or realigned

(PRoW)

Existing public right of way

HS2 Access road

Rail alignment

Stopped-up PRoW

BL

AC

KG

RE

AV

ES

LA

NE

Leeds Spur

OPERATION

Storage

Replacement Floodplain

C223-CSI-EV-DPL-030-622902-PETHOL0253

House of Lords Petitions HL:0253

property

Location of petitioner(s)Operation

Sharon-May and Richard Arthur Meanley

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AS SHOWN

Property

Petitioner(s)

Road Overbridge

A4097 Kingsbury Overbridge

Seeney Lane

with Schedule 11

Restored in Accordance

Kingsbury Road Railhead

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P3844 HOL/00253/0004

Dear Mr & Mrs Meanley Petition against the High Speed Rail (London – West Midlands) Bill – House of Lords Petition No. 253 I am the Director of Hybrid Bill Delivery at HS2 Ltd, which is acting on behalf of the Promoter of the High Speed Rail (London – West Midlands) Bill (‘the Bill’) currently before Parliament. I understand you have a number of concerns regarding the impacts of the Proposed Scheme and have petitioned the House of Lords on that basis. Objection to the Proposed Scheme and its impacts/amendment to the Kingsbury Road footprint In your petition you have raised objection to the Proposed Scheme and also suggested an alternative proposal for the Kingsbury Road railhead. Please be aware that the amendment to the railhead you suggest would require additional land outside the limits of deviation for the Bill and therefore require an Additional Provision (AP). At the very beginning of the House of Lords Select Committee’s hearings, on 19 May1, the Chairman, Lord Walker of Gestingthorpe, set out the Committee’s initial view on requests made by petitioners for changes to the scheme that would require an AP (that is to say that they would require powers which go beyond the scope of the existing Bill, such as requiring additional land, or would give rise to new significant environmental effects), namely that the Committee would not be able to require the Promoter to bring forward Additional Provisions unless they received an instruction from the House of Lords at Second Reading, which did not occur. Notwithstanding their initial view, the Committee allowed Chiltern District Council and the London Borough of Hillingdon to make representations on the matter to ensure the contrary view was given a fair hearing. The Committee heard the case for the House of Lords Select Committee, as the Select

1 The transcript can be found at http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/high-

speed-rail-london-west-midlands-bill-lords-committee/high-speed-rail-london-west-midlands-bill/oral/33501.html

Mr & Mrs Meanley School House Kingsbury Road Marston North Warwickshire B76 0DH By email: s.meanley@btinternet.com/ r.meanley@btintrnet.com

3 October 2016

P3845 (1) HOL/00253/0005

Committee in the second House, to be able to require the Promoter to bring forward Additional Provisions on 30 June 20162. The Committee’s decision on the issue was announced on 7 July 20163 and usefully summarised, along with other advice on how petitioners might best present their cases, in the Chairman’s statement on 19 July4:

“With our proceedings about to break for the summer recess, the Committee wishes to issue some guidance which may prove useful to petitioners appearing in the future. As to our programme, we’ll be hearing from petitioners in the Euston and Camden areas in September. Then we will resume our south-bound progress down the line when the House returns after the Conference recess in October. In the light of our ruling on additional provisions given on Thursday 7 July, we wish to make it absolutely clear that, in the absence of an instruction from the House, we will not hear argument for measures which would require an additional provision, that is, measures which would amount to significant changes to the scheme. In preparing their cases, petitioners should be extremely mindful of our limited powers. They will be squandering their time if they choose to present proposals which would require an additional provision, just as they will if they present proposals which go against the principle of the Bill. Instead, they would be wise to focus on issues and solutions over which the Committee does have power to intervene. The Committee also wishes to re-emphasise the merits of succinct and cogent presentations from petitioners and the desirability of petitioners grouping together to present a single case. Groups of petitioners from the same area are encouraged to appoint a lead petitioner to outline their case, with other petitioners from the group adding local detail where appropriate, instead of repeating the case. It is our clear view that there is no relationship between repetition and persuasiveness.”

Environmental assessment In your petition, you raise concerns that the Promoter has failed in its duty to assess the environmental impact on your property. You raised these issues in your petition against the Bill in the House of Commons (No. 851) and our position remains as set out in the Promoter’s Response Document (PRD) issued in response to your petition in the House of Commons. You appeared before the House of Commons Select Committee on 15 December 2014. Case specific details You raise a number of specific issues in relation to the handling of your case in your petition against the Bill in the House of Lords. Our position in relation to these concerns is set out in the PRD issued in response to your petition in the House of Commons and in the subsequent correspondence between us which is set out in the PRD issued in April 2016 in response to your petition in the House of Lords. Your property is outside the limits of deviation and is not required to be compulsory acquired to deliver the Proposed Scheme. However, the Promoter confirmed to you on 5 December 2014 that the Secretary of

2 The transcript can be found at

http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/high-speed-rail-london-west-midlands-bill-lords-committee/high-speed-rail-london-west-midlands-bill/oral/34714.html. 3 The transcript can be found at

http://www.parliament.uk/business/committees/committees-a-z/lords-select/high-speed-rail-london-west-midlands-bill-select-committee-lords/hs2-publications/. 4 The transcript can be found at http://www.parliament.uk/business/committees/committees-a-z/lords-select/high-speed-rail-

london-west-midlands-bill-select-committee-lords/news-parliament-2015/statement-of-procedure/.

P3845 (2) HOL/00253/0006

State had approved the case for purchase of your property, subject to contract and at the un-blighted market value, consistent with the terms that would apply were the property within the discretionary property schemes. The purchase of the property and your circumstances were being treated as a special case in relation to the Kingsbury Road railhead. You were heard before the House of Commons Select Committee on 15 December 2014. The Committee requested the parties negotiate acquisition of the property by the Promoter on the basis of un-blighted market value and costs contribution. On 14 January 2015 you wrote to us to note that you did not wish to accept the proposed offer to purchase the property and noted that you would be seeking a return to the Committee to seek a sale of the property based on safeguarding terms. We wrote to you on 27 January 2015 to clarify the terms of the offer and respond to the concerns raised. In February 2015 it was agreed that a valuation of the property take place and based on the valuation report received by us, an offer was made in March 2015. You rejected that offer. We then suggested that you seek a valuation and that this would be paid for by the Promoter, and this was taken forward. Following exchange of the reports, the two valuation agents considered the valuation evidence but were unable to recommend any settlement or compromise on their respective figures. In an attempt to resolve matters, we increased the offer on 25 June 2015 and proposed alternative settlement by means of an independent expert or a third valuer. The House of Commons Select Committee confirmed on 10 July 2015 that this would be the appropriate course and they directed the parties to make the necessary arrangements to reach an early conclusion on the matter. We continued to seek agreement for a choice of independent expert and further details of that correspondence is set out in the PRD issued in April 2016. Since the issue of that document I am pleased to note that this valuation has been sought and confirmed. Following further correspondence, a meeting took place with you and our property team in July 2016 to discuss the valuation and the contribution toward fees. Following that meeting, we wrote to you on 29 July 2016 with our final offer in relation to both matters and subsequently instructed our solicitors. Our solicitors wrote to your solicitors on 9 August with the draft contract and transfer. You helpfully confirmed on 19 September 2016 by email that you are progressing matters with regard to the conveyancing and hope for completion during October or November 2016. You have not yet confirmed that you are satisfied with the offered contribution towards fees. The House of Commons Select Committee considered whether it was appropriate for your home to be treated as if it were safeguarded and said:

‘this Committee is not likely to go saying that HS2 is going to have to treat as safeguarded many properties which are not safeguarded.’5

5 Paragraph 659 of the Minutes of Oral Evidence taken before the High Speed Rail Committee on the High Speed Rail (London-

West Midlands Bill – Monday, 15 December 2014 (Afternoon)

P3845 (3) HOL/00253/0007

The Committee did ask us to pay, as a discretionary measure, reflecting your particular circumstances, ‘some of the fees and costs that have been going on.’6 The amount offered toward costs has been increased since that offered before your appearance before the House of Commons Select Committee, based on the information provided by you in relation to eligible costs incurred. The letter of 29 July 2016 explains the reasoning for the amount offered in response to your claim and I repeat that position in the table below for your convenience:

Item Proposal HS2 Ltd offer

Comment

1 Market value (as determined by the expert)

£440,000 £440,000 Agreed in full.

2 Conveyancing costs – capped inc VAT

£7,200 £7,200 Agreed in full.

3 Stamp duty £12,000 £0 The property is not to be treated as safeguarded and claimed amount falls outside the definition of some fees and costs.

4 Contribution to the legal costs incurred inc VAT (half of that claimed to achieve settlement)

£6,000 £3,000 Offered half the amount claimed as some of the fees incurred were post Select Committee and involved challenging HS2 Ltd.

5 Misc. costs incurred in trying to sell the house on the open market

£1,550 £1,550 Agreed in full subject to receipt of evidence that the costs have been incurred.

6 Valuation costs in preparing the addendum to the expert inc VAT

£540 £540 Agreed in full.

7 A one off lump sum for the upset

£40,000 £0 The property is not to be treated as safeguarded and claimed amount falls outside the definition of some fees and costs.

Total £507,290 £452,290

I consider that this offer is in line with the direction of the House of Commons Select Committee and I confirm it is our full and final offer. I therefore hope that this addresses your concerns in relation to the matter of the costs contribution.

6 Paragraph 664

P3845 (4) HOL/00253/0008

Claim for costs of petitioning In accordance with previous established practice on hybrid Bills, costs and fees which owners incur both in drawing up and depositing their petitions and in presenting their case to the Select Committees of the Houses of Parliament will not be reimbursed. Erskine May: Parliamentary Practice confirms on page 1008:

‘Committees on hybrid Bills have no powers to award costs to any party.’ These arrangements are set out in HS2 Information Paper C9, Recovery of Costs by Property Owners, which should be read in conjunction with HS2 Information Paper C4, Land Acquisition Policy and HS2 Information Paper C8, Compensation Code for Compulsory Purchase. The award of costs for private Bills is governed by s10 of the Parliamentary Costs Act 2006 which sets the test for an award of costs. But as explained above, this does not apply to hybrid Bills which are public bills introduced by the Government, and in any event in this case the tests set out in s10 would not be met. In light of the information set out above and the progress made in relation to the purchase of your property, I hope that this gives you sufficient comfort to enable you to withdraw your petition. Petitions may be withdrawn by depositing a letter (or requisition) in the House of Lords Private Bill Office, signed by the Petitioner or agent. This may also be faxed to the House of Lords Private Bill Office. Please refer to the Lords petitioning guide at https://www.parliament.uk/documents/Lords-HS2/House-of-Lords-HS2-petitioning-kit-guide.pdf for further details. Yours sincerely

Roger Hargreaves Director, Hybrid Bill Delivery High Speed Two Limited

P3845 (5) HOL/00253/0009

 

1

FAO Clerk to the House of Lords Select CommitteeCC to Head of Petitions Management HS2 LtdMr David Walker – Parliamentary ClerkBy Email Only

12 October 2016

Re: Petition of Sharon & Richard Meanley HL: 253

Dear Sir

Further to our telephone conversation of 7 October 2016, I would be grateful if youwould place this matter before the Chair to Select Committee in order that a view maybe taken as to whether or not those outstanding petition issues as below-stated in theform of a Schedule of Issues, might fall outside the remit for consideration andadjudication by the House of Lords Select Committee in this hybrid bill petitioningprocess. Should the Select Committee determine that the outstanding issues are not ofthe kind that they will themselves adjudicate on, then I would hope to save time, costsand effort on the parts of all parties by withdrawing our petition and dealing with theseissues in different processes, or forums. Given that our petition has been listed forhearing on 25th October, I look forward to hearing from you as soon as ever possible.

Yours sincerely,Sharon & Richard Meanley07903 155426

Issue Petitioner’s position Promoter’s position1. Acquisition of

Petitioner’sproperty under thesafeguardingprocedures

Not agreed.The Petitioners have soughtacquisition of theirproperty by the Promoteron terms akin tosafeguarding given thefollowing considerations:-

a) Business case beingmet for acquisitionon these terms in oraround May toSeptember 2013;

b) That the Promoter’ssubsequent renegingon this position isunfair and withoutfoundation;

c) That the Petitioners’need to move is

Not agreed.By admission on the part ofthe Promoter (made on 12July 2016) that they couldbut fail to identifyjustification for the same,the Promoter is acquiringthe Petitioners’ property onterms not inkeeping withthe safeguardingprovisions, and on termsmore akin toexceptional/longtermhardship.

P3846 (1) HOL/00253/0010

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borne out of theoverwhelmingredevelopment andrestructuring of thePetitioners’ environsfor all those reasonsset out in theirpetition

d) The close proximityto the Petitioners’property, longevityand complexity ofthe Kingsbury RoadRailhead (which hadnot been consultedon) nor any dueprocess followed inrespect of the same;

e) That not to do so,represents singlingout of thePetitioner’sproperty given thecases of the sixGilson properties inexact same positionbut no more thantwo miles away,wherein they wereretrospectivelyprovided withsafeguarded status

2. Promoter’sApplication ofSection 9 DecisionDocumentConsiderations

Not agreed.The Petitioners contendthat the Promoter hasunfairly failed to look onthe case of the Petitionersas a section 9 casethroughout their six yearhandling of the matter. ThePetitioners contend that thePromoter has continued tomake their case akin toexceptional / longtermhardship, most recently intheir insistence that thereis required to be a thirdvaluation and the identity

Not agreed.The Promoter’s position isthat in acquiring thePetitioner’s property undersection 9 and meeting thecosts of conveyance up tothe sum of £6,000 theyhave fully met their duty offair application of section 9.

P3846 (2) HOL/00253/0011

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of that valuer is a surveyornamed on the Promoter’spanel of experts,compromising theindependence and fairnessof the matter of a thirdvaluation.This point was conceded bythe Petitioners in sheerdesperation for progress oftheir matter after suchdrawn out proceedings, andthey are of the view that inthe value of their propertyalone, (on which theacquisition price has beendetermined) they havesuffered a significant lossstanding at around£85,000.The Petitioners contendthat the Promoter hasfailed to fairly exercise itspowers under section 9,choosing rather to maketheir case fit existingprotocol of exceptionalhardship/longtermhardship as opposed to amore favourable move toassist the Petitioner’s inremoving themselves fromthis unhappy matter havingbeen thrust upon them

3. ConveyancingCosts anddisbursementsassociated withacquisition ofPetitioner’sproperty andPetitioner’spurchase ofalternativeproperty

Agreed.The Promoter will meet thePetitioner’s costs anddisbursements associatedwith their acquisition of thePetitioners’ property andthe Petitioners purchase ofan alternative property inthe sum of £6000 plus VATplus disbursements

Agreed.The Promoter agrees tomeet the Petitioner’s costsand disbursementsassociated with theiracquisition of thePetitioners’ property andthe Petitioners purchase ofan alternative property inthe sum of £6000 plus VATplus disbursements

4. Stamp Dutypayable by

Not agreed.On the basis that but for the

Not agreed.The Promoter makes no

P3846 (3) HOL/00253/0012

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Petitioner’s onpurchase ofalternativeproperty

scheme, the Petitionerswould not otherwise befacing the prospect of amove and such an out-of-pocket expense, thePetitioners seek a one-offlump sum payment whichrepresents the lesser of:

a) The stamp dutypayable by them onthe purchase of analternative familyhome, or

b) The stamp dutypayable on the valueof their currentwhom which is to beacquired by thePromoter.

offer of a one off lump sumpayment in settlement orpart settlement of thePetitioners requirement tofund a necessary StampDuty payment on theirpurchase of an alternativefamily home.

5. Reimbursement ofPetitioner’s legalfees £6,000

Agreed in part.The Petitioners’ haveconceded shared paymentarrangement whichprovides both parties payfifty per cent of thePetitioners’ legal costslimited to £3,000

Agreed in part.The Promoter has agreed tomeet the Petitioners’ legalcosts limited to £3,000

6. Reimbursementand payment ofestate agentmarketing feesassociated withproving blight andinability to sellproperty on theopen market

Agreed.The Petitioners shall bereimbursed by thePromoter to the sum of£350 in relation to theirpayment for the enhancedmarketing package takenout by them. Furthermore,the Promoters agree to theestate agents marketingfees arising out of anaborted marketing periodfor the property (agreedfixed fee price of £1000plus VAT)

Agreed.The Promoter agrees toreimburse the Petitionersand make payment to theSelling Agents uponproduction of relevantreceipts/invoices.

7. Compensation Not agreed.For all the reasons set outbelow in the annexedSchedule “A”, thePetitioners seek

Not agreed.The Promoter makes nooffer of compensation tothe Petitioners.

P3846 (4) HOL/00253/0013

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compensation from thePromoter

Schedule “A”

Extract from Statement of Evidence given to PACAC

1.3 I, Sharon M Meanley will say that in my case HS2 LTD have acted unjustly,unlawfully, and without regard to due process in that they have:1.3.1 failed to properly engage in meaningful consultation about the nature of

HS2 and its impact on my home;1.3.2 failed to provide opportunity for me to respond in meaningful fashion to

all or any of the public consultations issued under the hybrid bill process,namely and crucially in my case, in the draft Environmental Statementand the Environmental Statement public consultations;

1.3.3 failed to make a timely determination that my property came under phase1 of the proposed scheme AND were unreasonably late in theircommunication of that decision;

1.3.4 reneged on assurances and promises given to us at a meeting which tookplace on 29 May 2013, and subsequently;

1.3.5 failed to respond to my formal complaint dated 7 February 2014;1.3.6 from 29 May 2013 until 20 December 2013 misrepresented or failed to

discuss my case between relevant government departments AND in theperiod between those dates deliberately provided me with a falseimpression that my case was being looked at internally;

1.3.7 failed in their duty to attempt to mitigate pre-petition hearing issuescontained in my Parliamentary petition dated 14 May 2014;

1.3.8 failed in their duty to provide meaningful and due consideration to mysettlement proposals put forward in the pre-petition stages of my caseAND failed to provide counter proposals to settle my matter in the pre-petition stages of my case;

1.3.9 failed to provide full and meaningful consideration to my proposals toprogress or settle my matter during this post-petition stage of my case;

1.3.11 failed to provide meaningful counter proposals to settle our matter postpetition stage of our case

1.3.12 acting through their advocate at select committee hearing of our petitionon 15 December deliberately misled the SC about having sent to us animproved settlement offer

1.3.13 subjected me as an opponent advocate to case conduct which has fallenfar short of the standards which are acceptable for a government body;

1.3.14 failed in their duty to recognise that mine is a special case under section 9of the 2014 Decision Document and continue to do so;

1.3.15 have failed to comply with the recommendations of the Select CommitteeHonourable Members made at hearing of my petition on 15 December2014 and in their statement dated 12 January 2015;

1.3.17 acted unreasonably in their refusal of our Freedom of Informationrequest dated 15 March 2015;

P3846 (5) HOL/00253/0014

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1.3.18 failed to provide clear and appropriate instructions to the expert whichdefine the remit of his instructions AND continue to act unreasonably byplacing too much weight and importance on the valuation report byBrown & Co;

1.3.19 continue to act unreasonably in their refusal to accept my evidence of theunblighted market value of my home as per the property valuation reportprepared by Roger Hannah dated 30 April 2015;

1.3.20 continue to act unreasonably in their requirement of a third propertyvaluation;

1.3.21 continue to act unreasonably in their requirement that only a HS2 LTDpanel valuer be appointed to conduct that third valuation;

1.3.22 continue to act unreasonably in the delayed agreement to the terms ofinstruction of the third property valuation;

1.3.23 continue to act unreasonably in challenging the requirement on our partto engage independent legal advice and appoint a Parliamentary Agent;

1.3.24 continue to act unreasonably by requiring that I agree in principle toHeads of Terms setting out settlement terms in my case to which I do notagree ahead of a third property valuation;

1.3.25 in their handling of my case have failed and continue to fail in their dutyto recognise and give due consideration to Article 8 of the Human RightsAct 1998;

1.3.26 failed fundamentally to follow due process in my case, and continue intheir failure to follow due process in my case, thus injuriously andadversely affecting my ability to represent my matter in person;

1.3.27 fundamentally failed to follow due process in my case, and continue intheir failure to follow due process in my case, thus injuriously andadversely affecting my ability to represent my matter;

1.3.28 failed to give due care and attention to my case in their failure torecognise the significant adverse affects their conduct is having on mypersonal and professional lives, my health, my home, my personalhappiness and well-being, my business affairs, (together with all thosefactors which impact directly or indirectly my family);

1.3.29 continued to victimise, intimidate, marginalise, and discriminate againstme by their use of delay and strong arm tactics in their handling of mymatter;

1.3.30 failed to act consciously with little or no regard to the public purse incontesting my case and challenging me at every opportunity withoutfoundation to the effect of prolonging the prospect of settlement of mycase and incurring for all parties concerned unreasonable costs in doingso;

1.3.31 against the spirit of a sense of openness, fairness and justice they havetreated my case with implacable hostility and adopted an immovableposition which is founded on no reasonable grounds.

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P3846 (6) HOL/00253/0015