Mr Eddie Cairns
72 Hillhouse Street
GLASGOW G21 4HP
15 August 2016
Scottish Police Authority
1 Pacific Quay
GLASGOW G51 1DZ
Dear Sir or Madam,
COMPLAINT AGAINST THE CHIEF CONSTABLE OF POLICE SCOTLAND, MR PHILIP GORMLEY
I want to raise a formal complaint against the Chief Constable of Police Scotland, Mr Philip Gormley.
I sent an important letter dated 1 July 2012 by email to the Chief Constable of Strathclyde Police attaching several previous letters that I had sent to the Chief Constable of Strathclyde Police and to which reference was made in the letter dated 1 July 2012.
I sent another important letter dated 9 July 2012 by email to the Chief Constable of Strathclyde Police and I was notified by email on 12 July 2012 that the Chief Constable had instructed that my correspondence be passed to Mr Ruaraidh Nicolson, Assistant Chief Constable for Crime, who would ensure that I was contacted in due course.
Mr Nicolson has never ensured that I was contacted nor has he ever informed me why.
On 8 May 2013 I sent an email pointing out that I had not been contacted by anyone yet and that I had not followed this up before this time because of illness.
In due course ACC Nicolson’s failure to ensure that I was contacted became a responsibility of the new Chief Constable of Police Scotland, Mr Philip Gormley.
The allegations contained in my complaint to the Scottish Police Authority about ACC Nicolson’s failures also apply to this complaint about the Chief Constable of Police Scotland because the failures related to a direction from the Chief Constable of Strathclyde Police to ACC Nicolson that ought to have been followed up with appropriate action by the Chief Constable of Police Scotland to ensure its fulfilment, especially in view of the reminder I sent on 8 May 2013.
No retraction of the direction to ACC Nicolson to ensure that I was contacted has ever been notified to me.
Consequently I formally incorporate brevitatis causa the allegations against ACC Nicolson contained in my complaint about his failures into this complaint against the Chief Constable, including the supporting evidence already provided.
On 10 January 2016 I requested a review by Police Scotland of the case of alleged fraud in Enterprise Ayrshire and Scottish Enterprise in 1993, which was notified to me on 31 May 2016 to have been concluded.
Shortly thereafter I submitted to Police Scotland a complaint containing several serious concerns.
On 23 June 2016 I received a response indicating that the Chief Constable would not be responding to my complaint in the following terms, reproduced here in italics for convenience:
‘With reference to your letters dated 4 June and 8 June 2016, you were sent an email in answer to a query asking the status of your complaint. This was a courtesy email as your complaint had not at that time been assessed by Professional Standards.’
‘Police Scotland will not re-investigate your complaint. You should be aware of this, as your complaint went to PIRC for review.’
‘Your contact with DCI Thomson was in relation to what you reported as new evidence. After a review of this new evidence, it was assessed not to be the case and you received a letter from DCI Thomson notifying you of the same.’
‘You will not receive any further correspondence from Police Scotland in relation to this allegation.’
Contrary to the email from the Police, this complaint did not in fact go to the PIRC for review.
If the email from Police Scotland is referring here to my two complaints submitted to the Police Complaints Commissioner for Scotland in 2008 and 2010 clearly my concerns about material evidence having been concealed in 2016 and about Scottish Enterprise presenting false information to Police Scotland in April 2016 during a review beginning in January 2016 and ending in May 2016 could not have included all those allegations.
The exact texts of the sections in the forms containing details of the matters I submitted for review by the PCCS are replicated below:
17 November 2008
’WHY STRATHCLYDE POLICE DID NOT ASK ANOTHER FORCE TO INVESTIGATE ALLEGED FAILURES, IN THE PARTICULAR CIRCUMSTANCES.’
‘STRATHCLYDE POLICE’S STATEMENT THAT ALL THE EVIDENTIAL FACTORS I IDENTIFIED WERE KNOWN TO THE POLICE IN 1994’
21 June 2010
‘A DELAY OF 10 MONTHS IN RESPONDING TO MY LETTERS’
‘FALSE STATEMENTS ABOUT THE 1993 INVESTIGATION’
‘FALSE STATEMENTS ABOUT THE 2004 INVESTIGATION’
‘FALSE STATEMENTS ABOUT THE 2008 INVESTIGATION’
These details related to only two specific complaints that I had submitted earlier to Strathclyde Police and in response to which I had received two corresponding letters from Strathclyde Police, one dated 19 September 2008 and one dated 11 June 2010.
Perusal of the texts replicated above confirms that they did not address the matters included in my complaint about the review in 2016.
As for the assertion that evidence I had submitted to Police Scotland in 2016 was not new, my complaint to the SPA about the Deputy Chief Constable responsible for the maintenance of professional standards in Police Scotland addresses that issue and exposes it as false. The same details apply to this complaint.
In fact in 2016 I presented many items of evidence that had never been adequately considered or that had never been considered at all by the police. Inexplicably, the police have disregarded about a hundred items of evidence that I presented in 2016.
Since Police Scotland, under the Chief Constable’s direction, maintain that they had already considered the evidence I presented in 2016, but only refer to one item, the bank statement in the name of Mr Gary Tracey, an important question arises in any event. How did an employee of Enterprise Ayrshire come to have £187,000 of taxpayers’ cash at his disposal while it was excluded from the public authority’s balance sheet?
Since the police assert that they already considered this evidence what was the plausible explanation apparently discovered for these serious financial irregularities?
My complaint about the conduct of the Deputy Chief Constable responsible for the maintenance of professional standards in Police Scotland contains other allegations which are also applicable to this complaint about the Chief Constable of Police Scotland.
Therefore I formally incorporate brevitatis causa the allegations against the Deputy Chief Constable responsible for the maintenance of professional standards in Police Scotland into this complaint, including the supporting evidence already provided.
In a letter to me dated 31 May 2016 from Detective Chief Inspector Kenneth Thomson I was notified that, replicated here in italics for convenience:
‘DS Adams and DC Stewart have conducted a review and assessment of the reported ‘new evidence.’
On the contrary, the letter from Mr Thomson goes on to reveal that rather than conducting a review and assessment of the evidence I provided that had either not been adequately considered or not considered at all by the police previously, instead the police, under the direction of the Chief Constable, put considerable effort into investigating civil actions I had raised years ago.
In view of the detailed references to these civil actions contained in Mr Thomson’s letter, the police have beyond reasonable doubt colluded with Scottish Enterprise and their solicitors in a disgraceful attempt to undermine my credibility, to conceal material evidence, to avoid carrying out a proper investigation into alleged criminality and to pervert the course of justice.
Mr Thomson’s assertions that two of the documents submitted as evidence to the police were already included amongst productions in civil actions are entirely irrelevant. The implied suggestion that this somehow fulfilled the police’s responsibility to investigate evidence of alleged criminality that had either not been adequately considered or not considered at all by the Police is complete nonsense. The civil actions had nothing to do with the police. They were actions for damages, not criminal proceedings.
Since DS Adams and DC Stewart appear not to have carried out an adequate investigation into alleged criminality taking into consideration the evidence I submitted that had either not been adequately considered or not considered at all by the Police, beyond reasonable doubt they acted corruptly, under the direction of the Chief Constable, in order to cover for ACC Nicolson, a higher ranking officer in their chain of command, who is known to them to have been previously involved in the Scottish Enterprise case and who is alleged to have conspired to pervert the course of justice.
Available evidence indicates that the police and Scottish Enterprise have already colluded and interfered in civil actions and other legal proceedings unlawfully and unfairly in order to harm me and pervert the course of justice in this case.
In his letter to me dated 31 May 2016 Detective Chief Inspector Kenneth Thomson added:
‘Further to this, a writ was raised by you, reference A3641/2003, supported by multiple documents which included a ‘Fifth Inventory of Productions’. Within these documents is a copy of the RBS bank statement titled ‘Strictly Private and Confidential, Gary Tracey c/o Enterprise Ayrshire.’
The Fifth Inventory of Productions referred to above in fact contained only one item, the original Scottish Enterprise report, signed by the Scottish Enterprise investigating accountant and countersigned by DS William Watters himself, the police officer in charge of the initial police investigation.
Another rather obvious question arises. Why did DCI Thomson, DS Adams and DC Stewart not confront Scottish Enterprise on the important matter of several blatant defects apparent in this report? The police already informed me that this report had been destroyed years ago.
Clearly, Police Scotland seriously failed to act properly here in the public interest. Instead of addressing the alleged criminality supported by this report they ferreted out one page amongst what Mr Thomson admits to be multiple documents in this civil action, in a desperate attempt to discredit me, which is utterly shameful.
This proves beyond reasonable doubt that DCI Thomson, DS Adams and DC Stewart, under the direction of the Chief Constable, have colluded with Scottish Enterprise and their solicitors in another disgraceful attempt to undermine my credibility, to conceal material evidence, to avoid carrying out a proper investigation into alleged criminality and to pervert the course of justice.
In his letter to me dated 31 May 2016 Detective Chief Inspector Kenneth Thomson further added:
‘In respect of the matters you raised with DS Adams and DC Stewart these have been previously considered and do not support any ‘new evidence’ of criminality.’
This is another false statement from Mr Thomson which further indicates beyond reasonable doubt that Mr Thomson has concealed material evidence and acted corruptly in order to cover for ACC Nicolson’s alleged misconduct relating to this case.
Several important documents were submitted to Police Scotland that had either not been adequately considered or not considered at all by the Police previously. In particular, the following Items produced recently for Police Scotland confirm that for many years the police failed to collect evidence from me that they had said they would collect in relation to this case:
52. Letter to me from DI Robertson, Strathclyde Police, dated 20 February 2004.
53. Letter from me to DI Robertson, Strathclyde Police, dated 21 July 2004.
54. Recorded delivery proof for Item 53 above – side 1.
55. Recorded delivery proof for Item 53 above – side 2.
With regard to Mr Thomson’s assertion that these matters have been considered previously, I gave the following information to Police Scotland in January 2016 along with supporting evidence further indicating the falsity of Mr Thomson’s assertion, replicated here in italics for convenience:
‘I obtained important evidence in February 2003 and passed it on to the police.’
‘In July 2003 the police asked the Lord Advocate to raise a petition for me to be categorised as a vexatious litigant.’
‘Consequently from a very early stage the police and the Crown Office had no intention of reviewing properly this evidence. Instead they wanted to cover up the failures revealed in the evidence by having me legally disabled.’
In his letter to me dated 31 May 2016 Detective Chief Inspector Kenneth Thomson ended by asserting:
‘Therefore, I will not be instructing any further Police investigation.’
Mr Thomson failed to act in accordance with his responsibilities to ensure that an adequate enquiry was carried out into evidence that had either not been adequately considered or not considered at all by the police previously.
The available evidence indicates beyond reasonable doubt that Mr Thomson, Mr Adams and Ms Stewart conspired with Scottish Enterprise and their solicitors to pervert the course of justice in this case, a very grave matter.
Perusal of the original Scottish Enterprise report, referred to by Detective Chief Inspector Kenneth Thomson in his letter to me dated 31 May 2016 as contained in the Fifth Inventory of Productions in civil action reference A3641/2003, in conjunction with evidence I submitted to Police Scotland in 2016 would have confirmed to Detective Chief Inspector Kenneth Thomson, Detective Sergeant Steven Adams and Detective Constable Yuan-nee Stewart:
(1) the failures of police officers to ensure that an adequate investigation had initially been carried out in this case in 1993, including failures by Detective Superintendent Gordon Ferrie and Detective Sergeant William Watters,
(2) the falsity of subsequent statements by police officers that all the evidence I submitted to the police had already been considered in that initial report, including false statements by Assistant Chief Constable Ruaraidh Nicolson and Detective Inspector Graham Cowley,
(3) that material evidence had been concealed by employees of Enterprise Ayrshire and Scottish Enterprise in the context of assisting the police enquiry in this case,
(4) that Scottish Enterprise’s Head of Finance, Mr Tom Woodbridge, had concealed material evidence and misrepresented the Scottish Enterprise report in the context of assisting the police in their initial investigation,
(5) that my allegations about Scottish Enterprise’s original falsehoods and their recent additional falsehoods had been disregarded,
(6) that employees of the Scottish Office had conspired with Scottish Enterprise to pervert the course of justice,
(7) and that my allegation that Scottish Office officials conspired with Scottish Enterprise to pervert the course of justice in this case had been disregarded.
In July 2016 I received disclosures from Scottish Enterprise under the terms of the Data Protection Act 1998 which make reference to DC Stewart of Police Scotland.
The disclosures contain several matters of serious concern that I would bring to the attention of Police Scotland but for the notification to me on 23 June 2016 that I will not receive any further correspondence from Police Scotland in relation to this allegation.
I want to add the failure of the Chief Constable to respond to these matters of serious concern, which are detailed below, to my formal complaint against that senior officer.
The following matters of serious concern arise and require to be addressed in the public interest and in the interests of justice:
1. Mr Iain Scott, Scottish Enterprise’s Chief Financial Officer and Company Secretary, wrote to DC Stewart of Police Scotland on 15 April 2016 including the following statements, reproduced here in italics for convenience:
‘Hi DC Stewart,’
‘As discussed, here is a scan of the court papers from 2004. I have scanned them as 2 separate documents with the first being Productions 4 to 10 (where production 9 is the bank confirmation of the funds being transferred to a ‘’Customer Bid Deposit Account’’ for just over a month.’
Of course the chumminess reflected in this correspondence is entirely inappropriate in the context of an investigation into alleged financial irregularities in a public authority.
The document referred to here as production 9 is the Royal Bank of Scotland confirmation of a £187,000 deposit to account 00151450 in the name of Mr Gary Tracey dated 1 July 1993.
Significantly, Mr Scott culpably omits to mention that the funds in question, £187,000 of public money, were deliberately excluded from the company’s balance sheet for the entire period of its transfer into an account in the name of Mr Gary Tracey.
If the £187,000 held in the name of Mr Tracey had really been in the name of Enterprise Ayrshire, as suggested in Mr Scott’s letter, it would have been included in the company’s balance sheet as at 2 July 1993.
But the Scottish Enterprise report and the extract from my bank reconciliation as at 2 July 1993, which are both included in Mr Scott’s scanned documents sent to DC Stewart, confirm that £187,069 was missing from the company’s balance sheet at 2 July 1993.
Where was this money at 2 July 1993 and for several weeks thereafter? It was in the hands of Mr Tracey.
This deposit was MATURING at 2 AUG 1993, which was one calendar month and one day after the date of the initial deposit.
According to the terms of the account this money was actually committed in the name of Mr Tracey until 4 September 1993 because the money was deposited again into the same account on 3 August 1993 which means that it did not mature until 4 September 1993. But the ERDF receipt was to have been transferred to Scottish Enterprise during the July 1993 accounting period according to the operating contract. The accounts would normally be finalised around the middle of the following month, in this case around the middle of August 1993.
This evidence alone proves that the financial irregularities were fraudulent. Excluding the cash from the accounts was the deception that brought about the practical result of making the cash available to be taken control of without the owners’ consent, in other words without the general public’s consent as laid down in the laws applicable to this public authority, and thereby gaining interest that otherwise would not be gained, at the expense of UK taxpayers.
Mr Andrew Downie and Mr Gary Tracey took control of this public money beyond what was lawful. Taxpayers’ cash was indeed effectively stolen thereby.
The money was in the hands of Mr Gary Tracey for the whole time it was deliberately omitted from the company accounts as instructed by Mr Tracey.
In the context of a police review Mr Scott has beyond reasonable doubt concealed material evidence in respect of these points in an attempt to pervert the course of justice.
2. Mr Iain Scott wrote to DC Stewart of Police Scotland on 15 April 2016 including the following statements, reproduced here in italics for convenience:
‘The second document is Production 11, which is the ‘’Strathclyde Police report on Enterprise Ayrshire’’. You will see that page 14 of this document is the same bank statement that he has recently sent to you.’
Firstly, I did not present this document to Scottish Enterprise or to the police in this civil action, which was an action for defamation against a private individual.
Mr Scott’s assertion that this evidence was contained in the productions in a case against a private individual is entirely irrelevant and disingenuous in the context of this review.
Neither the police nor Scottish Enterprise had any valid involvement in this case.
However, the fact that Scottish Enterprise holds such documentation indicates that Scottish Enterprise, a public authority, was indeed improperly, unfairly and unlawfully involved in assisting my opponent in a civil action which had nothing to do with Scottish Enterprise or the police.
Scottish Enterprise was neither the pursuer nor the defender in this case. Why does Scottish Enterprise hold these details about me and why has Scottish Enterprise disclosed such details about me to the police? I believe this is a serious breach of the Data Protection Act 1998 and another indication that Mr Scott has beyond reasonable doubt concealed material evidence in an attempt to pervert the course of justice.
Mr Scott’s scanned documents on this case in his communication with DC Stewart clearly identify it as the case of Edward Edelsten Cairns v Andrew Downie.
The inclusion of this single page in the productions was in any event incidental. It happened to be included in the 36 page Scottish Enterprise report but there was no reference at all to this page in the case record.
Since the police informed me that their copy of this report was destroyed around the year 2000 this document would not have been available to the police for about the last 16 years.
In any event the Police Complaints Commissioner for Scotland rejected my provision of a copy of this report for consideration in its review of the Police’s handling of my complaints, as recorded in the PCCS report on this case dated August 2010.
As for any recorded consideration of this document by the police, none exists.
The Scottish Enterprise report falsely stated that this bank account was in the name of Enterprise Ayrshire and made no mention of the fact that it was plainly shown to be in the name of GARY TRACEY C/O ENTERPRISE AYRSHIRE.
‘C/O’ means ‘at the address of’.
Therefore this bank account, according to documentary evidence, was in the name of Mr Gary Tracey at the address of Enterprise Ayrshire.
Further, including the words ‘‘STRICTLY PRIVATE AND CONFIDENTIAL’ and ‘ALL ENQUIRIES TO GARY TRACEYTO ANDREW DOWNIE NO-ONE ELSE’ on the face of this bank statement was clearly abnormal and gave rise to a reasonable suspicion of financial irregularity but the Scottish Enterprise report completely overlooked this.
Mr Scott’s inclusions of the Strathclyde Police report on Enterprise Ayrshire and other productions in the scanned documents he sent to Police Scotland on 15 April 2016, which report Scottish Enterprise knows was in fact produced by one of their accountants Ms Mandy Dickson and not by the police at all, give rise to some important considerations:
(a) The police informed me that their copy of this report had been destroyed several years ago, around the year 2000.
Its provision to Police Scotland by Scottish Enterprise now permits perusal of its contents in the light of the available evidence.
(b) The first matter of concern is the amount of evidence concealed by Scottish Enterprise and the police, including in the recent review, as already detailed above and further detailed below.
(c) In his communication with DC Stewart Mr Scott included a scanned copy of my reconciliation showing the omission of the £187,069 in question from the company’s balance sheet as at 2 July 1993.
The report falsely stated that there was no evidence that this reconciliation had been carried out.
(d) In his communication with DC Stewart Mr Scott included a scanned copy of my email to Mr Gary Tracey and Ms Janie Maxwell dated 17 August 1993 which stated the following, reproduced here in italics for convenience:
‘For the record, as I said to you both today, I am not comfortable with your instruction to exclude from Enterprise Ayrshire’s balance sheet funds received from the EC.’
‘Your comment that the management accounts do not matter so much, being produced only for internal use, seems to underplay the potentially serious consequences of circulating figures that are incorrect.’
‘I stated to you both that I know this aspect of Scottish Enterprise’s finances is under investigation by the National Audit Office therefore you must accept my concern as genuine.’
‘I have been advised that such omissions from management accounts are in breach of the Institute’s ethical guidelines.’
The report completely excluded this very important evidence.
(e) In his communication with DC Stewart Mr Scott included a scanned copy of the extract from the manual cash book showing the following words at the record of £187,069 received on 25 June 1993, reproduced here in italics for convenience:
‘NO JOURNAL REQUIRED AS PER G.TRACEY’
The report referred to a later version where the words ‘TO GO THROUGH JULY ACCOUNTS’ had been added.
The report offered no explanation for this note, which corroborated my allegation of having been instructed by Mr Gary Tracey to falsify the accounts in respect of this receipt from the European Regional Development Fund.
Further corroboration is provided by the actions of other finance staff who acted in accordance with Mr Tracey’s fraudulent instructions to falsify the accounts
(f) In his communication with DC Stewart Mr Scott included a scanned copy of the SE report which concluded the following, reproduced here in italics for convenience:
‘The receipt of ERDF money was brought into the July financial ledger on 18 August. The money was received in June 1993 and should therefore have been accounted for in this month.’
This conclusion justifies my concern about the Enterprise Ayrshire accounts as they stood when I wrote my email on 17 August 1993.
In his communication with DC Stewart Mr Scott included a scanned copy of a press release in the following terms, reproduced here in italics for convenience:
‘STATEMENT GIVEN TO KIRSTY SCOTT, THE HERALD regarding allegations of mis-accounting at Enterprise Ayrshire’
‘Scottish Enterprise National took these allegations seriously, and investigated them thoroughly on the day that they were made. There is no substance to any of the allegations made regarding the receipt of European funds by Enterprise Ayrshire. Our enquiries are complete and there are no grounds for taking any action.’
‘Issued by the Press Office of Scottish Enterprise’
‘September 1, 1993’
Since the accounts had been corrected by £187,069 within hours of my written objections to the financial irregularities, plainly the press release was false.
Mr Scott included a scanned copy of this press release in his communication with DC Stewart. Clearly, Mr Scott is persisting in concealing material evidence and knowingly providing false information to the police to this day, a very grave matter.
Separately, there were several other new items of evidence submitted recently to Police Scotland which have either not been adequately considered or not considered at all by Scottish Enterprise, or by the police or by the Crown Office.
These appear to have been completely disregarded, which indicates beyond reasonable doubt that the police have colluded with Scottish Enterprise in a disgraceful attempt to undermine my credibility, to conceal material evidence, to avoid carrying out a proper investigation into alleged criminality and to pervert the course of justice in this case.
In his communication with DC Stewart dated 15 April 2016 Mr Iain Scott, Scottish Enterprise’s Chief Financial Officer and Company Secretary, indicated in the following terms that he would shortly be providing a statement on this case for Police Scotland:
‘I look forward to hearing from you next week regarding you coming in to our office to take a statement.’
Mr Scott’s statement did not lead to any report from Police Scotland to the Crown Office and Procurator Fiscal Service, which raises a reasonable suspicion that in his statement Mr Scott misrepresented the evidence he had attached to his email to DC Stewart on 15 April 2016.
Mr Scott had provided a copy of the original Scottish Enterprise report and other scanned documents that are rather obviously incompatible with that manifestly defective report, without qualification, comment or explanation, indicating that important evidence had been concealed by Scottish Enterprise in 1993 and again in April 2016.
Why then was no report submitted to the Crown Office and Procurator Fiscal Service following on from the review by Detective Chief Inspector Kenneth Thomson, Detective Sergeant Steven Adams and Detective Constable Yuan-nee Stewart which was completed in May 2016?
In these circumstances the fact that no report from Police Scotland has been submitted to the Crown Office and Procurator Fiscal Service cannot be relied upon to mean that there was no reasonable suspicion of criminality that ought to have been reported by the Police.
The Chief Constable has not provided a reason for failing to respond to my communications in this case which included the presentation of new evidence and evidence that has not been adequately considered or has not been considered at all by the police.
If he is relying upon the recommendation from the PCCS to Strathclyde Police in 2010 I submit that the recommendation was directed at police complaints. It was not intended, nor could it lawfully be intended, to apply to the presentation of new evidence or evidence that has not been adequately considered or has not been considered at all by the police.
The application of the PCCS’s recommendation to nullify the consideration of evidence of criminality that has not been adequately considered or has not been considered at all by the police may reasonably be regarded as an attempt to pervert the course of justice.
The PCCS did not have the authority to nullify proper policing by means of any such recommendation and if the Chief Constable is indeed relying upon the PCCS recommendation to disregard evidence of criminality that has not been properly considered he is failing to act in accordance with professional standards.
Such conduct amounts to no less than the deliberate concealment of material evidence in this case by the Chief Constable, a very serious matter.
If the Chief Constable is refusing to respond to my correspondence for some other reason I believe I ought to have been informed accordingly.
Failure to inform me either way is a breach of professional standards by the senior officer.
If you think the officer ought to be given an opportunity to change his mind please notify me. As things stand, however, I believe that it is reasonable for me to proceed in accordance with the existing stated position by the Police that I will not receive any further correspondence from Police Scotland in relation to this allegation.
The details provided above and in my previous correspondence indicate beyond reasonable doubt that the police, under the direction of the Chief Constable, have colluded with Scottish Enterprise in a disgraceful attempt to undermine my credibility, to conceal material evidence, to avoid carrying out a proper investigation into alleged criminality and to pervert the course of justice in this case.
Consequently I want to raise a formal complaint against the Chief Constable of Police Scotland, Mr Philip Gormley, in respect of these failures.
I will shortly provide further supporting evidence in subsequent emails.
Please inform me if you prefer the allegations and evidence incorporated above brevitatis causa into this complaint to be provided again in detail separately.