Statement 4 From BIG International

PART 1:

When the British drove themselves into Civil War it was because they wanted equal civil and political rights related to freedom of action. To even consider Civil War in the United Kingdom today would be a point furthest from the minds of the majority of UK Citizens.

Today's UK Citizens believe they have elected a Parliament of free MP's, who will always act in the Citizens best interests and protect their civil and political rights, which they have fought so hard to achieve.

All around the world we have listened to reports related to civil unrest within the United Kingdom. The British Government named flash points of civil unrest as something not within the Public Interest and developed government departments to deal with such situations. These Government Departments have now become a power unto themselves, with legal powers far above those of the nation's police force.

When such a situation develops it normally means something has gone seriously wrong within a freely elected democracy. Such developments normally mean that something or someone is pulling the strings behind the corridors of power.

Therefore, the Citizens of such a nation must ensure they correct that situation within law and show their elected government that they will support them against such situations. The controlled attacks are normally against a government's exchequer. The exchequer is the most exposed structure in society, because it holds the key to any given nation's wealth, assets and development.

The United Kingdom has seen strike after strike, which were brought under control by destroying internal industrial development, eventually allowing these assets of the United Kingdom to fall under the direct control of the very organisations which directly or indirectly organised the strikes by financial starvation.

If, as citizens of other nations around the world, we take the time to look at what has occurred within the United Kingdom since the late 1970's, we will start to understand the situations that are stealing the assets of our own nation, especially citizens in the United States.

We within the United States have seen President after President humiliated or directed away from doing what is correct for our nation. If a President was really strong and stood by the Citizens he would actually gain the support of our Citizens. Unfortunately in these circumstances, the powers behind the scenes find their influence and control becoming weaker. They look to do a deal or discredit the individual holding the power. If this fails the death of such an individual follows.

Here we have shown two broad aspects of a nation's government under control from outside sources. We have to ask who is responsible? Who is responsible for the current misuses of law by the British Government? Who is responsible for the situation which can discredit one of the strongest nations on earth? . . . the United States.

We could hold the financial institutions responsible as they can clearly be seen as organisations that manipulate our governments. We can hold the 'financial robber barons' behind such institutions as being responsible. We can blame the difference in understanding between various political parties. And so it goes on. There are many areas where we can allocate responsibility, fault or blame.

When you think about this question, there are too many avenues that we can direct our blame towards. Each of us with our own points of view on religious, political and work aspects, will accept one of these avenues. We usually find that one of these avenues will enable us to enter our own comfort zone and provide our personal escape from blame.

Unfortunately, we have to question why there are so many avenues of blame opened up to us? It's as if someone or something needs us all to blame something else, which unfortunately reminds me of Divide and Rule.

Let's develop these points into the form of a conversation.

"So are you saying that 'I' the individual am responsible?"

"What we are saying is that there are too many avenues of responsibility for each of us to fall into".

"So you are saying, 'I' the individual am responsible".

"Only the individual, not an organisation, can answer this question by looking at who or what we find responsible for current situations".

"How do you mean?"

"Well let's take my individual situation. I know while preparing this statement about the actual controls the financial institutions held over my life. I also know that before joining and helping the development of BIG International, I banked my wages with one of these financial institutions. I worked for an organisation that was in debt to one of these financial institutions. I worked for a boss who was also in debt to one of these financial institutions. I purchased my home, car, furniture and other goods by debt from these financial institutions. I had actually sold my future to these financial institutions and paid for the privilege.

When 'I' wanted to actually develop my understanding of my life and religion, 'I' found that 'I' had actually sold the major part of my adult life to the financial institutions. 'I' looked around at what 'I' felt 'I' owned and realised the financial institutions owned me lock, stock and barrel, plus the fact they had law on their side, because 'I' had contracted to this situation.

In my case, 'I' searched for who was responsible and found many avenues. It is easy to find an avenue of blame. For the first time 'I' didn't feel comfortable, 'I' knew exactly what 'I' had done. 'I', in my early adult life, had sold my free gift of life for a hand full of silver, maybe only to the value of thirty pieces of silver.

'I', for the first time in my adult life looked into what 'I' had actually done. 'I' decided to correct what 'I' had done and pay to get my original gift of life back. For me, it`s worked. 'I' have started to feel the beauty of freedom again, the joy of being with true friends and an inner happiness that others have noticed within me. Yes, 'I' learnt to look at holding myself responsible before taking one of the comfort avenues provided".

"So you are saying that the individual is responsible. In fact, you could say that you are holding me responsible."

"No. What 'I' am saying is that 'I' cannot hold someone else responsible until my own house is in order. And when my own house is order, 'I' still cannot blame or judge the actions of others towards me until 'I' have checked that my actions towards others, haven't damaged their rights. It's only when my own house is in order that 'I' can be truly there for the one's who care for me."

"Yes, but this isn't the answer to the attacks upon BIG International within the United Kingdom."

"Isn't it?"

"Well I don't really know now. I feel I should know but somehow, in this communication, you have removed my ability to assign responsibility for the actions taken against BIG International. Before it was easy. It was the people at the 'DTI' or the Judge. Now because of your article I have to consider the situation from my own point of view".

"No one else can think about your situation, so let's look at it together."

"OK."

"But remember only you can finally decide. Only you can be responsible for any blame attributed to your current situation within BIG International.

You have either met, read or have heard others talk about BIG International. You hear that BIG International provides a totally free lottery, what we call a 'Lottery for life'. From reading BIG International's information pack about its aims and organisation, you realise that BIG means 'Business Incentive Games'.

"Business", because interactive relationships between individuals is a structure of business.

"Incentive", because if we as individuals interact correctly together, our rewards are greater. But we have to also learn to share those rewards with others equally for true incentive of action to take place.

"Games", because many wise individuals have likened each learning step we take in life to the 'game of life'. What we say is that the playing field must be made even, in relation to the developing ability of each individual to participate, hence the free lottery."

"Yes I understand this, but I must admit that I had never truly thought of the meanings behind the words before. On reading the information pack I could clearly see that the lottery was in fact free and if I wanted to try I was free to do so. All I would have to send is the postage return cost, (via stamps or coupon) for receipt of my free lottery number, and a copy of the current newsletter, for my number range. This I thought was correct. I couldn't expect others to pay for my postage costs, especially when the service they provided gave another opportunity to my life."

"Right, so you made a free choice to join an international organisation. A choice that you believed you held the right to make as a free person within a democracy founded upon freedom."

"Yes, but I didn't even think about my rights. I just felt an opportunity like this was certainly worth looking into and all my loss could possibly be was my postage cost."

"During your period of playing the free lottery, you have seen BIG International grow and develop. Other organisations have joined BIG International and each provides a service that could possibly help you in your life. You have also seen each and every commitment statement made by BIG International met to you. In other words they have maintained their stated obligations to you."

"Yes this is true. Sometimes I had to read the information several times to obtain a full understanding and by taking this care, I started to realise exactly what you were attempting to achieve. It's hard to comprehend because BIG International's aims are so simple."

"Thank you. Now comes the problem. The aims of BIG International are simple but that simplicity is a threat to the current system of thinking. It provides an alternative and if alternatives become too strong, they can pass control of your life back to you, which makes you a truly freethinking individual."

"Now I see your point about the 'DTI' and the 'Judge'. They are actually protecting the rules made by the system which have taken my humanitarian right's away in relation to joining BIG International or in fact any other organisation I may wish to join."

"In a nutshell, you have answered the situation for yourself. If you are happy with that then maybe you should support the actions of the 'DTI' and the Judge. But if you feel this is wrong, then we have to work together to change the law within the United Kingdom to return your rights to you."

"I was happy until I realised that my rights have been removed by the actions of a self regulating financial structure that has structured laws ratified by government to remove my rights of independent action. In fact I now feel angry with myself for not realising such institutions have developed such powers over my everyday life."

"I'm sorry but this is a fact of life within the United Kingdom today."

"But what can I do about it?"

"Well that is an extremely good question. Let's look at it again. 'BUT WHAT CAN I DO ABOUT IT?'

You could go on the streets and march like women did in the United Kingdom when they wanted the simple right to vote. You will find the British Government has these types of demonstration well under control, because such action can cleverly be shown as detrimental to the Public Interest, eventually discrediting the organiser by rent a mob tactics.

You could take to riots and blowing up given institutions property and if you are violent enough, history shows that the British Government will work out a way of coming to terms.

You could mount a petition, collecting millions of signatures, which will then be stored where the British Government stores all other such petitions, All the names on that petition will then be placed onto a computer to ensure an eye is maintained locally on the individuals who signed such a petition.

You can simply continue to play the BIG free lottery and allow the government to show their cards even further in relation to your personal rights.

Or you can simply walk away and request a total money refund from any organisation introduced to you from BIG International's published information packs. Our doors will always be open for you to return.

You see, only your own direction in life, and what you believe is right can take you forward in your life. We could suggest many alternatives but the simple fact is, the financial institutions have removed your right to belong to any organisation not condoned by them. Let us repeat that. The financial institutions have removed your right to belong to any organisation not condoned by them They have also removed your rights to use your earned income how you decide. In fact, with the support of your government and your legal system, they have you and your finances totally under their control.

Now you can see the total situation in black and white. No grey areas. Nothing hidden. You are owned by the financial institutions of your nation. Your actions from this point must be yours but what we would suggest is that you seek legal advice in relation to your legal rights."

PART 2:

AN IDEA FROM A PLAYER

What I started to do was read all the forms that I receive in the post and then question the ones that state something like the following:

"False statements or failure to complete and return this notice within 21 days of receipt may result in prosecution."

I question how can any government department make threats against me? Have I even had the chance to consider the information required? By the way, this warning was on form VO 6000 (4/98) for Business Rates Revaluation 2000.

My wife and I always pay our business rent and rates yearly in advance, and this government office sends us a form that sets out a threat, then requests private trading information related to our business.

They quote that "this Notice is served under Paragraph 5 of Schedule 9 to the Local Government Finance Act 1988. Then it goes on to state, 'It is my belief that the information requested will assist me in carrying out functions conferred or imposed on me by or under Part 111 of the 1988 Act."

The moment they sent this form to our business it meant that either my wife or I could face prosecution within 21 days. Again my rights have been removed without notification or justification.

In my mind they should send us our rate bill and we should pay it. But no, they also wish to know all the private affairs of my company. Now can you see what is happening in the United Kingdom? Threat and intimidation is the first action of British Government Departments against its own Citizens. This is only one example of such forms, which remove your rights. One should notice that nearly all of these forms relate to a given Finance Act and who writes the rules that make up these acts? . . . the financial institutions.

I felt that I should ask the Valuation Officer for a copy of the ACT. He told me to go and buy one. Then stated he couldn't see what all the fuss was about. He's told me the information that he wants and I MUST comply. This public servant was totally oblivious to my Civil Rights, and so was I until the actions taken against BIG International.

My wife and I believe there should be a range of citizens forms to enable citizens to deal with situations which infringe or could infringe our civil rights. One form could be as the following:

IN THE CASE OF A PUBLIC SERVANT ENTERING YOUR HOME, GIVE THIS DOCUMENT TO THE PUBLIC SERVANT TO COMPLETE.

Public Servant's Questionnaire

Public Law 000 - 000 states in part: "The purpose of this Act is to provide given safeguards for an individual against invasion of personal privacy by given government departments and to permit an individual to determine what records pertaining to him/her are collected, maintained, used, or disseminated by such government department.

The following questions are based upon that act and are necessary in order that this individual may make a reasonable determination concerning divulgence of information to this government department.

Name of Public Servant:

Name of government department by which public servant is employed:

The mailing address of government department, from which the public servant came:

Did public servant furnish proof of identity? YES / NO Tick Accordingly

What is the nature of such proof of identity?

Will the public servant furnish a copy of the law or regulation which authorises this investigation YES / NO Tick Accordingly

Will the public servant read aloud the portion of the law authorising the questions which will be asked? YES / NO Tick Accordingly

Are the answers to the questions either voluntary or mandatory? VOLUNTARY / MANDATORY Tick Accordingly

Are the questions to be asked based upon a specific law, regulation, or are they being used as a discovery process?

What other uses may be made of this information?

What other government departments may have access to this information?

What actions will be taken against me if I should choose not to answer any, part or all of these questions?

Name of person within government department requesting that this investigation be made?

Is this investigation 'general' or is it 'special'?

Have you consulted, questioned, interviewed, or received information from any third party relative to this investigation?

If so, the identity of such third parties.

Do you reasonably anticipate either a civil or criminal action to be initiated or pursued based upon any of the requested information?

Is there a file of records, information or correspondence relating to me being maintained by this government department? If yes, which?

Is this government department using any information pertaining to me, which was supplied by another agency or government department?

May I have a copy of that information? YES / NO Tick Accordingly

Will the public servant ensure that the information in these files will not be used by any other government department, other than the one by whom this person is employed by? YES / NO Tick Accordingly If NO state why:

If any request for information relating to me is received from any person or agency, you must advise me in writing before releasing such information. Failure to do so may subject you to possible civil or criminal action as provided by the act.

I swear (affirm) that the answers I have given to the aforementioned questions are complete and correct in every particular.

X_______________________________ Date________/________/________

Witness:_________________________ Date________/________/________

The base of this questionnaire, with some slight variations from BIG International, was taken from "Advanced Freedom Solutions List". They have completed some remarkable research, in relation to the rights of the individuals. Their site is well worth a visit even if it's from general interest – http://ww.buildfreedom.com.

By providing this example of a self protection form, you can now see the sad state that democracy served by public servants has actually reached. When you consider that the public servant, who we pay to work for us, is actually doing the dirty work of the financial institutions. (Mr Bott of the DTI can be seen as a prime example. See Mr Bott's actual sworn statement at the end of this report).

Again you can't hold the public servant responsible. We can only take responsibility ourselves for allowing our society to reach such a sad level of democracy. I have to ask what is the next level of this particular situation? It may be we have already reached it without even knowing. Most of us have reached this level without realising how many of our Human Rights have actually been removed by self-interest groups, groups that protect the financial institutions from both the British Government and British Citizen.

PART3:

INTERVIEW WITH MR GRANT

We now turn to an interview held with Mr Grant by James Sancton.

S: "Mr Grant, you have permitted me to ask questions of you in relation to current and past events in your life. Is this correct and true?"

G: "Yes your statement is correct."

S: "Why have you taken it upon yourself to expose structures of corruption within the United Kingdom?"

G: "Any structure or system which corrupts the gift of life of any member of the human race from birth must be wrong. Especially if it's against the teachings of our faith, which represents our understanding of moral law. These teachings are provided to us from a very early age by the entrusted Custodians of our faiths. If this is not correct, the what was the purpose of Religious Education, Sunday School or any of the Religious Books handed down by generation after generation?"

S: "Surely, this answer is a cop-out. If we all started using the teachings of our faith, current society wouldn't be able to function?"

G: "I cannot answer your assumption to my previous answer if that is your view. I must respect it and determine my own actions. If this is a cop-out then the answer is yes.

You then use an interesting word, 'using'. This assumes that by learning the directions of faith, provided to us by our Creator and attempting to follow this path, I can be seen as 'using' my faith. Well I do hope this is correct. But you could also mean that I'm 'using' my faith to hide from the laws of society. This is not correct. Therefore, if what your question is stating is deemed to be correct, that current society wouldn't be able to function, then something is either very wrong with the Commandments handed down to us by our Creator or society is wrong. This would also mean that which was created as greater understanding of the direction given to Humankind than the Creators. If this is the case, there would be an emptiness left within millions of people around the world who have faith.

I believe that we are in service to our Creator to learn from our mistakes in relation to the teachings of the faith that I was placed into from conception. Over many years I have questioned my faith and searched for one which seemed more acceptable to me as an individual. This was as if I was saying that I knew better than my Creator, which led me to realise the true opportunity I had actually been given by my Creator. To learn, respect and accept that there are other faiths relating to given cultures. But this doesn't mean the directions of faiths are any different when determining the final conclusion. Only our Creator would know this. If this isn't correct then I can see no point to life. To be forced to believe that I was created to serve the bully or the human with the most power, are non related structures of Creation that are totally unacceptable to me.

S: "Why do you think a British Government Department brought about their action against BIG International?"

G: "I wouldn't say that they brought about the structure of their actions. From what I understand, BIG International is thinking differently in relation to the way that the British Government or any of it's representing departments are structured to work. When a section of the British Public wish to develop an alternative to the currently controlled structure, the British Government always attempts delaying tactics in the hope that the alternative goes away. When the alternative still doesn't go away the British Government flexes its muscles through various government departments. If this fails the British Government tends to force its view over by trying to find a solution, and the solution is normally a sell out. You have seen this in every aspect of British History. It is an old Government system which still believes in control regardless of moral law or Human Rights. This is how I see the situation within the United Kingdom. Therefore when dealing with BIG International, which isn't a legal identity in the United Kingdom, the only course open to them is intimidation of British Citizens, hence you get the situation of the current six defendants.

S: "I understand that the motion to finalise the winding-up-order will be in Court on the 8th July 1998. What are your feelings in relation to the use of Law in this situation?"

G: "I think your question is trying to get me hung as well as committed to prison. Let me explain how I see it. We have British Citizens using their free right of choice to join an international organisation. That seems fine to me. Now I feel for the judge in this situation because his judgement on the 8th July 1998 will hold many ramifications. The most important of these, in my mind, is that the British Citizen will have a major area of his/her Human Rights removed in one judgement . . . if the Judge allows the use of British Law in this way by a British Government department. Therefore in my eyes the question is simple. Will the judge uphold Citizens Rights or the British Governments structures of control? If he upholds the British Governments structures of control, then the British Citizen will now hold no rights to join an international organisation of any kind, especially in the areas of personal financial development. No right to spend personally earned income outside the control of the British Government.

The British Government have already taken our rights to spend cash privately. If you don't believe me, then go and try to buy a house for cash, or anything of reasonable value. In fact try to use cash and all the various agencies will start to invade your privacy. If you attempt to purchase the same articles via debt, then all is OK with the British Government. Therefore the British Government encourages expenditure via debt, rather than the old fashioned way of actually saving for what you want. You could say "put your cash into a bank", but if I do this then I'm simply back under control. You can't even pay for your legal costs via cash, because solicitors are controlled by the Law Society, who basically demand to see the money come from a bank. All a total invasion of personal privacy. From what I can see, the majority of people within the United Kingdom do accept this situation. The attitude is one of complacency, and "what can I really do about it in any case?". They already know that the financial institutions actually run this country, and not the elected government. When it's too late, the actual financial crash will come, throwing millions of people into poverty yet again. We seem to learn absolutely nothing from history or the teachings of our faiths until it's too late and many suffer. This is why I feel that it is wrong for any British Court to attempt to close down an alternative, which British Citizens freely choose for themselves."

S: "There have been many reports in the media basically pulling you apart, using names which would certainly upset me and most other people. Why don't you retaliate?"

G: "Basically life is too short. Providing I believe that my actions are correct, I will strive to complete that which I believe is correct. The problem comes when others start to believe in what I'm attempting to do and help me, making the situation a joint effort. For some reason British Government Departments see individuals working together as a threat to their authority. Maybe it is, but when this authority is controlled by sources outside government then I have a duty to protect my civil rights and moral rights. Without this same duty being carried by others of past generations, we would all still be living in the age of barbaric control by a divine leader, who was basically the biggest bully of the time.

S: "Are you concerned about current attempts to have you committed to prison?"

G: "There are two such situations. The first relates to a charge from the 'SFO' relating to lack of co-operation. This was after several days and many hours of interviews producing sixteen tapes of interview information. This was after my mothers home having been raided several times by given authorities, taking every piece of private paperwork and returning none. When I asked for such paperwork to answer given questions they refused. So the current situation is they have all my personal paperwork, and now they are going to commit me to prison for not having the paperwork which they have already taken.

In the second situation, this relates to Inner Sanctum. I openly agreed that I would not become involved in financial services. I have never been involved within financial services and never intended to become involved in financial services. This is why I agreed to such an order being made. (In other words the order didn't affect me, as an individual in relation to the direction that I wish to follow in my life) How they can now say, that I have broken that order is far beyond belief. It does concern me because I believe this to be a misuse of British Justice. It does concern me that in both cases I'm not to be permitted my rights to a correct trial or a jury. In other words I would clearly state that the committal proceedings are being brought to silence and discredit me in relation to the developing Inner Sanctum case against the British Government.

The first committal case has already cost over ten thousand pounds in legal fees. The second case has already eaten through twenty thousand pounds, with a further twenty three thousand pounds to be paid. Fortunately, I have been financed from donations from individuals who believe in my fight to place the 'J' back into justice.

It must be remembered that I have never failed to let it be known that I have already been to prison twice. The first occasion I walked into a Police Station and arrested myself. I was fighting against the corruption within retail and took a wrong turn. I stole money, which they called fraud to fight the original corruption, but my mind became split due to the guilt that I felt. This stopped me from moving forward towards my goal, hence the reason for arresting myself. The case came to court after a year had elapsed. I had offered to repay all the money. I had built up a successful retailing business serving the community of East London. This was my first offence ever, for which I was given three years in prison. People have asked me do I feel bitter? The answer to that is no, because I believed that I had paid back my debt to society and gained so much knowledge. On my release, I started to rebuild my life, helping some friends to develop a building company. The company started to grow and I advertised for an investor to take part. Because I wasn't part of an organisation that could accept such investments, I was given a further two and half years in prison. While waiting a year or so for the trial to come up, I had built a highly successful wholesaling business, serving several hundred retailing outlets on a weekly basis.

The case was an absolute shock. People gave evidence who I had never seen. The prosecution's witnesses were allowed to sit in court and follow the case before they took the stand. I had never experienced such a situation in my life, but here it was happening. This taught me just how corrupt justice is within the United Kingdom.

In both cases of imprisonment there was no rehabilitation training. There was no direction for my future life upon release. During the first month of my imprisonment one of my major warehouses was raided, paid for property was stolen, while the police looked on. I was finally made bankrupt while in prison, because I had signed a lease upon a building associated with the wholesale business.

I served my time of imprisonment and my five year term of bankruptcy, and had an opportunity offered to me within Saudi Arabia in 1984. I left with one hundred pounds in my pocket that my Mother had given as a loan, and a luggage case which she had bought for me.

Thanks to Saudi Arabia and Islam I had been given the opportunity to rebuild my life. On my return to the United Kingdom in 1989 the original harassment that I had faced from authority started again, but this time I was determined to fight such harassment all the way.

Yes it does concern me when British Institutions and Government Departments attempt to take ones life away. All I can say is the knowledge and experience I have gained, has certainly given me the opportunity and strength to consider and see where the actual problems lay, hidden within our society.

Now more and more individuals have seen what is happening, so my part is of little importance now. If they send me to prison this time, there are many who will take my work forward, and continue the fight to protect all our rights related to Humanity and Moral law."

S: "I understand that you work almost nineteen hour a days, and that you haven't taken a break since the early eighties. Would you say that recent pressures placed upon you have started to affect your health? Would you say that your current deterioration in health is directly due to the harassment received from British Government Departments?"

G: "My work is my life. The amount of hours is basically related to the pile of paperwork which seems to be constantly in front of me. Recently others became concerned for my health and finally a Judge ordered a full medical report. On this occasion, I decided to go to a totally independent organisation and Doctor, but because the Doctor's report was one day late, the judge decided not to take it into consideration when setting a date for trial. Never mind, that's life.

After reading the medical report of Dr Neil D Haughton BSc(Hons) MB BChir DCH DRCOG DFFP MRCGP. I realised how little time I actually had left at this level, to complete my work. Then came the unexpected Winding up Order of BIG / Courtney, with me named as first defendant, followed by the second committal application from the DTI already mentioned.

Believe it or not this situation came as a relief at first, because I believed at long last I was going to be in a position to place this whole situation before a British Jury. Therefore, you can imagine my surprise when I was informed that I was to be denied a Jury in open court before a Judge. But life and work must go on.

What really drags my energy down and really makes me feel tired, is fighting for the human rights of thousands of people who I believe in, and who placed there trust in an organisation which I eventually took the legal battle on for, Inner Sanctum. It must be remembered here, that I only took an interest in Inner Sanctum when it was being attacked by Government departments. I was never a member and never received any payments from the organisation. I really had become involved in a can of worms, but I totally believed in the concept and the originator behind Inner Sanctum and still do today, hence the reason for current actions against me.

So you see it`s not the work or hours, it's the hurt you see in people who have suffered due to illegal actions taken by a British Government Department, against organisations which offer a way forward that is outside the control of the financial institutions . It's the hurt you feel when you read statements from the Civil Service, that do not relate to truth. These hurts are the ones which drain my energy, not media reports or personal attacks upon myself.

It is also the hurt you feel when you see the society within which you live, have absolutely no feelings or concern, for those who gave their life or a percentage of their life for our Humanitarian Rights. Most within our society take so much of this for granted until they realise their rights have actually gone.

So yes, I do take the medical report seriously, and yes there are many individuals who now share my original load, but the feelings within one remain until the problem is solved and society's laws start to relate more closely to moral law.

S: "I understand from asking around that you are self-taught. Has this been a draw back in your life?"

G: "Without going into the ramifications of the problems of education I would say no, from the point of view that I do not believe I would have had so many wonderful learning experiences in my life.

It got to the point where I stopped worrying about the lack of my original education and started to learn in some cases from mistakes of my own and the education obtained by others. In other words I directed my ability to educate myself towards the task in hand. If I couldn't achieve or understand something I was never afraid to ask, regardless of how stupid I may appear.

This structure of learning actually broadened my educational horizons. You must understand, I have never been ashamed of being born in Old Street in London or moving to a GLC Council Estate in Romford. From a child I have always shared what ever I had. It provided me with enjoyment to share. In return, I have found that people have always been there for me during what some may call bad times.

Even my experiences in prison made me realise how fortunate I was. Many other prisoners would talk to me all through the night, sharing their personal experiences with me. They came from all walks of life, and each story confirmed to my mind that there was something drastically wrong, even then.

I would say, if you keep asking questions, without becoming distracted from your own learning goal, then you will start to feel the true beauty of educational advancement. I was fortunate, I had a Grandparent and a Parent who only wanted me to push for what I believed in for the direction of my life. Yes, they both had expectations, but they did not force their expectations upon me, except to believe in my Creator and serve others in duty."

S: "Would you call yourself a Religious person?"

G: "I really do not understand what a religious person is. You see I believe we are all born equal and my Gran always told me to remember the only fair thing in life is death, because that is our personal day of judgement. Death I have never feared, because I believe that I have always tried to face up to what I did wrong while I'm still alive. Yes, it makes life harder, but the advantages are considerable. Just being able to walk down any street in the world and having no fear of whom I may meet is a wonderful aspect of life for me. Never having to look the other way or duck out of the way of someone makes life for me. Always being available to face my accusers is energy for me. All these things make me the actual person that I have become thus far.

The second part of Mr Grants interview will be within Statement five from BIG International. Mr Grant's medical report is also released to enable all members of Inner Sanctum and Players of BIG International to understand Mr Grant's dedication to work and the advancement of Society, away from the controls brought about by the Financial Institutions within the United Kingdom.

We will also be requesting Paul Hesling to complete an interview and many others involved within Humanitarian work.

Due to the illegal actions taken by given British Government Departments against BIG International, we have been placed into the situation of a massive increase in the number of Players joining the Free Lottery, from all around the world.

Germany has now become our fourth largest Player Nation. France and Portugal have trebled their number of Players. Also considerable growth is now developing in all other nations throughout our global society. The public response to the DTI's actions have even shocked us.

The most surprising aspect of all, is the response we have seen here in the United States. The offers of help coming in from American Players to assist the 15000000 number range is quite amazing.

The surprise shown by some Americans to the attitude of the British Government and it's relationship with the Legal System towards British Citizens Human Rights, has caused considerable debate about the British Government's rights of acceptance within the United Nation's assembly. This is due to its total indifference to Humanitarian Rights for it's own Citizens.

We in America realise the shortfall of our own system when related to Human Rights. But we didn't realise just how free we actually are when compared with one of our closest allies. In the past we just complacently accepted the true values that we have actually gained, when we obtained Independence from the British system of rule. We have made many mistakes as a Nation in growth. I am pleased we decided to grow away from a governmental and legal system, which the world has recently seen by British Government actions, within the United Kingdom against its own Citizens and BIG International.

BIG International isn't even within the legal jurisdiction of the United Kingdom. The arrogance of the British Government, is well beyond acceptance within International legal systems of law. We will be spending a percentage of our legal fund to bring the British Government before the International Courts, for breaking the internationally accepted rights of all within all nations to be permitted to trade and develop equally with each other.

PART 4:

LETTER FROM DR NEIL HAUGHTON:

MEDICENTRE
the plaza
second floor
oxford street
london w1n 9dp

25th June 1998

Re: Mr Raymond Patrick Grant

TO WHOM IT MAY CONCERN

This is to confirm that the above named consulted me first on 27th April 1998 and that I carried out a full health assessment at that time. I saw him on one other occasion for a follow-up appointment.

One of my conclusions at this time was that Mr Grant was suffering from numerous stress related symptoms which included insomnia, lethargy, poor concentration, headaches, panic attacks, 'blank' episodes and difficulty carrying out any work. Mr Grant felt that these problems had been present for around 12 months but had worsened considerably in the few weeks prior to consultation.

I recommended to Mr Grant that if he didn't reduce his workload and other commitments, he may suffer from a mental breakdown as well as physical exhaustion.

It is also my opinion that should any further stress be imposed upon Mr Grant, if his mental state remains low, it would be very likely to lead to further mental illness. This may include severe depression and/or anxiety related disorders, which may in turn contribute to physical illness.

Should you require any further information regarding Mr Grant's health status, please do not hesitate to contact me at the address above.

Yours sincerely

Dr Neil D Haughton
BSc(Hons) MB Bchir DCH DRCOG DFFP MRCGP
General Practitioner, Medicentre

PART 5:

THE AFFIDAVIT OF MR PETER BOTT OF THE DTI.

1. Applicant
2. P G Bott
3. First Affidavit
4. Exhibits PGB 1-5
5. . . 1998

IN THE HIGH COURT OF JUSTlCE                              CH 1998 - T- No
CHANCERY DIVISION

BETWEEN:

(1) THE SECRETARY OF STATE FOR TRADE AND INDUSTRY
(2) THE DEPARTMENT OF TRADE AND INDUSTRY

Plaintiffs
                                          - and -

(1) RAYMOND PATRICK GRANT

(2) PAUL PHILIP HESLING

(3) LIONEL STILES

(4) PATSY ANN ROWLEY

(5) STEPHEN A ROWLEY

(6) DANIEL WARD

Defendants

AFFIDAVIT OF PETER GEOFFREY BOTT

I, PETER GEOFFREY BOTT, Civil Servant, of 10 Victoria Street, London SWIH ONN, MAKE OATH and say as follows:

INTRODUCTION

1. I am an investigator of the Company Law and Investigations Directorate of the Department of Trade and Industry and I am duly authorised by the First and Second Plaintiffs to make this Affidavit on their behalf.

2. I make this Affidavit from matters of which I and my colleague, Philippa Hahnel, have acquired knowledge during the course of an investigation pursuant to section 105 of the Financial Services Act 1986 ("the FSA 1986") into the affairs of the partnership, club or organisation known as "Business Incentive Games International" and or 'BIG International" and/or "BIG" and/or "B.I.G." ("BIG") and the partnership, club or organisation known as "Courtney Agencies", which purports to be a wholly-owned subsidiary of BIG ("Courtney"). Save where otherwise appears the facts and matters set out below are within my own knowledge and are true.

3 . I make this Affidavit in support of the Application herein for an interlocutory injunction restraining the First to Third and Sixth Defendants ("Mr Grant", Mr Hesling", "Mr Stiles" and "Mr Ward" respectively) and each of them from:

(1) carrying on an investment business in the United Kingdom, issuing investment advertisements and making any false or misleading statement for the purpose of inducing persons to enter into investments, contrary to the provisions of sections 3, 57 and 47 of the FSA 1986, and

(2) promoting, managing or carrying on any business through a prohibited association or partnership, contrary to the provisions of section 716 of the Companies Act 1985 ("the CA 1985"),

as well as for an interlocutory injunction restraining the First to Sixth Defendants and each of them from in any way dealing with the assets of BIG and/or Courtney or the proceeds thereof, or procuring or attempting to procure that such dealing take place, as well as for certain ancillary orders relating to the disclosure of the whereabouts and nature of the assets and records of BIG and/or Courtney, the appointment of Receivers and the delivery up of, inter alia, a laptop computer currently used by Mr Hesling in connection with the business of BIG and/or Courtney.

4. I am aware that the Law Officers of the Crown have informed the Second Plaintiff that they are content for the Second Plaintiff to seek the releif claimed in this action based on breaches of section 716 of the CA 1985.

THE INVESTIGATIONS INTO THE FIRST TO THIRD DEFENDANTS' AFFAIRS

5. On 24th March l997 Ms Hahnel, who is also an investigator of the Company Law and Investigations Directorate of the Department of Trade and Industry became duly authorised to exercise all the powers conferred by section 105 of the FSA 1986 for the purposes of investigating the affairs of Courtney and BIG. There is now produced and shown to me marked "PGB 1' a true copy of her section 105 authority. She required both Mr Grant and Mr Hesling to attend before her for the purpose of answering questions and providing information.

6. Mr Hesling did so on 24th March 1997. Mr Grant attended by telephone conversation on 24th March 1997 and in person on 22nd April 1997 (having failed to keep appointments for 26th and 27th March, and 3rd April, 1997).

7. On or around 19th March 1998 Ms Hahnel informed me in detail of the results of those interviews and gave me such documents as she had obtained from the First to Third Defendants, many of which are exhibited to this affidavit. The results of her investigations are referred to in this affidavit where indicated. and I believe them to be true.

8. In March 1998 the Plaintiffs decided to carry out further detailed investigations into the affairs of Courtney and BIG. On 20th March 1998 I therefore likewise became authorised to exercise all the powers conferred by section of the 105 FSA 1986 for the purposes of investigating the affairs of BIG and on 24th March 1998 I was further authorised to exercise all the powers conferred by that section for the purposes of investigating the affairs of Courtney (including, but not limited to, the affairs of Mr Grant and Mr Hesling, as persons connected with Courtney and BIG). On 20th March 1998 I became authorised to exercise all powers conferred by section 105 for the purposes of investigating the affairs of Mr Stiles (the latter authority is erroneously dated 20th March 1997). There is now produced and shown to me marked "PGB 2" a bundle of true copy documents. At pages l - 3 of Exhibit PGB 2 are copies of those section 105 authorities.

9. On 23rd March 1998 I left a copy of the authority relating to BIG at the home of Mr Hesling at 75 Kingsworthy Close, Kingston upon Thames, Surrey KT1 3ER, and requested him to contact me for the purpose of answering questions and providing information.

10. On 23rd March l998 I served a copy of the authority relating to Mr Stiles at 30 Hendfield Court, Beddington Gardens, Wallington, Surrey SM6 0JQ. I knocked on his door and interviewed him then and there. On the following day he attended at my offices at 10 Victoria Street, London SWIH 0NN to sign a letter I had written to him on that day confirming the information with which he had provided me on 23rd March and enclosing certain documents (pages 6-21 of Exhibit PGB 2). Mr Stiles claims to be an agent of BIG, as is further explained in paragraphs 95 to 97 below.

11. On 24th March 1998 I sent copies of both authorities to Mr Grant at 10 Swindon Gardens, Harold Hill, Romford, Essex RM3 3RH, requesting him to contact me for the purpose of answering questions and providing information.

12. On 24th March 1998 I sent copies of both authorities to Mr C Brind, head of Corporate Security at American Express Services Europe Limited, seeking details of investments from members of the public in BIG and/or Courtney through payment by American Express cards. On 30th March 1998 I sent copies of both authorities to Mr P Lucraft, a legal representative of MasterCard. with a similar request. As I will set out in more detail below, the application form for BIG invites members of the public to pay for their investment by American Express, VISA or MasterCard.

13. On 25th March 1998 I sent copies of both authorities to Mr I Levene, Senior Legal Advisor, Group Compliance at the National Westminster Bank plc. Mr Hesling operates an account at the National Westminster Bank at Kingston upon Thames in the name of "P P Hesling trading as Courtney Agencies". On 27th March 1998 I sent copies of both authorities to Mr D Hopton, Head of Fraud Prevention at Barclays Bank plc. Mr Grant had an account at the Romford branch of Barclays Bank plc in the name of "Raymond Patrick Grant trading as Courtney Agencies'. In both cases, I sought details of American Express, VISA or MasterCard payments made by investors into those accounts.

14. On 27th March l 997, I sent copies of both authorities to the Head Postmaster at Kingston upon Thames Post Office. That is the sorting office which covers PO Box 474, Kingston upon Thames, Surrey KTl 3YS, which is the sole given address to which all Courtney and BIG correspondence can be sent. I requested details of the collection and/or re-direction arrangements of such correspondence.

15. On 8th April 1998 I served copies of both authorities on Mr Hesling in person when I met him at his home at 75 Kingsworthy Close, Kingston upon Thames, Surrey KTI 3ER.

16. On 8th April 1998 by agreement I met Mr Hesling at 75 Kingsworthy Close. During the course of the meeting I completed a pre-prepared questionnaire with him. The answers to the questions do not reflect everything said during the meeting, but are nevertheless answers agreed with Mr Hesling. A copy of the questionnaire was sent to Mr Hesling on 17th April 1998 with the request that he make any necessary amendments, sign and date each page and return the document to me within seven days. Mr Hesling has not yet returned a signed copy. A true copy of the original questionnaire showing answers to questions is now produced and shown to me marked 'PGB 3".

17. On 12th April 1998 by arrangement Mr Grant and his solicitor Ms Jane Lane attended at my office at 10 Victoria Street, London SW1H 0NN. A similar questionnaire was used to note Mr Grant's answers in his presence to the pre-prepared questions. On 17th April 1998 a typed copy of the questionnaire was sent to Mr Grant with the request that he make any necessary amendments. sign and date each page and return the document to me within seven days. He has not done so. True copies of the typed and original questionnaires are now shown to me marked "PGB 4".

COURTNEY AND BIG

18. I have concluded on the basis of the investigations described above that the Defendants' investment business is carried on through Courtney, and I therefore begin by setting out the evidence connecting Mr Grant and Mr Hesling with that entity. Mr Grant and Mr Hesling appear to be the two Defendants who are most closely connected with Courtney, and who have been associated with it since its inception. The roles of the other four Defendants are set out in later sections of my affidavit, in the context of the particular aspects of the scheme run by Courtney with which they appear to have a particular connection.

19. Mr Grant and Mr Hesling both trade as Courtney Agencies. They both have (or have had) bank accounts where they are described as trading as "Courtney Agencies", and they both carry on business as or on behalf of Courtney.

20. I wrote to Barclays Bank plc on 27th March 1998 and requested documents from the bank relating to an account at their Romford branch. There is now produced and shown to me marked "PGB5" a bundle of true copy documents. Barclays Bank informed me by a letter dated 19 May 1998 that the account I had mentioned in my letter had been closed on 15 October 1997. However according to the statements the last transactions were on 29 and 30 .April 1997 when œ13,500 appears to have been drawn in cash: see pages 8a-8f of PGB5. The account was numbered 50829285 and was in the name of Raymond Patrick Grant trading as Courtney Agencies (prior to 2nd August 1996 the name of the account had been "Raymond Patrick Grant trading as Financial Solutions'). (Although the first given name is "Raymond" while Mr Grant calls himself "Ibrahim Grant", that was Mr Grant's first name until he changed it to Ibrahim. When I met Mr Grant on 12th April 1998 he told me that he in fact has seven different names, that his registered name is Raymond Patrick Grant and that he had never formally changed his name to Ibrahim Grant.)

21. During mv interview of Mr Grant on 12th April 1998, I asked him whether Courtney had a bank account in the United Kingdom. He told me that he did not know of any bank account for Courtney. Mr Grant stated that all funds received by Courtney on behalf of BIG were banked by BIG but that he did not know where the BIG bank account is maintained. Mr Grant acknowledged that he had maintained an account for Courtney at Barclays Bank in Romford but said that this had been closed after a meeting with my colleague, Philippa Hahnel last year.

22. I am informed by Ms Hahnel that on 22nd April 1997 she has asked Mr Grant three times whether Courtney had a bank account in the United Kingdom. Each time he said that Courtney did not have an account in the United Kingdom. Mr Grant stated that all Courtney's funds were banked at "SIB". After Mr Grant had denied that Courtney had a bank account in the United Kingdom, Ms Hahnel showed him details of the bank account referred to above. The details of the account showed that Mr Grant was the only person mandated to operate it: see page 2 of Exhibit PGB 5. Mr Grant told her that he operated the account but that it was not his account: he had authority from BIG to operate it.

23. Mr Grant also told me at the interview on 12th April 1998, without producing any documents in support of his statements, that:

23.1 he no longer holds the cheque book and paying-in book for the account but did in the past;

23.2 all statements and used cheque books and paying-in books were sent to BIG via courier;

23.3 payments were made from the account following receipt of instructions from BIG (and the instructions were then returned to BIG which explained why he had no such instructions in his possession), and

23.4 he had not received any monies from the account and had been living on monies that he had earned in Saudi Arabia in the early 1990s.

24. Mr Grant had told Ms Hahnel the same things on 22nd April 1997 (save that then, he said that he did hold a current cheque book and current paying-in book for the account). On that occasion, however, he also told her (again without producing any documents in support of his statements) that:

24.1 the payments from the account were for rates, gas and telephone bills, etc. and

24.2 payments into the account were payments made to Courtney by participants in the lottery promoted by Courtney, referred to below, and that these payments were received by Courtney on behalf of BIG.

25. When I met Mr Hesling on 8th April l 998 he told me that he had an account (number 7126329) in the name of "P P Hesling trading as Courtney Agencies" with the National Westminster Bank at its branch at 5 Market Place, Kingston upon Thames, Surrey KTI IJX. He claimed not to have any bank statements relating to the account, though he did produce an unused cheque book.

26. Mr Hesling told me that payments are made into that bank account from some of the funds remitted to BIG at PO Box 474, Kingston upon Thames (to the best of my knowledge the only address to which Courtney and BIG correspondence may be sent). He told me that when he needs funds to pay expenses on behalf of Courtney he asks permission of BIG to bank some of the receipts from members of the public. He said that he does not know who actually gives him permission as it is a verbal message passed through a courier.

27. Mr Grant told Ms Hahnel on 22nd April 1997 how he commenced trading as Courtney. By way of background. he explained that BIG, which he said was incorporated in the Bahamas and based in New York, runs a free weekly lottery, the first prize in which is the guaranteed minimum income derived from œ25 million in shares, and that there were numerous other prizes, including some in cash. He told her that he was introduced to someone from BIG, whose name he cannot remember, by somebody else, whose name he also cannot remember. They met in a hotel foyer which he said he thought was the Intercontinental in London. The outcome of that meeting was that he, trading as Courtney Agencies, made an oral agreement with BIG to retain an office service agency for BIG in the United Kingdom.

28. During my own interview with Mr Grant on 12th April 1998, he explained that BIG is based at a lawyers' office in New York but has offices throughout the world, through which it runs a free weekly lottery. He told me that he was introduced to BIG by someone who is now deceased whom he was unwilling to name, and that he (Mr Grant) was appointed to "build Europe". He also told me that in about the beginning of 1997 he met BlG's senior legal advisor (who he said was also a director of BIG), a Mr Jason Saracen, at the Grosvenor House Hotel in London. He believes that Mr Saracen was an American. He claims not to know the reason for the meeting, but thought it was to see whether he (Mr Grant) was as English as he appeared to be. Aside from that, Mr Grant was unable to describe any personal meetings with anyone from BIG. That notwithstanding, Mr Grant claims to have set up the original BIG structure in Europe which he said comprises approximately 2.780 branches, with agencies below them. Courtney was one such agency.

29. Mr Grant told me on 12th April 1998 that he had received the post addressed to BIG at a Post Office box number in Romford and that he used to pass it to a courier without opening it. He explained to me (as he had also explained to Ms Hahnel) that he always met the courier in the foyer of the Trust House Motel in Brentwood Essex. The address for BIG was later changed to the PO Box in Kingston and Mr Hesling took over the collection and forwarding of the post, as is explained below.

30. When I met Mr Hesling on 8th April 1998 he told me that Mr Grant (as Courtney) was appointed the "Master Agent" for BIG but that following his interview with Ms Hahnel in April 1997 he ceased to hold that position. Mr Grant told Ms Hahnel on that occasion that BIG had about 6 agents in the United Kingdom, only one of whom (Mr Hesling) he knew by name. (There was no mention then of the 2,780 branches, with agents below them, now allegedly spread across the United Kingdom and Continental Europe.) He told her that he used to meet the 6 agents in the Trust House Motel on the same day as the courier from BIG. He did not know how the other agents were made aware of his meeting with the courier, but he said he assumed that they were informed by BIG of the date and time of the meetings (the venue being always the same). He said he did not know the names of the agents (save for Mr Hesling), nor did he wish to as he did not like the look of them and had as little to do with them as possible; thus he claimed not to enter into conversation with them. He explained that at the meetings it was the practice for each agent, separately, to hand a brown envelope to him (Mr Grant), which he then passed on to the courier from BIG. He said he was not aware of the contents of any of the envelopes.

31. According to Ms Hahnel, Mr Grant told her that his remuneration for this work as Courtney was to receive 15% of the monies paid to BIG by individuals in the United Kingdom participating in the BIG lottery, and 7% of the monies paid to BIG by individuals in Continental Europe participating in the BIG lottery, and that he estimated that by 22nd April 1997 he had earned a total commission of œl 3,660,000, although this had not been paid to him. When I met Mr Grant on 12th April 1998 he told me that he had still not been remunerated for his services by BIG or Courtney but that he was entitled to be paid under the agreement. He told me that he is now owed œ20-22 million. It would therefore appear that Mr Grant has earned (although not been paid) some œ7,000,000 since he has ceased to be the Master Agent, and that his involvement in the affairs of BIG and/or Courtney must, if that is true, have continued following his interview by Ms Hahnel.

32. Mr Hesling's role in relation to Courtney is as follows:

33. The promotional literature for both Courtney and BIG gives only one postal address, which is "Courtney Agencies, PO Box 474, Kingston upon Thames, Surrey KT1 3YS." Mr Hesling told me on 8th .April 1998 that he took over the collection of the post from the PO Box from Mr Grant when Mr Grant ceased to be the Master Agent and that he opened the mail and sorted it into orders with money and orders without. He said that he currently receives between 1,000 and 3,000 letters each week and that some of these are registered because they contain cash or are from abroad. Mr Hesling told me that he then passes the already-opened post to a courier who calls on him although he does not know his identity and has no means of contacting him.

34. Ms Hahnel informs me that she was told by Mr Hesling in April 1997 that he sorts the mail and banks the cheques and once a week sends the mail to Mr Grant at the latter's home address at 10 Swindon Gardens, Harold Hill, Romford, Essex RM3 3RH. She says that Mr Hesling told her that he meets Mr Grant once each fortnight and that it was Mr Grant who requested him to open the bank account referred to above in the name of "P P Hesling trading as Courtney Agencies". When I met Mr Hesling myself on 8th April 1998 he told me that he still meets Mr Grant once a fortnight but that this is now in connection with Inner Sanctum. The High Court closed down Inner Sanctum in 1995 following an application by the Secretary of State for Trade and Industry and the Department of Trade and Industry on the grounds that it constituted an unauthorised investment business and a prohibited association or partnership. A permanent injunction was obtained against Mr Grant restraining him from, inter alia, carrying on an unlawful investment business.) Thus according to Mr Hesling, the mail now allegedly goes direct to the courier from BIG and is no longer routed via Mr Grant.

35. Mr Hesling told me on 8th April 1998 that he is paid by BIG for his services and that œ1,000 per month is credited to his "ABS account" (which is explained at paragraph 54.3 below), from which he can draw by making requests that funds be moved from that account to any other account, including to the Courtney account at the National Westminster Bank in Kingston upon Thames (from which he can withdraw cash). Mr Hesling said that he did not have a personal bank account into which the money could be transferred; withdrawals could not be made directly from his "ABS account" (for reasons which will become more clear when those accounts are explained in paragraph 59 below). In short, it appears that his alleged salary ends up in the account into which payments made to Courtney by participants in the lottery are paid when Mr Hesling opens the Courtney mail. Mr Hesling was unable to show me any statements for his alleged ABS account which could show how payments of his monthly salary were routed in the way he described.

36. In contrast to all this, Mr Hesling told Ms Hahnel in April 1997 that he works for Courtney on a non-salaried basis. This is notwithstanding that, as he told her, his involvement with Courtney arose from a request to Mr Grant to help him find employment, Mr Hesling having met Mr Grant in connection with their previous association with Inner Sanctum. It was some time after the closure of Inner Sanctum that, in early 1996, he telephoned Mr Grant to ask him for help. They met in a Trust House Forte hotel on the M25, and that is when Mr Hesling agreed to provide what he has described to Ms Hahnel as administrative support for Courtney in its involvement with BIG.

37. Mr Hesling told me, during his interview with me on 8th April 1998, that his oral agreement with Courtney includes the following duties. He picks up and collates the mail for Courtney that is sent to PO Box 474, Kingston upon Thames. The mail includes applications sent by individuals for "free" lottery tickets, as well as cheques for "Profit Re-Imbursements" (or "PRs") or for becoming "Players" or "Agents" in the lottery system (these terms are explained below).

38. Mr Hesling was unable to show me any examples of such mail. In fact, Mr Hesling told me that he did not have any records or correspondence relating to BIG or Courtney. He also said that he had not maintained any records relating to his personal agency with BIG or Courtney.

39. Mr Hesling told me on 8th April 1998 that in addition to dealing with the post he drafts BIG' s promotional materials (which are described below). As stated in paragraph 33 above, the promotional literature for both Courtney and BIG gives only one postal address, which is "Courtney Agencies, PO Box 474, Kingston upon Thames, Surrey KTl 3YS." Royal Mail Customer Services informed Ms Hahnel in 1997 that mail sent to that address was automatically re-directed and delivered by the Post Office to 75 Kingsworthy Close, Kingston upon Thames, Surrey KTl 3ER, Mr Hesling's home address, the re-direction service having been set up by Mr Hesling on 21st May 1996. Royal Mail Customer Services have since confirmed to me, upon the production of my section 105 authority, that mail sent to that address is now collected by Mr Hesling (perhaps because it has now reached such a large volume), and I asked the Royal Mail if they would copy the outside of all correspondence received for 7 days commencing 28th March 1998. Mr Dudley Elston of the Royal Mail has produced a report (exhibited at pages 37-39 of Exhibit PGB 5) which shows that 546 letters were received in that period, of which 66 were registered items for which Mr Hesling signed. (I have not exhibited photocopies of the individual letters.) As mentioned in paragraph 33 above Mr Hesling explained that the registered letters contain cash and are predominantly from abroad.

40. When I met Mr Hesling on 8th April l998 1 asked him when the courier last collected the post and he told me that the courier last called on Thursday 26th March 1998. I also asked him when the post was last collected from the Post Office and he told me that was also Thursday 26th March 1998 and that he therefore did not have any post on the premises. In addition to photocopying the envelopes of all letters sent to PO Box 474, Kingston upon Thames, Mr Elston of the Royal Mail has also copied the receipts signed by Mr Hesling for the registered and recorded delivery letters which had been received after 26th March 1998. In his report (which is referred to at paragraph 39 above) Mr Elston records that the post was not collected until 7th April 1998, the day before the interview, and that it was collected by Mr Hesling in person who signed for the registered items.

41. Whilst it is clear that both Mr Grant and Mr Hesling trade as "Courtney Agencies", their involvement in the entity which they (and Courtney's promotional literature, to which detailed reference is made below) refer to as "Business Incentive Games International" or "BIG International" or "BIG" or B.I.G." is less easily understood.

42. Neither Mr Grant nor Mr Hesling was able to provide me with any detailed information about BIG. Mr Hesling did provide me with copies of promotional literature which emanated either from Courtney or BIG and which he himself has drafted: see pages 40- 57 of Exhibit PGB 5. Furthermore, during the meeting with Mr Grant on l2th April 1998 he agreed to provide a paper he had written on BIG and although I reminded him in a letter dated 17th April 1998 the paper has not been produced. Neither of the First and Second Defendants has been able to provide me with a postal address for BIG, nor is one provided in any of the promotional literature. This is in spite of the fact that both Mr Grant and Mr Hesling have told me that they no longer have bank statements, cheque books, paying-in books or purchase invoices relating, to the business passed through the Courtney bank accounts in their names because they send them all on to BIG. Moreover, neither the promotional literature nor either of the First and Second Defendants has been able to provide me with a telephone number for BIG, other than a number for answerphone or fax-back services. This is in spite of the fact that Mr Grant and Mr Hesling have both told me that they receive their instructions from BIG.

43. Mr Grant has refused to provide me with the narne of the person who introduced him to BIG or the name of the person from BIG with whom he (trading as Courtney) contracted to retain an office service agency for BIG in the United Kingdom and Europe. Indeed he has not been able to provide me with the name of a single employee or officer of BIG (not even the identity of the person or persons who issue his instructions), or even any other person associated with BIG, other than Mr Jason Saracen, mentioned in paragraph 28 above. He has been unable to name anyone associated with any of the 2 780 branches of BIG that he claims to have organised across Europe. The only agent of his own branch that he is able to name is Mr Hesling. .Mr Hesling, likewise, has been unable to name a single employee or officer of BIG or anyone associated with it, other than Mr Grant. He told me that his instructions are all given via a courier, either in person or over the telephone (the courier, he said, always telephones him; he has no way of contacting the courier). Neither Mr Grant nor Mr Hesling has been able to produce any document that verifies or confirrns the existence of BIG as an independent entity.

44. On 22nd April 1997 Mr Grant told Ms Hahnel, in relation to his Courtney account referred to above, that payments into the account were payments made to Courtney by participants in the lottery promoted by Courtney, referred to below, and that these payments were received by Courtney on behalf of BIG. In fact, none of the account statements in my possession for that account indicate payments to BIG. Mr Grant told me on 12th April 1998 that he had not received any monies from the account and had been living on monies that he had earned in Saudi Arabia in the early 1990s.

45. In fact, the account statements in my possession indicate that in the 9 month period from August 1996 to April l997 (which is approximately when he stopped using the account) payments out of the account totalled œ97,646.35 and that of this sum, œ51,780 00 was drawn out of the account in cash and a cheque for œ7,000.00 was drawn and made payable to Mr Grant, and encashed on 2nd April l997: pages 3 to 8f of Exhibit PGB 5. On 29th November 1996 and 24th December 1996 cheques for œ1,090 and œ645 respectively, and made payable to Paul Hesling were encashed: page 6 of Exhibit PGB 5.

Therefore when payments did go out of that account, they appear to have gone to Mr Grant and Mr Hesling, not to an entity named BIG.

46. Furthermore, Mr Grant's statement that he had been living on monies that he had earned in Saudi Arabia in the early l 990s contrasts with an earlier statement he made during a telephone conversation with Ms Hahnel on 24th March 1997 when he said that the Department of Trade and Industry' s inquiries into Inner Sanctum had left him without access to bank accounts and money, and that he therefore had to rely on his church for funds.

47. Mr Grant was not able to identify the location of the œ20-22 million that he estimated was due to him from BIG by way of commission for the period from the end of 1995 until April 1998, other than that he had requested that it be returned to what he called the "core fund" of BIG. He did not suggest that it was in an ABS account (explained in paragraph ..below) as he told me on 12th April l998 that he had only heard of ABS indirectly and had not taken much interest.

48. According to Ms Hahnel, Mr Grant told her that monies due to him from BIG were paid into an account with Swiss Investment Bankers AG ("SIB AG"?, which he described to her as a non profit-making bank incorporated in the Dominion of Melchizedek. Mr Grant was not able to tell her any other details about SIB AG. He told her that he did not know even the current trading address of SIB AG, and that he had never seen a statement from SIB AG relating to the account in which the estimated millions of pounds due to him from BIG was held. For the reasons set out at paragraphs 54.3 and 59 below, I believe that SIB AG is a fictitious entity.

49. Mr Grant explained to me on 12th April 1998 that he had never made enquiries about the monies said to be owed to him, because he took a vow of poverty in l 986, has stuck to it since then, and so has no need for the œ22 million.

50. I am aware of no documentary evidence that indicates or suggests that BIG is an entity that is independent of Courtney, or even any documentary evidence that indicates or suggests that BIG does in fact exist. All of the documentary evidence in my possession, and in particular the promotional literature (to which I will refer in detail below), is consistent with my belief that the business purportedly conducted by BIG is in fact conducted by Mr Grant and Mr Hesling under the name Courtney Agencies.

THE COLLECTIVE INVESTMENT SCHEME CARRIED ON BY THE FIRST AND SECOND DEFENDANTS

51. Mr Grant has promoted and formed, and both he and Mr Hesling have managed, a collective investment scheme in the United Kingdom under the names "Business Incentive Games International", "BIG International", 'BIG", "B.I.G." and ' Courtney Agencies ', as is explained in the following paragraphs.

52. By means of a variety of promotional literature, members of the public are induced to take part in a "free" lottery purportedly conducted by BIG by sending 4 stamps to Courtney, together with their personal details. Such members of the public are then sent a 'free" ticket which is purportedly entered into 13 weekly lottery draws.

53. Members of the public are further induced to increase their position in the lottery purportedly conducted by BIG by becoming a "Player" of BIG. In order to become and remain registered as "Players", members of the public are obliged to invest a fixed annual amount of œl0.

54. Members of the public do not increase their position in the lottery purportedly conducted by BIG simply by being "Players"; but by being "Players", they are said to be entitled to make further investments. Registered "Players" are induced to buy "Profit Re-Imbursements" (or "PRs'), which entitle them to:

54.l a second "free" lottery ticket, which is purportedly entered into 13 weekly lottery draws,

54.2 the extension of the validity of the first ("free ') ticket during the period for which they remain "Players" (one year at a time):

54.3 a so-called private offshore bank account (called a 'Player's Account") held with Allied Beneficial Services ("ABS"), an entity allegedly linked to BIG and to which further reference is made at paragraph 82 below (these are the so-called "ABS accounts" already referred to in paragraph 35 above). All prize winnings and re-imbursements are allegedly paid into the "Player's' ABS account, and this account is said to bear interest at the rate at 4.25% per month, and

54.4 a "Lodgement" of œ400 placed in the "Player's Account": the œ400 remains the property of ABS (curiously it is said to belong to the bank, not BIG) but the annual interest of œ259.13 apparently accrues to the "Player".

55. "PRs" are thus said in the promotional literature to enable "Players' to "share in the profits of the lottery," without necessarily even winning a prize.

56. In order to maintain his or her investment in the so-called share in the profits of the lottery, each "Player" is obliged to invest œ60 at the beginning of each new year, on top of the œ10 investment to remain a "Player". Each "Player" is entitled to invest in one or more "PRs", though BIG claims to reserve the right to restrict the number of "PRs" depending on demand.

57. I should mention at this point that holders of "free" tickets, whilst allegedly qualifying to win a prize in the lottery, do not actually qualify to claim and be paid that prize unless they already hold a "PR", or pay œ70 to register as a "Player" and acquire one. The lottery is therefore not in fact free.

58. Registered 'Players" are further induced to become "Agents". By being "Agents'', "Players" earn commission on every "PR" sold by them, on every 'New Agent" he or she introduces and on every "PR" (after the first 50 "PRs" sold by the "Player") sold by his or her "New Agent. The commissions take the form of lodgements paid into the "Player's Account": œl00, œ240 and œ20 respectively, with interest at 4.25% per month accruing to the "Agent".

59. No sums held in the ABS "Player's Accounts" can be transferred to any other nominated bank account until after a minimum period of 12 months. The "Agent" is however allegedly permitted to draw the commission earned on the purchase of "PRs by "Players" he has introduced. According to Mr Hesling the interest on the "Agents"' commission for introducing "Players" and "New Agents" can be drawn in cash or transferred to a bank account two calendar months after the new investor has made the payment to Courtney; I have been unable to find this fact stated anywhere in the promotional literature.

60. In order to maintain his or her position as an "Agent", each "Player" is obliged to invest œ360 at the beginning of each new year, on top of the œ10 investment to remain a "Player".

61. Members of the public who have become "Players" and who have invested in a "Profit Re-Imbursement" have (since around January l 998) been further induced to invest in "Profit Reimbursement Enhancement Programmes" (or "PREPs'). A "Player" is said to be entitled to invest in one "PREP" for every "PR" held.

62. The purchase of a "PREP" allegedly entitles the investor to 100 further lottery tickets. These are also described as being "free" tickets. However, in order to maintain that investment (and to access the other "benefits" of the "PREP", described below), each "Player" is obliged to invest a sum of œ6,000 per "PREP". This sum must be placed in an account with any one of the world s top 10 banks, and the "Player" is said to have full control over this for the first 12 months. Interest accruing on the account must be paid to BIG. Also, after 12 months, the œ6,000 must be paid over to "BIG", which credits a "standard Lodgement" of œ40,000 (100 x œ400) to the investor's "Player's Account", allegedly producing an ongoing annual return of œ19,913.

63. However, the "PREPs' do more than simply enable "Players" to "share in the profits of the lottery" by way of interest earned on "Lodgements" and the possibility of winning prizes: they supposedly also enable them to receive an "additional and accountable return" from a special project fund. Thus at the 12 month "maturation point", BIG promises that, for each "PREP", œ20,000 is paid by BIG into the investor's "Project Account" (not to my knowledge described further in the promotional literature). The "Player" will then direct that this sum is placed into one or more "Projects" in "Units" of œ5,000. "Projects" are said to be financed by the so-called "Project Development Fund" which, by implication, comprises or includes the total fund of all "Project Accounts". The "Project Development Fund" is said to provide opportunities for employment and manufacturing via the various "Projects" supported by the fund, as selected by its investors. The profits generated by the 'Projects' will then allegedly be paid back to the "Player's Account" of the investing "PREP" holder, based on the number of œ5,000 "Units" that such investor has placed in the "Project".

64. As in the case of "PRs", so in the case of "PREPs" there is an elaborate commission structure for "Agents" who introduce further investments from investors below them in the pyramid structure.

65. Entry to the weekly lottery draws supposedly held at offices maintained by BIG on 6th Avenue, New York, New York (the closest description ever given to a proper postal address) allegedly opens the possibility of winning one of a number of prizes. These are stated to include share prizes, cash prizes, a vehicle prize, a mortgage prize and millennium party prize. In particular:

65.1 the share prizes are prizes which allegedly last for a specific term (ranging from l year to 15 years) over which they generate 4.25% interest per month on the total amount (up to "$œ25 million" [sic] every week, as well as several prizes worth "$œ15 million". - $œ7 million", '$œ4 million and "$œ1 million" every week), that interest accruing to the winner's "Player's Account", (whether investors win a prize in Pounds Sterling or in US Dollars is alleged to depend on what currency . his or her investment was made in);

65.2 the alleged cash prizes range from "$œ125,000" to "$œ1000"; 65.3 the vehicle prize allegedly buys the winner a car worth œ15,000, replaced every 3 years, indefinitely,

65.4 the alleged mortgage prize is a payment of œ500 per month towards the winner's mortgage, for a period of 5 years; and

65.5 the alleged millennium party prize is a one week holiday for two plus a party to celebrate the Millennium ("scheduled so that the winners can link up with other people involved in celebrations worldwide'), worth œ14,000.

66. Additions alleged to have been made to the above selection of prizes since the launch of the lottery include a "Darsell Corporation retirement fund prize" generated by a "lodgement" of œ10,000 earning interest at 4.25% per month, and 'home groceries prizes" of œ500 per month for 5 years or œ250 per month for one year, by way of re-imbursement of grocery bills.

67. The draw prize fund is expressed to be "usually more than œ50 million per week" and is alleged to be related to the income BIG generates world-wide. It is further alleged to be determined a month in advance, based on the growth of BIG up to that point

68. The collective investment scheme described above is or has been carried on by Mr Grant and Mr Hesling from both of the following permanent places of business maintained by them in the United Kingdom:

68.1 10 Swindon Gardens, Harold Hill, Romford, Essex RM3 3RH (Mr Grant's home address, to which Mr Hesling has told Ms Hahnel he re-sends the mail received and sorted by him at his own home address), and

68.2 75 Kingsworthy Close, Kingston upon Thames, Surrey KT1 3ER (Mr Hesling s home address and the address to which all mail sent to Courtney's return address of PO Box 474, Kingston upon Thames, Surrey KT1 3YS, given in its promotional literature as more particularly referred to below, is or has been re-directed).

69. I believe that neither Mr Grant nor Mr Hesling is an authorised person within the meaning of Part I, Chapter III, nor an exempt person within the meaning of Part I, Chapter IV, of the FSA 1986. Furthermore, I believe that the collective investment scheme described above is not one which is authorised or recognised within the meaning of Part I, Chapter VIII of the FSA 1986.

THE INVESTMENT ADVERTISEMENTS

70. I have discovered from cheque payments shown in the bank statements relating to Mr Hesling's account with NatWest in Kingston that printing work has been placed by Courtney with Interact Marketing Services Limited (trading as O & M Printwize) of 9 Stepfield, Witham, Essex CM8 3BN ("O & M"). I was told by a Mr Anton Polonijo. the managing director of O & M, that Courtney has placed contracts with O & M since 25th November 1997 and had paid œ12,493.65 in printing costs by the end of April 1998 (please see page 93 of Exhibit PGB 5). The printing had been of folders, newsletters and application letters relating to the BIG lottery. The orders were placed in Mr Hesling's name, the contact telephone number was his home telephone number and the invoice address PO Box 474, Kingston. Print runs have varied in size from 2,000 to 100,000.

71. On Friday 15th May 1998 I was told during the course of a telephone conversation with Mr Polonijo that Mr Hesling had recently instructed his firm to print 30,000 lottery tickets in addition to folders. newsletters lnd application letters relating to the BIG lottery. He has since confirmed this by fax. shown at pages 94 - 95 of Exhibit PGB 5. The tickets for BIG's alleged lottery in New York are therefore now being printed in the United Kingdom.

72. Previously, Courtney has made cheque payments to Al-Shafi Print of 484 Barking Road, East Ham, London E6. On 12th August l 997 Ms Hahnel was told by an officer or employee of Al-Shafi Print that Al-Shafi Print had done work for Courtney. When I met Mr Hesling on 8th April 1998 he told me that he now places BIG's printing requirements with Reading Graphics of Kingston. I have not been able to ascertain whether either of those firms were being engaged in printing lottery tickets

73. The following promotional literature all bears the name and address of Courtney, and I believe that Mr Grant and Mr Hesling, trading as "Courtney Agencies", have issued that literature or caused it to be issued by procuring its printing and publication. There are three main classes of printed literature (in addition to the lottery tickets themselves, also bearing the name and address of Courtney-and not of BIG-, examples of which are set out at pages 40 - 92 of Exhibit PGB 5):

73.1 First, a publicity brochure headed "BIG INTERNATIONAL The World's Most Powerful FREE Lottery System" which contains, inter alia, a BIG Player Registration Form" and a "Free Ticket and P.R. Order Form", inviting members of the public to invest in Courtney and/or BIG ("the Brochure"). At least 3 versions of the Brochure have been issued, true copies of which are set out at pages 40 - 43 and 74 - 77 of Exhibit PGB 5.

73.2 Secondly, a newsletter to investors headed "BIGNEWS", purporting to contain information about BIG and Courtney, a list of recent lottery draw results, up to date values of investments and recent developments on, inter alia, fax-back and other communications services in relation to the lottery, the availability of promotional literature for Agents and the structure of "Agents"' commissions ("the Newsletter"). At least 11 editions of the Newsletter have been issued (it appears to be issued monthly). At least one edition contains a "BIG International Agent Agreement" application form. All editions invite members of the public to invest in Courtney and/or BIG. True copies of each edition of the Newsletters in my possession are set out at pages 44 - 57 and 78 - 92 of Exhibit PGB 5. Mr Hesling told me on 8th April 1998 that it is he who puts together the Newsletters.

73.3 Thirdly, letters and information leaflets sent out to "Agents" by Courtney ("for and on behalf of BIG International"): two examples are set out at pages 87 - 89 of Exhibit PGB 5 (a newsletter introducing the new 'PREPs') and pages 58 - 72 of Exhibit PGB 5 (a response issued by BIG International to an article critical of BIG written by Tony Hetherington of the Mail on Sunday; Mr Hesling told me on 8th April 1998 that this response had been drafted by Mr Grant and that it was probably a co-effort with one of BIG's legal advisers).

74. It appears that the Brochures are distributed both by Courtney and by the "Agents": several versions of the Newsletter advertise Brochure or Newsletter packs, or packs which combine copies of both, generally weighing approximately 2 kg per pack, which may be purchased by "Agents". Mr Stiles (the Third Defendant) has admitted to me that, as an "Agent", he distributes Brochures and Newsletters, as is shown in the letter and its enclosures referred to in paragraph 10 above (pages 6-23 of exhibit PGB 2).

75. In addition to these printed investment advertisements, there is an internet web site located at http://www.biglotto.com. which is advertised on the front page of each Newsletter and on the Brochures. The web site is headed "BIG - The World's Most Powerful Free Lottery System - œ25 Million / $37.5 Weekly Jackpot - Cash Prizes œ1,000 / $1,500 - œ125,000 / $187,500 - Make Money Even if You don't Win a Prize - A System for Players that Enjoy a Game for Freedom - Not only a Game but a Re- imbursement Savings System - Become an Agent", and purports to contain information about BIG and Courtney, including how BIG works, the "Players Account", draw results and prizes, news and information, currencies in which subscriptions may be made (a total of 23 are listed), a page inviting readers to become an "Agent" with information on how to do so, as well as information on how to obtain "free" tickets and other information inviting members of the public to invest in Courtney and/or BIG. A true copy of the Web Site as at 18th May 1998 is exhibited at pages 149 - 181 of Exhibit PGB 5.

76. Lastly, it may be that promotional material is also distributed by e-mail. E-mail discussion groups are advertised in several editions of the Newsletter. Since I have not taken the opportunity of taking part in one of these discussion groups. I do not know whether the collective investment scheme is in fact also advertised in this way.

77. I believe the "owner" of the e-mail address to be Courtney: the address itself is "courtney@biglotto.com" and it appears in a publication produced by Mr Hesling on behalf of Courtney. The "owner" of the Web Site is not known to me. However, there is a statement on the page described as "contact information" which reads: "Email address courtnev@biglotto com" (see page 164a of Exhibit PGB 5). Further- more, Courtney's postal address is also given on that page. I therefore believe that the investment advertisements issued on the internet and on e-mail have likewise been issued by Mr Grant and/or Mr Hesling on behalf of Courtney.

78. Mr Grant has indeed said as much. He told me on 12th April 1998 that it is Mr Hesling who handles the pieces on the internet. However he also said that most of what he had seen there appears to be "correct and legally accurate". As I will seek to demonstrate in the next section of my affidavit, the position is in fact quite the opposite.

THE MISLEADING STATEMENTS

79. The following false or misleading or deceptive statements, promises and forecasts are contained in the promotional literature issued by Mr Grant and Mr Hesling and referred to in the preceding section.

80. The following words appear on the front of every version of the Brochure and on the front of every edition of the Newsletter: "Business Incentive Games International. Division of Co. No. 26525B. Incorporated 30iO9/1994" and, on the front of every edition of the Newsletter: "New York, USA, Nassau, Bahamas; AE Hulst. Netherlands; NSW, Australia; Austria, Switzerland": see for example pages 44, 46, 48 and 78 of Exhibit PGB 5. These were actual or implied statements that BIG was a division of a registered company, duly incorporated, and that it had branches or offices in the places listed. I believe that, in fact. BIG has no such branches or offices, for the reasons given in paragraphs 42 to 50 above, namely that BIG does not exist or has no existence independent of that of Courtney Furthermore, Mr Grant has told Ms Hahnel in April 1997 that BIG is incorporated under the laws of the Bahamas, but in fact I am informed by mrs Jane Lloyd, Commercial Officer of the British High Commission in Nassau, that there is no registration in the Bahamas matching either the name or registration number referred to in the Newsletters and on the Brochures: see page 182 of Exhibit PGB 5. Neither Mr Grant nor Mr Hesling has been able to provide me with any postal address for BIG in spite of having issued that statement, and there is no address (other than merely "BIG's New York offices on 6th Avenue" - see page 150 of Exhibit PGB 5) or contact telephone number set out in any of the documents referred to above and issued by Mr Grant and Mr Hesling.

81. An earlier version of the Web Site (dated 24th June 1997, and shown at page 95a of Exhibit PGB 5) bears the words: "BIG provides each player with a private bank account in a recognised offshore banking system with offices in Austria and Switzerland. As part of the privacy arrangements, the bank will write to you directly to inform you of your account details and how you can transfer and withdraw from your account. Your off- shore account receives any winnings from each prize draw. ..", and "Whenever you buy a 12 month ticket, a reimbursement back into your private off-shore account occurs." This was an actual or implied statement that Courtney and/or BIG belonged to or were associated with an independent international banking organisation. In fact:

81.1 The "bank" referred to is SIB AG (referred to in paragraph 48 above), an alleged entity which has been described to Ms Hahnel by Mr Hesling as an organisation that trades in banking instruments, as the organisation to which each œ400 "Lodgement" belongs, and as Mr Grant's bank trading organisation, and which has been described to Ms Hahnel by Mr Grant as a non profit-making bank.

81.2 Mr Grant has told Ms Hahnel that SIB AG is incorporated in the Dominion of Melchizedek, which is, as far as I am aware, a "state" which owns no territory and is not recognised by the Government of the United Kingdom. I would like to refer to and rely on paragraphs 5.1 to 5.6 of the affidavit sworn on 3rd April l995 by Christopher John Dent in the matter of the Secretary of State and another (plaintiffs) against Lewis Diffey and others (defendants) 1995 T No 1945 (the Inner Sanctum action).

81.3 SIB AG is not authorised to conduct banking business in the United Kingdom and never has been, as is confirmed by the Bank of England's Supervision and Surveillance Department in a letter to Mr Sibley of the Second Plaintiff dated 16th March 1998 (pages 187 - 188 of Exhibit PGB 5).

81.4 I believe that SIB AG has no offices in either Austria or Switzerland, and its only given place of business (that is, with an actual address) was at 28 Grosvenor Street, London WIX 9FE, but I was informed by Paul Smith of the Bank of England on 19th May 1998 that when the Bank of England searched those premises on or around 13th February 1995 in connection with the closure by the Secretary of State for Trade and Industry and the Department of Trade and Industry of the business known as Inner Sanctum (the members of which the same "bank" was also alleged to have serviced) it found no sign there of any banking activity.

81.5 Furthermore, whilst some of the investors' funds (in the form of cheques made out to Courtney Agencies) appear to be paid into the Courtney account held in the name of Mr Hesling, there is no indication in the statements for that account in my possession that money passes from that account to BIG or to SIB AG: see pages 9 - 11 of Exhibit PGB 5.

81.6 No "cheque" issued by or drawn on SIB AG can be paid into or otherwise cleared through any bank in the United Kingdom.

82. The December 1996 edition of the Newsletter bears the words: "ABS - Allied Beneficial Services are the clearance house for all BIG Player accounts ...". Investors with Player Accounts have been sent statements purporting to be issued by Allied Beneficial Services, which set out account details and bear the following words at the bottom: "Private Banks Clearance Services." (A recent example is shown at page 185 - l 86 of Exhibit PGB 5.) These were actual or implied statements that Courtney and/or BIG belonged to or were associated with or were serviced by an independent United Kingdom clearing bank. In fact:

82.1 No place of business for Allied Beneficial Services is given, the First and Second Defendants have been unable to supply any evidence that an independent entity known as Allied Beneficial Services does in fact exist. and I believe that the statements were issued or caused to be issued by Courtney, acting by Mr Grant and Mr Hesling.

82.2 The Bank of England has confirmed that no entity known as Allied Beneficial Services is authorised to conduct banking business in the United Kingdom (pages 187 - 188 of Exhibit PGB 5).

83. I should mention that the promotional literature appears no longer to give the impression that ABS is independent of BIG: thus the current version of the Web Site, under the heading "Player Account", describes ABS as "an administrative department within BIG's financial organisation" (page 1-4 of Exhibit PGB 5; also no further mention of SIB AG is made in recent versions of the promotional literature). If BIG is a fictional entity, it must follow of course that that statement is equally untrue.

84. Earlier versions of the Web Site refer to an entity named Shared Shares International which is alleged to be "responsible for providing and organising the massive Jackpot Share Prizes" and then set out "a listing of the companies that SSI holds shares in". That is a list consisting of approximately l 70 companies quoted on London Stock Exchange Limited, as well as an entity referred to as "Swiss Inv Bank". (It came as little surprise to me that, when comparing the version of the Web Site dated 23rd January 1998-shown at pages 129 - 132 of Exhibit PGB 5 - with a version printed off on 24th June 1997-shown at pages 96-100 of Exhibit PGB 5 - the list of companies has remained identical.) Philippa Hahnel has investigated a selection of the companies there listed. The registrars of each of the following companies have stated by telephone that Shared Shares Intemational is not shown as a shareholder: Barclays Bank plc British Gas plc, Bass plc, Marks & Spencer plc, Thames Water plc and PowerGen plc.

85. Each version of the Brochure describes the alleged benefits of investing in the BIG lottery. Included among these are that:

85.1 "Players receive a Player Account into which any prize winnings and all re-imbursements are placed. Monies in this account receive interest at 4.25% per month."

85.2 "The draw takes place every Friday in BlG's New York offices on 6th Avenue. The Jackpot prizes are œ25 Million in Stockmarket Shares and œ125,000 in cash."

85.3 "The odds of winning the Jackpot vary but are roughly 1.5 million to l . The odds of winning any prize each week are roughly 40,000 to 1."

86. Those statements were each untrue: there was no realistic prospect of BIG being able to generate sufficient capital growth or income from the funds invested in Courtney and/or BIG to honour the commitments made by those statements, in particular because the alleged prize fund relates to income generated through the fees payable for the privileges associated with being a "Player", a 'PR" or an "Agent", as is stated elsewhere in the promotional literature: see the statements in one of the Brochures set out at pages 42 of Exhibit PGB 5. No prize winner's name is ever mentioned in the promotional literature or draw results; and to my knowledge no press article has ever appeared, as often happens when large prizes are won in the National Lottery despite attempts to maintain the Winners' confidentiality. When I asked Mr Hesling what evidence he had that anyone has received a prize he said that he had spoken to people who had received them. Mr Grant told me that he did not know that "Players" had received prizes, though the "Agents" who were claiming that their "Players" had received prizes would know who they were, which he considered was a remarkable situation considering that none of them had paid for the opportunity.

87. The January 1998 edition of the Newsletter states, in relation to the "Projects" to be funded by the newly introduced "PREPs", that: "In the unlikely event that a project fails to produce a profit, or collapses, then the units of œ5k/$7.5k placed into that project by the Player are returned to the player for placing into another project of their choice. This ensures that each player never loses his/her initial project stake. I am not aware of any evidence to suggest that this statement is or can be true: presumably if a project fails, that means the money invested in it has been lost.

88. Each version of the Brochure (as well as some editions of the Newsletter and the Web Site), describes BIG as a lottery "registered with the International Lottery Guild, a body which sets standards for lotteries world-wide. BIG's registration number is ILG/INT/2945/.ag." These were actual or implied statements that the lottery promoted or proposed to be promoted in Great Britain by Courtney and/or BIG was properly registered and therefore not unlawful. In fact:

88.1 During the course of a telephone conversation Ms Hahnel has been informed by the Gaming Board (Lotteries Section), which is responsible for licensing lotteries in Great Britain, that The International Lottery Guild is not an entity or organisation empowered to authorise the promotion of lotteries in Great Britain. I am not aware of any evidence to suggest that The International Lottery Guild is an entity which exists at all.

88.2 The lottery promoted or proposed to be promoted by Courtney and/or BIG is one which is unlawful under section I of the Lotteries and Amusements Act 1976. In this regard, I would like to refer to and relv on paragraphs .... - .... of my affidavit of even date [please change if necessary] in the winding up proceedings brought in parallel with this action by the Secretary of State as petitioner against Courtney No of 1998.

89. One of the Brochures contained, inter alia, the following statements (at page 40 of Exhibit PGB 5):

89.1 "BIG International is quickly becoming one of the world' s largest humanitarian organisations, joining and supporting many other organisations, which are fighting for human rights and human environmental protection."

89.2 "Originally developed for employees within large multi-national corporations BIG has, through the work of such agents as Courtney Agencies, become the first humanitarian organisation devoted to total profit redistribution globally."

89.3 "During its fourteen years of research and development, BIG has also become the world's first citizen controlled and directed organisation which is globally promoted by its own success to each given citizen.

90. I am not aware of any evidence that can support the truth of any of those statements and I invite this honourable Court to conclude that each statement is inherently unlikely to be true, and therefore false or misleading.

BREACH OF SECTION 716 OF THE COMPANIES ACT 1985

91. The First and Second Defendants manage and promote the business of Courtney as set out above.

92. I believe that there are in excess of hundreds (or even thousands) of investors in Courtney who participate in its business with the object of acquiring gain for Courtney and/or for themselves. Mr Grant told Ms Hahnel on 22nd April 1997 that, to his knowledge, there were at that time only 6 agents for BIG or Courtney in the United Kingdom. The figure given by Mr Hesling, a short time later, was 140. Furthermore, the December 1996 Newsletter states that "BIG now has over 550,000 Players worldwide", the first two versions of the Brochure in my possession mention a figure of "over 500,000 Players worldwide" and the most recent version of the Brochure in my possession states that "BIG started in 1993 and now has over 1,000,000 players worldwide". Furthermore, for the reasons set out in the final section of this affidavit, I have concluded that the number of participating members in the scheme is still rising rapidly.

93. As explained at paragraph 54 above. 'Players" are members of the public who are enabled, by means of their investment in Courtney to share in the profits of the lottery, by way of interest on "Lodgements ', by way of lottery prizes, by way of commissions according to a complex commission structure, and by way of profits deriving from the "Projects" that are financed by the Project Development Fund".

94. In the circumstances, it appears to me that the business of Courtney is being carried out in breach of section 716 of the CA 1985.

THE ACTIVITIES CARRIED OUT BY THE THIRD, FOURTH, FIFTH AND SIXTH DEFENDANTS

95. In about March 1998 the Plaintiffs became aware that a Mr Stiles is using the BIG/ Courtney lottery, and its promotional materials, as a means of carrying on a highly objectionable scheme by which he induces elderly members of the public to mortgage their homes by representing to them that the BTG, Courtney lottery will enable them to clear off any sums borrowed on the security of their homes within a year. This scheme is described in the next 3 paragraphs.

96. Mr Stiles claims to be an "Agent" for BIG, as is shown by a copy of a Brochure indicating his name and address: Mr Lionel Stiles of 30 Hadfield Court, Beddington Gardens, Wallington, Surrey SM6 0JQ (pages 9-11 of Exhibit PGB 5).

97. First, I have concluded that as an "Agent" promoting Courtney and/or BIG's collective investment scheme from his home address, and not to my knowledge being duly authorised to do so, Mr Stiles is carrying on an investment business in the United Kingdom, issuing investment advertisements and making false or misleading statements for the purpose of inducing persons to enter into investments, contrary to the provisions of sections 3, 47 and 57 of the FSA 1986.

98. But secondly, and more particularly, Mr Stiles has placed at least one advertisement in Active Life, a magazine aimed mainly at the elderly. Those responding to the advertisement were sent a letter prepared by Mr Stiles (a copy of which, dated 20th January 1998, was passed to my attention, and is set out at page 8 of Exhibit PGB 5). That letter includes the following passages:

98.1 "We are enclosing the "BIG" brochure and application form with some examples and explanation of how various sums of money can grow when placed within the "BIG" reimbursement savings system."

98.2 "Unfortunately we can no longer expect the State to look after us as we grow older, and indeed recent court cases have shown that some people have been forced to sell their own homes in order to pay for nursing care within the local authority, thus depriving their heirs of this inheritance."

98.3 "There are many of us who have a home that has a small or no mortgage on it, but we do not have a large enough income to really enjoy the lifestyle that we desire, perhaps with a new car, taking several holidays a year, or treating the grandchildren as much as we want. The "BIG" concept is that you can raise money using your home as a collateral and use this capital sum to create a much better income, whilst remaining the beneficial owner of your own home."

98.4 "There are less attractive plans marketed by other companies, but these usually mean your home will permanently become the property of a third party and no longer be available for you to dispose of as you would like. The profit reimbursement of "BIG" offers a new way to make your home work hard for you, and provide the income you want.

98.5 "Should you wish to raise money be mortgaging or re-mortgaging your property, we are able to give you assistance in this matter, and you will see from the enclosed information and examples you would be able to clear any loans after the first year, leaving you debt free."

99. The explanations referred to are set out at pages 9 - 11 of Exhibit PGB 5. The letter, together with its enclosures, contains a number of misleading statements, most of them of the same kind as described above and untrue for the same reasons, or because they are based upon statements already described which are untrue. However the scheme promoted by Mr Stiles is in one sense even more objectionable than the BIG/Courtney lottery in its simple form, because while the latter is aimed at inducing members of the public to part with disposable income, Mr Stiles' scheme is aimed at inducing members of the public (being a generally more vulnerable class of members of the public) effectively to part with their homes: given the nature of the lottery as already discussed, there is no realistic prospect of BIG being able to generate sufficient capital growth or income from the funds invested in Courtney and/or BIG to honour the commitments made by the statements found in Mr Stiles' letters.

100. The role played by the Fourth and Fifth