The E.ON Board of Directors [UK] (jointly and
severally)
PARTICULARS OF OFFENCES
Perverting the Course of Justice
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, with intent
to pervert the course of public justice, did a series of acts which had a
tendency to pervert the course of public justice in that they:
(i)
false invoiced
Leonard Richard Fulcher for the supplier of electricity against a meter which
does not exist on his farm
(ii)
unlawfully
applied for a Bankruptcy Petition against Leonard Richard Fulcher (still to be
heard)
(iii)
authorised
fraudulent documents to be entered into Court proceedings against Leonard
Richard Fulcher
(iv)
failed to act on
information supplied by Leonard Fulcher that a meter had been stolen from his
farm
(v)
provided false
information to Norfolk Constabulary
(vi)
allowed Kate
PARRY and Thomas DENASH of Parry&Company to adduce fraudulent documents
into Court by way of Laura ADCOCK
(vii)
provided false
information to Leonard Richard Fulcher
(viii)
conspired with
others to falsely imprison Brian Pead
(ix)
conspired with
others to cause actual bodily harm to Brian Pead
(x)
conspired with
others to harass Brian Pead, Loenard Fulcher and Karen Fulcher
(xi)
failed to report
criminal damage to a gate at Ramblewood Farm
(xii)
failed to report
criminal damage to a car belonging to E.ON
(xiii)
failed to report
an accident
(xiv)
failed to report
careless driving
(xv)
failed to report
a failure to provide an evidential specimen
(xvi)
failed to report
a failure to give permission for a laboratory test
(xvii)
failed to
investigate fraudulent invoices when brought to their attention
(xviii)
conspired with
District Judge Rutland not to allow incontrovertible evidence into a Hearing
3KL00178 (an Application to Set Aside a Bankruptcy Petition) that a meter
claimed by E.ON to be on site at Ramblewood Farm was not, in fact, on that site
or under the control of either Leonard Richard Fulcher or Karen Fulcher and
that it did not, in fact, exist
Harassment
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, did pursue a
course of conduct amounting to the harassment of Brian Pead and Leonard Richard
Fulcher and Karen Fulcher and did cause them alarm and distress contrary to the
Protection from Harassment Act 1997.
Fraud by failing to disclose information
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, did commit
fraud by deliberately failing to disclose documents to the police, to Leonard
Richard Fulcher, to Karen Fulcher, and Brian Pead, and to the Courts, contrary
to the Fraud Act 2006.
Fraud by abuse of position
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, did abuse
their position as Board Member with E.ON in that he/she/they perpetrated a
series of crimes and human rights abuses against Brian Pead, Leonard Richard
Fulcher and Karen Fulcher and pursued a course of conduct amounting to the
harassment of Pead and the Fulchers, which he/she/they knew, or ought to have
known, would cause them alarm and distress, contrary to the Fraud Act 2006 and
contrary to the Protection from Harassment Act 1997 and the Human Rights Act
1998.
Fraud by false representation
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, did make
false representations and provide false documents to the police and to the Courts
in relation to Pead and the Fulchers, contrary to the Fraud Act 2006.
Assault
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, were
complicit in the unlawful assault on Brian Pead, contrary to section 39 of the
Criminal Justice Act 1988.
Criminal Damage
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, on 01 August 2013, were complicit in causing criminal
damage to the property owned by Leonard Richard Fulcher and Karen Fulcher, in
that a car belonging to E.ON was driven recklessly into a gate at Ramblewood
Farm and interfered with the normal running of a fly wheel on the gate,
contrary to s. 1(1) of the Criminal Damage Act 1971.
Misuse of Public Funds
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, between 01 July 2007 and 25 September 2013, did misuse
public funds in perpetrating crimes and human rights abuses against Brian Pead
and Leonard Richard Fulcher and Karen Fulcher.
Failing to Stop or Report an Accident
The
E.ON (UK) Board of Directors, comprising of Tony COCKER, Dave NEWBOROUGH, David
BIRD, Don LEIPER, Fiona STARK, Rene MATTIES, Sara VAUGHAN and Tony AINSWORTH,
JOINTLY AND SEVERALLY, on 01 August 2013, did fail to report an accident after
having been informed of criminal damage to a gate on Ramblewood Farm, contrary
to the Road Traffic Act 1988, s.170.
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