Saoirse Maxwell
[Address Redacted], Co. Galway
[Phone Number Redacted]
E-mail: saoirsemaxwell@redacted.com

FILE COPY

July 8, 2011

Mr. Damian Brass
Jaggers and Brass Solicitors
[Address Redacted]
[Address Redacted]
Dublin

RE: Your Ref: [Redacted]

Dear Damian:

Thanks for your email of July 4 regarding your trip to Rosslare, etc.

You do not mention whether you sought clarification from [Mr and Mrs Taxi–Driver regarding their witnessing of Mom's will. I make no judgement regarding the veracity of any of their statements made in April. However, the fact they made these statements is true and provable. Once again: Mr Taxi–Driver stated he would not have signed Mom's will, because he would not have seen it. Mrs Taxi–Driver contradicted his statement two hours later. Neither can recall seeing Mom sign the Will in their presence.
You note in your letter of June 27, responding to mine of June 17, that this raises a ‘number of issues which should clearly be investigated.’ I agree. It seems prudent to at least seek an "Affidavit of Attesting Witness" from each of them in order to ensure the integrity of mom's will. (As I wondered about in my email to you of June 29). I believe this to be in everyone's best interest. If you recall, you have received at least one statement from one of my siblings indicating some possibility of contesting this will.
•1. Please inform me of what actions you have taken or will take regarding an Affidavit from Mr and Mrs Taxi–Driver.

I requested mom's land line records from Eircom for the sole purpose of adding to the ever growing body of evidence showing the isolation, control, egregious crimes and violation of human rights perpetrated by Ethan Maxwell against Mom while she was your client. I continue to seek having him called to account by the proper authorities, for these crimes.
•2. Is Jaggers and Brass representing Ethan Maxwell at this time in any capacity whatsoever?

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You note in your email of July 4, that it may be argued that these phone records may be “assets” in mom's estate, and if so, should not be released without the permission of the Executors, including Ethan Maxwell.

You have previously stated to me that in the administration of Mom's estate, two executors in agreement would override the objections of the third. I have verified this independently. Therefore Ethan Maxwell's permission is not necessarily required to release these phone records to me.
•3. Will you forward these records to me upon receipt?

It is my understanding that it is the Executors' duty and responsibility to seek and protect all assets of the deceased's estate.
•4. If you deem these phone records to be “assets” of my mother's estate, please explain why you flatly refused my request seeking these “assets” in our recent phone conversation.


In your checking Mom's house and the accumulation of post, I would like an itemised list of that post. I would also like an inventory of all redirected mail to your offices.
•5. Please furnish an itemised list of accumulated post in Mom's house and inventory of all redirected post.

You state in your email that you took possession of the item in Mom's safe deposit box from Ulster Bank in Wexford. You have previously related to me the existence of more than one item in the safety deposit box.
•6. Please clarify this.

As you recall, Ulster Bank had informed you that Mom had no safe deposit in their bank. I provided you with information that indicated that Mom did indeed have one. I requested that you take additional steps, beyond what had been done, to ascertain the existence or non-existence of safe deposit boxes in other banks that she held accounts with, given that they had given you the same negative answer you had initially received from Ulster Bank.
•7. In light of Ulster Bank's erroneous assertion that mom had no safe deposit box with them, what additional steps did you take regarding AIB, BOI and POSB to ascertain the existence of other safe deposit boxes or assets held with them?

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Damian, I am seeking clarification regarding a few additional things. As always, my sole motivation and focus is on seeking justice for Mom and that Ethan Maxwell be held to account for his criminal actions. Some of these I have sought from you before, but received no response.

I am in receipt of a copy of a letter from Jaggers and Brass to my brother Conor and dated September 13, 2010, threatening him with an “Order” to prevent him “besetting” mom or her property. You will recall my letter to you on Sept. 24, 2010 where I also questioned would I receive a similar letter upon my visit to Mom.
•8. Please tell me plainly whether or not this letter was issued from Jaggers and Brass.

I understand that mom's handbag is in your possession, as per my brother Sean.
•9. Will you provide me with an inventory of items and copies of all documents in her handbag? If not, please explain why not.

I have many times, because of the financial abuse perpetrated by Ethan Maxwell upon my parents, expressed to you the necessity of requesting Mom's past financial records. You told me, during our June 24 conversation, this could not be done until all her accounts were closed.

This statement directly contradicts earlier statements you made to me that her financial records could be sought after the Grant of Probate issued. I have spoken with each of the legal departments of the banks involved. They have also contradicted your latest statement, and in fact have procedures and protocols in place to facilitate this.

You have previously stated to me that you would be willing to pursue Ethan's involvement in Mom's financial affairs. You stated we could get copies of financial records and seek to recover any money wrongfully taken from Mom by Ethan Maxwell.

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Damian, you assured me several times that if I wanted all of Mom's bank and credit card records, you would get them for me. I want them. You stated you would facilitate me 100% in this regard after the Grant of Probate.
•10. I seek an unambiguous answer to this question: Will you seek Mom's past financial records for me? If not, why not?

Mom, as you probably know, was loathe to spend money on herself, and indeed was wearing nighties in the hospital I recall her wearing when I lived at home. She even wore clothes left by her daughters when we left home. There is no question that she was very frugal, careful and responsible concerning her finances.

I have previously provided you with information from statements retrieved from her fireplace (scorched and burned) and scraps retrieved from the bottom of her rubbish bin and cheque registers with missing Memos. These show tens of thousands of Euros leaving her accounts, including hundreds of Euros per month via ATM withdrawal. They show single withdrawals of up to €50,000 at a time. I want to know the circumstances of these transactions.

Her ATM card was not in her possession. I believe (because of what records of ATM withdrawals and purchases I do have sight of) that an investigation into Mom's past financial records would easily show that Ethan Maxwell was in fact in control of her accounts and treating them as his own.
•11. Please explain what steps you intend to take regarding these issues. If you do not plan to take any steps, please plainly explain how it is in your clients' (i.e. beneficiaries') best interest to not pursue this.

Mom's credit card was not in her possession. You have stated to me that Ethan Maxwell did not have authorisation to use this card. Given that there are charges on it for Ethan Maxwell's meals, utilities, and fuel, and the fact he was using this card for personal purchases as Mom lay dying in the hospital, it seems prudent to me to seek a complete accounting of Mom's credit card. It would be equally prudent to seek recompense to Mom's estate from Ethan Maxwell AKA [one of Ethan's aliases].
•12. Will you seek a complete accounting of Mom's credit card charges? If not, please plainly explain how it is in your clients' best interest to not pursue this.

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I refer once more to our meeting with Geoffrey Blair and Nathaniel at Wexford General Hospital on November 4, 2010. You stated that Mom left you instructions regarding her desired funeral arrangements. You stated that you received this typed letter with Mom's signature in May 2009. You indicated at our Nov. 4 meeting that it was with you, at that time, in her file.

You were very clear on the matter, Damian. You stated this arrived subsequent to the EPA being made. You mentioned again that it was typed, that Mom didn't type and you were going to ignore it. In response to a previous request for this letter, you indicated on April 28th 2011, you couldn't recall ever receiving instructions from Mom concerning her funeral. I am still seeking sight of this letter.
•13. Will you please search again, and clarify the existence of this letter? If you cannot find it, please clarify what you were referring to so clearly during that meeting.

Damian, I know that I can contact you or Langdon easily if I need to. I have had great difficulty contacting the third executor, Ethan Maxwell. My phone calls are either not accepted or blocked. There is no response to correspondence. The only sure way I know to contact him is through the fax machine at [his place of employment]. I am hesitant to do this.

I know Ethan Maxwell expressed to you his desire to receive no correspondence from his brothers and sisters, or any letters from solicitors on their behalf, etc., but as a beneficiary, I would like to be able to reliably contact him, an Executor, in regards to Mom's estate.
•14. Please provide me with reliable contact details, i.e., working phone number, valid email, etc. to allow me to contact the third Executor, Ethan Maxwell, directly.

Damian, I request that you respond to the bulleted questions and issues by the end of business July 22 in writing. It would be extremely helpful to me in choosing further steps I need to take in seeking justice for Mom. We all make our choices here. As stated previously, this criminal behaviour will not stop with Mom as the pattern with my late Uncle Paddy and late father Cecil Maxwell shows and now the family's inability to contact Ronan Maxwell.

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Please be assured that I am as always willing and eager to help you in any way that I am able. You said to me previously that it is important for justice to be done. I agree with you 100% and continue on that path.

As I recall, earlier attempts to organise clearing out Mom's belongings with my sisters, and with your encouragement, were swiftly nullified by your instructions this could not be done until after Grant of Probate issued. I can only assume this directive resulted after speaking with Ethan.

Looking forward to hearing from you.

Best,

Saoirse Maxwell
Via email and registered letter