From: “Conor Maxwell” conormaxwell@redacted.com
To: jaggersandbrass@jaggersandbrass.ie
Sent: Friday, 24 September, 2010 1:52:39 PM
Subject: Fw: Emailing: IMG REFERENCE [Redacted]

Dear sirs,

I am in receipt of your letter of which a copy is attached.

The comments made in your letter are unreservedly refuted by me. My wife and two children were with me when I visited my mother, having made two previous attempts to see her while on holidays at home but was prevented I can only assume from doing so by my brother Ronan. I met Ronan when attempting to visit my mother but in case you are not aware [Redacted] and should not be considered a reliable witness.

Any comments made to my mother are simply hearsay and I will consider what has been said to her, by whoever said it to her, as having been done by me to have been deliberately distorted to cause her distress. Can you confirm the identity of who said these things to her and exactly what was said so I can provide defence on this very serious allegation and take appropriate action.

You should be aware that your letter was opened by my wife and it caused her great distress. I will be seeking redress for this particularly because if you had taken the time to find out what was going on you would never have sent this letter to me.

This is the second letter you have sent me now. The first I did not need to respond to as it contained information that meant absolutely nothing to me and I had no idea why it was sent to me.

I find it unforgiveable that my reasonable attempts to see my mother who is over 80 years of age and in the last years of her life have been suggested to not be reasonable. Can you please elaborate on what exactly was unreasonable about my actions?

I am putting you under notice that I will be making visits to my mother and so suggest that you proceed with a barring order bearing in mind that I will be attending court to present my side of the case and will be assisted in this by the rest of my family. If I am not given the opportunity to do this I will consider this a breech of my human rights and my mother's human rights to see her grand children and will take action accordingly.

I suggest that you discuss confidentially with my mother what is going on here as there has never been a problem between me and my mother. Or indeed my father notwithstanding the very serious allegations made in the past against him regarding child abuse which social welfare were involved in.

You should be aware that I have visited my mother regularly and spoken to her regularly until last year but have been prevented from doing so since then as her phone has been repeatedly disconnected and despite many attempts from me to visit her I have been unable to do so. You should also be aware that my mother was physically afraid last year when she met me and my family that someone else would find out about that visit. I leave you to investigage that.

I look forward to your response to the above and I will shortly provide you with a full history and family account, in conjunction with my siblings, so you have irrefutable evidence to ensure you can provide your client with the full and correct legal advice.

I have copied this to the rest of my family given the very serious allegations you have made against me.

Yours faithfully

Conor Maxwell