Freeman Megamerge

• Not really grasping what a County Registrar does
• Not knowing how the amicus curiae process works but thinking that it gives them some kind of carte blanche to shout as loudly as they can
• Wanting to rely on a European Directive that hasn't yet been transposed (and doesn't need to be for some months yet)
• Thinking their Constitutional rights are absolute
• Wanting Gardai to consent to being arrested by them (but wisely decide against laying a hand upon said Gardai)

Caveat of affirmation: I respectfully assert my statutory right to fair and equitable treatment, and reserve the moral right to disengage communication with any individual or agency who, through the means of misinformation, evasiveness, obfuscation, deception or other disingenuous tactics, contrives to avoid fulfilling their mandate to the public [as defined in the Constitution, respective codes of ethics, oaths of office and/or terms of service] other than where I am legally obliged to do so. I further affirm my right to note, report, record and/or publish any communications sent or received for the purposes of transparency, due accountability, and in the interests of natural justice. I further reserve the right to hold responsible under the law any individual, agent or agency I deem responsible for deliberate civil, criminal or constitutional breaches, and to bill any such agents or agencies for time and costs incurred. I do not deal with anonymous, pseudonymous, allonymous or imaginary entities. Annotated emails are accepted under certain exceptional or pre-agreed circumstances, but important or legal correspondence must also be sent as hard copies, duly signed. Unsigned correspondence that is not ascribed to one authorised individual will not be responded to and may be returned for signing, with costs billed to the source thereof. Please be advised.

Although Mr Flynn complains in the affidavit that he swore on the 23rd April 2014 to ground the present application that its contents may not be complete due to the shortness of time available to him for its preparation, I note that it runs to approximately 55 pages and comprises 175 numbered paragraphs of closely spaced type. No doubt, Mr Flynn would borrow a phrase from Blaise Pascal in submitting that he made his affidavit very long because he did not have the leisure to make it shorter.

Instead, in broad terms the defence comprises: first, a series of complaints alleging procedural unfairness and a want of form in the progress of the proceedings to date; second a series of technical objections to the validity of the mortgage deed upon which the bank relies; third, a series of technical objections to the validity of the loan agreement between the company and the bank; fourth, a series of technical objections to the validity of the demand for repayment of the loan made by the bank; fifth, a bare assertion that the bank’s solicitors acted for both the bank and the company in the relevant transactions, thereby creating a conflict of interest; sixth, a bare assertion that the company had a collateral agreement with the bank whereby it was only required to make repayments on its indebtedness for a period of one year; seventh, a bare assertion that the bank was negligent in lending to the company; eighth, a series of technical objections to the bank’s locus standi to bring or maintain the proceedings; and ninth, a bare assertion that “Land and Conveyancing Act 2009 unconstitutional.” Mr Flynn submitted that this was only an outline defence and sought to reserve the company’s right to enter a full and proper defence if he is granted permission to act as the company’s legal representative.