AFFIDAVIT OF FACTS AND LEGAL ARGUMENT EUROPEAN COURT OF HUMAN RIGHTS APPLICATION UNDER ARTICLE 34 – FORM 47

INTRODUCTION

1. This affidavit is submitted in support of my application under Article 34 of the European Convention on Human Rights and letter to the Registrar of 18^th July 2025.

2. I allege that the actions of the UK Financial Conduct Authority (FCA), the UK judiciary, and associated actors constitute multiple and ongoing violations of my rights under the Convention.

3. In particular, I bring to the Court’s attention the fraudulent and unlawful proceedings under Order 34/2023, culminating in a judgment dated 16 July 2025 by Judge Anthony Baumgartner of Southwark Crown Court, and a forthcoming sentencing hearing scheduled for 30 July 2025.

4. This affidavit incorporates referenced documents, including:

   1. Mr Stamp Restraint Order

   2. Judicial Review Bundle (Southwark Crown Court)

   3. Judicial Review Decision – AC-2023-LON-003629 SLD

   4. Sealed Variation Order (31 May 2024)

   5. Affidavit – Denial of Jurisdiction, Denial of Service, Malfeasance, Appointment of Attorney-in-Fact

   6. Motion to Strike Out

   7. Affidavit of Recusal

   8. Notice of Rescission of Service

   9. Affidavit of Rebuttal

   10. Notice of Estoppel and Escalation (10 July 2025)

   11. Critique of Judgment (16 July 2025)

   12. Notice of Recission of Bench Warrants

   13. Lawful Notice to Cease and Desist

   14. 18 July 2025 Letter to Registrar

   15. Analyses of Alister Mackenzie

   16. Crown Collusion Dossier

   17. Comparative Summary APPG Report on FCA

   18. Anthony Stansfeld report on HBOS/FCA

   19. ECHR Case Precedents

   20. UK Human Rights Record Report

   21. MATRIXFREEDOM Memorandum Propoganda

5. SUMMARY OF THE FACTUAL AND LEGAL GROUNDS

   ORDER 34/2023 AND THE FRAUDULENT PROSECUTOR

   1. Order 34/2023 was engineered and enforced using a fictitious individual, “Alastair Mackenzie,” as prosecutor. Evidence shows this name does not correspond to any lawful officer with prosecutorial standing under POCA or FSMA.

   2. Despite multiple notices requesting proof of identity, authority, or delegation, the FCA failed to validate this individual. Continued reliance on this name constitutes fraud by false representation (Fraud Act 2006).

   3. Neither Iain Clifford the man, nor any MATRIXFREEDOM member, has ever offered regulated financial services. This was confirmed by over 500 sworn witness statements. The FCA has not rebutted this, making Order 34/2023 void on its face.

   4. The FCA’s goal was entrapment: to obtain a Civil Restraint Order against the man, not just the body corporate, thereby ensuring any act of living would breach the Order.

   5. This strategy resulted in the judgment of 16 July 2025, and a sentencing hearing now set for 30 July 2025, exposing the affiant to imminent incarceration.

   6. Crucially, Judge Anthony Baumgartner failed in his judicial duty to establish whether “Alastair Mackenzie” was a bona fide prosecutor. He made no attempt to seek evidence from the FCA that they had reasonable cause to believe that regulated financial services were being conducted which would require authorisation. The absence of such due diligence points to a clear and deliberate dereliction of judicial responsibility.

   7. This judicial failure strongly suggests collusion between the FCA and Judge Anthony Baumgartner in orchestrating an entrapment by design, culminating in Order 34/2023.

   8. This strategy resulted in the judgment of 16 July 2025, and a sentencing hearing now set for 30 July 2025, exposing the affiant to imminent incarceration.

6. JUDICIAL MISCONDUCT AND VIOLATIONS OF NATURAL JUSTICE

   1. Prior to the judgment of 16 July 2025, I served a formal motion to strike out the Order as void ab initio, and a Notice of Recusal of Judge Anthony Baumgartner. Both were ignored.

   2. At the hearing on 30 June 2025, my Attorney-in-Fact, David Ayerst, attempted to read a statement requesting that the proceeding be moved to a Court of Record. He was forcibly removed by seven court security officers. This unlawful removal denied me my right to be heard.

   3. The judgment issued on 16 July 2025 was defective in law, omitting fundamental findings, relying on hearsay, lacking proof of breach, failing to identify a lawful prosecutor, and ignoring unrebutted notices and affidavits.

   4. I subsequently served an Affidavit of Rebuttal of the Judgment and reiterated the rescission of all service addresses. Despite this, the Court has scheduled a sentencing hearing on 30 July 2025. This is a breach of Article 6 (right to a fair trial) and Article 13 (right to effective remedy).

   5. I also served a formal Notice of Rescission of Bench Warrants and a supplemental ECHR submission.

7. PERSECUTION AND RETALIATION

   1. The present proceedings form part of a 20-year pattern of persecution arising from my whistleblowing:

   1. Exposed HBOS asset stripping fraud (2005–2009)

   2. Reported regulatory failures to FSA/FCA (2011–onward)

   3. Filed complaints through MPs Caroline Dinenage and George Hollingbery, rebuffed by Margaret Cole and Andrew Bailey

   4. Submitted dossier to the Treasury Select Committee (2011), ignored

   5. Exiled to North Cyprus under duress due to Civil Restraint Orders

   2. The persecution has continued through the denial of my judicial review in 2024 by Justice Sweeting, who refused to allow me to present my case as a pro se litigant, despite clear misconduct grounds.

8. VIOLATION OF PROCEDURAL AND SUBSTANTIVE RIGHTS

   1. I have been deprived of:

   1. The right to be heard (Article 6)

   2. Access to an effective domestic remedy (Article 13)

   3. Protection from arbitrary punishment (Article 7)

   4. Peaceful enjoyment of property (Protocol 1, Article 1)

   5. Freedom of expression and association (Articles 10 and 11)

   2. These actions constitute persecution under Article 3 and Article 8, given the cumulative targeting, censorship, asset restraint, exile, and judicial entrapment.

9. KEY PERPETRATORS OF HUMAN RIGHTS BREACHES

   1. Nikhil Rathi – CEO of the FCA

   2. Richard Harmer – Attorney General

   3. Matthew Stone – FCA operative

   4. Pietro Boffa – FCA’s expert witness

   5. Anthony Baumgartner – Judge at Southwark Crown Court

   6. Justice Sweeting – Denied 2024 judicial review

   7. Simon Goldberg – Involved in enforcement decisions

   8. Dan Neidle – External complainant and instigator

   All are jointly and severally responsible for denial of remedy, violation of procedural rights, and continuation of a fraudulent prosecution.

10. CHRONOLOGY OF PERSECUTION (2005–2025)

    1. 2005–2009: I acted as a whistleblower against systemic fraud at HBOS.

       1. In 2007, I was offered a deal by senior executives at HBOS in exchange for not opposing their plan to seize Integrity customer assets to shore up their insolvent balance sheet.

       2. I refused. This marked the beginning of sustained retaliation by UK financial and regulatory institutions.

    2. 2010: My company, Integrity, was unlawfully liquidated by the FSA in conspiracy with HBOS.

       1. The FSA appointed Peter Middleton of Middleton Partners as liquidator. At the time, he was facing bankruptcy.

       2. The FSA later bribed Middleton to falsely confirm that Integrity was responsible for regulatory failures, allegedly causing investor losses.

       3. In truth, the £400 million in customer investment assets were seized by HBOS, not lost through collapse or wrongdoing.

       4. Integrity conducted no regulated activity in relation to those investments.

       5. Middleton sold the company’s assets for just £50,000, despite its multi-million-pound valuation.

       6. This false narrative led to a public censure and enabled the FSCS to issue £80 million in false compensation payouts, shielding HBOS from liability.

    3. 2011: I submitted formal complaints to the FSA via MPs Caroline Dinenage and George Hollingbury.

       1. Both MPs were shocked by the unlawful liquidation of Integrity and the absence of regulatory activity.

       2. The FSA responded via Margaret Cole and Andrew Bailey, confirming refusal to reopen the matter due to Peter Middleton’s false assertions.

       3. Both MPs were then silenced and refused further contact.

       4. I submitted a full dossier to the Treasury Select Committee, which never responded.

       5. These events were later supported by findings in the Anthony Stansfeld report on HBOS fraud and regulatory cover-up.

    4. 2012: I uncovered and exposed Richard Clay’s £50 million pension fraud.

       1. Clay offered me a £10 million bribe in 2012 to suppress the exposure. I refused.

       2. I reported the fraud to the FCA and SFO. Both refused to act.

    5. 2015: I was prevented from submitting a whistleblower report to Nottingham Police. Evidence suggests FCA interference.

    6. 2017: The FCA issued a defamatory Supervisory Notice, falsely alleging I was conducting unauthorised investment activity with Stargate Capital Management.

       1. The FCA removed the original notice and backdated a second notice, attempting to erase the first.

       2. I challenged the notice in the Upper Tribunal, winning the case UK Innovative TI v FCA (2017), now a precedent.

       3. The FCA then closed Stargate and coerced Peresh Shah, the firm’s owner, into signing an agreement never to work with me again.

    7. 2018: My Judicial Review was struck out without hearing and erased from public records—an unprecedented act.

    8. 2021–2022: I launched MATRIXFREEDOM, a lawful private trust platform. This triggered media smears, financial sabotage, and surveillance.

    9. 2023: I was arrested under Order 34/2023 for contempt—engineered using a fictitious prosecutor, “Alastair Mackenzie.”

       1. Not only was Mackenzie fictitious, but no evidence existed of any financial services being offered by me or any MATRIXFREEDOM member.

       2. The FCA knew this, but pursued a strategy of entrapment by design.

       3. Their aim was to obtain a constraint order against me personally, knowing that mere existence as a man would constitute a breach.

       4. This led to the judgment of 16 July 2025, asserting I had breached Order 34/2023.

       5. The judgment was defective in law, ignoring evidence, jurisdictional denials, affidavits, and attorney representation. It relied on a non-existent complainant and ignored over 500 affidavits confirming MATRIXFREEDOM provided no regulated services.

    10. 2023: Various bank accounts under Iain Clifford Stamp were frozen with funds in excess of £50,000.

    11. 2023: A BullionVault precious metals account was divested from gold and silver and frozen, account value in excess of £400,000.

    12. Two Iain Clifford Stamp controlled UK companies destroyed, bank accounts frozen and no way to operate them.

    13. 30 June 2025: A hearing at Southwark Crown Court occurred. My Attorney-in-Fact, David Ayerst, was barred from reading a prepared notice and was forcibly removed by Judge Anthony Baumgartner, in violation of fair hearing principles and lawful representation rights.

    14. 2024: A Judicial Review was initiated under case number AC-2023-LON-003629 and presided over by Justice Derek Sweeting.

        1. I was denied a hearing as a pro se litigant and was railroaded by procedural suppression.

        2. Justice Sweeting refused to allow presentation of jurisdictional challenges, ignored multiple affidavits, and suppressed all reference to the fictitious prosecutor.

        3. This conduct is subject to a formal judicial misconduct complaint (Annex X), and exemplifies denial of remedy through procedural dishonour.

    15. 2024–2025: I was placed under a General Civil Restraint Order (GCRO). I entered constructive exile in North Cyprus to avoid unlawful incarceration.

    16. 27 June 2025: I lawfully rescinded all presumed addresses for service, including correspondence locations and email accounts, which were no longer under my control.

        1. Despite this, the FCA and Southwark Crown Court continued to send documents to rescinded addresses and invalid emails.

        2. My Declaration of Rescission, backed by CPR, FCA Handbook, LPA 1925, and case law (Tinkler, Anufrijeva), stands unrebutted.

        3. Service was never lawfully effected.

    17. 30 June 2025: At a hearing before Southwark Crown Court, my duly appointed Attorney-in-Fact, David Ayerst, attempted to read out a lawful declaration asserting the move of the proceedings to a Court of Record. Judge Anthony Baumgartner denied him the opportunity to speak. Instead, he was forcibly removed by seven security guards, an act that constituted obstruction of representation and denial of lawful due process.

    18. 16 July 2025: Judge Anthony Baumgartner delivered a defective judgment asserting a breach of Order 34/2023. The judgment:

        1. Was issued despite no valid service of documents due to prior rescission of service.

        2. Relied on an unverified and fictitious complainant—Alastair Mackenzie—whose existence has not been lawfully substantiated.

        3. Ignored jurisdictional denials, standing affidavits, and all lawful notices submitted to the court.

        4. Failed to engage with over 500 affidavits confirming that MATRIXFREEDOM provided no regulated financial services.

        5. Represented an unlawful assumption of jurisdiction and an orchestrated abuse of judicial discretion.

    19. 30 July 2025 (Scheduled): The FCA, using the false identity of Alastair Mackenzie, has scheduled a sentencing hearing at Southwark Crown Court.

        1. Based on all current conduct and patterns, it is almost certain that Judge Baumgartner will issue an arrest warrant for my incarceration.

        2. This will represent the culmination of the unlawful judicial theatre initiated via Order 34/2023, fraudulently upheld by Crown actors in dishonour and breach of their oaths.

11. LEGAL AND PROCEDURAL ABUSES

    1. Fictitious Prosecutor: “Alastair Mackenzie” has no legal existence, delegation, or authority. His use was fraud.

    2. Void Jurisdiction: I denied joinder. All service was defective. No rebuttal was issued.

    3. Constructive Trust Fraud: Order 34/2023 operates as a trust. I am the Executor. Court assumed role of beneficiary fraudulently.

    4. Denial of Representation: My Attorney-in-Fact was lawfully appointed and barred from appearing.

    5. Suppression of Evidence: Over 500 member affidavits ignored. No rebuttals.

    6. Entrapment: Order 34/2023 was engineered to criminalise lawful activity. No complainant. No hearing.

    7. Defective Judgment: Judge Baumgartner’s ruling of 16 July 2025 ignored legal authority, trust declarations, jurisdictional denials, affidavits, and attorney standing. It is void ab initio.

    8. Conspiracy and Institutional Collusion: The Crown, through the FCA, judiciary, and the Attorney General’s Office, has conspired to silence me as a whistleblower. This includes:

    1. Suppression of my exposure of the HBOS Reading fraud and Richard Clay’s misconduct.

    2. Failure to act on submitted evidence and jurisdictional notices.

    3. Alignment with the systemic findings of the APPG Report, confirming regulatory failure.

    4. Reinforcement from the Anthony Stansfeld Report, which details how fraud within the banking sector has been covered up by the FCA, the SFO, and others.

    5. A clear pattern of retaliation against whistleblowers in favour of protecting institutional interests over consumer rights.

12. SYSTEMIC CROWN COLLUSION

    The Crown Collusion Dossier reveals coordination among FCA, SFO, FSCS, HM Treasury, and judiciary to target me. It documents a deliberate campaign to destroy MATRIXFREEDOM and suppress whistleblowing.

13. REPUTATIONAL WARFARE

    1. Dan Neidle (Tax Policy Associates): Former Clifford Chance partner. Repeats FCA defamation.

    2. Simon Goldberg (EmpowerThePeople): Rival PMA operator. Mimics Crown propaganda.

    3. I am barred from suing them due to the GCRO. The impact has been catastrophic:

    1. Public vilification

    2. Mental health deterioration

    3. Loss of business partnerships

    4. Collapsing remedy infrastructure

    5. Propaganda targeting by Simon Goldberg and Dan Neidle

14. UNLAWFUL SERVICE AND RESCISSION

    1. On 27 June 2025, I rescinded all consent to service. The addresses used by the FCA and courts are unauthorised. Service remains invalid. The courts have no jurisdiction.

15. PERPETRATORS OF THE HUMAN RIGHTS BREACHES

    1. The following individuals are named as principal actors responsible for the systemic and targeted breaches of my fundamental rights under the European Convention on Human Rights:

    1. Nikhil Rathi, Chief Executive Officer of the Financial Conduct Authority (FCA) – responsible for directing policy, authorising malicious prosecutions, and allowing the abuse of enforcement powers.

    2. Judge Anthony Baumgartner, Southwark Crown Court – delivered a judgment on 16 July 2025 based on fictitious prosecution, unlawful procedures, and denial of lawful representation.

    3. Justice Derek Sweeting, Royal Courts of Justice – presided over a judicial review and suppressed due process, denying me the right to be heard as a pro se litigant.

    4. Matthew Stone, FCA Officer – directly involved in the investigation and orchestration of unlawful legal actions against me.

    5. Pietro Boffa, FCA’s alleged “expert witness” – provided knowingly false or speculative testimony that misrepresented facts and misled the court.

    6. Richard Harmer the Attorney General (UK) – failed to intervene in clear instances of unlawful prosecution and denial of jurisdiction, constituting dereliction of duty.

    7. Dan Neidle, purported tax and legal expert – repeatedly made defamatory public statements designed to discredit me and undermine public trust in my work.

    8. Simon Goldberg, associated legal commentator – engaged in coordinated reputational attacks through media platforms, contributing to psychological distress and impairing my ability to lawfully operate MATRIXFREEDOM.

    9. Paul Tustain – BullionVault Founder & Chairman

    Each of these actors has played a role in what amounts to coordinated persecution, reputational sabotage, abuse of process, and denial of access to justice.

16. UK’s HUMAN RIGHTS RECORD

    1. 563 judgments by ECtHR

    2. 327 confirmed violations

    3. Pattern of abuse under Articles 6, 8, 10, 13

    4. Precedents: Gillan, Othman, Anufrijeva, Tinkler, Associated Newspapers

17. CONVENTION VIOLATIONS

    1. The following human rights violations specifically relate to the issuance and enforcement of Order 34/2023 and its aftermath. While systemic persecution spans earlier years, I acknowledge these may not qualify for redress under the four-month rule but serve as context for motive and continuing harm.

    Article	Violation
    Art. 3	Prohibition of inhuman or degrading treatment – Threat of incarceration under void judgment; forced exile; psychological persecution
    Art. 5	Right to liberty and security – Unlawful restraint without due process, anticipated unlawful incarceration under a void order
    Art. 6	Right to a fair trial – No lawful prosecutor; denial of attorney-in-fact; ignored affidavits; defective judgment
    Art. 8	Respect for private and family life – Constant interference through FCA harassment, exilic displacement, suppression of lawful enterprise
    Art. 10	Freedom of expression – Systematic suppression of whistleblowing and communications with MPs and oversight bodies
    Art. 11	Freedom of assembly and association – Targeting of MATRIXFREEDOM and its members; dissolution of related ventures
    Art. 13	Right to an effective remedy – Judicial review refused; all domestic avenues exhausted or denied
    Art. 14	Prohibition of discrimination – Targeted due to status as whistleblower, lawful dissenter, and free-standing private entity
    Art. 17	Prohibition of abuse of rights – Use of law (Order 34/2023) to eliminate basic freedoms and constitutional standing
    Art. 18	Limitation on use of restrictions for improper purpose – Entrapment strategy used to silence and imprison a dissenter
    Prot. 1-1	Peaceful enjoyment of possessions – Unlawful seizure and restraint of trust assets and business operations

18. ADMISSIBILITY

    1. Timely: The fake prosecutor was only discovered in July 2025.

    2. Order 34/2023 Judgement 16^th July 2025

    3. Sentencing 30^th July 2025

    4. No Remedy: GCRO blocks all legal redress. No internal appeal is possible.

    5. Urgent Harm: I remain under threat. My mental health and liberty are in peril.

19. RELIEF REQUESTED

    I respectfully request:

    1. A finding of violation under Articles 6, 8, 10, 13, 17, 18, and Protocol 1.

    2. Rule 39 interim measures suspending Order 34/2023 and staying all enforcement, prosecution, or sentencing.

    3. Immediate release of funds frozen or withheld under color of Order 34/2023, including but not limited to:

       • BullionVault account (IAINSTAMP)

       • Any accounts or assets under FCA direction, influence, or implication

    4. Public correction and annulment of the fraudulent record, clearing my name and confirming my status as the lawful General Executor.

    5. Declaration that the proceedings under Order 34/2023 were void ab initio and engineered through collusion and entrapment by FCA officials and judiciary.

    6. Any other remedy or relief the Court deems just and equitable under Article 41.