AFFIDAVIT OF REBUTTAL OF JUDGEMENT

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AFFIDAVIT OF REBUTTAL OF JUDGEMENT

AND NOTICE OF CONSTRUCTIVE TRUST FRAUD

ORDER 34/2023

NOTICE TO AGENT IS NOTICE TO PRINCIPAL

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IN THE CROWN COURT AT SOUTHWARK

Served Upon: JCIO, Serious Fraud Office, Public Inquiry Committee, Financial Conduct Authority, and all Parties Cited in Certificate of Service

Filed by: Iain Clifford, occupant of the office of the General Executor of the Estate known as [IAIN CLIFFORD STAMP]

In the Matter of Order 34/2023 and the Judgment of Judge Anthony Baumgartner – Dated 16 July 2025

Jurisdiction: United Kingdom (under protest and without prejudice)

Served upon: Southwark Crown Court, the FCA, SFO, JCIO, and all relevant parties

I, Iain Clifford, a living man, the general executor and sole beneficiary of the Estate formerly known as [IAIN CLIFFORD STAMP], solemnly affirm and declare the following under oath, under penalty of perjury and under full commercial liability:

1. The Crown’s Fraud and Reliance on a Fictional Prosecutor

A. It is now a matter of record that the individual named “Alastair Mackenzie”—relied upon by the Crown and the Financial Conduct Authority (FCA) as a prosecutorial authority—is merely an appointed representative, listed on the FCA Register as of 23 December 2024.

B. Appointed representatives are not employees of the FCA, nor do they possess any lawful delegation or statutory authority to prosecute under the Financial Services and Markets Act 2000 (FSMA) or the Proceeds of Crime Act 2002 (POCA).

C. Despite this, Crown actors—including the FCA, Southwark Crown Court, and associated enforcement officers—have continued to rely on the name “Alastair Mackenzie” in legal filings and enforcement proceedings. This reliance is fraudulent, as it misrepresents the existence of a lawful prosecutor and constitutes a breach of public trust.

D. All Crown actors involved must be presumed to know—or ought to have known—that no prosecutorial standing exists for this individual. Their continued reliance on a fictional or placeholder identity constitutes constructive fraud, impersonation of a public officer, and a violation of the Fraud Act 2006.

E. Furthermore, this fraudulent reliance forms part of a broader pattern of entrapment by design. For over 15 years, I, the affiant, have been subjected to a coordinated campaign of retaliation and persecution by Crown agencies in response to my whistleblowing activities, including disclosures related to HBOS, Richard Clay, and systemic misconduct within the FCA.

F. This pattern of abuse—now culminating in the unlawful enforcement of Order 34/2023—confirms that the Crown’s actions are not only procedurally defective but also malicious in intent. All parties involved are now vicariously liable for the harm caused by this entrapment and for the continued denial of justice to a protected whistleblower.

2. No Jurisdiction Exists Over the Living Man

A. I rebut in full the assertion made by Judge Anthony Baumgartner that I, the living man Iain Clifford, have breached Order 34/2023. That order, void ab initio, was fraudulently presumed to apply to me under a fictitious legal presumption. I have never provided, offered, or arranged any regulated financial services under the Financial Services and Markets Act 2000 (FSMA). Nor have I acted under the body corporate known as IAIN CLIFFORD STAMP, which is an extinguished legal fiction.

3. No Evidence of Breach Exists

A. To this date, no lawful evidence has been submitted by the FCA, Southwark Crown Court, or any other party to establish that I:

  • i. Hold any bank account in the name of IAIN CLIFFORD STAMP;
  • ii. Operate any company in that name offering regulated services;
  • iii. Am the author, controller, or provider of any regulated financial product;
  • iv. Have ever conducted business in breach of FSMA.

B. The judgment fails to substantiate any such activity and rests upon hearsay, presumptions, and a conflation of my position as a founder and speaker with that of a service provider or regulated entity.

4. Role of MATRIXFREEDOM and Lawful Activity

A. MATRIXFREEDOM is a private members association (PMA), lawfully constituted and operating under the principles of private association. All members of MATRIXFREEDOM are protected by statutory rights and privacy guarantees afforded to members of such associations.

B. As the founder and educational presenter, I, the living man Iain Clifford, merely host webinars and deliver educational content to members of MATRIXFREEDOM across various jurisdictions globally. These webinars are non-commercial, non-regulated, and do not constitute financial services or investment advice as defined under the Financial Services and Markets Act 2000 (FSMA) or the Regulated Activities Order 2001 (RAO).

C. There is no provision in Order 34/2023 that prohibits the living man from presenting educational webinars to members of a private members association.

D. Furthermore, Judge Baumgartner failed to produce any evidence that the living man, Iain Clifford, or the body corporate known as IAIN CLIFFORD STAMP, ever provided any regulated financial services as defined under the Financial Services and Markets Act 2000. The Financial Conduct Authority (FCA) has also failed to bring forward any such evidence. In fact, over 500 witness statements from members of MATRIXFREEDOM confirm that they were never offered any financial services that would require FCA authorisation or licensing. This absence of evidence further invalidates the presumption of breach under Order 34/2023.

5. Service Has Been Formally Rescinded

A. I affirm that service at the following addresses has been lawfully rescinded via notice dated 27 June 2025:

  • i. 4C Glebe Park Avenue, Bedhampton, Havant, Hants PO9 3JR
  • ii. iain@mtrxf.org
  • iii. iain@wealthfortress.co.uk

B. The Notice of Rescission of Service remains unrebutted and forms an estoppel by acquiescence. Any claim of lawful service thereafter is void under:

  • i. FCA GEN 2.2.14R – Communication is not effective unless received;
  • ii. CPR 6.23 – Valid service must be to a designated address;
  • iii. Interpretation Act 1978, s.7 – The presumption of service is rebuttable;
  • iv. Law of Property Act 1925, s.196(4) – Requires known residence or business.

6. All Liability Falls to the Crown

A. As previously declared and noticed, the body corporate IAIN CLIFFORD STAMP is an artificial entity created and governed by the Crown. Therefore, under the Crown Proceedings Act 1947 and the doctrine of sovereign responsibility, any financial, legal, or civil liability attributed to that estate belongs to the Crown itself.

B. This assertion has been lawfully noticed and unrebutted, forming further estoppel in law.

7. Notice of Persecution, Retaliation & Collusion

A. The attempt to use Order 34/2023 to criminally sanction me is:

  • i. Retaliatory in nature, arising after whistleblowing on HBOS, Richard Clay, and the FCA;
  • ii. Procedurally defective;
  • iii. Based on no verified complainant, no client harm, no FCA enforcement file, and no due process.

B. The civil restraint order (2024) unlawfully bars me from accessing the Court of Appeal or Supreme Court, forcing me into exile in North Cyprus and depriving me of a remedy under domestic law. I have been left with no forum but the European Court of Human Rights.

8. Notice of Rebuttal to Judgment

A. The judgment of Judge Baumgartner:

  • i. Offers no explanation as to the identity, authority, or prosecutorial status of the alleged FCA complainants;
  • ii. Makes no finding as to the lack of harm or evidence;
  • iii. Refers to breach of Order 34/2023 without proof of any underlying activity;
  • iv. Ignores my role as a private man under trust, not a service provider.

B. I have provided no services, issued no invoices, and conducted no business in a regulated sphere. I act solely as a public speaker and founder of Matrix Freedom, which is a private membership association (PMA) lawfully excluded from FSMA regulation.

9. Conclusion and Demand

A. I demand the immediate and permanent withdrawal of any motion, warrant, or order of enforcement under Order 34/2023. Failure to do so will be pursued as:

  • i. Malfeasance in public office;
  • ii. Constructive trust fraud;
  • iii. Denial of the right to a fair trial (Article 6 ECHR);
  • iv. Violation of Article 13 and Protocol 1, Article 1 of the ECHR.
  • v. Evidence of systemic persecution for inclusion in my petition to the European Court of Human Rights.

10. Final Declaration

A. I declare under full penalty of perjury and in honour that:

  • i. The Crown and FCA have no lawful claim against me
  • ii. All proceedings are void for want of jurisdiction
  • iii. I am the living man, not subject to administrative presumptions
  • iv. I hold lawful superior title as General Executor of the decedent estate

B. Any continued action constitutes trespass, constructive fraud, and breach of trust

JURAT

I Iain Clifford, holding the office of General Executor of the [IAIN CLIFFORD STAMP] estate, a divine (holy) living spirit, born again, incarnate with life as a man under God’s law, attest and affirm that the aforementioned is true and correct, attested to and submitted by a living, breathing, self-aware man, under God. I further acknowledge that this is an act of my free will and Deed.

I solemnly swear and affirm, under penalty of perjury, that the contents of this document are the truth, the whole truth, and nothing but the truth.

By: Iain Clifford
3rd July Twenty Twenty-Five.

Witnesses

Witness 1: Andrew Michael – Signed – 21st July 2025
Witness 2: David Ayerst – Signed – 21st July 2025
Witness 3: Angela John – Signed – 21st July 2025

Certificate of Service

I Iain Clifford, Certify the foregoing was provided by UK Special delivery mailed to:

The Registrar
European Court of Human Rights
Council of Europe
1 avenue de l’Europe
F‑67075 Strasbourg Cedex
FRANCE

As per Section 196(4) of the Law of Property Act 1925 and Postal Services Act 2000.

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