⟡ SWANK Evidentiary Catalogue
Filed date: 21 July 2025
Reference Code: SWANK-RM-JR0512
PDF Filename: 2025-07-21_SWANK_Addendum_RositaMoise_JudicialReviewPreActionResponse.pdf
1-Line Summary: Rosita Moise responds to Judicial Review pre-action with polite delay tactics and absolute procedural denial of disability accommodations already breached.
I. What Happened
On 12 May 2025, Senior Solicitor Rosita Moise issued a formal response to my Pre-Action Protocol Letter, dated 25 April 2025, which challenged the Local Authority’s decision to escalate my family’s case to PLO (Public Law Outline) proceedings.
My letter established:
That no safeguarding threshold had been met;
That written-only communication had been medically required and repeatedly denied;
That the PLO decision represented procedural retaliation against a disabled parent asserting her legal rights.
Rather than substantively engage with these points, Rosita’s reply delayed response by citing a bank holiday, then forwarded a generic acknowledgment attachment — void of analysis, remedy, or recognition of the legal violations outlined.
She offered no comment on:
The psychiatric evidence from Dr. Rafiq (26 November 2024);
The multiple Equality Act breaches already triggered;
Or the blatant contradiction of treating disability adjustments as “non-engagement.”
II. What the Complaint Establishes
Rosita Moise’s email and the attached document represent an archetypal act of administrative deflection — a performance of polite reception in place of legal remedy.
This behaviour establishes:
Zero willingness to withdraw from PLO despite a complete collapse of lawful justification;
Zero accountability for Equality Act breaches related to access, tone, and communication method;
Institutional pretence that delay is diplomacy, even when delay escalates harm.
This is not a conversation. It is a gatekeeping mechanism dressed as correspondence.
III. Why SWANK Logged It
Because this moment marks the formal confirmation that the Local Authority never intended to honour written-only accommodations, even when:
Repeatedly requested
Medically supported
Protected by law
Raised in pre-litigation
Because this was the tipping point: when your legal objections were not misunderstood, but professionally ignored.
And because when a Local Authority’s solicitor receives a disability rights claim, then responds only to the calendar, she is not acting in good faith — she is acting in bureaucratic ritual.
IV. Violations
Equality Act 2010, Sections 20 and 149 – Failure to implement known adjustments
Article 6 ECHR – Right to participate effectively in legal process
Article 8 ECHR – Unlawful interference with family life through false escalation
Judicial Review Protocol – Inadequate response to a detailed pre-action letter
Professional standards for public law practice – Avoidance of statutory compliance
V. SWANK’s Position
Rosita Moise was given an opportunity — not to win an argument, but to demonstrate lawful engagement.
She chose not to.
She acknowledged receipt, attached a document, and marked a delay — but did not acknowledge harm, did not retract PLO, and did not implement the most basic accommodation known to the case.
This response is not a rebuttal. It is an evasion.
This filing serves as a record of refusal disguised as reply, and confirms why formal judicial review proceedings were filed thereafter.
⚖️ Legal Rights & Archival Footer This Dispatch Has Been Formally Archived by SWANK London Ltd. Every entry is timestamped. Every sentence is jurisdictional. Every structure is protected. This document does not contain confidential family court material. It contains the lawful submissions, filings, and lived experiences of a party to multiple legal proceedings — including civil claims, safeguarding audits, and formal complaints. All references to professionals are strictly in their public roles and relate to conduct already raised in litigation. This is not a breach of privacy. It is the preservation of truth. Protected under Article 10 of the ECHR, Section 12 of the Human Rights Act, and all applicable rights to freedom of expression, legal self-representation, and public interest disclosure. To mimic this format without licence is not homage. It is breach. We do not permit imitation. We preserve it as evidence. This is not a blog. It is a legal-aesthetic instrument. Filed with velvet contempt. Preserved for future litigation. Because evidence deserves elegance, retaliation deserves an archive, and writing is how I survive this pain. Attempts to silence or intimidate this author will be documented and filed in accordance with SWANK protocols. © 2025 SWANK London Ltd. All formatting and structural rights reserved. Use requires express permission or formal licence. Unlicensed mimicry will be cited — as panic, not authorship.