Standards & Whinges Against Negligent Kingdoms (SWANK London Ltd.): procedural neglect

Showing posts with label procedural neglect. Show all posts

Re: Westminster Children’s Services — In the Matter of Grandparent Contact and State-Created Deprivation

⟡ ADDENDUM: On Grandparent Contact and Local Authority Failures ⟡

“The Erasure of Intergenerational Bonds: On Phantom Facilitation and State-Created Deprivation”

Filed: 15 September 2025
Reference: SWANK/WESTMINSTER/ADDENDUM-NANA-001
Download PDF: 2025-09-15_Addendum_Nana001.pdf
Summary: Addendum documenting Westminster’s failure to facilitate lawful grandparent contact, causing emotional harm and procedural neglect.

I. What Happened

• The maternal grandmother confirmed weekly availability at four fixed times (Tuesdays and Thursdays at 12:00 p.m. and 5:00 p.m. EST).
• Despite her proactive availability, the Local Authority failed to organise consistent sessions.
• As of filing, three consecutive weeks have passed without grandmother contact, due solely to Westminster’s inconsistency.

II. What the Addendum Establishes

• Parental and Family Support — grandmother is willing, available, and committed.
• Institutional Neglect — LA failure unlawfully disrupts family bonds.
• Emotional Harm — children denied stability, reassurance, and intergenerational care.
• Displacement of Duty — statutory duties improperly shifted onto family members.

III. Why SWANK Logged It

• Legal relevance: failure to facilitate grandparent contact breaches statutory duties.
• Oversight value: exposes neglect disguised as neutral oversight.
• Historical preservation: records a three-week deprivation caused by institutional irresponsibility.
• Policy precedent: confirms administrative disarray is not lawful justification for restricting contact.

IV. Applicable Standards & Violations

Domestic Law
• Children Act 1989, Sections 1, 22(3)(a), 34 — welfare and contact duties breached.
• Children Act 2004, Section 11 — safeguarding duty violated by failure to facilitate.

Human Rights
• Article 3 ECHR — emotional deprivation amounts to degrading treatment.
• Article 6 ECHR — fairness undermined by lack of scheduling.
• Article 8 ECHR — family life obstructed by omission.
• Article 14 ECHR — discriminatory disregard for international family contact.
• UNCRC Articles 9, 12, 18 — children denied lawful contact, voice, and intergenerational support.

Academic & Oversight Authority
• Bromley’s Family Law — contact is a child’s right, not LA discretion.
• Bromley on Extended Family — intergenerational ties central to welfare.
• Ofsted fostering standards — duty to promote family contact breached.
• SWE Standards & Working Together (2018) — integrity and timeliness absent.

V. SWANK’s Position

This is not safeguarding.
This is the procedural erasure of a grandmother.

We do not accept three-week deprivations disguised as oversight.
We reject institutional neglect as lawful facilitation.
We will document the State’s obstruction of intergenerational bonds.

⟡ This Entry Has Been Formally Archived by SWANK London Ltd. ⟡

Every entry is timestamped. Every sentence is jurisdictional. Every structure is protected.

This is not a blog.
This is a legal-aesthetic instrument.

Filed with deliberate punctuation, preserved for litigation and education.
Because evidence deserves elegance.
And retaliation deserves an archive.

⚖️ 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.

I Laid Out the Law. Now They Can Read It Back to Me — in Court.

⟡ “They Ignored My Emails. So I Gave Them a PDF.” ⟡
A formal evidence statement authored by Polly Chromatic outlining Westminster’s repeated failure to provide communication adjustments. Every ignored message is cross-referenced. Every breach is named. Every consequence — from panic attacks to educational disruption — is laid out in calm, clinical clarity. Not a feeling. A file.

Filed: 31 January 2024
Reference: SWANK/WCC/ADJ-FAIL-01
📎 Download PDF – 2024-01-31_SWANK_EvidenceSummary_CommunicationAdjustmentRefusals_MedicalHarm_ClaimAttachment.pdf
Multi-statute legal brief documenting Westminster Council’s refusal to implement lawful communication adjustments. Anchored in Equality Act, Human Rights Act, and DPA. Summarises medical harm, institutional retaliation, and procedural neglect. Intended for use in judicial review, PHSO complaint, and active civil claim. SWANK status: founding exhibit.

I. What Happened

Polly Chromatic created a formal record of refusal. In it, she stated:

That she had made repeated written adjustment requests due to verbal disability
That these requests were either ignored or procedurally weaponised
That the failure caused:
- Medical risk (e.g. panic attacks, oxygen stress, dysphonia flare)
- Safeguarding retaliation
- Educational interference in home-based learning
That evidence files were being maintained and published via SWANK

The file includes:

A factual narrative
Chronology of adjustment requests
Direct links to evidence documents
Applicable law
The specific harms now forming part of her legal claim

It is a testimony with citations.

II. What the File Establishes

That communication adjustments were a medical necessity, not a preference
That Westminster was formally notified and procedurally noncompliant
That harm was predictable, recorded, and now litigated
That SWANK is not a blog — it is an evidentiary archive, legally framed
That the parent is not disengaged — she’s a legal historian

This wasn’t just documentation.
This was the indictment in narrative form.

III. Why SWANK Filed It

Because a pattern is only a pattern when you write it down. Because emails get lost in inboxes — but a timestamped PDF with a statute list is harder to ignore. And because after a year of politely reminding them what the law requires, this file said: we’re done reminding — we’re now recording.

SWANK archived this because:

It’s the cornerstone of your Equality Act claim
It gathers individual emails into a single act of structured resistance
It confirms the State understood the request and refused it anyway
It legally reframes neglect as a violable act, not a clerical oversight

IV. Violations

Equality Act 2010 –
• Section 20: Adjustment refusals documented in writing
• Section 26: Harassment caused by repeated boundary violation
• Section 27: Procedural retaliation after lawful requests
Human Rights Act 1998 –
• Article 3: Psychological harm via procedural indifference
• Article 8: Infringement on family privacy through forced contact
Data Protection Act 2018 / GDPR –
• Records maintained without accommodating known disability context
• Failure to correct inaccurate behavioural assumptions
Children Act 1989 –
• Educational harm due to procedural disruption
• Emotional instability in family due to safeguarding negligence

V. SWANK’s Position

You don’t get to say “we didn’t know” when the file has footnotes. You don’t get to mistake formatting preference for medical accommodation. And you don’t get to ignore a legally required adjustment and still call yourself a safeguarding professional.

SWANK London Ltd. classifies this document as a foundational evidentiary record of statutory breach — formatted for court, copied to history.

⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡ Every entry is timestamped. Every sentence is jurisdictional. Every structure is protected. 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. This is a legal-aesthetic instrument. Filed with velvet contempt, preserved for future litigation. Because evidence deserves elegance. And retaliation deserves an archive. © 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.

You Can’t Dismiss Someone’s Disability — And Then Act Like You Never Saw It

⟡ “I Said I Was Ill. He Said ‘Please Stop Forwarding Me These Emails.’” ⟡
A short exchange with Metropolitan Police that proves it doesn’t take a paragraph to document disregard. Sometimes, a one-sentence response is all the negligence you need.

Filed: 15 October 2024
Reference: SWANK/MPS/DIS-01
📎 Download PDF – 2024-10-15_SWANK_Email_MetPolice_AminurRashid_DisabilityDismissal_MedicalDisclosure.pdf
Correspondence to the Metropolitan Police and Westminster safeguarding services disclosing active illness, breathing difficulty, and verbal disability. Officer Aminur Rashid replies with procedural disinterest and a command to stop emailing — fully cc’d to safeguarding.

I. What Happened

In mid-October 2024, Polly Chromatic sent an email to Westminster safeguarding and GP Dr Reid disclosing the following:

A fever
Difficulty breathing
Ongoing verbal trauma
A medical complaint against her GP
And a clear disability adjustment request to communicate via email only

This wasn’t an escalation. It was survival.
But the Metropolitan Police responded anyway. And what did they say?

“Please stop forwarding me to these emails.”

That’s it.
No welfare check. No referral. No concern.
Just silence, wrapped in administrative dismissal — and cc’d to safeguarding.

II. What the Email Establishes

That a lawful disability accommodation was requested
That police and safeguarding were notified of acute medical distress
That the reply from MPS was not protective — it was performative rejection
That systemic disregard can be boiled down to one reply
That the state saw a collapsing parent — and logged her as spam

III. Why SWANK Filed It

Because there’s no need for speculation when they write it down for you. SWANK archived this to:

Prove that institutional actors received medical disclosures — and replied with dismissal
Demonstrate that verbal disability was documented and denied
Capture police refusal in the body of a single sentence
Establish the tone of systemic negligence before safeguarding escalation

This isn’t a dramatic letter. It’s worse: it’s a casual refusal to acknowledge human need.

IV. Violations

Equality Act 2010
• Section 20: Communication adjustment ignored
• Section 27: Retaliatory tone in response to medical disclosure
• Section 149: Public authority’s failure to eliminate discrimination
Human Rights Act 1998 –
• Article 8: Family and private life
• Article 3: Degrading treatment through indifference
Police Code of Ethics –
• Respect for human dignity
• Responsibility to act with care toward vulnerable individuals
NHS Duty of Candour & Coordination – Dr Reid’s inclusion is a medical safeguarding trigger point

V. SWANK’s Position

This wasn’t a failure to respond. It was a decision. A decision to view medically vulnerable people as inconveniences. A decision to ignore statutory adjustments. A decision to protect the inbox, not the individual.

SWANK London Ltd. recognises this as an official procedural rejection of medical reality, delivered by the Met in under 12 words.

Chromatic v. The Cult of Unexamined Files

⟡ In re: The Jurisprudence of Evidentiary Saturation ⟡
An exhaustive compilation demonstrating that truth can be buried beneath the sheer weight of institutional disregard.

Filed: 1 July 2025
Reference: SWANK/ROYALCOURTS/SUPPORTING-EVIDENCE-ZC25C50281
📎 Download PDF – 2025-07-01_SupportingEvidence_ZC25C50281.pdf
Supporting evidence index: a dossier of medical records, procedural timelines, and forensic documentation unheeded by the state.

I. What Happened
Over two years, the applicant compiled a meticulous evidentiary archive detailing medical diagnoses, trauma histories, procedural sabotage, and institutional harassment. Despite filing thousands of pages of sworn documentation, the response from the safeguarding authorities was an unbroken litany of either tactical silence or patronising deflection. This compilation stands as a monument to the proposition that quantity of evidence is irrelevant when the state prefers not to look.

II. What the Complaint Establishes

That the applicant has furnished more clinical and procedural proof than most public inquiries.
That no volume of corroboration can penetrate an institutional apparatus committed to predetermined outcomes.
That the statutory obligations of child welfare were subordinated to the bureaucratic imperative of reputational self-preservation.
That trauma documentation was treated as an inconvenience rather than a mandate for action.
That the right to be heard was reduced to a purely ceremonial exercise.

III. Why SWANK Logged It
Because the evidentiary record deserves the same respect the children never received. Because the ritual of ignoring documentation is the hallmark of procedural theatre masquerading as child protection. Because the archive itself is now the only locus of accountability in a system that prefers erasure to remedy.

IV. Violations

Children Act 1989 (Duty to safeguard welfare—repeatedly subordinated)
Article 3 ECHR (Prohibition of degrading treatment—documented extensively)
Article 8 ECHR (Right to family life—ignored despite forensic corroboration)
Equality Act 2010 (Disability discrimination—proven in the record)

V. SWANK’s Position
This was not safeguarding. It was the curatorial dismissal of lived reality, accomplished with the bureaucratic serenity of a system that never intends to acknowledge the harm it causes.
We do not accept the aesthetic of “insufficient evidence” when the evidence has been filed tenfold.
We will document every iteration—permanently, contemptuously, unimpressed.

⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡

Every entry is timestamped.
Every sentence is jurisdictional.
Every structure is protected.

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.
This is a legal-aesthetic instrument.
Filed with velvet contempt, preserved for future litigation.

Because evidence deserves elegance.
And retaliation deserves an archive.

© 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.

She Was Too Sick to Speak. They Still Didn’t Show.

⟡ “I’m Sick — and She Didn’t Even Show Up.” ⟡
A clinical risk warning, ignored. A meeting, skipped. A person, discarded.

Filed: 11 January 2025
Reference: SWANK/WCC/EMAIL-34
📎 Download PDF – 2025-01-11_SWANK_Email_KirstyHornal_ClinicalRisk_NoShowComplaint.pdf
Polly Chromatic informed Westminster and her solicitor, Laura Savage, that she was too unwell to continue being harassed — and that once again, Kirsty Hornal didn’t bother to show up. In a system that demands compliance, even no-shows have consequences. The message was brief. The implication was devastating.

I. What Happened

– Polly was sick.
– Polly was exhausted.
– Polly was clear.

She emailed:

“Social worker didn’t show up today. I’m tired of being bothered while I’m sick.”

Kirsty Hornal was expected.
She wasn’t there.
The cycle of disturbance without accountability continued.
Only now — it’s recorded.

II. What the Email Establishes

That Polly Chromatic was medically unwell at the time of institutional contact
That her symptoms were known and repeatedly exacerbated by unscheduled interaction
That Westminster social worker Kirsty Hornal failed to attend a scheduled contact
That emotional exhaustion and harm were formally communicated
That silence, again, replaced safeguarding

III. Why SWANK Filed It

Because even no-shows leave bruises.
Because being medically exhausted isn’t an invitation — it’s a limit.
Because she wasn’t asking for anything.
Just for it to stop.
And even that was ignored.

IV. Violations Identified

Failure to attend scheduled meeting without notice or clinical accountability
Disregard for medical boundaries communicated by a disabled parent
Procedural inconsistency resulting in emotional and physical distress
Lack of safeguarding follow-up following a missed contact event
Institutional minimisation of illness as a barrier to engagement

V. SWANK’s Position

Polly was sick.
Kirsty didn’t come.
And still, the pressure mounted.

No escalation.
No support.
Just quiet abandonment —
while pretending they care.

Now, we file the silence.
And mark it:
Clinical Risk. No Show. Public Record.

We Addressed the Commissioner. The System Sent a Link.

⟡ “We Filed a Complaint With the Commissioner. They Sent a Link.” ⟡

Metropolitan Police Acknowledge Formal Complaint on Negligence, Retaliation, and Adjustment Failure — But Redirects to Website Without Action

Filed: 18 February 2025
Reference: SWANK/MPS/NEGLECT-01
📎 Download PDF – 2025-02-18_SWANK_MetPolice_ComplaintCommissioner_ResponseRedirect_ProceduralDeflection.pdf
Summary: The Met Police Commissioner’s Office responds to Polly Chromatic’s formal complaint by forwarding it to Professional Standards and redirecting to a public complaints link, ignoring content and legal notice.

I. What Happened

On 17 February 2025, Polly Chromatic submitted a formal complaint to the Commissioner of the Metropolitan Police, cc’ing:

Legal counsel (Blackfords & Merali Beedle)
NHS representative (Philip Reid)

The complaint cited:

Police negligence in safeguarding follow-up
Retaliation following complaints
Repeated refusal to accommodate written-only communication

On 18 February 2025, the Commissioner’s Office replied:

Acknowledged receipt
Stated they have “no direct involvement” in investigations
Forwarded the complaint to Professional Standards
Suggested Polly use the public-facing “Report a Crime” and “Make a Complaint” webpages
No direct response to legal action language or disability rights claims

II. What the Record Establishes

• The Met received a legally framed complaint but offered no institutional response
• The response was automated, generic, and dismissive, regardless of content or cc’d parties
• No action or contact was made by Professional Standards at the time of filing
• This reflects a system-wide minimisation of disability-based retaliation reports
• It supports future claims of procedural neglect, disability discrimination, and legal disregard

III. Why SWANK Logged It

Because when you email the Commissioner about rights violations, and they respond with a link, the system is saying: “We read it. We won’t act.”
Because redirection is institutional denial with polite language.
Because this was not a report. It was a warning. And they dismissed it anyway.

SWANK logs the moment a Commissioner’s inbox became a firewall.

IV. SWANK’s Position

We do not accept that formal legal notices are answered with public forms.
We do not accept that disabled complainants are redirected instead of heard.
We do not accept that this constitutes “receipt.”

This wasn’t just inaction. It was institutional gaslighting.
And SWANK recorded it.

⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡

Every entry is timestamped.
Every sentence is jurisdictional.
Every structure is protected.

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.
This is a legal-aesthetic instrument.
Filed with velvet contempt, preserved for future litigation.

Because evidence deserves elegance.
And retaliation deserves an archive.

© 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.

They Weren’t Fighting Until You Got Involved.

⟡ Two Sons. One Door. No Help. ⟡

When the State Withdraws, the Injured Mother Becomes the Crisis Unit

Filed: 13 June 2025
Reference: SWANK/DOMESTIC/SIBLING-ESCALATION-01
📎 Download PDF – 2025.06.13_SiblingEscalation_UnaidedProtection_StatutoryAbsence.pdf
No safeguarding record exists for this event — not because it was irrelevant, but because it indicts those who were supposed to care and didn’t.

I. What Happened

On Friday 13 June 2025, two adolescent boys — aged 13 and 16 — began play-fighting over a bag of crisps. The moment shifted, as these moments do, into something more dangerous. Within seconds: a chokehold, retaliatory strikes, and a domestic scene no social worker would ever log — because no social worker was there.

The mother, disabled and alone, intervened physically.
She was injured.
She succeeded.

She called no agency. She called no line. She called Krystyna, the porter.
Krystyna came.
That was the only institutional presence: a building staff member.
Not a department. Not a service. Not a “team.”

There was no emergency call because the emergency had already been addressed — not through intervention, but through absence.

II. What the Incident Establishes

• This mother de-escalated sibling violence with no assistance
• Her injury was the only price the system demanded
• The emotional context was not “family dysfunction,” but exhaustion by institutional incursion
• The root cause was jurisdictional erosion, not neglect
• No threshold for safeguarding was crossed — unless that threshold is “being abandoned repeatedly”

This was not a red flag.
It was a white flag.
And no one responded.

III. Why SWANK Logged It

Because surveillance is only triggered when a mother fails — not when she bleeds and succeeds.
Because statutory presence evaporates the moment it would require liability.
Because this is the kind of incident that will never be referenced by Children’s Services — not because it’s minor, but because it’s inconvenient.

SWANK records what institutions redact.
SWANK files what the state cannot afford to remember.

This family was not at risk.
They were over-targeted, under-supported, and left to hold their own line.

IV. What the Law Says (But Did Not Do)

• Children Act 1989 – Duty to provide support and safeguarding.
• Equality Act 2010 – Obligation to accommodate written-only communication.
• Human Rights Act 1998 – Right to private life without coercive neglect.
• Working Together to Safeguard Children (2018) – Duty to intervene pre-crisis.
• UNCRC, Article 19 – Protection from institutional harm, not just parental.

V. SWANK’s Position

We reject the narrative that absence is benign.
We reject the rebranding of abandonment as empowerment.
We reject the selective memory of services that track every email but log no injuries unless they can be used against the parent.

This was not a family in crisis.
This was a state in dereliction.
And the archive now reflects exactly that.

⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡

Every entry is timestamped.
Every sentence is jurisdictional.
Every structure is protected.

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.
This is a legal-aesthetic instrument.
Filed with velvet contempt, preserved for future litigation.

Because evidence deserves elegance.
And retaliation deserves an archive.

⟡ Straw Therapy for Structural Collapse: When Dysphonia Meets Decorative Care ⟡

⟡ The Asthmatic, The Voice, and The Posture Plan: A Clinic That Breathed Around the Problem ⟡
Filed: 8 December 2024
Reference: SWANK/SLT/Wood-HarleyENT-2024
📎 Download PDF — 2024-12-08_SWANK_Wood_Report_MuscleTensionDysphonia_EosinophilicAsthma.pdf

I. When Breathing Fails and They Prescribe Diaphragm Discipline

This document records a formal consultation at the Harley Street ENT Clinic, where a mother of four, chronic asthmatic, and post-toxic exposure patient presented with:

Persistent dysphonia
Breathing pattern dysfunction
Exhaustion from speech

The therapeutic outcome? A beach pose. A Lax Vox straw. And a water intake target.

She brought a voice problem shaped by sewage fumes, inflammation, asthma, and systemic fatigue.
They handed her posture.

II. What Was Said (and What Was Not)

Diagnosis: Muscle tension dysphonia
Clinical complicators: Eosinophilic asthma, reflux, nasal damage, suspected MACS
Noted symptoms: Choking episodes, chest rashes, fast speech, clavicular breathing
Therapeutic action: Hydration reminder and guided exhalation through a straw

Pathology met politeness. The outcome was decorative concern.

III. Why SWANK Filed This

Because chronic breathlessness in a disabled woman with confirmed asthma and environmental injury deserves more than nasal rinse praise and GRBAS scores.

This letter documents:

Clinical acknowledgement without clinical urgency
Procedural empathy without substantive intervention
A case of medical decorum performing as care

IV. SWANK’s Position

We do not believe "moderate dysphonia" captures the lived experience of gasping to finish sentences.
We do not accept fast speech as a diagnosis.
We reject posture-led gaslight in place of respiratory rehabilitation.

Let the record reflect:

The asthma is real
The exposure is real
The dysphonia is real
The action plan — was quaint

This was not a treatment pathway.
It was a polite stroll around a clinical emergency.

⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡

Every entry is timestamped.
Every sentence is jurisdictional.
Every structure is protected.

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.
This is a legal-aesthetic instrument.
Filed with velvet contempt, preserved for future litigation.

Because evidence deserves elegance.
And retaliation deserves an archive.

Recently Tried in the Court of Public Opinion

I. What Happened

II. What the Addendum Establishes

III. Why SWANK Logged It

IV. Applicable Standards & Violations

V. SWANK’s Position

I. What Happened

II. What the File Establishes

III. Why SWANK Filed It

IV. Violations

V. SWANK’s Position

I. What Happened

II. What the Email Establishes

III. Why SWANK Filed It

IV. Violations

V. SWANK’s Position

I. What Happened

II. What the Email Establishes

III. Why SWANK Filed It

IV. Violations Identified

V. SWANK’s Position

⟡ “We Filed a Complaint With the Commissioner. They Sent a Link.” ⟡

I. What Happened

II. What the Record Establishes

III. Why SWANK Logged It

IV. SWANK’s Position

I. When Breathing Fails and They Prescribe Diaphragm Discipline

II. What Was Said (and What Was Not)

III. Why SWANK Filed This

IV. SWANK’s Position