1

Suite 101

254 Pentonville Road

London N1 9JY

England

6 May 2014

Dr Navanethem Pillay

United Nations High Commissioner for Human Rights

Office of the United Nations High Commissioner

for Human Rights (OHCHR)

Palais des Nations

CH-1211 Geneva 10

Switzerland

Dear High Commissioner Pillay

I write as the Managing Director of Network for Church Monitoring (N4CM) to ask you to

urge the United Kingdom to accede to the first Optional Protocol to the International

Covenant on Civil and Political Rights (ICCPR), the multilateral treaty that commits its

parties to respect the civil and political rights of individuals, including the right to freedom of

speech.

The first Optional Protocol sets out a system by which the UN’s Human Rights Committee

can receive and consider complaints from individuals who allege a violation of the ICCPR.

But since the UK Government has not ratified the Optional Protocol, individuals living in the

UK are not currently permitted to submit written communications to the Committee. Indeed,

the UK is the only European Union member state and one of only three members of the

Council of Europe not to have acceded to the Protocol.

My wife and I complain of an orchestrated campaign of harassment and intimidation by the

Security Service (MI5) and/or Government Communications Headquarters (GCHQ) over a

period dating back to September 2003, after having exhausted all available domestic

remedies and after having my application declared inadmissible by the European Court of

Human Rights. Please see my Communication enclosed herewith; paragraphs 46-52 outline

why the Vatican and the hierarchy of the Catholic Church should be monitored.

We note the UK Government’s response in the sixth periodic report under the ICCPR that it

does not see “a compelling need to accept individual petition to the UN”, in particular its

claim that “the practical value to the individual citizen is unclear”. However, we believe that

the Government should be urged to reconsider, as a priority, accession to the first Optional

Protocol in order to guarantee effective and consistent protection of the full range of ICCPR

rights.

Yours sincerely

Declan Heavey

Managing Director

Network for Church Monitoring

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DECLAN HEAVEY V. THE UNITED KINGDOM

COMMUNICATION SUBMITTED FOR CONSIDERATION UNDER

THE FIRST OPTIONAL PROTOCOL TO THE

INTERNATIONAL COVENANT ON CIVIL AND POLITICAL RIGHTS

Before:

The United Nations Human Rights Committee

c/o Office of the High Commissioner for Human Rights

1211 Geneva 10, Switzerland

Fax: + 41 229179022

Submitted by:

Declan Heavey

Suite 101, 254 Pentonville Road

London N1 9JY

United Kingdom

Mobile: +44 (0) 7880 437 681

Email: dheavey@gmail.com

Date: 6 May 2014

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I. APPLICANT/STATE CONCERNED

A. Information Concerning the Applicant of the Communication

1. The Applicant in this Communication is Declan Heavey, a citizen of the Republic of

Ireland who lives in the City of London in the United Kingdom. He was born on 4 September

1960 and is a former teacher of physical education. His wife is a naturalized Irish citizen born

on 26 March 1965 in Madrid in Spain. She is a former psychologist and lives with the

Applicant in the City of London. They have no children. Before moving to the United

Kingdom in August 2003, the Applicant and his wife lived for ten years in Dublin in the

Republic of Ireland.

2. The Applicant is the Managing Director of Network for Church Monitoring (N4CM),

a non-profit company limited by guarantee which has been registered in England and Wales

since January 2011. He and his wife have been forced to live rough on the streets of the City

of London for more than 3 1/2 years in total (from 4 November 2006 to 13 July 2009 and

again from 14 April 2013 to the present day), and this despite the participation of 39 Nobel

Prize winners in their Church and State website at churchandstate.org.uk; other participants

include 13 US National Medal of Science winners, seven prominent members of the UK’s

House of Lords and hundreds of distinguished scholars from around the world.

B. State Party Concerned

3. The State Party to the International Covenant on Civil and Political Rights (the

Covenant or ICCPR) against which this Communication is directed is the United Kingdom.

4. The United Kingdom of Great Britain and Northern Ireland formally acceded to the

ICCPR on 20 May 1976, but has yet to accede to the first Optional Protocol. Please see cover

letter to the UN High Commissioner for Human Rights dated 6 May 2014 above.

II. ARTICLES VIOLATED/EXHAUSTION OF DOMESTIC REMEDIES/OTHER

INTERNATIONAL PROCEDURES

A. Articles of the ICCPR Violated

5. This case arises in relation to the harassment, directed surveillance and interception of

communications by the Security Service (MI5) and/or Government Communications

Headquarters (GCHQ) over a period dating back to September 2003. It is submitted that this

case involves the violation of Article 19 of the Covenant, relating to the Applicant’s right to

freedom of expression, and in particular his right to impart information on the Internet.

B. Exhaustion of Domestic Remedies

6. Since 2003, the Applicant has sought repeatedly to put a stop to the harassment in its

various forms without success. On 16 June 2010, the Applicant’s parliamentary

representative, then Home Office Minister Lynne Featherstone, wrote to Home Secretary

Theresa May laying out the Applicant’s concerns regarding the interception of his and his

wife’s emails. In a letter dated 12 November 2010, Security Minister Baroness Pauline

Neville-Jones recommended the Investigatory Powers Tribunal (IPT) to investigate. The IPT

is the only Tribunal to whom complaints about the Intelligence Services can be directed, and

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under section 67(8) of the Regulation of Investigatory Powers Act 2000, there is no appeal

from a decision of the IPT. The Applicant therefore exhausted all possible domestic remedies

by bringing a claim before the IPT.

7. The Applicant lodged his claim with the IPT on 10 August 2011 in respect of ongoing

interception by MI5 and/or GCHQ over a period dating back to September 2003. The

Applicant also alleged harassment, directed surveillance, the disabling of Internet access at

home and in public libraries, interference with a website, blog and emails and interception of

privileged communications by one or both agencies.

8. The Applicant informed the IPT that he and his wife were living in the same ‘safe

house’ MI5 whistleblower David Shayler lived in for a couple of years (until 2007), where

they were being repeatedly threatened and harassed by their live-in landlady, human rights

activist Belinda McKenzie (see paragraphs 23-25 below). According to BBC Panorama, Mr

Shayler “caused the biggest crisis of official secrecy since the spy catcher affair” – he was

jailed for seven weeks in 2002 for breaking the Official Secrets Act. It is unfortunate that Mr

Shayler declared that he was the Messiah in 2007, became a squatter, and was subsequently

ridiculed in the press and media for changing his name to Delores Kane. A New Statesman

article published in September 2006 featuring Mr Shayler and Ms McKenzie gives no

indication that Mr Shayler believed he was the Messiah at that time; whilst a Daily Mail

interview with Mr Shayler explicitly shows he believed himself to be Jesus by June 2007 (see

Annex 1, MI5/GCHQ: MI5 whistleblower David Shayler, p. 18). He has never regained his

normal self.

9. Within two weeks of the Applicant’s complaint to the IPT, Facebook had disabled his

wife’s account, their web host SiteGround had to twice block their IP address due to a large

number of simultaneous connections towards their server, Ms McKenzie had served them

with a backdated notice to vacate their flat, and Haringey Council had left the Applicant with

his first shortfall in rent to pay (see paragraph 24(1) below). Nonetheless, the Tribunal

dismissed the claim within three weeks, on 1 September 2011, stating (see Annex 2,

MI5/GCHQ: Investigatory Powers Tribunal Decision, p. 19):

The Investigatory Powers Tribunal has carefully considered your complaint and Human Rights Act

claim, and has concluded that it is obviously unsustainable, and thus falls within the provisions of

Rule 13(3)(a) of the Investigatory Powers Tribunal Rules 2000, such that, pursuant to s67(4) of the

Regulation of Investigatory Powers Act 2000, the Tribunal has resolved to dismiss the claim.

10. The Applicant remains aggrieved by the decision of the IPT to dismiss his claim

without calling upon information or evidence in addition to that provided by him, which he

had informed the Tribunal was “wide-ranging”, including, but not limited to, papers

correspondence, memoranda, contracts, agreements, and other records from a blog/diary

called “Network for Church Monitoring (N4CM) Blog”. (The N4CM blog, which has been

vandalised on several occasions, even carries a screenshot of a Skype chat exposing the

homophobic abuse of a distinguished American scholar by an anonymous perpetrator.) It was

also made known to the Tribunal that the Applicant could adduce evidence other than his

own. For example, third parties could have confirmed that phone calls from the Applicant had

been cut off in mid-sentence and emails sabotaged (see paragraph 37 below).

11. According to the UK human rights group Justice, the IPT has only ever upheld 10

complaints out of 1,100 considered over the past decade. They observe that “[e]ither public

bodies get their surveillance decisions miraculously right in 99.1% of cases, or the IPT is

simply inadequate as a mechanism for investigating claims of abuse”. Liberty, one of the

UK’s leading civil liberties and human rights organisations, asks: “How can the public have

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any confidence in a process which is held in secret, gives little or no reasons for its decisions

and whose judgment cannot be brought into question in any court of law?”

12. In this regard, it is important to underscore that the discriminatory surveillance

suffered by the Applicant and his wife is not an isolated event. Rather, it is emblematic of a

larger pattern of surveillance by law enforcement officials in the UK that has been well-

documented by international and domestic human rights bodies. In May 2012, Liberty

expressed concern that “state sanctioned surveillance against specific individuals takes place

on a massive scale”. British police and government agencies are requesting personal

information about Facebook users more than almost anywhere else in the world (behind the

USA and India), according to the company’s first global government requests report, released

in August 2013. Since the Guardian began publishing material leaked by US whistleblower

Edward Snowden in June 2013, there have been a spate of top secret GCHQ documents

reported on and published around the world. In February 2014, the Independent reported the

following: “The covert GCHQ unit – the Joint Intelligence Threat Research Group (JTRIG) –

runs what it terms an ‘Effects’ programme against Britain’s enemies under what it calls the

four Ds: ‘Deny/ Disrupt/ Degrade/ Deceive’. The mission of the unit is: ‘Using online

techniques to make something happen in the real or cyber world.’” Journalist Glenn

Greenwald, through whom Snowden’s revelations came to the world, wrote on 19 February

2014 that leaked documents include “detailed reports on GCHQ’s attempts to compromise

basic encryption methods used to safeguard internet security, the GCHQ’s role in spying on

the Brazilian oil company Petrobras, the GCHQ’s targeting of UN charities and officials, the

GCHQ’s use of ‘dirty tricks’ including ‘honey traps’ and fake victim blog posts, the GCHQ’s

attacks on ‘hactivists’, GCHQ’s surveillance of YouTube and Blogger activity and related

activities to covertly influence internet discourse, GCHQ’s surveillance through phone apps

such as ‘Angry Birds’, and – just yesterday – GCHQ’s covert monitoring of visitors to the

WikiLeaks website”. Privacy groups have now commenced lawsuits against GCHQ.

C. Other International Procedures

13. The Applicant complained to the European Court of Human Rights (ECHR) on 19

October 2011. He invoked Articles 8 (right to respect for private and family life and

correspondence) and 13 (right to effective remedy) of the European Convention on Human

Rights. He submitted that the interference with his rights under Article 8 was not prescribed

by the law, that it did not pursue any of the legitimate aims in Article 8(2), and that the

interference was not necessary in a democratic society. He also submitted that there was no

effective remedy available in respect of the interference, in violation of Article 13.

14. The ECHR, sitting in a single-judge formation (VA De Gaetano assisted by a

rapporteur), dismissed the claim within 14 weeks, on 24 January 2012, stating (see Annex 3,

MI5/GCHQ: European Court of Human Rights Decision, p. 20):

In the light of all the material in its possession, and in so far as the matters complained of were

within its competence, the Court found that they did not disclose any appearance of a violation of

the rights and freedoms set out in the Convention or its Protocols.

15. The ECHR letter of dismissal dated 31 January 2012 refers to the Applicant’s

“application lodged on 5 September 2011”. In fact, the Applicant’s application was lodged

with the Court on 19 October 2011. On 5 September 2011, the Applicant merely expressed

his intention to lodge an application with the Court.

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III. BACKGROUND FACTS

16. The Applicant believes that the activities complained of are directly linked to a 1997

High Court case in Ireland involving the Roman Catholic Hospitaller Order of St John of God

that the Applicant successfully defended in person, and his subsequent move to the UK in

August 2003 to develop the then Network of those Abused by Church (NAC). The four-day

High Court case was the first ever hearing of a ward of court action before a jury. The

Applicant also applied to have the case heard publicly and – in another first in the history of

the State – the ward of court process was opened to public scrutiny (see Annex 4, “Wards of

court lose rights and liberties”, The Irish Times (1997), p. 21). The Applicant successfully

argued before a 12-person jury that the action, arising out of a dispute over his father’s will,

was no more than an attempt to cover up wrongdoing by the Hospitaller Order of St John of

God in the mid-1980s (see Annex 5 and 6 relating to the St John of God Order for details, pp.

22-24).

17. The St John of God Order is a Spanish Catholic congregation with over 300

hospitals and centres in 53 countries throughout the world. The Order provides mental health

services, care for older people and services for children and adults with disabilities. It is one

of 18 religious orders that signed up to a 2002 redress agreement between the congregations

and the Irish Government which indemnified the orders from claims made by abuse victims

in exchange for payments and property capped at €127 million. According to the Irish Times,

unpublished estimates compiled by senior Department of Education officials put the final bill

for the redress scheme at €1.47 billion, up from the €1.36 billion that had been quoted. There

are 138 religious congregations in Ireland, including the 18 held accountable by the State for

abusing children in their institutions.

A. Birmingham (29 September 2003 to 3 November 2006)

18. Soon after arriving in the UK from Ireland on 18 August 2003, the Applicant and his

wife settled in Birmingham to work on the NAC website (from 29 September 2003 to 3

November 2006). From the outset of their first tenancy in the UK’s second city, they were

subjected to an orchestrated campaign of harassment and intimidation, which included

difficulties with Internet access in public libraries, the maladministration of bank, electricity,

gas and council tax accounts, and extensive damage caused by flooding from the flat above;

all of which is well documented in the Applicant’s personal website (now offline), with

photographs of the damage done to their flat. For two years, the Applicant and his wife

survived off their savings until they were forced onto state benefits in July 2005.

19. On 27 September 2006, the Applicant’s joint claim for Jobseeker’s Allowance was

terminated by the Department for Work and Pensions because it was alleged by Erdington

Jobcentre in Birmingham that he did not sign on for Jobseeker’s Allowance earlier that day,

when in fact he was not scheduled to sign on until two days later (see Annex 8, Department

for Work and Pensions: Letter terminating benefits claim, p. 26). A simple check of the

Applicant’s and his wife’s previous signings would have established that they signed on every

second Friday, not every second Wednesday. Nonetheless, subsequent letters from the

Applicant to the Jobcentre and the Secretary of State for Work and Pensions went

unanswered, in clear violation of the Jobseeker’s Allowance Regulations 1996.

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B. Sleeping rough in London (3 November 2006 to 13 July 2009)

20. For more than two-and-a-half years (from 3 November 2006 to 13 July 2009), the

Applicant and his wife were forced to live rough on the streets of London, where the

Applicant’s case regarding the termination of his joint benefits claim was dismissed by the

High Court (Judicial Review), the Court of Appeal and the ECHR – only to be reinstated

three months after they came off the streets (see paragraph 24 below). Neither the Applicant

nor his wife could be referred to a hostel due to not being on benefits and had to frequent day

centres for the homeless where they experienced harassment and violence at the hands of

homeless people; all well documented with crime reference numbers and other supporting

evidence in the N4CM (then NAC) blog, opened in November 2006. The N4CM blog also

contains crime reference numbers and other evidence which show that at night the Applicant

and his wife were attacked on several occasions, hosed, urinated on, and harassed by the City

of London Police. The Applicant complained in open correspondence to senior church

leaders, police officers and politicians, but without any effect (see, for example, Annex 23,

City of London Police: Reply from Commissioner Mike Bowron (2009), pp. 61-62).

21. The Applicant submits that the following three examples from his and his wife’s

time on the streets, by no means exhaustive, bear all the hallmarks of directed surveillance

(i.e. surveillance that is covert but not intrusive):

(1) On 22 September 2007, at a time when the Applicant was answering questions on

the James Randi Educational Foundation Forum to raise money to help him and his wife

survive on the streets, his wife was severely assaulted while sleeping (crime reference no.

CR/007884/07);

(2) On 8 March 2008, three days after an email of reply from then Home Secretary

Jacqueline Smith stating that it was unlikely the Applicant’s emails were being intercepted,

the then NAC website was removed permanently from the Internet (see N4CM blog of 14

March 2008, “SpamCop reports Declan as a spammer”);

(3) On 18 June 2008, the same morning the Applicant was due to post his second

Request for Priority to the ECHR, all his and his wife’s money and documents were stolen

in a day centre for the homeless run by the Roman Catholic Sisters of Mercy (crime

reference no. 4215697/08). The Sisters of Mercy subsequently refused to release CCTV

footage of the robbery to the police (see Annex 7, Sisters of Mercy: Reply from Apostolic

Nuncio to Great Britain, p. 25).

22. The Applicant’s Internet activity was monitored and restricted throughout the time

he and his wife were confined to living on the streets. In October 2007, he began an online

petition to the United Nations in support of embryonic stem cell research. This petition had

been signed by 22 Nobel Prize winners by the time the NAC website was removed

permanently from the Internet (see paragraph 21(2) above). In an email of 29 February 2008

to Home Secretary Jacqueline Smith, the Applicant not only complained of interception but

pointed out that all emails sent to him after 12 August 2007 had been moved to Trash and

over 300 draft documents deleted, including the names and email addresses of more than

2,500 scientists from around the world (see Annex 11, Home Office: Complaint to Home

Secretary re interception, p. 34). The Applicant still complains about interception to this day

(see paragraph 35 below).

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C. London (13 July 2009 to 14 March 2013)

23. On 13 July 2009, through an associate in America, the Applicant and his wife were

put in contact with human rights activist Belinda McKenzie after the Applicant received an

email earlier in the day from the City of London Police confirming that, without a court

order, the police would require him and his wife to move from where they had been sleeping

for almost a year (see Annex 23, City of London Police: Reply from Commissioner Mike

Bowron (2009), pp. 61-62). Ms McKenzie, who had previously housed MI5 whistleblower

David Shayler for a couple of years (see paragraph 8 above), agreed that the Applicant and

his wife could live in her home as tenants in an upstairs self-contained flat. On 24 July 2009,

Ms McKenzie wrote to the same associate in America stating that it was her expectation that

her house will become an “in house charity” for impoverished activists supported by “some

kind of international fund”.

24. Three months after the tenancy began, on 9 October 2009, the Applicant had his

joint claim for Jobseeker’s Allowance reinstated. However, the Applicant and his wife

continued to be the targets of a well-orchestrated campaign of harassment and intimidation

(see Annex 14, Belinda McKenzie: Letter to Prime Minister re property warrant, p. 40). Here

are just two illustrative examples of the sorts of tactics employed in this campaign and come

from the last year of the tenancy alone:

(1) On 24 January 2012, High Court Judge Mitting ruled in the case of Heavey v London

Borough of Haringey that it was lawful for Haringey Council to leave the Applicant with a

shortfall of £76.92 in rent to pay each month because the Council covered his annual rent

liability (see Annex 12, Haringey Council: Order by High Court Judge Mitting, p. 35).

These shortfalls arose from the difference between the Applicant’s housing benefit

payments of £230.77 per week, paid fortnightly at the rate of £461.54 (£923.08 per four

week period) and his monthly rent liability of £1000. The Applicant was only able to meet

these shortfalls throughout the rental year out of his Jobseeker’s Allowance (for both his

wife and himself) of £111.45 per week because he paid rent inclusive of all extraneous

charges save telephone line.

(2) On 21 August 2012, Ms McKenzie signed an undertaking to the Court promising not

to harass the Applicant and his wife following her builder’s removal of the door to their

flat (see Annex 15, Belinda McKenzie: Undertaking to the Court promising not to harass,

pp. 41-42). Ms McKenzie explained to the Court: “I removed the interconnecting door that

makes the flat self-contained in order to signal to them that their tenancy was over, in my

mind anyway. They immediately called the police who said I had a right to remove my

own door.” The Metropolitan Police refused to charge Ms McKenzie with a criminal

offence, stating: “On arrival the officers have established that your landlady had arranged

for a builder to remove the front door which she stated, you had erected without her

permission”. On 26 June 2013, the Independent Police Complaints Commission (IPCC)

upheld the Applicant’s appeal against the police investigation into his complaint “on

information only”, deciding nonetheless that the evidence “does not indicate that a

criminal offence may have been committed” and that “no further action is required by the

force in this instance” (see Annex 20, Belinda McKenzie: Independent Police Complaints

Commission Report, pp. 51-57).

25. On 17 October 2012, Deputy District Judge Peart issued an accelerated possession

order granting Ms McKenzie possession of the Applicant and his wife’s flat on 1 November

2012 (see Annex 16, Belinda McKenzie: Accelerated Possession Order by Deputy District

Judge Peart, p. 43). At an appeal hearing, District Judge Alderson acknowledged that there

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was a note in the file from Peart J stating that he had not read the Applicant’s defence.

Alderson J conceded that Ms McKenzie’s claim for accelerated possession did not contain the

correct paperwork; however, because he had all the paperwork relating to the tenancy in the

Applicant’s appeal bundle, he set aside Peart J’s accelerated possession order and issued an

ordinary possession order with the same effect, i.e. eviction within two weeks of his order

(see Annex 17, Belinda McKenzie: Possession Order by District Judge Alderson, p. 44). On

11 March 2013, Circuit Judge Cryan refused the Applicant permission to appeal to the Circuit

Court against a decision by the District Court to refuse him a stay of eviction. Cryan J had

before him a statement dated 5 March 2013 from Ms McKenzie’s ex-husband, Dr Nigel

McKenzie, a consultant psychiatrist in Highgate Mental Health Centre, stating that the

Applicant and his wife’s flat was required for somebody with a mental illness. He dismissed

the Applicant’s request for permission to appeal on the basis that it had no reasonable

prospects of success (see Annex 19, Belinda McKenzie: Eviction Order by Circuit Judge

Cryan, p. 50). Accordingly, the Applicant and his wife were evicted from their flat by the

bailiff on 14 March 2013.

26. In his Permission to Appeal application, the Applicant provided Cryan J with ample

evidence that he and his wife had been experiencing an accommodation blockade through

surveillance for the best part of a year previous, including, inter alia, the interception of

privileged communications, the sabotage of flat viewings, and home Internet cuts (41

recorded times in the preceding two weeks alone). They were refused assistance by Haringey

Council because they were assessed as non-priority, e.g. they had no children, the Applicant’s

wife was not pregnant, they were not vulnerable as a result of age (young or old), disability,

mental health issues, etc. (see Annex 18, Belinda McKenzie: Skeleton Argument filed in the

possession appeal, pp. 45-49). Following their eviction on 14 March 2013, the Applicant and

his wife attempted to break this accommodation blockade by relocating to Brighton,

described by needaproperty.com as “an ideal location to find flats”.

D. Brighton (14 March to 5 April 2013)

27. While staying in a bed and breakfast in Brighton (from 14 March to 5 April 2013),

the Applicant and his wife ran into the same accommodation blockade through surveillance

that had been maintained in London for the best part of a year previous (see paragraph 26

above). During the three weeks they stayed in the city, they were subjected to lengthy Internet

cuts in the B&B, and over 40 letting agents contacted failed to get back to the Applicant with

a flat viewing. The Applicant was denied assistance by Brighton and Hove City Council on

the same grounds as cited by Haringey Council in London, namely that he and his wife were

not seen as sufficiently vulnerable, and Brighton Housing Trust could only advise him and his

wife to pack up and leave the city.

28. On 26 March 2013, having secured a commitment from a benefactor in America for

an interest free loan to cover his first six months’ rent (to be paid back through Brighton and

Hove City Council’s Housing Benefit scheme), the Applicant viewed a one bedroom flat

advertised in the local newspaper. The landlord was willing to accept six months’ rent up

front with a credit reference; however, forty minutes after texting the Applicant with his email

address for this reference, the landlord withdrew his offer of the flat by text (see Annex 21,

Brighton: Landlord’s text messages, p. 58). Thereafter, the Applicant was unable to obtain a

flat viewing in Brighton or the surrounding areas, despite talking with a number of landlords

over the telephone who had advertised in the local newspaper and/or on the Gumtree website.

The Applicant and his wife were forced to return to London on 5 April 2013 in a last

desperate attempt to avoid homelessness.

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E. Back to sleeping rough in London (14 April 2013 to the present day)

29. As a direct result of the accommodation blockade through surveillance that the

Applicant and his wife experienced in London and in Brighton for the best part of a year

previous (see paragraphs 26-28 above), they were forced back onto the streets of the capital

on 14 April 2013. They returned to the same rough sleeping pitch they had before coming off

the streets in July 2009 – until it was fenced off in December 2013. Within days, the charity

Broadway Homelessness and Support (“Broadway”) denied them support to access the

private rented sector (see paragraph 30 below). This notwithstanding that the Applicant: (a)

had been provided with the deposit on a flat and one months’ rent up front by a benefactor in

America, (b) has a perfect Housing Benefit track record, (c) has an immaculate credit report

from the credit reporting agency Experian, (d) has a wholly acceptable reference letter from

his previous tenancy stating that the Applicant and his wife “kept the property in very good

order, were quiet and paid the rent on time”, and (e) has two personal references of the

highest quality, one of which has been written by a retired American physician currently

living in London (see Annex 22, Live-in care: Personal references, pp. 59-60).

30. In March 2013, Broadway CEO Howard Sinclair wrote in the Guardian that there

are occasions when the charity has accommodated rough sleepers straight from the streets. In

addition to the Mayor of London providing Broadway with £5 million under his No Second

Night Out project, the charity has received £10 million from London and Quadrant Housing

Trust, alongside the support of three other trusts, to accommodate people in London for

whom there has been no other option, according to Mr Sinclair in the same article. On 29

August 2013, the Applicant filed a claim in the High Court for judicial review against

Commissioner of Police for the City of London Adrian Leppard and Home Secretary Theresa

May following the decision of the former not to ask Broadway to engage with him and his

wife in relation to their welfare and access to the charity’s service for supporting clients to

find accommodation in the private rented sector, because the police service has “no mandate

to become involved” (see Annex 24, City of London Police: Reply from Commissioner

Adrian Leppard (2013), p. 63). The Applicant argued in his claim form that it was

unreasonable for the City of London Police to refuse to ask Broadway to help them find

private sector accommodation whilst at the same time threatening them with hosings by street

cleaners (see Annex 25, City of London Police: Application for Judicial Review, pp. 64-69).

On 6 February 2014, Deputy High Court Judge Bidder ruled: “The refusal of the First

Defendant to ask the charity ‘Broadway’ to engage or help the Claimant and his wife with

their welfare or accommodation is not arguably unreasonable. It is not its job to intervene in

any disagreement between a charity and those seeking that charity’s help” (see Annex 26,

City of London Police: Order by Deputy High Court Judge Bidding, p. 70).

31. On 7 January 2014, the Applicant and his wife enrolled in a three-month rolling

winter night shelter programme for rough sleepers run by the West London Churches

Homeless Concern (WLCHC). Two days later, on 9 January, they turned up at Barnsbury

Jobcentre of the Department for Work and Pensions to sign on for Jobseeker’s Allowance

only to be told that the Applicant’s joint claim had been terminated. Neither the Applicant nor

his wife has ever been issued with a letter of termination with or without appeal rights, and on

22 January the Applicant filed a claim in the High Court for judicial review against Secretary

of State for Work and Pensions Iain Duncan Smith on the ground of procedural unfairness

(see Annex 10, Department for Work and Pensions: Application for Judicial Review, pp. 28-

33). It is especially noteworthy here that the Applicant has provided the Court with

substantial evidence that in late 2013 he was twice sanctioned on a new claim for jobseeker’s

allowance that he never made. The Applicant has yet to hear back from the Court; however,

on 21 January, the day before he lodged his case against the said defendants, he and his wife

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were approached by a WLCHC caseworker about an offer of a flat for them made by the

Single Homeless Project (SHP) that would be paid for by housing benefit if they could

produce two employment contracts amounting to £6,000 per annum.

32. Following a donation from an American benefactor, on 5 February 2014 the

Applicant and his wife presented the SHP with two signed 12-month £3000 employment

contracts as employees of Network for Church Monitoring that were due to commence on the

next working day after they moved into suitable accommodation. The SHP then told the

Applicant and his wife that they must first come up with two payments each under contract

before the Clearing House, a lettings service run by Broadway, would have a housing

association flat for them paid for by housing benefit. This was a very big ask indeed, since it

effectively meant that the Applicant and his wife had to be at least one month suitably

employed on the streets before Broadway would nominate them for a property. Then, on 26

March, having satisfied this requirement, the Applicant and his wife were informed by their

SHP caseworker that the Family Mosaic Housing Association had a flat for them in the

London Borough of Newham; but first the property could not be viewed until the caseworker

returned from his three-week annual leave and then, after the applicant and his wife viewed

the property on 29 April, their move-in date scheduled for no later than 5 May was postponed

on 2 May without a new date set (Annex 28, Single Homeless Project: Family Mosaic flat,

pp. 73-76). Consequently, the Applicant and his wife have again been street homeless since

the closure of the WLCHC night shelters on 13 April.

33. On the night of 13 April 2014, the Applicant and his wife’s last night with the

WLCHC, the Applicant was seriously threatened by another rough sleeper in an unprovoked

attack (crime reference number: 6007292/14), and this notwithstanding that he had

complained in four open emails to WLCHC Chairman Rev Brian Leathard about being

kicked awake in the middle of the night on five separate occasions – twice in one night. The

next morning, on 14 April, after providing the Metropolitan Police with a statement and

photograph of the suspect, the Applicant attended Charing Cross Hospital and was diagnosed

with asthma and a chest infection. He attended the Royal London Hospital the following

night, the discharge summary stating: “Was assessed and advised to continue with current

treatment, but if situation worsening to reattend as chest infection could worsen to

pneumonia. If possible should try to find accommodation off the street.” Nonetheless, the

following day, on 16 April, Haringey Council refused the Applicant temporary

accommodation on the grounds that he did not have a priority need. Later that day, the

Applicant requested a discharge summary from Charing Cross Hospital to ask for a review of

the Council’s decision but was told by the head of the emergency department that not only

would he have to wait at least two weeks for it, but he would have to pay £50 for information

the Royal London Hospital issued immediately upon request and free of charge (see Annex

29, Charing Cross Hospital: Email re discharge summary, p. 77). Fortunately, the Applicant’s

discharge summary from the Royal London Hospital also states: “Diagnosed with asthma and

a concurrent chest infection on 14th April at first attendance to Charing Cross Hospital”. As a

result, on 17 April, the Applicant was able to ask for a review of Haringey Council’s decision

without a discharge summary from Charing Cross Hospital, but he has yet to learn whether he

will be forced to submit an application to the High Court for a judicial review into the

Council’s decision to refuse him temporary accommodation despite his particular

circumstances and medical condition (see Annex 13, Haringey Council: Pre-action letter re

temporary accommodation, pp. 36-39).

34. Both the Applicant and his wife are deeply concerned that the accommodation

blockade through surveillance that they have experienced in London and in Brighton for near

on two years has now been extended to beyond the close of the WLCHC winter night shelters

12

on 13 April 2014; especially as the Applicant has been diagnosed with asthma, which is a

chronic, or life long, disease that can be serious – even life threatening. This situation is

exacerbated by the Applicant and his wife having no choice but to spend their nights sleeping

in night buses since 23 April 2014, the Applicant’s wife having been threatened the night

before by two City of London Police officers with an arrest on the trumped-up charge of

assaulting a police officer (see Annex 27, City of London Police: Police complaint, pp. 71-

72). The following is an extract from the Applicant’s wife’s N4CM blog of 23 April under the

title, “Barbican security guard calls the Police to have us removed... and I am threatened with

an arrest on the trumped-up charge of assaulting a police officer” (this blog contains a

photograph of the Applicant packing his bags with one of the police officers clearly visible in

the foreground):

Last night a Barbican security guard called the police as we were bedding down, and PC 667CP

and PC 602CP from Bishopsgate Police Station were on us in minutes. They threatened to dump

our belongings onto the street if we didn't move immediately, which then became they were going

to come down later with street cleaners to hose us out, which then became two female officers

were going to arrest me later on the trumped-up charge of assaulting a police officer. (I straight

away thought of an article I read a couple of weeks ago about a gang of Romanian rough sleepers

who terrorised residents, tourists and shopkeepers for two years around Marble Arch, one of the

capital's best known and most central landmarks, because the police could do nothing about them.)

We eventually decided to spend the night in King's Cross train station rather than risk my arrest on

such a serious trumped-up charge and today have come to the conclusion that we have no choice

now but to spend our nights sleeping in night buses until the Single Homeless Project comes

through with their offer of a flat, first tabled on 21 January.

35. As the Applicant’s wife documents with supporting evidence in the N4CM blog, this

situation is further exacerbated by having their bandwidths ‘squeezed’ and being denied

access to the Internet for lengthy periods in public libraries, Pret a Manger and Caffe Nero

coffee shops, and McDonalds food outlets – meaning any work on their Church and State

website to raise funds to increase the chances of them coming off the streets by their own

volition is severally restricted. The Applicant’s wife has also produced ample evidence to

show that their communications continue to be intercepted and sabotaged (see, for example,

N4CM blog of 28 February 2014, “Declan has it confirmed: his surveillance email is not

getting through to people”).

F. Surveillance, free speech and the right to privacy

36. The Church and State website has been removed from the Internet on five distinct

occasions. For example, in May 2012, Just Host, the domain’s then registrar, changed the

domain name server records without permission or authorisation and disabled the Applicant’s

wife’s facility to correct these records herself (see Annex 30, Just Host: Complaint to

European Commission, pp. 78-83). No sooner had the Applicant’s wife successfully

transferred the domain name to SiteGround’s registrar on 8 June 2012, than, on 14 June 2012,

the site was vandalised to such an extent that the Applicant’s wife was advised by the

wordpress theme designers that she had no option but to scratch the theme she had been

working with for over two years and start over with a new theme (see Annex 31, WordPress:

Final exchange with theme designer, p. 84). The Chairman of N4CM, Dr Stephen D

Mumford from North Carolina, US, has been funding the site since December 2010, and

domain since June 2012. Nonetheless, the site continues to be attacked; for example, the

Applicant’s wife has posted blogs with corroborative evidence showing that articles

throughout the N4CM website are regularly targeted, and this includes the reduction of

Facebook share counts in every section of the site by anything up to 600 shares a time to date.

13

37. The Applicant further complains that the extent of the manipulation and control of

his and his wife’s emails has resulted in the shelving for over three years of his petition to the

United Nations in support of embryonic stem cell research - and this despite the fact that the

petition has been signed by 29 Nobel Prize winners as well as hundreds of other distinguished

scholars from around the world. It has also resulted in the shelving of the Applicant’s

statement to President Barack Obama and members of the US Congress regarding forest

conservation, published in April 2011, which within 48 hours had been signed by a recipient

of the Blue Plant Prize, widely considered the environmental equivalent of a Nobel award. In

April 2010, an associate of the Applicant’s in America wrote to Home Office Minister Lynne

Featherstone, stating: “I am truly appalled by the unlawful violation of the Heavey’s basic

right to send and receive email without interference. I would be most grateful for anything

you may be able to do by way of taking measures to correct this gross abuse.”

38. Despite Minister Featherstone’s letter to the Home Secretary in June 2010 regarding

the interception of the Applicant and his wife’s emails (see paragraph 6 above), there has

been no response from the Home Office into why they continue to encounter problems with

their email (see paragraph 35 above). The Applicant has also amassed irrefutable evidence

relating to the sabotage of his and his wife’s mail, including the non-delivery of registered

items. In the case of Heavey v Haringey Council (see paragraph 24(1) above), the Applicant

was denied an oral hearing which he otherwise would have been entitled to had he received

an order from the Court when it was sent to him. Subsequently, the Applicant’s application

for an order extending time for renewing his application for permission to apply for judicial

review to an oral hearing and for the file of his claim to be re-opened was refused by Mitting

J (see Annex 12, Haringey Council: Order by High Court Judge Mitting, p. 35). On 20 July

2013, the Applicant complained to Secretary of State for Work and Pensions Iain Duncan

Smith about the Department for Work and Pensions and its manipulation of data on his joint

claim for Jobseeker’s Allowance, including but not limited to changing the Applicant’s

wife’s name on the claim without her consent or authorisation (see Annex 9, Department for

Work and Pensions: Complaint to Secretary of State re manipulation of data, p. 27).

Nonetheless, in late 2013, the Applicant was twice sanctioned on a new claim for jobseeker’s

allowance that he never made (see paragraph 31 above).

39. The Applicant submits that the harassment, intimidation and discrimination he and

his wife continue to experience is politically motivated, that it is the product of directed

surveillance, and that it is certain to continue. In June 2012, the Applicant received a response

from the European Commission concerning the problems his wife encountered when seeking

to renew her passport at the Irish Passport Office in London. She had been told by a passport

officer that her application could not be processed unless she surrendered the originals of all

her proof documents in spite of her problems with post (see paragraph 38 above). This is

something the Applicant was not asked to do when he renewed his passport in December

2011. According to the EC Directorate-General for Justice, given that Irish law provides for

passports to be issued and renewed, Ireland complies with its obligations under EU law

regardless of how burdensome or unwarranted the requirements of the Irish authorities might

be (see Annex 32, Irish Passport Office in London: Reply from European Commission, p.

85). The inescapable conclusion to be drawn from this reason as to why it was not open for

the European Commission to pursue the Applicant’s wife’s case further is that under EU law

there is no remedy for discrimination.

40. After an accommodation blockade through surveillance that has been maintained for

now almost two years (see paragraphs 29-33 above), the Applicant and his wife may soon be

forced to apply for political asylum in other countries on the grounds that they have been

persecuted in the UK and have a well-founded fear of further persecution because of their

14

political opinion. The Applicant has made a complaint to the City of London Police

Professional Standards Directorate about the two City of London Police officers who stopped

him and his wife on 22 April 2014 for sleeping rough and threatened his wife with an arrest

on the trumped-up charge of assaulting a police officer (see Annex 27, City of London Police:

Police complaint, pp. 71-72). They are particularly concerned about the threat to physical

health posed by spending their nights sleeping in night buses since 23 April, especially as the

Applicant has a chronic asthma condition that can be life threatening (in a severe attack, the

airways may become completely blocked leading to respiratory failure). And this despite that

the Applicant has had a claim, albeit dismissed, in the High Court for judicial review against

Commissioner of Police for the City of London Adrian Leppard and Home Secretary Theresa

May following the refusal of the former to ask the homeless charity Broadway to engage or

help him and his wife with their welfare or accommodation (see paragraph 30 above).

IV. VIOLATION OF ARTICLE 19 OF THE COVENANT

41. Article 19 of the Covenant provides, in pertinent part:

2. Everyone shall have the right to freedom of expression; this right shall include freedom to seek,

receive and impart information and ideas of all kinds, regardless of frontiers, whether orally, in

writing or in print, in the form of art, or through any other media of his choice.

3. The exercise of the rights provided for in paragraph 2 of this Article carries with it special

duties and responsibilities. It may therefore be subject to certain restrictions, but these shall only

be such as are provided by law and are necessary:

a) For the respect of the rights or reputations of others;

b) For the protection of national security or of public order, or of public health or morals.

42. The Applicant and his wife are indisputably targeted because they are imparting

information through the N4CM website which is often critical of church authorities, in

particular the Vatican and the hierarchy of the Catholic Church. The types of action taken by

States to limit the dissemination of content online not only include measures to prevent

information from reaching the end-user, but also direct targeting of those who seek, receive

and impart politically sensitive information via the Internet. Physically silencing criticism or

dissent through harassment and intimidation is an old phenomenon, and also applies to

Internet users. This issue has been explored in the Special Rapporteur’s report to the General

Assembly under the section on “protection of citizen journalists” (A/65/284). Such actions

are often aimed not only to silence legitimate expression, but also to intimidate a population

to push its members towards self-censorship.

43. Freedom of expression, as protected under Article 19 of the Covenant, has been

recognised by international tribunals, national courts and commentators as vital not only to

the development of the individual, but to the securing and protecting of democracy itself. As

the Committee has explained: “It is in the essence of [free and democratic] societies that its

citizens must be allowed to inform themselves about alternatives to the political

system/parties in power, and that they may criticize or openly and publicly evaluate their

Governments … within the limits set by Article 19, paragraph 3” (see Aduayom et al. v. Togo,

Communication Nos. 422-24/1990 (1996), § 7.4).

44. According to the Report of the Special Rapporteur on the promotion and protection

of the right to freedom of opinion and expression (A/66/290):

15

…restrictions must be formulated in a way that makes clear that its sole purpose is to protect

individuals from hostility, discrimination or violence, rather than to protect belief systems,

religions or institutions from criticism. The right to freedom of expression implies that it should be

possible to scrutinize, openly debate and criticize, even harshly and unreasonably, ideas, opinions,

belief systems and institutions, including religious ones, as long as this does not advocate hatred

that incites hostility, discrimination or violence against an individual or a group of individuals.

45. Furthermore, the Special Rapporteur stresses that, as stipulated in Human Rights

Council resolution 12/16 (para. 5(p)(i)), the following types of expression should never be

subject to restrictions: discussion of government policies and political debate; reporting on

human rights, government activities and corruption in government; engaging in election

campaigns, peaceful demonstrations or political activities, including for peace or democracy;

and expression of opinion and dissent, religion or belief, including by persons belonging to

minorities or vulnerable groups.

Why the Vatican and the hierarchy of the Catholic Church should be monitored

46. If the Special Rapporteur was concerned that the restrictions just referred to created

problems under Article 19, the Committee will surely find the harassment and intimidation

that the Applicant and his wife endure to be troubling. Sadly, the institution of the Roman

Catholic Church appears to have become a political one above all else. To survive and expand

for so many centuries it was compelled to become a political power, and it has become a

financial power as well. Sometimes the Church undertakes activities that are political or

economic under the guise of religion. But the image of the Catholic Church presented by the

mainstream media does not reflect these realities.

47. N4CM Chairman Dr Stephen D Mumford, the founder and President of the Center

for Research on Population and Security in North Carolina, US, has written extensively about

the grave threat to the future of humankind and the democratic institutions of the United

States posed by the Catholic Church. He has revealed that the Church has exerted great

influence on US policy in population matters as a result of its intimidation of elected officials

and the built-in reverence most Americans have for an ecclesiastical hierarchy. The teachings

of the Church and its hierarchy’s insistence that these teachings be followed have resulted in

an unintentional suppression of the substantial knowledge about the consequences of

overpopulation. The main source of energy, organization, and direction of the anti-abortion

movement in the United States and the movement to frustrate enforcement of US

immigration laws is the Roman Catholic Church.

48. Dr Mumford reveals in his book, “American Democracy and The Vatican”, that the

Catholic Church in effect controls most governments in Latin America and many in Africa

and the Philippines. Authorities in these countries live under constant intimidation by the

Church, which can threaten to bring about the downfall of a regime by arousing its citizens

through pastoral letters and other means should the government refuse to conform to the

Church’s agenda. This ultimate step is ordinarily avoided through manipulation – by weeding

out “troublemakers” before they rise to power. On the other hand, those who are loyal are

well rewarded in their search for positions of power; they are assisted by the Church in their

ascension to high positions in government. Government leaders who owe their first loyalty to

the Vatican represent different proportions of office holders in different countries.

49. Dr Mumford cites an example in Chile. In 1979, with approval from the minister of

health of Chile, Dr Ben Viel began setting up a female sterilization program with $1 million

worth of sterilization equipment provided by the International Planned Parenthood Federation

16

in London. When the equipment arrived in Chile, a Father Ibanes Langlois, serving as a

messenger for the Vatican, met with the president of Chile. There was then and continues to

be a disagreement between Chile and Argentina, almost bringing the two countries to war

over the Beagle Channel at the tip of South America, that may prove to be rich in oil. Chile

and Argentina had agreed to let the pope mediate the dispute. Langlois informed the president

that, if this sterilization equipment was not removed from Chile, the pope would favour

Argentina in the settling of the Beagle Channel dispute. The president called in the minister

of health and ordered him to get the sterilization equipment out of the country. Dr Viel was so

notified by the minister of health, and it was shipped out.

50. In a 1992 videotaped interview with Dr Mumford (available for public viewing for

the first time on N4CM’s Church and State website), the late Prof Milton Siegel details how

the Vatican seized control of World Health Organization (WHO) family-

planning/contraception-related policy-making right from its earliest stages. Prof Siegel was

the Assistant Director-General of WHO for its first 24 years, and considered among the

world’s foremost authorities on the development of WHO policy. During the third World

Health Assembly (1950), the Vatican threatened to kill WHO and start their own organization

if the director general did not stand up before the Assembly and specifically state that WHO

would not get involved with family planning, which he duly did. WHO did not get involved

at all for more than a decade. In its 64-year history, WHO has had a deplorable record in

family planning. Its commitment has been minuscule, and even today family planning

accounts for only a tiny fraction of its budget. The Vatican continues to have considerable

influence at WHO. In the mid-1990s it succeeded in having appointed as director of WHO’s

Human Reproduction Program a professor from a Catholic University in Rome, Dr Giuseppe

Benagiano, the son of Pope Paul VI’s dentist. Dr Benagiano promptly set out to kill any

further clinical studies of a non-surgical method of female sterilization called quinacrine

sterilization, or QS. At that time, it had been accepted voluntarily by more than 50,000

Vietnamese women with no reported deaths or life-threatening complications (see Annex 33,

“WHO creates demand for abortions”, Pittsburgh Tribune-Review (2004), p. 86).

51. The Vatican has, points out Paul Blanshard in “American Freedom and Catholic

Power”, a full civil government with a flag, a police force, courts and postage stamps. It

issues currency and passports to its citizens, and has a large and active diplomatic corps,

headed by a Secretary of State with ambassadors called nuncios. The government is

completely autocratic with all legislative powers vested in the pope. This means that there is

no separation of church and state. It also means that the Vatican claims jurisdiction

“everywhere where there are Catholics”. It claims representation in the United Nations and

functions like a nation-state in international gatherings at the same time that it functions like a

church. Yet, politicians would never investigate the Vatican’s numerous attempts to influence

or control nation states’ foreign or domestic policy because, like a chameleon, it would claim

it was merely functioning as a church, not as a state. In fact, it is already so powerful that

anyone who tried to investigate it would find such an endeavour a political liability.

52. The inescapable conclusion to be drawn from these observations is that the Catholic

Church is skilfully manipulating governments and influencing international bodies of a

purely secular nature. The Vatican uses its position not only to protect its autonomy from

outside intervention, but to impose its view on the rest of the world. Numerous observers

over the years, including scholar Paul Blanchard, have correctly described the Catholic

Church as a political institution cloaked in religion.

17

TABLE OF ANNEXES

ANNEX 1: MI5/GCHQ: MI5 whistleblower David Shayler 18

ANNEX 2: MI5/GCHQ: Investigatory Powers Tribunal Decision 19

ANNEX 3: MI5/GCHQ: European Court of Human Rights Decision 20

ANNEX 4: “Wards of court lose rights and liberties”, The Irish Times (1997) 21

ANNEX 5: St John of God Order: Complaint by Elliott Duffy Garrett Solicitors 22

ANNEX 6: St John of God Order: Reply from Provincial of All Ireland 24

ANNEX 7: Sisters of Mercy: Reply from Apostolic Nuncio to Great Britain 25

ANNEX 8: Department for Work and Pensions: Letter terminating benefits claim 26

ANNEX 9: Department for Work and Pensions: Complaint to Secretary of State 27

ANNEX 10: Department for Work and Pensions: Application for Judicial Review 28

ANNEX 11: Home Office: Complaint to Home Secretary re interception 34

ANNEX 12: Haringey Council: Order by High Court Judge Mitting 35

ANNEX 13: Haringey Council: Pre-action letter re temporary accommodation 36

ANNEX 14: Belinda McKenzie: Letter to Prime Minister re property warrant 40

ANNEX 15: Belinda McKenzie: Undertaking to the Court promising not to harass 41

ANNEX 16: Belinda McKenzie: Accelerated Possession Order by DDJ Peart 43

ANNEX 17: Belinda McKenzie: Possession Order by District Judge Alderson 44

ANNEX 18: Belinda McKenzie: Skeleton Argument filed in possession appeal 45

ANNEX 19: Belinda McKenzie: Eviction Order by Circuit Judge Cryan 50

ANNEX 20: Belinda McKenzie: Independent Police Complaints Commission Report 51

ANNEX 21: Brighton: Landlord’s text messages 58

ANNEX 22: Live-in care: Personal references 59

ANNEX 23: City of London Police: Reply from Commissioner Mike Bowron (2009) 61

ANNEX 24: City of London Police: Reply from Commissioner Adrian Leppard (2013) 63

ANNEX 25: City of London Police: Application for Judicial Review 64

ANNEX 26: City of London Police: Order by Deputy High Court Judge Bidding 70

ANNEX 27: City of London Police: Police complaint 71

ANNEX 28: Single Homeless Project: Family Mosaic flat 73

ANNEX 29: Charing Cross Hospital: Email re discharge summary 77

ANNEX 30: Just Host: Complaint to European Commission 78

ANNEX 31: WordPress: Final exchange with theme designer 84

ANNEX 32: Irish Passport Office in London: Reply from European Commission 85

ANNEX 33: “WHO creates demand for abortions”, Pittsburgh Tribune-Review (2004) 86

18

ANNEX 1

19

ANNEX 2

20

ANNEX 3

21

ANNEX 4

22

ANNEX 5

23

24

ANNEX 6

ANNEX 7

25

ANNEX 8

26

27

ANNEX 9

28

ANNEX 10

29

30

31

32

33

ANNEX 11

34

35

ANNEX 12

36

ANNEX 13

37

38

39

40

ANNEX 14

41

ANNEX 15

42

43

ANNEX 16

ANNEX 17

44

45

ANNEX 18

46

47

48

49

50

ANNEX 19

51

ANNEX 20

52

53

54

55

56

57

58

ANNEX 21

59

ANNEX 22

60

ANNEX 23

61

62

63

ANNEX 24

64

ANNEX 25

65

66

67

68

69

70

ANNEX 26

71

ANNEX 27

72

73

ANNEX 28

74

75

76

77

ANNEX 29

78

ANNEX 30

79

80

81

82

83

84

ANNEX 31

85

ANNEX 32

86

ANNEX 33