THE HIGH COURT

RECORD No. 9291P/2007

BETWEEN:

THE GOVERNOR AND COMPANY OF THE BANK OF IRELAND AND ALLAN LEWIS

PLAINTIFFS

AND

JOHN GILL

DEFENDANT

NOTICE OF MOTION

TAKE NOTICE that on the 11th day of February 2008 an Application will be made to the Honourable High Court for a Mareva Injunction on the grounds that the Order made against me on the application of The Governor and Company of the Bank of Ireland and Allan Lewis is an infringement of my Constitutional Rights under Article 40.3.1' and 2' of the Constitution and Article 40.6.1'-1 including Article 40.11 & 111. The right to assemble peaceably and the right to form associations. Which Order was perfected on the 18th day of December 2007.

WHICH APPLICATION will be grounded upon proceedings to date and on Sworn Affidavits already filed and lodged together with any other evidence that the Honourable Court may seem just.

Dated this the 20th of December 2007

Signed: John Gill

Filed at the High Court Central Office on the 21st of December 2007.