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

SUPPLEMENTARY AFFIDAVIT OF JOHN GILL

I, John Gill of Drumline, Newmarket on Fergus, County Clare, aged 18 years and upwards make Oath and say as follows.

1. I am the Defendant in this matter. I make this Affidavit on my own behalf. I make it from the facts within my own knowledge save where otherwise appears and where so appears I believe same to be true, accurate and correct.

2. I say and believe that the Affidavit of Solicitor Allan Lewis, Legal Advisor to the Bank of Ireland, 125 O'Connell Street, Limerick City is an appalling malicious act of deceit, it is a deliberate misrepresentation of the truth, a wilful lie and falsehood. There are no words that could adequately describe the enormity of Corruption, Criminal Deception, Perjury and actual Perversion of the Course of Justice that Solicitor Allan Lewis has been involved in since the 18th of October 2001 in an effort to destroy me John Gill and escape with the E17,041.82 cover up for the theft of my property (Site No.3) from Folio 6976F County Clare at Woodland Heights, Newmarket on Fergus, Co Clare in which Mr Lewis has taken a leading hand in aiding and abetting the THEFT of this site with Solicitor John Hickie and Auctioneer John O'Doherty of Limerick City.

3. I say and believe that I published no false or malicious statements concerning Solicitor Allan Lewis, but Allan Lewis did with vengeance, spite and hate when named and exposed in corrupt ring of money laundering and property stealing, crawl into the gutter in an effort to embarrass me with the same corruption and criminal deception as Casey & Co. Solicitors used in the theft of my bungalow at Woodpark, Bunratty, County Clare, a theft that would have been successful had it not been for my stand against corruption and for the enormous help and determination of the colleagues of Allan Lewis who played a major role in the exposure of the rotten criminal deception of the family firm of fraudsters who without cause or reason destroyed my livelihood and shattered my whole existence for their own selfish greed and in the knowledge that the chance of being caught was zero or thereabouts, but how wrong they were thanks to the decent, upright honest Officers of the Courts and decent upright, honest civil servants - they may be few in numbers but not small in INTEGRITY.

4. I say and believe that Solicitor Allan Lewis has accepted a payment of E17.041.82 from Thomas Tynan and Bill Holohan Solicitors and Officers of the Courts that is part of the sum of E250,000.00 obtained by Mass Corruption, Criminal Deception, Perjury, False Accounting and Perverting the Course of Justice. The E17,041.42 is the last of five corrupt Taxations from one corrupt Court Case in which Solicitor Allan Lewis played a central role. There is no concealing or disguising the facts of injustice and we hope that justice will be done and seen to be done. Allan Lewis, Legal Advisor to the Bank of Ireland, 125 O'Connell Street, Limerick City would now appear to have the full backing of Brian Goggins, Governor of the Bank of Ireland and Richie Boucher, Chief Executive of the Bank of Ireland, to hold onto the stolen E17,041.82 which is the proceeds of mass corruption, criminal deception, perjury, money laundering and false accounting while using the Justice System to prevent me from exercising my rights under the Constitution and the European Convention on Human Rights.

5. I say and believe that Solicitor Allan Lewis is using the Companies Registration Office to cover up for his own unlawful activity, criminal deception and false Sworn Affidavits. I have four Tax Clearance Certificates which were obtained by me when I took over the Company's debts in 1994 but was frustrated and gagged by the Chief State Solicitor's Office and Mary Flanagan of the Department of Finance who by lies and deception prevented me from going any further. Mary Flanagan from the Department of Finance is always there when we call to the Office at Merrion Street, but when she is told who is waiting in the reception to meet her, she is suddenly not at work. The truth becomes a reality and is difficult to face.

6. I say and believe that following six and a half years of inflicting on me John Gill severe torment, anguish, inhuman and degrading treatment and torture by holding onto my two Original Land Certificates Folios 6976F and 6141F County Clare thereby denying the right to transfer my development sites for which Sales were agreed on twelve occasions. Solicitor Allan Lewis did not mention in his Sworn Affidavit of the 12th of December 2007 the fact that the two Original Land Certificates were held on Bogus Authority, criminal deception, perjury, dishonesty and unlawful activity. And for Allan Lewis, FORGERY is a criminal offence, and I quote from Section 25.-(1) of the Criminal Justice (Theft and Fraud Offences) Act 2001: A person is guilty of forgery if he or she makes a false instrument with the intention that it shall be used to induce another person to accept it as genuine and, by reason of ho accepting it, to do some act or to make some omission to the prejudice of that person or any other person. These are the facts and Forgery is the crime committed.

7. I say and believe that you say you are not aware of the whereabouts of Original Land Certificate Folio 6141F County Clare. Is this, Mr Lewis another scurrilous lie equal only to the false misleading Affidavits you have prepared for the Court to believe from the 18th of October 2001 to this very day? I will in their own separate volumes produce and display to the Court on the 11th of February the criminal corrupt conduct of John Casey & Co. in the destruction of my livelihood in their criminal corrupt greed for money and property with total disregard for the Rule of Law and the devastation caused by the criminal thuggery that Solicitor Allan Lewis has benefited from to the tune of E17,041.82 as a paid employee of the Bank of Ireland, and the honest answer is that Crime does pay. Is this the only corrupt and underhanded act that Allan Lewis has been involved in, only time will tell.

8. I say and believe that in the handing over of my Original Land Certificate Folio 6976F to THIEVES, that Solicitor Allan Lewis has opened a new chapter of corruption, lies and deception. A person guilty of forgery is liable on conviction or indictment to a fine or imprisonment for a term not exceeding 10 years or both. The Bank of Ireland Manager at 125 O'Connell Street, Limerick did accept my Original Land Certificate Folio 6976F County Clare on false documentation and on a false Authority while knowing full well that the documentation and the Authority was false. The Instrument was false and the Bank of Ireland was without a shadow of a doubt aware that it was false, and to add insult to injury it was done for spite, hate and cover-up, which is what is happening six and a half years later by the same Legal Advisor to Bank of Ireland handing over my Land Certificate to thieves.

9. I say and believe that I will produce before the Court on the 11th of February, Sales that I have lost and that I have been deprived of to the value of E658,940.00 due to the malicious criminal conduct of Solicitor Allan Lewis, Legal Advisor to the Bank of Ireland, now the leading figure of the criminal gang along with Thomas Tynan, Solicitor Bill Holohan, Solicitors Shaun Elder and Andrew Darcy, Solicitor John Hickie, Barristers Lorcan Connolly and Tom Kinirons who have no answer for the last lie only tell another lie, and if it transpires that Allan Lewis has the full support of Mr Brian Goggins and Mr Richie Boucher, then the Bank of Ireland has something to be proud of.

10. I say and believe that of all the eleven sales that I have lost and will have documented evidence of on the 11th of February 2008, one did not have their deposit returned and one was at a loss of £1,500.00 having applied for and been granted full planning permission. Judge Peter Charlton, who is a highly respected Judge of the High Court did say that Allan Lewis was known to him for twenty-five years and that he was a decent man. In Queensland, Australia some years ago a policeman who was retired for some time was arrested for crimes he was involved in during his time as a serving police officer and they were not petty crimes, and likewise the crimes of Allan Lewis for the past six and a half years are anything but petty. Unlike in the false corrupt Affidavit of cover-up, spite, hate and prejudice in an effort to demean, demoralise and make me look like a bankrupt kid, in the eyes of honest men Solicitor Allan Lewis may have bitten off more than he can chew.

11. I say and believe that my exhibits will expose the fact that the Affidavits of Allan Lewis and all involved in the destruction of my livelihood, my health and wellbeing are an act of the lowest kind of criminal, malicious Perjury, carried out and sworn by rotten RUTHLESS criminals for no other reason than cover-up for the grabbing greedy.

12. I say and believe that the only answer to this appalling travesty of justice is for Solicitor Allan Lewis to come clean and tell the truth, return to me the stolen money that you have received from Holohan/Tynan belonging to me. Hand over my two Original Land Certificates that the Bank of Ireland has for six and a half years deprived me of. You Allan Lewis cannot deny the fact that you have instructed the Bank of Ireland managers not to hand over these documents to me. Some of those Bank Managers told us that they could do without this publicity, they further told us that you could be retiring very soon and my hope is that you do not do a bunk like Solicitor Michael Lynn from Crossmolina and spend the money you have belonging to me - the proceeds of serious criminal thuggery - in far foreign fields.

13. I say and believe that you must be aware that hits on the Rate Your Solicitor website have reached two million two hundred thousand and growing at a rate of up to five thousand per day. This surely must be of some concern to any right thinking citizens and members of Government to witness and read about paid members of a leading bank in the State making off with large sums of stolen money from one of its honest citizens. The more you think about it, the more bewildering it becomes.

14. I say and believe that from all over the world and right across the 32 counties of Ireland there is tremendous goodwill for the growing numbers who are standing up and exposing white collar crime for what it is: the ruination of the vulnerable and less well off. Corruption ruins lives and there are thousands who have suffered the same agonising fate as I am suffering at the hands of a paid official of the Bank of Ireland.

15. I say and believe that my Schedule Index will explain in detail the background of the enormity of corruption that has brought the Irish Legal System into disrepute, an appalling scandal that this profession has inflicted on itself.

16. I pray that this Honourable Court will grant me an Order compelling Solicitor Allan Lewis to hand over to me my E17,041.82 and return to me my two Original Land Certificates Folio Numbers 6976F and 6141F County Clare together with an Order allowing me my Constitutional Rights - the right to sell my property.


SWORN BY THE SAID JOHN GILL AT SHANNON IN THE COUNTY OF CLARE THIS THE 8TH DAY OF FEBRUARY 2008 BEFORE ME A COMMISSIONER FOR OATHS AND I KNOW THE DEPONENT.

Tomas Mac Cormaic
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COMMISSIONER FOR OATHS