INVESTOR

rescue.org

Claims Management Unit

Solicitors Regulation Authority
The Cube
199 Wharfside Street
Birmingham
B1 1RN

Our Ref: YOU1000 11th November 2016

Dear Sir or Madam,

Re: Submission of Claim by Ms Michelle Danique Young

In respect of Rohrer & Co / Bracewell Law / Axiom Litigation Fund

I am writing in support of a claim form for the above named who is a victim of the Axiom Litigation Fund
fraud involving Mr Tim Schools and numerous British solicitors and law firms who conspired with him
including Rohrer & Co / Bracewell Law whom Ms Young appointed to handle her complex divorce case. I
have been asked to assist Ms Young with all aspects of her case as I am an expert in the frauds surrounding
this case having been appointed to assist the Axiom Action Group recover funds shortly after the
appointment of Grant Thornton as Receivers. Ms Young has attached her claim form to this letter.

I support hundreds of investors who lost their life savings as a result of these abhorrent acts by a group of
like minded solicitors who took complete advantage, in a number of ways. I will be writing to you shortly
with a view to co-ordinating claims from each of these investors but I wish to focus here on the issues
surrounding Ms Young. I have provided only broad details here as the case is extremely complex and will
require a great deal of explanation and evidence. The aim here is merely to commence dialogue with you so
that you can receive everything you require in order to make reparation to Ms Young.

1. Background

Ms Young has been identified publicly as a client of Rohrer & Co by the Official Receivers UHY Hacker
Young in their ‘Statement of Proposals’ dated 19th August 2013.

Ms Young is the ex-wife of a former property entrepreneur who died in very public circumstances on 8
December 2014. Mr and Ms Young divorced in 2007 and for the next six and half years contested extremely
acrimonious ancillary relief proceedings in the full glare of the media spotlight. The case went to trial before
Moor J (see [2013] EWHC 3637 (Fam)) who made an award in favour of Ms Young for approximately
£26.5m.

In April 2010, on HMRC’s petition, Mr Young was made bankrupt and David Ingram was appointed Trustee
in Bankruptcy. In December 2013 Mrs Young submitted a proof of debt in the bankruptcy for £26.5m and, in
February 2014, requested a meeting of creditors be convened to consider replacing the trustees due to their
lack of progress in tracking down his assets. Ms Young failed in her attempts partially because she was
unable to substantiate her criticism of the Trustees.

Despite the award by the family court, Ms Young is still fighting for payment from the estate and has had to
endure a ten year fight for justice to prove that Mr Young hid assets from the proceedings amounting to
£100m - £200m or more. She has been perceived, extremely harshly in my view, as a conspiracy theorist
despite the fact that she presented a great deal of factual evidence to the courts.

In recent months, the publication of the ‘Panama Papers’ proved those submissions to be correct.

‘Investor-Rescue.Org’ is a non-trading style of:

Paradox Intelligence Ltd

25 Pickwick Road, Corsham, Wiltshire. SN13 9BQ P!r!"#
Tel: +44(0) 7854 571174
Registered in England & Wales
!"#$%%!&$"'$
Company Number: 09193662
2. The Bracewell Law aspects:

Due to the complexities of the case and the allegations being brought by Ms Young, it was proving very
difficult to unravel the offshore structures put in place by Mr Young’s team and to prove that the bankruptcy
was contrived. The frustrations of knowing you are correct and having service providers fail to discover such
evidence made Ms Young out to be a conspiracy theorist and she was roundly criticised in Court and ended
up moving from one firm of solictitors to another.

Without access to her husband’s hidden wealth she was reliant on Litigation funders to assist and, time after
time, these companies failed to secure acceptable progress despite Ms Young furnishing documents that
supported her allegations. She ended up leaving Vardags and appointed DWFM Beckman ("DWFM") who
helped to make an application for funding, jointly with Steptoe & Johnson, to the Axiom Litigation Fund, via
Bracewell Law / Rohrer & Co (BLR). Our understanding of the process is that Axiom required BLR to
undertake what was known as a Desktop Review of the case and that Chris Hales, as the only senior solicitor
at the firm, performed this task.

Ms Young had received a record maintenance order of £27,000 a month before Mr Young declared himself
bankrupt and the BLR confirmed that the case appeared to be worth a large amount both in terms of the
potential settlement and the fees they might earn. The case was however extremely complicated and would
require considerable resources.

Following Mr Hales’ review the Axiom Fund itself became involved in looking at how best it could fund
such a high profile / high value case and Ms Young is aware that Mr Hales then attended several meetings
with a specialist legal advice company, brought in by the Axiom Fund, called Mayer Brown who helped to
devise various options for funding her case. The initial suggestion proposed by Axiom was a Tri-partite
agreement involving both BLR and DWFM but this was rejected by DWFM who, we understand, were
unwilling to accept certain liabilities.

In December 2011 rather than lose the commercial opportunity (or so it seemed at the time), Axiom proposed
that they provided the litigation funding direct to BLR who then acted as Project Manager of the case, with
DWFM acting in the capacity of its agent. Ms Young then entered into a number of agreements, including a
retainer letter with BLR dated 5th December, to bring the funding into effect in that same month.

The level of funding was agreed £3,250,800 plus a facilitation fee of £1,625,400 making a gross loan of
£4,876,200. The funding for the case apparently arrived almost immediately however DWFM did not sign
their agency agreement until the following month. As far as Ms Young was aware, the proposed deal was that
BLR's fees were to be calculated at 25% of all the other fees or expenses relating to the case whether they
were incurred by DWFM or the Financial Investigations company FTI Consulting. Whilst these additional
fees seemed to be high, BLR had justified them by stating they would be providing full project management
on the case and also taking on the financial risks relating to the loan from Axiom. In her desperation to see
justice done, Ms Young reluctantly accepted this position because it seemed that BLR were also desperate to
help her.

It was at this point that the arrangements turned sour with almost immediate effect. DWFM were working on
the basis that they had full autonomy of the case and that BLR’s role was, quite simply, to bring into effect
the funding by whatever means. BLR and DWFM therefore had a very turbulent relationship from the outset.
Whilst Ms Young continued to authorise the invoices for both DWFM and FTI, it was apparent that matters
were constantly being disrupted and delayed when they reached BLR. Rather than project managing the
case, they seemed to be the cause of endless problems with DWFM and Ms Young becoming increasingly
concerned, particularly when it was obvious that BLR were not experienced in this type of case yet they
seemed to want to be involved in strategy. Ms Young has since learnt that DWFM wrote numerous letters
and emails of complaint to BLR.

BLR began to question each and every expense by FTI and DWFM to such a degree that the case was
completely ruined at this point. As a direct consequence, the relationship between Ms Young and DWFM
also began to deteriorate. BLR attempted to bring in another forensic specialist to replace FTI at a reduced
cost to them whilst also taking steps, behind her back, to remove themselves from the Funding Agreement.
From start to finish BLR received more than £3m for their limited involvement but only paid invoices
amounting to just over £1m. With the benefit of hindsight it would appear that BLR’s involvement here
amounts to little more than Maintenance and Champerty and their is a question mark as to where the
remainder of Ms Young’s fees ended up. The obvious suggestion would be that BLR attempted to offshore
the excess when they discovered that the Axiom Fund had collapsed and that the £3m deposited with Pictet
was made up of a sizeable portion of her fees. The behaviour of BLR, throughout Ms Youngs involvement
with them, appears to have been consistent with a desire to monitor her actions and disrupt progress but this
sounds like another conspiracy theory, that is until one examines the detail.
3. The multiple connected parties committing fraud:

3.1. There is a fraud by Tim Schools who set up the Axiom Fund. As an expert in global financial fraud,
the model for this fraud was established in the Isle of Man with the Bank Louis Property Fund. This was one
of the first ‘Ponzi’ schemes to include a real asset base within the fraud to distort any investigations into it.
This new model suggested that only half of the Funds were ‘Ponzi’ related and the rest were loosely attached
to a particular type of asset, in this first known case, the assets were property related. The architect behind
the fraud was the Bank Louis Company Secretary Nathan Bloch.

3.2. Since these are not entirely Ponzi schemes they have become known as quasi-ponzi or ‘Quonzi’
schemes. It is believed that one of the victims of the Bank Louis fraud was Tim Schools though this is
anecdotal. What we know is that Nathan Bloch leaves Bank Louis prior to the fraud being detected and he
resurfaces within Tim Schools’ inner circle during the formation of the Axiom Fund. The Modus Operandi of
these two frauds is absolutely identical in delivery with the only exception being that the assets in Axiom are
litigation cases, presumably because that is the world in which Schools operated.

3.3. Whenever a fund of this nature collapses, fraud investigators will often look to see if the assets are to
be ‘Phoenixed’ into another entity such that the fraud can be continued, under a new guise, to the benefit of
others in the criminal network. In the case of Axiom, the first person on the scene was Yoram Yossifoff of
City Equities Ltd (amongst others). This raised numerous red flags with me as his name was known to me
from his involvement at Portsmouth FC along with Marc Jacobs and Daniel Azougy, a convicted fraudster.
Further investigation would show his involvement in and around Centaur Litigation Fund (A £100m+
collapse being administered by Grant Thornton in Australia).

3.4. Around the same time, I had been approached by a number of investors in Tiuta PLC / Connaught
Asset Management Ltd, to conduct a fraud investigation into that case. I was surprised to see that the Modus
Operandi and location of that fraud was also directly attributable to the ‘Bloch’ model at Bank Louis and
Axiom. This meant there had to be commonality within the criminal networks involved. An analysis of Tiuta
directors showed that Steven Nicholas, the Chief Executive, was an associate and former business partner of
Rachel Hutson.

3.5. Tiuta PLC is significant because it is reputed to be one of the companies owned, or controlled by Ms
Young’s ex-husband. According to an informant I have, a regular visitor to the company who appeared to
exert some control over the business was a senior executive at Jirehouse, the company who, it is alleged, hid
Mr Young’s global assets and put forward the notion that he was bankrupt. This same individual appears in
another offshore fraud I am investigating as an associate of the fraudster in that case. Previous investigations
performed on behalf of Ms Young have suggested that Jirehouse itself was owned and controlled by Mr
Young.

3.6. In a similar way, when Rohrer and Co was suspended, UHY Hacker Young (the receiver of choice
for Yossifoff), were appointed and immediately set up a pre-pack deal with a company called Mulberry Finch
(MF). The director of MF, Soteris Nicholas, was recently fined by the Solicitor’s Disciplinary Tribunal for
allowing Yossifof, Daniel Azougy and City Equities to have control within the company. Soteris is, in fact,
Steven Nicholas of Tiuta and I can be sure of this as I have a note of the meeting whereby the company was
being lined up for sale by Isis Ebrahim and others to him. For some strange reason, both Rachel and Alan
Hutson were present at that meeting.

3.7. Steven Nicholas was also previously involved with both Mark Lorrell and George Giorgiou of
Lorrell, Giorgiou Nicholas LLP, as the names might suggest. We believe there may also be a link to Portland
Group in Switzerland who assisted Tim Schools with his movement of funds internationally.

4. Outcomes:

However you interpret the information above, from BLR being a small part of a conspiracy to defraud
investors to a concerted and brutal attempt, by Scot Young and others, to pervert the course of justice, it is
now evident that Ms Young was correct about the levels of offshore funds being hidden from her. We have
this from our own investigations up to this point and the revelation that many of the offshore structures
feature in the Panama Papers. We understand that many people within Scot Young’s network went to
extraordinary lengths to deny her access to information and we cannot rule out the possibility that the Axiom
funding, initiated by Rachel Hutson, was no more than a means to control and subvert progress on Ms
Young’s part.

Due to the fact that she fought so vehemently against all of these odds, she has been tarnished and sullied at
each and every stage to the point that it is extremely difficult for her now to find support of any kind. She has
been fortunate in finding a journalist at the Sunday Times who believed in her and introduced her to me as an
expert in this particular group of frauds.
In order for Ms Young to overturn all of the previous decisions and force the appointment of new trustees in
bankruptcy it is imperative that she is provided with the appropriate funds and also reimbursed for the losses
caused by the many lawyers who have created these problems. This letter is intended to back up her claim
against BLR and Chris Hales, in particular. She has suffered direct and indirect losses as result of their
actions over a short period of time and she is being made accountable for those losses with several actions
against her putting her into extreme financial difficulties, despite a £26.5m order.

Ms Young wishes to claim the full amount paid to BLR which was never utilised and which appears to have
been paid, somewhat erroneously, to Grant Thornton following intervention on the Pictet account. We
believe this figure to be somewhere in the region of £1.5m to £2.1m. In addition, the work carried out by FTI
Consulting is now worthless and has to be revisited before any lawyer, or new funder, will take on the case
again. For these reasons, Ms Young wishes to discuss with you the possibility of structuring a payment up to
the £2m maximum permitted by your Fund. The majority of any payment will simply be to replace funds that
have been denied to her as result of these various actions. The outcome we have discussed includes, as a
broad package of solutions:

4.1. 10% (£200k) as an amount in damages to alleviate Ms Young’s immediate financial issues;

4.2. 10% (£200k) as an amount to conclude all remaining complex financial investigation and
intelligence activities in order that the case is once again viable and attractive to a specialist law firm and
litigation funder of repute;

4.3. 60% (£1.2m) to make immediate settlement with several third parties who made claims against Ms
Young following the forced collapse of her case by BLR and the network around them and, finally;

4.4. 20% (£400k) as a preliminary legal pot to allow Ms Young and ourselves to explore the potential to
return to the High Court and deliver a settlement in her favour with access to the offshore elements.
You will appreciate that this is an extremely complex and unusual situation and Ms Young does not have any
hard and fast notion as to how compensation should be provided or utilised other than the broad suggestions
above. The intention of any payment is simply to put her back in the position she was in prior to meeting
BLR when she had a strong case and several funders wishing to back her. Exploration of the Panama
materials is likely to re-establish that position and a small element of damages to alleviate the problems
caused does not seem, to me, to be unreasonable given the amount of stress and personal vilification caused
here by various members of the legal profession.

5. Next steps:

I am an expert in complex financial intelligence and investigations and have been introduced by the
journalist involved at the Sunday Times. I am not a claims management company nor do I have any
intentions to operate in that area. Ms Young has submitted this claim herself and this letter has been written
merely to outline, at a high level, the types of issues that Ms Young has faced and continues to need support
with. I have offered to provide whatever help I can through my not-for-profit consumer support capabilities
with Investor-Rescue.Org but I am not being paid.

Should you agree to compensate Ms Young along the lines suggested my understanding is that I will be
involved in the strategic planning of the investigation work and that a number of my wider associates will be
involved in carrying out that work, for a fee.

At this stage, Ms Young’s intention is merely to make a claim and begin a process of dialogue that will allow
you to gain a better understanding of the facts and evidence so that some sort of package can be agreed in the
near future. She is completely open to your own suggestions and input and is prepared to offer up some of
her own findings to help you tackle some of the remaining conspirators.

I trust this is sufficient for now and would welcome your getting in touch with me in the first instance. This
is only due to the amount of stress this is causing to Ms Young who wishes for me to act as a buffer for now.
There are others who could perform this role if there is any worry that I may be conflicted in some way.

Yours sincerely,

Stuart Cotton
Stuart Cotton
Managing Director:
Paradox Intelligence Ltd
Founder:
Investor-Rescue.org