Begin forwarded message:

From: “Rebecca Butterfield”
Date: 11 February 2014 14:31:20 GMT+2
To:
Cc: peter.morey@cafcass.gsi.gov.uk>
Subject: FW: Request for information Case Number LA13P00059 , Mr & Mrs Ferreira

Dear Mr Ferreira

Following your email to Mrs Kaur-Kelly on Friday, please find below a copy of the email that she has forwarded to me and a copy of my response to her.

I propose to draft a statement of issues and case summary to assist the Court, and will ensure that this issue is included in that so it can be addressed on 28th February.

Kind regards

Becky Butterfield
BSG Solicitors

http://www.bsglaw.co.uk

BSG Solicitors is the trading style of Blackhurst Swainson Goodier LLP which is a
limited liability partnership registered in England and Wales (Registered No. OC350314).

We use the word ‘partner’ to refer to a member of the LLP, or an employee or consultant
who is a lawyer with equivalent standing and qualifications.Partners: Mark Burrow,
George Mercer BA, Tom O’Neill LLB, James Goodier MA (Oxon), Keith Parr BA,
Andie Brown LLB, Rebecca Lauder LLB.

Registered office 3&4 Aalborg Square, Lancaster, LA1 1BJ. Authorised and regulated
by the Solicitors Regulation Authority (no. 00524974).

From: Rebecca Butterfield
Sent: 11 February 2014 12:11
To: ‘Dalvinder Kaur-Kelly’
Subject: RE: Request for information Case Number LA13P00059 , Mr & Mrs Ferreira

Dear Mrs Kaur-Kelly

Thank you for your email. I have considered the questions that Mr Ferreira wishes you to answer, and my view is that these are questions that should properly be put in either cross examination, or as formal questions to you with the permission of the Court.

I suggest that I raise this as an issue at the hearing on 28th February, as at this hearing the Judge will be determining Mr Ferreira’s application to set the final order aside, and if granted, the Court can consider whether these questions should be put in writing in advance of a final hearing, or whether they can simply be dealt with by way of cross examination.

If Mr Ferreira wishes to make an complaint to your governing body then that is a matter for him. No doubt they will notify you directly in due course in that event. However in relation to the questions he has asked, I suggest that you take no further action on these, as you are a jointly instructed expert and you have concluded the work that the Court has directed you to complete. I will contact you further after the hearing on 28th February to confirm the position.

It would be helpful if you could confirm in advance of the hearing, in the event that the Court does order responses to questions, your likely timescales and estimated costs for doing so. Could you also please confirm, in the event that the matter is listed for a further final hearing, your likely costs in attending Court for a full day inclusive of travel expenses, so that we can make the parties aware and arrange to be put in funds on account.

I will notify Mr Ferreira of the position.

Many thanks for your continued assistance.

Becky Butterfield
BSG Solicitors

From: Dalvinder Kaur-Kelly [mailto:info@nkpsychological.co.uk]
Sent: 10 February 2014 09:11
To: Rebecca Butterfield
Subject: Fwd: Request for information Case Number LA13P00059 , Mr & Mrs Ferreira

Dear Ms Butterfield,

I have received the email below from Mr Ferreira. I was not in my office on Friday. I would be grateful if you could provide me with some clarity on how the Parties/Court wish for me to respond to his email.

I look forward to hearing from you.

Kind regards,

Dalvinder Kaur-Kelly

———- Original Message ———-
From: Phill Ferreira
To: “info@nkpsychological.co.uk”
Date: 07 February 2014 at 12:05
Subject: Request for information Case Number LA13P00059 , Mr & Mrs Ferreira

Dear Mrs. Dalvinder Kaur Kelly,

I hope this email finds you well.

I am currently in consultation with the HPC and the Medical Ombudsman and have been asked to make this request for information to yourself and allow you 7 days to respond.

1. Please could you explain as an independent expert why you provided Cafcass with a draft report 2 days before your final report was provided to myself.

2. Please could you explain as an expert how basic details like even my age is incorrect in your report , was this in fact my evaluation you commented on or someone else

3. Please could you provide the details of time spend on testing and interviewing me , keeping in mind that you where 45 min late for our meeting and we had only 3 hours and 20 min before I had to leave for my flight to leave the UK

4. Please can you explain as an expert how you are able to make a diagnosis on one interview , but yet non of your peers would be able to do so or even claim that this is possible

5. Please could you explain as an expert how you are allowed to quote my personal emails but yet you claim to be independent

6. Please could you explain why you refuse to provide the scoring details on the test you made me complete

7. Please could you explain as an expert how you make no reference in your report to my cultural back ground and in fact being South African and not English and the alternative tests that should have been used.

8. Please can you as an expert explain how you are able to say my statements were rehearsed but you offer no example of what I have said in fact

9. Please can you as an expert explain the quotes you use of me which is words and fracases that as a South African , Afrikaans speaking person I would never use and don’t even know the meaning off

10. Please as an expert can you explain why you refused my request to review the case file going back to April 2013 to understand my frustration but yet you were happy to use an extract of some of my emails to the legal team

11. Please can you provide details of the number of family law cases you have been involved in and how many of them are shown with males having personality orders

12. Please can you as an expert explain why you have decided details we discussed in dept re the blackmail from my wife’s family should not be in your report.

The notice time will be recorded as per the ZAR local time that this email is sent to you.

Should I not receive and acknowledgement of this email by close of play today , I take it as seen by you and should you choose not to respond and handle this matter in Court , please confirm your intention of same ASAP.

Looking forward to hear from you.

Kind regards,

Phill Ferreira

Sent from my iPad
Dalvinder Kaur-Kelly [Mrs]
B.Sc[Hons], M.Sc, C.Psychol
Consultant Forensic Psychologist

NK Psychological Services Ltd
PO Box 1603
Rowley Regis
B62 2HR

t:
e:info@nkpsychological.co.uk