20150303_0617_04_
20150303_0617_06_
20150318_0335 – Attached Letter
20160817_0510
20251126_0325
20251126_0325
Mandatory 14-Day Quarantine: Every arrival had to undergo a strict, mandatory 14-day quarantine at an Alternative State Quarantine (ASQ) hotel at their own expense.
20200518_0205
Email to the Competition and Marjets Authority
Attachment PDF pages 37-38
Steven D. Kalavity
Email: stevenkalavity@gmail.com
RE: PGS EXPLORATION (UK) LIMITED
4 The Heights, Brooklands, Weybridge, Surrey, KT13 0NY ENGLAND
Company number 02904391
COMPANY OFFICERS:
Director Rune Olav PEDERSEN 01 September 2017 – present
Nationality: Norwegian
Country of residence: Norway
Occupation: Chief Executive Officer (CEO) PGS ASA
Director Gottfred LANGSETH 23 March 2004 – present
Nationality: Norwegian
Country of residence: Norway
Occupation: Chief Financial Officer (CFO) PGS ASA
Director Merethe BRYN 30 June 2023 – present
Nationality: Norwegian
Country of residence: Norway
Occupation: Vice President (VP) Global Tax PGS ASA
Director Christin STEEN NILSEN 14 February 2003 – 30 June 2023
Nationality: Norwegian
Country of residence: Norway
Occupation: Vice President (VP) Chief Accountant PGS ASA
Director Jon Erik REINHARDSEN 1 April 2008 – 31 August 2017
Nationality: Norwegian
Country of residence: Norway
Occupation: Chief Executive Officer (CEO) Petroleum Geo-Services (PGS) ASA
Secretary Carl RICHARDS 13 September 2013 – 25 May 2018
Occupation: Head of Legal PGS Europe Africa Middle East
Secretary Maria Candida Ferreira PINTO 15 August 2008 – 13 September 2013
Occupation: Head of Legal PGS Europe Africa Middle East
PRINCIPAL CONTACT
John FRANCAS
Head of Legal – UK, Africa and Middle East
4 The Heights, Brooklands, Weybridge, Surrey, KT13 0NY ENGLAND
PGS ASA (PGS) is a Norwegian based company. PGS EXPLORATION (UK) LIMITED is a subsidiary of PGS. The current officers / directors of PGS EXPLORATION (UK) LIMITED are executives of PGS. The Directors of PGS EXPLORATION (UK) LIMITED are Norwegian and executives-employees of PGS.
PGS EXPLORATION (UK) LIMITED is a company located and registered in England. As such, PGS EXPLORATION (UK) LIMITED is governed by the laws of England and must conduct legal business within the constraints of the laws of England.
PGS EXPLORATION (UK) LIMITED and Steven D. Kalavity (SDK) already have a defined legal relationship. PGS EXPLORATION (UK) LIMITED and SDK are bound by two contracts governed by the laws of England.
1) Employment Contract, signed 20 July 2010 (EC).
2) Employment termination settlement contract, signed 5 December 2013 (the “Settlement”).
Global law firm Watson Farley & Williams, London (WFW) serve as legal advisors to PGS EXPLORATION (UK) LIMITED in relation to UK employment law. WFW also has a branch in Thailand at Unit 902, 9th Floor, GPF Witthayu Tower B, 93/1 Wireless Road, Lumpini, Patumwan Bangkok 10330, Thailand.
The laws of England provide all of the legal avenues for PGS EXPLORATION (UK) LIMITED to seek damages for any breach of the EC and Settlement Confidentiality terms, such as publication of content that disparages PGS EXPLORATION (UK) LIMITED or any of its officers or employees.
The main point that PGS EXPLORATION (UK) LIMITED and their agent Duensing – Kippen fail to address is what becomes of the terms and conditions of the EC and Settlement once the claim in Thailand is resolved? If PGS EXPLORATION (UK) LIMITED and WFW have violated English laws or regulations, both would be accountable for these violations in England because they are English companies. A Thailand court cannot change this.
SDK wants to take responsibility for his actions. SDK has always believed that such responsibility must adhere to the signed contracts governed by the laws of England which defines the legal relationship between PGS EXPLORATION (UK) LIMITED and SDK.
The signed contracts between PGS EXPLORATION (UK) LIMITED and SDK already prohibit and provide avenues of redress for, if any, SDKs disparaging publications, just as SDK informed Duensing – Kippen within our first correspondence in 2018. The exception are publications that expose qualifying conditions, as defined by the UK Public Interest Disclosure Act 1998 (PIDA). Whistleblowing is legally protected disclosure. SDK informed Duensing – Kippen that he was a whistleblower by email 17 May 2018.
The EC references the PGS UK OFFICE PERSONNEL HANDBOOK which states:
…..
It is important to note that disparagement differs from defamation. Defamation typically applies to false statements and requires some degree of malice, while disparagement is much broader. Defamation is “do not make up bad things about us to hurt us,” while disparagement is “do not say bad things about us even if they are true.” For there be a contract breach in Confidentiality SDK need only to publish content that disparages PGS for them to sue for damages.
PGS and WFW are both subjects within many of the SDK publications which SDK states to be legally protected public disclosure or whistleblowing under the terms of both the PGS EXPLORATION (UK) LIMITED and SDK EC and Settlement citing PIDA.
PGS EXPLORATION (UK) LIMITED has never cited a breach in either the EC or Settlement governed by the laws of England. The EC and Settlement would be breached if SDK published content that directly or indirectly disparages, is harmful to or damages the reputation or standing of PGS EXPLORATION (UK) LIMITED, or any Related Party.
SDK is not fluent in the Thai language and no publication by SDK regarding PGS EXPLORATION (UK) LIMITED, or any Related Party has ever been written by SDK in the Thai language. The PGS EXPLORATION (UK) LIMITED officers initiating these claims in Thailand are not fluent in the Thai language either and are not Thai citizens. SDK publications were written to get the attention of officers and employees of PGS and PGS EXPLORATION (UK) LIMITED who speak English. Regardless, the EC and Settlement remain governed by the laws of England.
SDK has written parties to get legal clarification from PGS, WFW and Duensing – Kippen but received no definitive response addressing these significant concerns.
from: Steven Kalavity stevenkalavity@gmail.com
roto: berit.osnes@pgs.com,
gareth.jones@pgs.com,
gottfred.langseth@pgs.com,
ir@pgs.com,
kristin.omreng@pgs.com,
lars.mysen@pgs.com,
nathan.oliver@pgs.com,
NAulak@wfw.com,
olaf@duensingkippen.com,
per.arild.reksnes@pgs.com,
rob.adams@pgs.com,
rune.olav.pedersen@pgs.com,
sarah.murphy@pgs.com,
terje.blojseth@pgs.com,
Carl Richards carlrichards1@googlemail.com,
GDPR gdpr@pgs.com,
John Francas john.francas@pgs.com,
Landau Law pl@landaulaw.co.uk,
Tippaya Moonmanee tippaya@duensingkippen.com
date: Jun 11, 2020, 7:18 PM
subject: Notice of PGS ASA breach of Employment Contact (2010)
PGS ASA,
PGS ASA (PGS) is a Norwegian based company. SDK was employed by the PGS ASA subsidiary PGS Exploration (UK) Limited, 4 The Heights, Brooklands, Weybridge, England, KT13 0NY by contract governed by the laws of England.
The PGS UK Office Personnel Handbook (“Handbook”) forms part of the contract of employment and states that the laws governing the policies within the Handbook are those of England and Wales. Of special note is Handbook section 2.9 Confidentiality, [i];
Each member of staff also agrees that he/she will not, during the course of his/her employment or at any time thereafter either make or publish, or cause to be made or published, to anyone in any circumstances any statement (whether of fact, belief or opinion) which directly or indirectly disparages, is harmful to or damages the reputation or standing of the Company or any of its directors, officers, employees, agents or shareholders.
In this paragraph 2.9, any reference to “Company” includes, for the avoidance of doubt, all companies in the PGS Group and each member of staff’s undertaking to the Company in this paragraph 2.9 is given to the Company for itself and as trustee for each company in the PGS Group.
The provisions of this paragraph 2.9 shall be without prejudice to a member of staff’s duties at common law.
PGS ASA refuse to clarify nor address concerns regarding the “criminal defamation” litigation that they have sponsored against former employee, Steven Kalavity (“SDK”) using the legal system of Thailand
The legal actions PGS ASA have taken against SDK in Thailand are a material breach of the original contract of employment which is governed by the laws of England.
(a) that a criminal offence has been committed, is being committed or is likely to be committed,
(b) that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he is subject,
(c) that a miscarriage of justice has occurred, is occurring or is likely to occur,
(d) that the health or safety of any individual has been, is being or is likely to be endangered,
(e) that the environment has been, is being or is likely to be damaged, o
(f) that information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed
The contractual Confidentiality terms and conditions are included to protect PGS ASA reputation. PGS ASA is illegally using the Thai legal system to retaliate, defraud, defame, and extort their victim of crimes and a whistleblower. PGS ASA corrupt actions are damaging the reputation and values of PGS ASA.
THE LITIGATION PGS ASA SPONSORS IN THAILAND IS ILLEGAL. PGS ASA MUST PROCEED THROUGH THR ENGLISH SYSTEM OF JUSTICE.
Regards,
SDK
SDK has believed that PGS EXPLORATION (UK) LIMITED is misusing the Thailand justice system to avoid accountability under the laws and contracts governed by the laws of England.
PGS EXPLORATION (UK) LIMITED has had both a legal and contractual obligation as well as a fiduciary duty to abide by the terms of contracts that they are a party to and then cite any contract Confidentiality breaches that negatively impact PGS in accordance to the laws of England and through the courts of England.
SDK has always wanted to honor and defend all of his actions and publications under the laws of England that govern the PGS EXPLORATION (UK) LIMITED and SDK legal relationship. It is PGS EXPLORATION (UK) LIMITED that has not taken any action under the laws of England that govern the EC and Settlement.
SDK has always believed that there was an agency problem, or jurisdiction issue, in PGS EXPLORATION (UK) LIMITED litigating through the Thailand justice system. PGS EXPLORATION (UK) LIMITED is the PRINCIPAL and Duensing – Kippen is an AGENT for PGS EXPLORATION (UK) LIMITED. Legal authority runs from the PRINCIPAL to the AGENT.
SDK has never understood how there could be legitimate claims in Thailand that bypass the EC and Settlement governed by the laws of England? SDK has believed that as an agent of PGS EXPLORATION (UK) LIMITED, Duensing – Kippen cannot act in a way that PGS EXPLORATION (UK) LIMITED cannot legally do themselves, such as work outside the boundaries of the laws of England to breach contracts governed by the laws of England.
Both the EC and Settlement Confidentiality terms cite the UK Public Interest Disclosure Act 1998 (PIDA).
SDK has always believed that his publications were legally qualified public disclosure.
PIDA protects workers from detrimental treatment or victimization from their employer if, in the public interest, they blow the whistle on wrongdoing. For a disclosure to be protected by PIDA provisions it must relate to matters that “qualify” for protection. Qualifying disclosures are disclosures which the worker reasonably believes tends to show that one or more of the following matters is either happening now, took place in the past, or is likely to happen in the future: a criminal offence; a breach of a legal obligation; a miscarriage of justice; a danger to the health and safety of any individual. concealment of information tending to show any of the matters that qualify.
Norway’s Working Environment Act (WEA) states that it is an employee’s right and obligation to notify censurable conditions. This means that a worker has no choice but to report if the matter is serious enough. Reporting serious offences in Norway is an obligation vested in law because whistleblowing is crucial to keep work environments safe and to prevent unhealthy leadership. Some censurable conditions are: danger to life or health, corruption and fraud, abuse of authority, discrimination, bullying and an unsatisfactory working environment.
Two-years eight-months and 24 days after the first published legal disclosure on 3 July 2015, SDK received an email from a gmail account purporting to be from the PGS EXPLORATION (UK) LIMITED Secretary, Carl Richards, threatening to press criminal defamation charges in Thailand as an individual not associated with PGS.
Richards is misrepresenting his agency as an officer and employee of a company governed by the laws of England with the responsibility to protect PGS EXPLORATION (UK) LIMITED reputation and value and not just his own through adhering to the laws of England.
Date: 26 March 2018 at 17:30
Subject: Material on nopgs.com & social media
To:
Steven,
I am writing to you in a personal capacity, and only about the material you have posted online about me. I am not writing as a representative of PGS. I have no authority to discuss any material you have posted online about PGS or other individuals, nor to discuss your employment / data protection dispute with PGS.
When we worked together, our relationship was always courteous, so I am disappointed to see the material about me in your online postings, including (but not limited to) your article “Carl Richards, Arbitrary and Capricious Company Secretary” and also the various images I attach here, some of which have been distributed on various social media platforms.
You will understand that I can’t accept having this kind of material posted about me. I understand that you reside in Thailand. I therefore came to Bangkok last week and sought advice from a Thai law firm (i.e. for me personally, not for PGS, and only in relation to the material you have posted about me). My Thai lawyers advised that the material you have posted about me is defamatory, and in particular contravenes Thailand’s Computer Crime Act of 2017. They have advised me on the enforcement process, and they are standing by should it be necessary for me to follow that process.
I still wish you no ill-will whatsoever, and do not wish to cause you any difficulty. However, you will understand that I absolutely cannot permit my professional reputation to be damaged in this way. I am therefore asking you (in the same courteous manner that we had previously dealt with each other) to delete all references to me on your nopgs.com site, and to delete all postings with links or images featuring from your various social media platforms. If you do this then I will take the matter no further.
Please confirm.
Respectfully,
Carl
The Email from Carl Richards came from an unverified gmail account, not an @pgs.com account. SDK had published numerous articles, submitted formal complaints to PGS Compliance, and posted in the PGS LinkedIn™ comment space. SDK did not know how seriously to consider such an Email.
Steven Kalavity Fri, Apr 6, 2018 at 1:22 AM
To: Carl Richards
The postings relate directly to your Carl Richards professional capacity and agency as Head of Legal and Secretary of PGS Exploration UK Limited.
My postings have been whistleblowing. The postings are not personal.
Allegations presented within the blog articles have also been presented to UK ActionFraud and the UK Serious Fraud Office. There has been no official response from Petroleum Geo-Services ASA or PGS Exploration UK Limited agents.
For future correspondence, please provide proof of identity and any aspects of the posted blog articles which are not truthful with data to support your claim.
Regards, SDK
SDK removed content and awaited more information / Emails. However, Richards never replied and provided the requested verification information and so content was made public again. SDK had to provide two sources of notarized identification to WFW before his SAR would be processed. Richards provided no verification information. It would have been irresponsible to continue any more dialogue beyond this point without being provided the requested information.
SDK believed that an officer and employee of PGS Exploration (UK) Limited should expect that some verification of identity and legitimacy would be requested. SDK also believed that it was illegal for a company located and registered in England to use the Thai criminal justice system. A business governed by the laws of England would be expected to conduct legal business within the constraints of the laws of England.
On 15 May 2018, SDK received another email from an individual purporting to be a Thai lawyer representing Richards. However, Richards’ lawyer refused to provide substantive verification of identity, qualification and agency to SDK, as requested.
from: Thai Lawyer
to: boycottpgs@gmail.com
date: May 15, 2018, 2:07 AM
subject: URGENT & IMPORTANT_Defamatory Statements
security: Standard encryption (TLS) Learn more
: Important according to Google magic.
RE: Defamatory statements
Dear Mr. Steven
Please find the legal notice letter attached.
Best regards,
Tippaya Moonmanee
Dear Mr.Steven Kalavity,
We represent Mr. Carl Richards (“Our Client”) in relation to certain defamatory and untrue statements and images concerning Our Client that you have posted on several websites.
We do not represent Petroleum Geo-Services.
We refer to ANNEX A as a selection of some of the defamatory and untrue statements against Our Client. Although our Client is under no obligation to prove that your statements against him are untrue, it is our position that they are in fact untrue.
We also refer to ANNEX B as examples of defamatory images that you have posted.
Please note that by posting these statements and images you have committed a criminal offence under the Thai Criminal Code and Computer Crimes Act. Our Client is further entitled to compensation for damages due to your illegal action under the Civil and Commercial Code. The fact that some of the images have now been removed does not relieve you of criminal liablity for having posted them.
…
We therefore demand that you immediately remove all direct or indirect reference to Our Client from the material you have posted. If you fail to do so we are instructed to take legal action against you accordingly.
Yours faithfully,
Ms. zzzzzzzzzz
Authorized Lawyer
The Claims sponsored by PGS EXPLORATION (UK) LIMITED and delivered by Duensing – Kippen in Thailand citing the laws of Thailand are a material breach of both the EC and Settlement that are explicitly governed by the laws of England. Companies governed by the laws of England must deliver claims in the English language using the English courts.
Duensing – Kippen has delivered Legal Notices and Claims to the address where SDKs passport was registered with Thailand Immigration. SDK is a US citizen. SDKs legal address is in the US. SDK has no permanent residence or legal address in Thailand.
from: No PGS boycottpgs@gmail.com
to:
date: May 17, 2018, 3:16 AM
subject: Re: URGENT & IMPORTANT_Defamatory Statements
mailed-by: gmail.com
zzzzzzz,
I have never received confirmation from your Client, “Carl Richards” that he, indeed is the actual person mentioned in the referenced blog post articles. I received an email from an unverified account from a person purporting to be “Carl Richards” However, this person never confirmed his identity in fact.
Therefore, I would encourage “Carl Richards” confirm proof of identity and that he has, in fact, engaged you.
However, regardless of this confirmation, image files containing the purported portrait of Carl Richards Head of Legal and Secretary, PGS Exploration (UK) Limited have been removed from websites which I control.
It may take some time for these image files to stop circulating in the cyber-space.
I have also encouraged any individuals named and written about within my blog post articles to contact me directly for any corrections and clarifications of fact. Your client has not done this.
Further, the blog post articles regard Carl Richards professional performance, and are considered to be whistleblowing – or identifying corruption and wrong doing by corporate officers. My claims have been provided to UK ActionFraud (police) and the UK Serious Fraud Office, as well as professional oversight organizations.
Therefore, I would hope that your client would engage me directly and provide details to improve certain details of the posted content.
However, at its core, my requests have been simple. I want the officers of PGS Exploration (UK) Limited to authenticate the contents of my professional personnel file. Currently, it is populated with what I claim are illegal forged documents that were used to form an illegal contract. This contract is covered by the laws of England and, if valid, have all the instruments of redress to affect the outcome which he is seeking through engaging a firm in Thailand.
This is what I would like Carl Richards to prove is untrue.
I worked in England on a visa, but I am a USA citizen. My wife is a Thai national.
Best regards,
Steven Kalavity
Richards resigned as Secretary of PGS EXPLORATION (UK) LIMITED 25 May 2018, according to the Companies House website information. As an officer of PGS Exploration (UK) Limited there could never be any distinction between the individual Carl Richards and his agency as PGS Exploration (UK) Limited Secretary.
On 18 June 2018, SDK submitted an SAR (2018 PGS SAR) citing the new General Data Protection Regulation (GDPR) that was replacing DPA. On 16 July 2018, SDK received a response to the 2018 SAR. SDK had to provide PGS with documented proof of his identity, including US passport data and current residence, to PGS before they agreed to process the PGS SAR.
SDK had also submitted an SAR to Watson Farley & Williams 19 August 2016 (WFW SAR) to confirm what data was being processed for SDK and his family. WFW requested the following to confirm SDK identity before processing the WFW SAR:
On Tuesday, August 30, 2016 2:16 PM, Neeta Aulak NAulak@wfw.com wrote:
Dear Mr Kalavity
Further to your subject access request dated 19 August 2016, we will require the following from you in order to process your request:
Please note that Subject Access Requests under the Data Protection Act 1998 are limited to personal data held about an individual.
Kind regards
NEETA AULAK
Director of Risk and Compliance
Watson Farley & Williams LLP
15 Appold Street | London EC2A 2HB
WFW, the advisors to PGS EXPLORATION (UK) LIMITED on matters of UK employment law received sensitive SDK data including US passport and US Texas identification, inlcuding SDK US address information to process the WFW SAR. WFW also knew SDKs address in Thailand in 2016. SDK had to wire transfer payment to WFW to pay for the SAR processing:
Re: Subject Access Request – Data Protection Act 1998
From: Steven Kalavity
To: naulak@wfw.com
Date: Sunday, September 11, 2016 at 11:35 PM MDT
Neeta Aulak,
Today I have made a duplicate wire transfer of the one made one-week ago to process my subject access request. This means what should have been a simple process has cost twice as much money, taken twice as much time, and involved additional emails.
I am not pleased about this. In my view, Watson, Farley & Williams (WFW) has thus far performed unprofessionally. Whether the obstruction is intentional or a competency matter, I do not know. However, I wanted to relate my concerns straight-away, for the record.
When I see performance issues at the front end of any (legal) transaction it leads me to believe that there may be other risk and compliance issues hidden out of sight. We become what data controllers process about us. The integrity and efficiency of the processors and processes applied is paramount.
During my initial correspondence I tried to be very clear in letting WFW understand my special circumstances. Because of these special circumstances, additional clarity needed to be provided. I conveyed that I would pay the fee by wire transfer from Thailand.
WFW provided payment instructions, WHICH I ADHERED TO.
Following the wire-transfer, I contacted WFW and let them know the projected time line and payment details.
I requested that WFW keep me informed of the status/progress of the wire transfer.
However, WFW conveyed incorrect /incomplete information.
WFW did not keep me informed of any problems in a timely manner, and in fact the
contact went on holiday
On a Friday, WFW informed me that the requested entire 10 GBP payment did not reach the WFW account due to a WFW RBS account incurred bank transfer fee (5 GBP).
First of all, the 10 GBP amount is the MAXIMUM amount that a data controller can charge to process an SAR. It is not a set amount. WFW can charge any amount in between 0-10 GBP. Further, how would I possibly know what the incurred wire transfer fee of a WFW controlled account is? Apparently, WFW has an accounting department. Shouldn’t have they known and shouldn’t have this amount been included in the instructions?
The result of this is that because WFW communicates poorly I am held accountable to pay the extra money and waste the extra effort. Is this reasonable? The greatest risk to project success is communication (according to PMI).
I hope that we can both improve on this moving forward.
Regards,
Steven Kalavity
SDK had to provide both PGS and their legal advisors, WFW with proof of identity for them to process an SAR. However, both Richards and Duensing – Kippen refused to provide SDK with any verification data when they were accusing SDK of criminal defamation. SDK actually believed that he was the target of extortion and not a valid Thailand criminal complaint.
John Francas, Head of Legal, PGS Europe, Africa, and the Middle East signed the response to SDKs 2018 PGS SAR. The response did not reveal anything, such as what is the legal relationship between PGS Exploration (UK) Limited and Duensing – Kippen or Carl Richards and Duensing – Kippen? Again, there was no verification that Duensing – Kippen actually was legally representing anyone with regard to SDK publications.
In the response to the 2018 PGS SAR Francas did reference the Settlement as a legal instrument. SDK had been publishing legally protected disclosure – or whistleblowing for almost three years. PGS EXPLORATION (UK) LIMITED had never requested that SDK stop publishing. The only threats were received on behalf of an individual Carl Richards, not attached to PGS and Duensing – Kippen who said that they did represented Richards.
The Francas response to the 2018 PGS SAR PGS EXPLORATION (UK) LIMITED:
###
We have determined that applicable law allows us to deny your request on the basis that processing of your personal data, if any, that may have occurred since your previous request on 10 October 2014 (“the 2014 SAR”) has only been performed in order to seek privileged legal advice in respect to your various direct and indirect communication with or about PGS and/or its employees or advisors. Accordingly, we are denying your request under the exception contained in Schedule 2, paragraph 19(a).
Schedule 2, paragraph 19(a):
19 The listed GDPR provisions do not apply to personal data that consists of—
(a) information in respect of which a claim to legal professional privilege or, in Scotland, confidentiality of communications, could be maintained in legal proceedings, or
Francas is citing UK law. Comprehensive data protection laws are essential for protecting human rights – most obviously, the right to privacy. PGS was sharing SDK private information with Duensing – Kippen in Thailand to process a criminal complaint while they were supposed to be processing SDKs SAR.
One of the exceptions to the attorney-client privilege is the crime-fraud exception. This exception applies when communications are made in furtherance of a crime or fraud.
SDK does not believe that there was a distinction between PGS EXPLORATION (UK) LIMITED Secretary Carl Richards and PGS EXPLORATION (UK) LIMITED. Richards, in bpth his professional and legal capacity of PGS EXPLORATION (UK) LIMITED Secretary had the legal responsibility to uphold the laws of England that governed PGS EXPLORATION (UK) LIMITED contracts and make certain that Directors comply with the laws and carry out their duties according to the laws and regulations of England.
Within publications, SDK has claimed that the Settlement was an illegal instrument used to illegally terminate whistleblower SDKs employment on false pretenses. WFW conspired with law firm Landau, Zeffertt & Wier (LZW), who were the paid advisors of SDK, to coerce SDK to accept the Settlement to terminate his employment. WFW and LZW cooperated with PGS EXPLORATION (UK) LIMITED to populated SDKs professional personnel file with defamatory forged documents. This is the subject that SDK publications assert and provide evidence of.
On 13 September 2018, SDK was traveling back to the US to visit his mother and other family members when he received a legal notice in the Thai language by email. SDK later heard from his wife that a firm copy of an actual criminal claim was delivered to the address provided to PGS EXPLORATION (UK) LIMITED when SDK submitted his SAR.
SDK had to shorten the length of his stay in the US and return to Chiangrai, Thailand. Duensing – Kippen had delivered two (2) claims to the address that was provided to PGS to process the SDK SAR 18 June 2018. One claim was delivered on behalf of Richards (the “Richards Claim”} and another claim (the “PGS Claim”) were delivered on behalf of PGS EXPLORATION (UK) LIMITED directors: Rune Olav Pedersen, Gottfred Langseth, and Christin Steen-Nilsen.
PGS and Duensing – Kippen never provided SDK with verification data or even attempt to clarify issues in the English language. Yet, Duensing – Kippen could summon SDK from the US to respond to a criminal complaint. It never seemed reasonable nor professional. What SDK first noticed was that Duensing – Kippen had explicitly stated within the 15 May 2018 email that they did not represent PGS. This was a clear material misrepresentation of fact.
The 2018 Duensing – Kippen for PGS EXPLORATION (UK) LIMITED claim did not address many publications that included documented evidence supporting the published assertions exposing illegal and non-compliant acts by PGS, WFW and LZW. Most notably, the claim did not authenticate the documents held within SDKs PGS professional personnel file, as was requested within the 17 May 2018 email to tippaya@duensingkippen.com , to prove that SDK allegations were false and malicious. The claim did not disprove any of the substantive claims which had been published on NoPGS.com.
The PGS Claim had been assembled directly from SDK personal data provided to PGS for identification verification to process SDKs 2018 PGS SAR. The PGS EXPLORATION (UK) LIMITED claim had pages copied directly from the 2018 PGS SAR. The dated documents within the PGS EXPLORATION (UK) LIMITED claim showed that the PGS EXPLORATION (UK) LIMITED claim had been constructed when SDK was waiting for the Response.
Within the 15 May 2018 email, Duensing – Kippen lawyer Tippaya Moon has explicity stated that she / Duensing – Kippen was not representing PGS. This was clearly an intentional misrepresentation. Duensing – Kippen had never responded and provided requested verification information regarding the Richards Claim. The PGS Claim was in the Thai language, but included excerpts from SDK publications in the English language. The Claim also included copies of the identification pages from the recently submitted SAR to PGS.
The PGS Claim was published in the Thai language but included PGS EXPLORATION (UK) LIMITED information in the English language. The claim also included segments of certain articles published on NoPGS.com. It did not include the many articles that had been emailed to PGS Compliance throughout 2016 that PGS had taken no action on. For instance, the PGS Claim did not include the 3 July 2015 article stating that PGS was processing defamatory forged documents within SDKs professional personnel files.
PGS and Richards proffered Compromise agreements for SDK to sign to avoid proceeding to court trial in Thailand Criminal Court SDK did not believe that the PGS EXPLORATION (UK) LIMITED and SDK contract dispute could be legally resolved outside the courts of England.
SDK breached the Confidentiality agreement signed 11 November 2018, according to PGS EXPLORATION (UK) LIMITED when he reported censurable conditions to PGS business partner, Japan Organization for Metals and Energy Security (JOGMEC) as SDK felt obligated to do since PGS is a Norwegian company.
PGS immediately retaliated citing a breach in the newly signed PGS and Richards signed Compromise Agreements and threatened new criminal charges against SDK. PGS and Duensing – Kippen placed a hold on the process. During this waiting period, SDK ordained as Buddhist monk for 9-days. SDK returned prepared to proceed to trial. PGS and Duensing – Kippen decided not to proceed to trial.
However, during the waiting period, around 10 December 2018, website NOPGS.com was stolen and all content / evidence was lost and unaccessible. Some NoPGS.com content had never been backed-up and so could not be republished or referenced for a court proceeding. Much of the first claim referenced content on NoPGS.com. There was no NoPGS.com prior to the trial date.
The Confidentiality agreements signed in November 2018 included dispute resolution venues in the Kingdom of Thailand or any Texas state or federal court situated in Harris County Texas:
(6) Regardless of where any alleged breach occurs, the Plaintiff may, may in its sole discretion, enforce this Agreement in the courts of the Kingdom of Thailand or in a Texas
state court in Harris County and/or the United States District Court for the Southern District of Texas, Houston Division, and the Defendant shall submit to the jurisdiction of the foregoing courts. The parties irrevocably and unconditionally waive, to the fullest extent he or it may legally and effectively do so, any objection that they may now or hereafter have to the laying of venue of any suit, action or proceeding arising out of or relating to this Agreement in any Kingdom of Thailand court, or any Texas state or federal court situated in Harris County Texas. The parties also hereby irrevocably waive, to the fullest extent permitted by law, the defense of an inconvenient forum to the maintenance of such action or proceeding in any such court elected by Plaintiff. This Agreement shall be construed in accordance with the laws of the venue where the Plaintiff elects to enforce.
Is Duensing – Kippen legally qualified to process a Confidentiality agreement within any Texas state or federal court situated in Harris County Texas? It is a violation of law to assert such legal qualifications if one does not possess them. PGS should know this as they have an office and do business in Harris County Texas.
The Directors of PGS EXPLORATION (UK) LIMITED are the same people who are Directors of Petroleum Geo-Services Inc., the US subsidiary of PGS ASA. PGS has never initiated a claim in the US (Houston, Texas) against SDK where they have an office with legal staff. PGS chooses to use the Thailand system of justice where they have no business entity or agency?
SDK asked many questions to PGS and Duensing – Kippen following his coerced signing of the Confidentiality agreements. SDK moved back to the US in July 2019. SDK had no legal permanent address in Thailand. This can be confirmed by Thailand Immigration. SDK had no right nor ability to remain in Thailand indefinitely.
SDK is a US citizen. PGS and Duensing – Kippen were informed that US citizen SDK had moved back to the US. Yet, PGS and Duensing – Kippen continued to deliver claims where my wife and children were staying. This was not SDKs legal address. Therefore, SDK never regarded the notices as true legal claims but more as illegal harassment.
SDK sent many emails to PGS and Duensing – Kippen from December 2018 through June 2019 requesting answers to many questions about the legality of the PGS EXPLORATION (UK) LIMITED Thailand claims. PGS and Duensing – Kippen would not answer but kept demanding SDK comply with their demands.
In February 2020, PGS and Duensing – Kippen and SDK demanded that SDK attend a court proceeding in Thailand. This was economically and practically infeasable as the COVID-19 crisis was evolving and there were travel restrictions. Again, PGS and Duensing – Kippen continued to demand SDK return to Thailand but never addressed questions regarding the legality of these demands.
Duensing – Kippen and PGS EXPLORATION (UK) LIMITED have refused to deliver Legal Notices and Claims to SDK legal US address outside of Thailand in the English language. The PGS EXPLORATION (UK) LIMITED who brought this claim do not reside in Thailand and cannot even read and comprehend the claims presented to the Thailand courts written in the Thai language.
What is wrong with the laws of England? Between 3 July 2019 and 31 December 2023, PGS never even tried to employ the Confidentiality agreements prohibiting the publication of content which disparages PGS or any of its stakeholders governed by the laws of England. Francas wrote on behalf of PGS EXPLORATION (UK) LIMITED that the Confidentiality terms in the EC remained valid. They allowed the publication of multiple letters and articles mostly requesting answers.
PGS EXPLORATION (UK) LIMITED also never executed the terms of the Agreements for resolution in the state or federal courts of Harris County, Texas. PGS and Duensing – Kippen literally waited until SDK visited Thailand again on a Tourist 30-day visa. PGS does not even have a business entity in Thailand. Nonetheless, PGS EXPLORATION (UK) LIMITED, a company located and registered in England, governed by the laws of England, pursues criminal claims against a former employee and US citizen in Thailand.
Misusing a US citizens passport is a serious US federal crime. Although the US doesn’t have a national identification system for its citizens, the passports issued by the US federal government can serve a similar purpose. These travel documents certify the owner’s identity and allow them to enter and exit the country. Misusing a passport is a fraud crime and anyone who commits the above violations – or helps another commit them – is liable to harsh penalties. According to US federal law, a person commits the offense of misusing a passport by copying and using the passport copy of a US citizen without their permission.
Document evidence (the 2018 Duensing – Kippen PGS EXPLORATION (UK) LIMITED) complaint clearly shows that the criminal complaint prepared by Duensing – Kippen on behalf of PGS EXPLORATION (UK) LIMITED was formed by misusing SDK sensitive data. PGS copied then pasted SDK passport and address information from the 2018 PGS SAR directly into the Duensing – Kippen prepared complaint.
SDK never gave either PGS or Duensing – Kippen permission to copy and share his passport details and registered address in Thailand. PGS was provided with SDK passport and registered Thailand address for the sole purpose of confirming identification to process an SAR. Duensing – Kippen and PGS EXPLORATION (UK) LIMITED) then used this stolen information to form the criminal complaint that allowed them to illegally stalk and harass SDK and his family.
The address Duensing – Kippen and PGS EXPLORATION (UK) LIMITED) have been using is not SDKs legal permanent address in the US but the address where SDK registered while he stayed in Thailand on tourist visa and long – stay marriage visa. Duensing – Kippen and PGS EXPLORATION (UK) LIMITED) have demanded that US citizen SDK return to Thailand from the US to answer false charges of criminal defamation under the Thailand criminal code while ignoring their duties under the laws of England.
PGS and WFW have misused the SDK personal data. SDK provided his passport, US driver license / identication and Thailand address information for the explicit purpose of identification verification for processing the WFW SAR and PGS SAR and deliver information to SDK, if needed. Instead, PGS and WFW illegally retaliated against SDK for publishing legally protected public disclosure implicating PGS and WFW as perpetrators.
In July 2015, following the publication of An American, the UK Data Protection Act, Petroleum Geo-Services (PGS) and the Tyranny of “Accurate Data” (3-Jul-2015) , on the LinkedIn™ Pulse platform. PGS Exploration (UK) Limited had the legal obligation to enforce the Cofidentiality terms of either the 2010 or 2013 signed contracts between PGS Exploration (UK) Limited and SDK that prohibit publication of content that disparages PGS or its stakeholders. PGS and WFW are misusing of the Thailand justice system through Duensing – Kippen in an effort to avoid accountability for their actions by the laws of England.
The reason that there are so many publications is because PGS, WFW, and LZW have refused to enforce and take action using the Confidentiality terms in both the EC and Settlement. PGS, WFW, and LZW have deliberately misled SDK and provided false information to obstruct justice. The employment contract dispute between PGS EXPLORATION (UK) LIMITED and SDK should have never existed. There should have never been a Settlement.
Confidentiality clauses cannot be used to prevent whistleblowing under PIDA. (The same is true under the laws of Norway.) However, the Settlement was unlawfully used to silence and remove SDK and his family from England to the US (Houston, Texas). PGS EXPLORATION (UK) LIMITED employed law firm Watson Farley & Williams to process the Settlement that in its final form referenced the 20 September 2013 grievance (the “Grievance”).
The Grievance was qualifying disclosure, or whistleblowing. SDKs hired law firm LZW to advise on the Grievance and help SDK. Instead, LZW conspired with PGS and WFW to illegally terminate a US citizen whistleblower. SDK became aware of this later when he was back in the US.This is why PGS, WFW, and LZW do not want to pursue justice in the courts of England as the EC and Settlement prescribe.
In October 2014, SDK submitted a subject access request (SAR) citing the UK Data Protection Act 1998. I received the personal subject data including his professional personnel file. SDK discovered that PGS EXPLORATION (UK) LIMITED was processing fake personal data. None of the documents being processed bore his signature except the Settlement. SDK believes that he was the target of a conspiracy to defraud. This is the subject of most of the SDK publications that PGS declares to be defamation.
Upon that discovery, SDK complained vigorously. SDK sought legal advice on how to proceed. SDK filed an ActionFraud (police) report August 2015. SDK knew something was very wrong, but no one would help or investigate the matter. On July 3, 2015, SDK wrote about his experience with the SAR and published it on his LinkedIn™ Pulse space. There was no reaction to ‘An American, the UK Data Protection Act, Petroleum Geo-Services (PGS) and the Tyranny of “Accurate Data”’ from PGS, in terms of citing a contract breach for publishing disparaging content.
SDK continued publishing and commenting on the PGS LinkedIn™ page exposing corruption. PGS never commented or invoked a contract breach. SDK wrote multiple emails to PGS compliance and was ignored. Making no progress, SDK began publishing articles to vent his frustrations since all of the official channels were ineffective. SDK first began publishing on the LinkedIn™ Pulse platform. Many of these articles / links were Emailed to PGS Compliance. PGS never cited any breach in either the EC or Settlement.
SDK also tried to excite legal action by posting comments in the PGS LinkedIn™ space. Again, PGS never cited a breach in either the Confidentiality terms of the EC or the Settlement that prohibit publications that disparage PGS or any of its stakeholders. On 20 August 2016, SDKs LinkedIn™ account was restricted. PGS got the legal public disclosure removed through complaining to LinkedIn™ and not employing the contract Confidentiality terms that restrict desparaging former employers but not blowing the whistle!
• Boycott Petroleum Geo-Services (PGS) Capital Markets (25-Jul-2016)
• Petroleum Geo-Services (PGS) Mob Gaslighting (30-Jun-2016)
• Petroleum Geo-Services (PGS) Mob Values (14-Jun-2016)
• The Petroleum Geo-Services (PGS) Ambush Meeting and the Definition of Fraud (24-May-2016)
• Petroleum Geo-Services (PGS) and the Veneer of Governance (8-May-2016)
• Our Deepwater Horizon (4 April 2016)
• Petroleum Geo-Services (PGS) Markets and the Anonymous Executive (9-Feb-2016)
• Workplace Bullying is an Agency Problem and Often a Crime (1-Feb-2016)
• The Society of Exploration Geophysicists (SEG) Should Expel Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen (11-Oct-2015)
• Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen Should Resign 2 (20-Sep-2015)
• Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen Should Resign (6-Sep-2015)
• When Human Resources is Corrupt (10-Aug-2015)
• An American, the UK Data Protection Act, Petroleum Geo-Services (PGS) and the Tyranny of “Accurate Data” (3-Jul-2015)
• Between the Bully and the Deep Blue Sea (5-Jun-2015)
In August 2016, SDK created and published old and new content on personal website, NoPGS.com (NO Psychopaths in Geo-Services) and published new content. Again, SDK made PGS compliance aware of these publications. And still, PGS EXPLORATION (UK) LIMITED never exercised their legal and fiduciary duty to protect the Company reputation and value through a claim citing the EC and Settlement Confidentiality clauses.
• Petroleum Geo-Services ASA (PGS) EVP Per Arild Reksnes Operations Artifice (9-Jun-2018) p105-106
• How Corrupt Bullies and Lawyers Ruined a Marine Geophysical Company 20-May-2018) p107
• Carl Richards’, Secretary, PGS Exploration UK Limited, Silence Implies Agreement and the Abrogation of Fiduciary Duty (20 April 2018) p108-109
• Norway’s Equinor Corruption Perception Delusion and Moral Turpitude (21 March 2018) p109-111
• Carl Richards, Arbitrary and Capricious Company Secretary, PGS Exploration (UK) Limited (24 Feb 2018) p112-118
• 17) A Texan’s Run-in with Criminals in #Weybridge, #England (30-Jan-2018)
• The Crimes of @PhilipLandau #London #EmploymentLaw #Solicitor and Petroleum Geo-Services #PGS #CEO #Pedersen (30-Dec-2017) p118-120
• Norway Oil and Gas Industry Corruption Flows through Petroleum Geo-Service ASA (PGS) (11-Dec-2017)
• Why Focusing on #HarveyWeinstein #Harassment is a Problem (16 November 2017)
• ActionFraud Report (Posted November 2017)
• Petroleum Geo-Services #PGS #CEO #Pedersen and the Management of Gang Rape (24 October2017) p120-123
• My Philip Landau and Watson, Farley & Williams (WFW) London Solicitors Testimonial ( 8 November 2016 updated 9 April 2017 )
• The Society of Exploration Geophysicist (SEG) Should Investigate the Petroleum Geo-Services (PGS) CEO Reinhardsen Cabal ( 17 October 2016 )
• Open Letter to Petroleum Geo-Services ASA Board of Directors (18 June 2017) p124-128
• Petroleum Geo-Services ASA (@PGSNews) CEO Reinhardsen Perverting the Course (1 June 2017 )
• What #PhilipLandau, #London #EmploymentLaw Solicitor taught me about Settlement Contracts (30 April 2017) p128-129
• Petroleum Geo-Services ASA (@PGSNews) CEO Reinhardsen Perverting the Course (1 June 2017) p129-131
• Culture Breathes from Human Resources (24 September 2016)
• The Crimes of Petroleum Geo-Services (PGS) CEO Jon Erik Reinhardsen (4-Sep-2016)
• Boycott Petroleum Geo-Services (PGS) (20-Aug-2016)
PGS has never taken any action against SDK citing a contract breach of either EC and the Settlement. SDK has published, within several publications, that the Settlement is an illegal instrument. PGS, WFW, and SDKs advisors, LZW conspired to coerce SDK into signing the Settlement. As part of the Settlement terms, SDK and his family were sent out of England back to the US. SDK was reimbursed when he was back in the US. In this way, SDK could not easily use the courts of England.
Rune Olav Pederson was with PGS ASA Legal Compliance when the 20 September 2013 Grievance was submitted and when the false / forged records were placed into SDKs professional personnel file.
While § 1028 addresses general identification fraud, the federal government often uses more specific laws for passport crimes:
PGS Exploration (UK) Limited Criminal Defamation Claim Filed Against a Whistleblower in Thailand. PGS Exploration (UK) Limited never envoked the terms and conditions of the employment contract and termination settlement contract governed by the law of England where publications would be in breach. PGS Exploration (UK) Limited and their co-conspirators their legal counsel, Watson Farley & Williams along with SDK legal advisor” Philip Landau do not want to present in a legitimate UK court of law.
(A) Mr. Carl Richards (the “Plaintiff”); and
(B) Mr. XXX (the “Defendent”)
The Plaintiff and the Defendant are collectively called the Parties.
WHEREAS:
The Plaintiff has filed the criminal case number 2552/2561 (the “Criminal Case”) to the Central Criminal Court of Thailand against the Defendant for the offences of defamation by publication and computer crime. The Criminal Case concerns the publication by the Defendant of material which is critical, insulting, or disparaging towards the Plaintiff or which accuses any of the foregoing of acts or omissions which are criminal, unethical, disreputable or otherwise improper (the “Publication”).
The Plaintiff is willing to withdraw the Criminal Case subject to the terms of this Agreement.
Therefore, the Parties agree to the following:
(1) The Defendant warrants that he has deleted or will within 48 hours of the execution of this Agreement delete the Publication and all other material similar to the Publication from all websites, social media platforms, and any other platforms, and any other digital or physical media whatsoever.
(2) The Defendant agrees that the Defendant will not publish (or cause to be published) the Publication or similar content in the future on any website, social media platform or any other digital or physical media whatsoever, including without limitation in any e-mail.
(3) If the Defendant publishes (or causes to be published) any material which refers or relates to the Plaintiff (whether or not such material constitutes a breach of Clause (2) hereof) then the Plaintiff may give notice to the Defendant to remove such material or amend it so that it no longer refers or relates to the Plaintiff, and the Defendant shall comply with such notice within three days. Such notice will be deemed to have been delivered to the Defendant if sent to the email address
(4) If at any time, the Defendant is in violation of Clause (1), (2) or (3) hereof, the Defendant agrees to immediately pay a penalty of USD 50,000 (fifty thousand United States dollars) (the “Penalty”) to the Plaintiff, which shall constitute a debt due from the Defendant to the Plaintiff. Further, nothing in this Agreement precludes the Plaintiff from filing a further criminal or civil proceeding against the Defendant arising from a breach of this Agreement or from any other act or omission after the time period set out in Clause (1) hereof. If the court finds in favour of the Plaintiff in any criminal or civil proceeding contemplated by this Clause (4) then the Defendant shall pay the Plaintiff full legal costs arising from such proceedings on an indemnity basis.
(5) Within 10 days after the Defendant completes the obligation under Clause (1), the Plaintiff will file a request to withdraw number 2552/2561 to the Central Criminal Court of Thailand and provide a copy of such request to the Defendant.
(6) Regardless of where any alleged breach occurs, the Plaintiff may, may in its sole discretion, enforce this Agreement in the courts of the Kingdom or Thailand or in a Texas state court in Harris County and/or the United States District Court for the Southern District of Texas, Houston Division, and the Defendant shall submit to the jurisdiction of the foregoing courts. The parties irrevocably and unconditionally waive, to the fullest extent he or it may legally and effectively do so, any objection that they may now or hereafter have to the laying of venue of any suit, action, or proceeding arising out of or relating to this Agreement in any Kingdom of Thailand court, or any Texas state or federal court situated in Harris County Texas. The parties also hereby irrevocably waive, to the fullest extent permitted by law, the defense of an inconvenient forum to the maintenance of such action or proceeding in any such court elected by Plaintiff. This Agreement shall be construed in accordance with the laws of the venue where the Plaintiff elects to enforce.
(7) This Agreement was the result of a negotiated settlement and may not be construed as having been prepared by any one party.
(8) The Plaintiff may assign its rights and benefit under this Agreement to any third party, and such third party may enforce this Agreement (including collection of the Penalty if payable) directly against the Defendant.
Accepted and agreed to as of the 9/11/2018 (09 November 2018)
THE PLAINTIFF:
Mr. Carl Richards by Miss Tippaya Moonmanee
THE DEFENDANT:
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WITNESS:
Mr. Pracha Sangob
This Agreement is made by and between:
(A) PGS EXPLORATION (UK) LIMITED (the “Plaintiff”); and
(B) Mr. Steven David Kalavity (the “Defendent”)
The Plaintiff and the Defendant are collectively called the Parties.
WHEREAS:
The Plaintiff has filed the criminal case number 2551/2561 (the “Criminal Case”) to the Central Criminal Court of Thailand against the Defendant for the offences of defamation by publication and computer crime. The Criminal Case concerns the publication by the Defendant of material which is critical, insulting, or disparaging towards the Plaintiff or which accuses any of the foregoing of acts or omissions which are criminal, unethical, disreputable or otherwise improper (the “Publication”).
The Plaintiff is willing to withdraw the Criminal Case subject to the terms of this Agreement.
Therefore, the Parties agree to the following:
(1) The Defendant warrants that he has deleted or will within 48 hours of the execution of this Agreement delete the Publication and all other material similar to the Publication from all websites, social media platforms, and any other platforms, and any other digital or physical media whatsoever.
(2) The Defendant agrees that the Defendant will not publish (or cause to be published) the Publication or similar content in the future on any website, social media platform or any other digital or physical media whatsoever, including without limitation in any e-mail.
(3) If the Defendant publishes (or causes to be published) any material which refers or relates to the Plaintiff (whether or not such material constitutes a breach of Clause (2) hereof) then the Plaintiff may give notice to the Defendant to remove such material or amend it so that it no longer refers or relates to the Plaintiff, and the Defendant shall comply with such notice within three days. Such notice will be deemed to have been delivered to the Defendant if sent to the email address stevenkalavity@gmail.com.
(4) If at any time, the Defendant is in violation of Clause (1), (2) or (3) hereof, the Defendant agrees to immediately pay a penalty of USD 50,000 (fifty thousand United States dollars) (the “Penalty”) to the Plaintiff, which shall constitute a debt due from the Defendant to the Plaintiff. Further, nothing in this Agreement precludes the Plaintiff from filing a further criminal or civil proceeding against the Defendant arising from a breach of this Agreement or from any other act or omission after the time period set out in Clause (1) hereof. If the court finds in favour of the Plaintiff in any criminal or civil proceeding contemplated by this Clause (4) then the Defendant shall pay the Plaintiff full legal costs arising from such proceedings on an indemnity basis.
(5) Within 10 days after the Defendant completes the obligation under Clause (1), the Plaintiff will file a request to withdraw number 2552/2561 to the Central Criminal Court of Thailand and provide a copy of such request to the Defendant.
(6) Regardless of where any alleged breach occurs, the Plaintiff may, may in its sole discretion, enforce this Agreement in the courts of the Kingdom or Thailand or in a Texas state court in Harris County and/or the United States District Court for the Southern District of Texas, Houston Division, and the Defendant shall submit to the jurisdiction of the foregoing courts. The parties irrevocably and unconditionally waive, to the fullest extent he or it may legally and effectively do so, any objection that they may now or hereafter have to the laying of venue of any suit, action, or proceeding arising out of or relating to this Agreement in any Kingdom of Thailand court, or any Texas state or federal court situated in Harris County Texas. The parties also hereby irrevocably waive, to the fullest extent permitted by law, the defense of an inconvenient forum to the maintenance of such action or proceeding in any such court elected by Plaintiff. This Agreement shall be construed in accordance with the laws of the venue where the Plaintiff elects to enforce.
(7) This Agreement was the result of a negotiated settlement and may not be construed as having been prepared by any one party.
(8) The Plaintiff may assign its rights and benefit under this Agreement to any third party, and such third party may enforce this Agreement (including collection of the Penalty if payable) directly against the Defendant.
Accepted and agreed to as of the 9/11/2018 (09 November 2018)
THE PLAINTIFF:
Miss Tippaya Moonmanee, the Appointee
THE DEFENDANT:
SDK
WITNESS:
Mr. Pracha Sangob
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Once the employer submits the SMS notification, the Home Office will process it and send a visa curtailment letter directly to the worker. This officially cuts their visa short to 60 days (or whatever time remains on their visa, if less). During this time, they must secure a new sponsor, switch to an alternative visa route, or leave the UK.
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Termination Settlement Contract pages 09 – 10
When a UK law firm merges or dissolves, advisors must securely retain client settlement records for the statutory limitation period, typically 6 years, under the Limitation Act 1980. Under the ICO UK GDPR guidelines, they must uphold client confidentiality, securely manage data transfers, and enforce secure disposal afterward.
The Whistleblower was technically employed (being paid) through 31 December 2013. There had been plans to visit Denver, Colorado, USA for the Christmas through New Year holiday period and then head to Houston. The Whistleblower did not have a home in Houston to move the family to. Following a period of time, the family got situated and the household goods from England arrived. Once moved in, the Whistleblower submitted expenses to England. Oddly, the human resources (HR) who was implicated in the acts of harassment, discrimination, and defamation, as stated within the 20 September 2013 Grievance document, handled closing out the terms of the Termination Settlement Contract and delivering the money. This was finalized in about April 2014.
There was no communications between Philip Simon Landau and the Whistleblower prior to the request for the legal file. Philip Simon Landau never confirmed that the Company fulfilled the terms through international removal reimbursement costs.
(Looking back, this was ensurance that the Whistleblower would leave England and not be able to easily pursue legal redress.)
In October 2014, the Whistleblower submitted a subject access request (SAR) citing the Data Protection Act.
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Under UK law, law firms are required by the Solicitors Regulation Authority (SRA) to notify current and former clients of mergers, acquisitions, or closures, and to inform them of how their files and any active undertakings will be handled SRA Firm Closures Guidance. Solicitors owe a continuous duty of care to their clients, even after a firm ceases operating
If your legal advisor’s firm merged, the successor firm typically takes on the liabilities and responsibilities of the previous practice. If the firm dissolved, you may need to track down where your files were transferred or reach out directly to the SRA. [1, 2, 3, 4, 5]
A signed settlement agreement is a legally binding contract under Section 203 of the Employment Rights Act 1996 Settlement Agreement Clauses Explained. The legal consequences depend on who breached the contract: [1, 2]
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