The mother’s permission application
28.The mother’s permission application sets out the financial relief she will seek if she were given unconditional permission to issue her fourth Schedule 1 application. She will seek a school fees order, capitalised by payment of a lump sum, and a variation of the general maintenance order. Specifically, she will seek an increase in the periodical payments for A from £1,315 to £4,350 per month backdated to April 2020, giving rise to arrears of £88,000. In addition she will seek lump sums totalling £230,000 to finance A’s private education for four years and to discharge certain debts. She will therefore seek a total capital payment of £318,000, primarily intended to meet the cost of private education for A for four years.29.The mother’s statements in support of her application are unfortunate litanies of invective. The same allegations are recycled. Thus, in the 3-page summary statement which I ordered the partes to file she stridently alleged in language both melodramatic and self-righteous, that the father was guilty of :a)Non-disclosure for the last 14 years (paras 1, 3, 4, 10, 13)b)Making an “unprecedented and threatening” application for contact (para 5)c)Inciting care proceedings (para 8)d)Withholding maintenance after the ECRO was made (a new and false allegation)e)Using the ECRO to unjustly prevent her from issuing an application for a non-molestation order in response (para 9)f)Unabated wholesale denigration of her as a mother and litigant (para 10)g)Abuse of the ECRO privilege to engage in “slander and damming prejudice” against her character…so as “to indulge his unscrupulous financial agenda” (para 12)h)A “16 year-long wholesale denigration of her as a wife and mother” (para 13).All of these allegations were untrue, and all had been found to be untrue on previous occasions.