Dear David Seymour,

This is a request for Official Information based on your 1 May 2024 letter to me regarding crimes committed by Southern Response.

Your response to my letter can be viewed at: https://drive.google.com/file/d/1aFMD2JM...

On 2 April 2024 I requested that the New Zealand Government take over my efforts regarding the prima facie criminal fraud committed by Southern Response and the New Zealand laws violated by those with a duty of care for the population of New Zealand. I also requested that the Government pay for lawyers to come to a fair settlement of my unsettled home insurance claim.

In your response you only mentioned the settlement of the claim.

You stated that you spoke with Southern Response and they provided you with a list of 3 circumstances in which they have paid claimants legal fees. You also stated that I did not meet the criteria for any of the circumstances.

1) Please provide me with all documents and information related to the list of 3 circumstances being a fixed list that did not expand over time.

. The reason that I am requesting this is because it would appear that this list has expanded over time, and that there is no reason that it could not be expanded further to accommodate my circumstances.

2) In my request I did not ask for Southern Response to agree to pay the legal fees, I requested that the Government do so.

. Please provide all documents and information on the steps taken to ascertain if the Government would be willing to pay to settle the claim, and the conclusions of that process.

One of the circumstances listed where legal fees would be paid was “to enable a policy holder to bring a test case that is likely to have significant policy implications for Southern Response and its broader claims portfolio. For example, the Dodds proceedings.”

3) Please provide me with all documents and information related to any assessment of the facts that I presented to you about the prima facie criminal fraud committed by Southern Response, in general but also including if this would be likely to have significant policy implications for Southern Response.

4) Please provide all documents and information related to the decision that the above option was not offered as being available to settle my claim.

In your reply you wrote “I understand that the root of the delay in settling your claim is a dispute between you and Southern Response on the proposed repair methodology for your property…”

5) Please provide all documents and information on how you have understood the delay in settling the claim being related to the repair methodology instead of the criminal fraud that they have committed against me.

In your response you only addressed information contained in two pages of the fourteen page letter.

6) Please provide all documents and information on the decision to not address 12 pages of my letter in your response.

It is commonly understood that the position of Minister for Regulation involves upholding the rule of law.

7) Please provide all documents and information related to the position of Minister for Regulation involving the upholding of the rule of law.

8) Please provide all documents and information related to efforts undertaken to understand the implications of rule of law in relation to the 12 pages of my letter that were not addressed in your response.

In your response you have stated that you are responding as a shareholder Minister for Southern Response. When the office of Christopher Luxon told me they had forwarded the communication to the office of the Minister for Regulations. When I received confirmation of receipt from your office I was told it fell under your Associate Finance portfolio.

9) Please provide all documents and information related to the decision to address my letter as the shareholder Minister for Southern Response, instead of as Associate Finance Minister, or Minister for Regulations, when the majority of my letter was about financial crimes by Government employees, and the covering up of those crimes by other Government employees.

Regarding shareholder Minister for Southern Response communication with Southern Response.

10) Please provide all documents and information related to your communications with Southern Response regarding me, my claim, or my letter to which you responded.

11) Please provide all documents and information related to David Clark’s communications with Southern Response regarding their crimes, to which he initially said did not exist, then said he lied about it not existing because the information contained within the communications would impede his ability to have frank conversations with Southern Response about the crimes they are committing.

12) Please provide all documents and information related to Grant Robertson’s communications with Southern Response regarding their crimes.

In my letter I mentioned that I would need to address a number of Ministers if the Government decided not to take on the responsibility of ensuring accountability for the unlawful acts that I have experienced and been instructed to investigate by the Serious Fraud Office.

13) Please provide me with the details for the Minister responsible for the Financial Service Providers (Registration and Dispute Resolution) Act 2008.

. I am requesting this in relation to the Insurance and Financial Services Ombudsman Scheme violating the Act.

14) Please provide me with the details for the Minister responsible for the Ombudsman Act 1975.

. I am requesting this in relation to the Ombudsman, Peter Boshier, and staff violating the Act.

15) Please provide me with the details for the Minister for Justice.

. I am requesting this in relation to Her Excellency The Right Honourable Dame Cindy Kiro, GNZM, QSO Governor-General of New Zealand via Government House staff stating that I need to speak to the Minister of Justice to arrange the removal of Peter Boshier from his position of Ombudsman of New Zealand.

16) Please provide me with the details for any other shareholder Ministers for Southern Response.

. I am requesting this in relation to the financial crimes committed by Southern Response staff and your decision to not address these matters in your response.

17) Please provide me with the details for the Minister responsible for the Earthquake Commission.

. I am requesting this in relation to EQC working with Southern Response to hide criminal fraud.

18) Please provide me with the details for the Minister responsible for Radio New Zealand.

. I am requesting this in relation to RNZ unlawfully destroying official information relating to the crimes committed by Southern Response.

19) Please provide me with the details for the Minister responsible for the New Zealand Police.

. I am requesting this in relation to my police report about the crimes of Southern Response having been read, then unread, and remaining re-unread for 21 months after it was submitted, where I have been told by the police that I shouldn’t be speaking to the police because I’m requesting that Government Employees be held accountable for their crimes.

These requests are being made on the grounds of public interest in relation to the matters of transparency; participation; accountability; administration of justice; health, safety and the environment.

Please note that the requests are not just for documents, but also information. As such with regards to the Office of the Ombudsman guidance document “The OIA for Ministers and Agencies” these requests for official information include “information held in the memory of” the Minister and his staff. As such unless there is a document which provides the information requested, the Minister and staff must be questioned to provide the held information from their memory. No sections of this request can be denied based on Section 18(e) unless they are also denied on Section 18(g).

Each of the points is an individual request for official information. If any of the responses need to be extended that should not impact delivery of responses for those that do not require an extension. Any decision to extend a deadline should be accompanied with the grounds for the decision.

Any information that is denied should be accompanied with the grounds for the decision to deny the information. These should include the dates and times that the Minister and staff was questioned about their memory of the official information.

As per the Office of the Ombudsman guidance a clarification requested will only reset the deadline for the individual requests where a clarification is provided, the remainder of the requests for official information in this communication will have the original deadline remain.

Further in relation to the Office of the Ombudsman guidance “The agency’s primary legal obligation is to notify the requester of the decision on the request ‘as soon as reasonably practicable’. The reference to 20 working days is not the de facto goal but the absolute maximum (unless it is extended appropriately).” If the notification does happen on the last day of the 20 working day deadline please provide the grounds for why the decision was made that it was not ‘reasonably practicable’ to provide the decision sooner.

Yours faithfully,

.