FIXED DATE CLAIM FORM
Form 2 [Rule 8.1(4)]

IN THE SUPREME COURT OF JUDICATURE OF JAMAICA
IN THE CIVIL DIVISION
CLAIM NO.

IN THE MATTER OF THE CONSTITUTION OF JAMAICA
AND

IN THE MATTER of an Application by MAURICE
ARNOLD TOMLINSON, alleging a breach of his
rights under sections 13(3)(a), 13(3)(c), 13(3)(g),
13(3)(i)(i), 13(3)(j)(ii), 13(3)(o), 13(3)(p), 13(3)(6)
and 14 of the Charter of Fundamental Rights and
Freedoms (Constitutional Amendment) Act, 2011
AND

IN THE MATTER of an Application by MAURICE
ARNOLD TOMLINSON for constitutional
redress pursuant to section 19(1) of said Charter
AND

IN THE MATTER of an Application made pursuant to
Rule 56.9 of the Civil Procedure Rules, 2002 (CPR)

 BETWEEN:

MAURICE ARNOLD TOMLINSON

CLAIMANT

AND

THE ATTORNEY GENERAL OF JAMAICA

DEFENDANT

The Claimant, MAURICE ARNOLD TOMLINSON, Attorney-at-law of 19 Angella Close, West
Green, Montego Bay, in the parish of Saint James, claims against the Defendant THE ATTORNEY
GENERAL OF JAMAICA, c/o the Attorney General’s Chambers, 2 Oxford Road, Kingston 5, in
the parish of St. Andrew, for constitutional redress and seeks the following:

1. A declaration that, to the extent consensual sexual activities between persons age 16 or older,
including persons of the same sex, are criminally prohibited and penalized under sections 76,
77 and 79 of the Offences Against the Person Act, 1864 [“OAPA”], those sections contravene
one or more of the following provisions of the Charter of Fundamental Rights and Freedoms
(Constitutional Amendment) Act, 2011 [“the Charter”] and are therefore, to that extent, of no
force or effect:
a) the rights to liberty and to freedom of the person, guaranteed by sections 13(3)(a),
13(3)(p) and 14;
b) the right to security of the person, guaranteed by section 13(3)(a);
c) the right to freedom of expression, guaranteed by section 13(3)(c);

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 d) the right to equality before the law, guaranteed by section 13(3)(g);
e) in the case of OAPA section 79, the right to freedom from discrimination on the
ground of being male or female, guaranteed by section 13(3)(i)(i);
f) the right to respect for and protection of private and family life, and of privacy of
the home, guaranteed by section 13(3)(j)(ii); and
g) the right to protection from inhuman or degrading punishment or other treatment,
guaranteed by sections 13(3)(o) and 13(6);
2. An order that sections 76 and 77 of the OAPA will continue to apply to penalize nonconsensual sexual activity, including with a person under the age of sixteen;
3. An order that section 79 of the OAPA in its entirety is null, void, and of no force or effect;
4. For greater clarity, a declaration that to the extent sections 76 and 77 of the OAPA do not
apply to consensual sexual activities between any persons age 16 or older, including persons
of the same sex, then such activities are also excluded from the operation of sections 2, 29, 30,
31, 32, 33, 34, 35 and the First Schedule of the Sexual Offences Act, 2009 [“SOA”], and
regulations 11, 16, 17, 18 and 21 of the Sexual Offences (Registration of Sex Offenders)
Regulations, 2012 [“SOA Regulations”];
5. In light of the unconstitutionality of the impugned provisions and the remedies sought above,
an order prohibiting the Jamaica Constabulary Force from laying charges under section 79 of
the OAPA, and under sections 76 and 77 of the OAPA in relation to consensual sexual
activities between persons above the age of sixteen, including persons of the same sex, and
further prohibiting the Director of Public Prosecutions or its agents from prosecuting any
person accordingly;

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 6. Such other declarations and orders and such directions as this Honourable Court may consider
appropriate for the purpose of enforcing or securing the enforcement of the aforementioned
declaration and orders; and
7. Such further and/or other relief as this Honourable Court may deem just.
The Claimant seeks the above-noted relief on the following grounds:
The Claimant
8. The Claimant is a gay man, an attorney-at-law and a citizen of Jamaica. He is also a wellknown human rights activist, including for the human rights of lesbian, gay, bisexual,
transgender and intersex (LGBTI) persons. As a result of his activism, he has been exposed to
death threats in Jamaica (which an Assistant Commissioner of Police directly attributed to the
existence of the laws that criminalize consenting adult male same-gender intimacy). In
addition, the Claimant is legally married to another man under the laws of Canada and travels
regularly between his homes in Jamaica and Canada.
9. He has a reasonable fear that his private acts of intimacy with his partner could invite criminal
prosecution and/or harassment from police, any conviction for which could, under the
impugned provisions in OAPA, as well as sections 2, 29, 30, 31, 32, 33, 34, 35 and the First
Schedule of the SOA, and sections 16, 17, 18 and 21 of the SOA Regulations, result in years
of imprisonment with hard labour, compulsory registration as a “sex offender,” and all the
attendant reporting obligations and infringements of personal freedom attendant upon that,
including the possibility of further penal sanction.
The Impugned Provisions
10. As it now stands, Jamaican law criminally prohibits and harshly penalizes virtually any
consensual sexual activity or relations between men above the age of consent to sexual

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 relations otherwise specified in law (i.e., the age of sixteen, as set out in sections 4 and 8 of the
SOA). This legal regime consists of several inter-related components, as described below.
11. First, OAPA section 76 makes it an offence for any man to engage in “buggery” – i.e., anal
intercourse – with another man, imposing a maximum sentence of ten years’ imprisonment
and hard labour:
Unnatural Offences
76. Whosoever shall be convicted of the abominable crime of buggery,
committed either with mankind or with any animal, shall be liable to
be imprisoned and kept to hard labour for a term not exceeding ten
years.

12. Second, OAPA section 77 forbids a man from participating in sexual acts leading to the
completion of anal intercourse with another man, and imposes a maximum sentence of seven
years’ imprisonment with hard labour:
77. Whosoever shall attempt to commit the said abominable crime, or
shall be guilty of any assault with intent to commit the same, or of any
indecent assault upon any male person, shall be guilty of a
misdemeanour, and being convicted thereof, shall be liable to be
imprisoned for a term not exceeding seven years, with or without hard
labour.
13. Third, OAPA section 79 prohibits any act of “gross indecency” by a man with another man,
imposing a maximum sentence of two years’ imprisonment with hard labour:
Outrages on Decency
79. Any male person who, in public or private, commits, or is a party
to the commission of, or procures or attempts to procure the
commission by any male person of, any act of gross indecency with
another male person, shall be guilty of a misdemeanour, and being
convicted thereof shall be liable at the discretion of the court to be
imprisoned for a term not exceeding two years, with or without hard
labour.

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 14. Neither “indecent assault” (in s. 77 of the OAPA) nor “gross indecency” (in s. 79 of the
OAPA) has been definitively interpreted by the Jamaican courts. However, the use of such
terms in the law of the United Kingdom, from which the colonial-era OAPA provision is
replicated, has been interpreted to include “any act involving sexual indecency between male
persons,” including at least mutual masturbation, forms of intercrural contact, and oral-genital
contact,1 and historically the use of “indecency” offences to prosecute an even broader range
of expression of physical affection and intimacy by gay men has been observed in the United
Kingdom and other Commonwealth countries that inherited such law as former British
colonies. There is little doubt, from the wording and history of the impugned provisions, and
their presentation and placement within the OAPA, that these provisions are intended to
criminally prohibit and penalize consensual sexual activity between men.
15. Furthermore, as a result of amendments to the law of Jamaica governing buggery and gross
indecency between men ─ pursuant to both the SOA and the SOA Regulations ─ a
conviction under any of sections 76, 77 or 79 of the OAPA would result in the Claimant, or
other persons engaged in any of the consensual sexual activities captured by those sections,
being mandatorily registered as a “sex offender” and subject to all the registration and
reporting requirements, and potential additional penal sanctions, attaching thereto. Section 2
of the SOA designates offences found in the First Schedule of the SOA as “specified
offences” to which reporting obligations under the SOA (Part VII) apply. The SOA’s First
Schedule explicitly incorporates by reference sections 76, 77, and 79 of the OAPA as
“specified offences.” As a result of these changes in the law, in effect as of 2011 and 2012,
persons convicted of any of the offences of buggery, attempted buggery, or gross indecency
between men (i.e., under any of OAPA sections 76, 77 and 79) are subject to the following

1

Dudgeon v. United Kingdom, Application No. 7525/76, ECHR Series A, No. 45 (22 October 1981), para. 14 (per
European Court of Human Rights, declaring the prohibition to be in breach of the UK’s obligations under the International
Covenant on Civil and Political Rights, to which Jamaica is also a party and to which the reasoning of the Court in Dudgeon
would equally apply).

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 additional elements of the regime criminalizing gay men and other men who have sex with
men in Jamaica:
a. Section 29 of the SOA provides for a Sex Offender Register to be maintained by a Sex
Offender Registry and indicates that under section 30 persons convicted of any of
these offences must be so registered therein.
b. Sections 30 and 31 of the SOA provide for how information on the register shall be
treated, including information about persons convicted of buggery, attempted buggery
or gross indecency between men, as defined in the OAPA, as well as the length of
time for registration as a sex offender (10 years with the possibility of further
extension).
c. Section 32 specifies that any person convicted of these offences must report to a Sex
Offender Registry Registration Centre and be registered as a sex offender, and is
further prohibited from leaving Jamaica before reporting to said Centre.
d. Section 33 provides that any person convicted of buggery, attempted buggery or gross
indecency between men, as defined in the OAPA, must report to the Centre within
fourteen days if he changes his residence and/or name and must also report between
eleven months and one year after he last reported to the Centre.
e. Section 34 requires every person convicted under sections 76, 77 and/or 79 of the
OAPA to advise the Centre, within fourteen days, of:
i. every address or location at which he stays or intends to stay, and of his actual
or estimated dates of departure from, and return to, his main residence, or a
secondary residence if he is in Jamaica but is absent from his main residence
and every other residence for at least fourteen days;

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 ii. his actual or estimated date of departure from his main residence and any
secondary residence if he is outside of Jamaica for at least fourteen days; and
iii. his actual return to his main residence or any secondary residence after a
departure referred to in (a) and (b) above.
f. Section 35 of the SOA provides that if a person is convicted of any of the offences of
buggery, attempted buggery or gross indecency between men under sections 76, 77 or
79 of the OAPA, and that person fails to satisfy the reporting requirements of Part VII
of the SOA, the person has committed a criminal offence and is liable to a maximum
sentence of twelve months’ imprisonment and a fine of one million dollars.
g. In addition, persons convicted of buggery, attempted buggery or gross indecency
between men, as defined in OAPA sections 76, 77 and 79, are subject to additional
infringements of rights under the SOA Regulations, adopted pursuant to the SOA.
Regulation 11 provides that information regarding the person’s designation as a sex
offender, including the offence for which he was convicted, shall be available to,
among others, prospective employers and employees of the person, as well as persons
managing educational institutes at which the sex offender is enrolled or seeks to enrol
– further revealing the person’s sexual orientation to yet more people, with additional
attendant risks to safety and further exposure to unjustified discrimination. Regulations
16 and 17 repeat the reporting requirements found in Part VII of the SOA for any
person convicted under any of sections 76, 77 and 79 of the OAPA. Regulation 18 of
the SOA Regulations also requires that a person convicted under any of sections 76,
77 and 79 of the OAPA must carry a “Certificate of Registration of Sex Offender” at
all times when away from his main residence or face a maximum sentence of twelve
months’ imprisonment and a fine of one million dollars. Finally, Regulation 21 of the
SOA Regulations further provides that any breach of any obligation imposed on a
person under the regulations, in relation to which no penalty is otherwise specified in

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 the regulations, is liable upon summary conviction to a maximum penalty of twelve
months’ imprisonment and a fine of one million dollars.
Effects of the law on the Claimant and others similarly situated

16. Sections 76, 77 and 79 of the OAPA have numerous adverse consequences on the daily lives
of the Claimant and other similarly situated gay men and other men who have sex with men
(MSM).

17. These provisions place the Claimant, as a gay man, at risk of being arrested, prosecuted and
convicted – and subjected to all the stigma and adverse physical consequences of a criminal
provided for in Jamaican law regarding consensual sex between adult men. As a result the
Claimant is forced to either deny his identity and his relationship or contravene the OAPA and
risk criminal conviction and grossly harsh punishment.

18. The criminalization of consensual sexual conduct in which, by his sexual orientation, the
Claimant is naturally inclined to engage, amounts to a direct and blatant denial of equality
before the law for the Claimant and other gay men in Jamaica. This officially sanctioned
stigmatization and discrimination by the state, via the harsh sanction of the criminal law,
further invites and incites the public to subject the Claimant and other persons identified as, or
perceived to be, engaging in same-sex sexual activity to unjustifiable discrimination in all
spheres of life. This discrimination expresses itself through both actual acts of – and the everpresent risk or threat of – blackmail, harassment, violence, and reduced and unequal access to
facilities and services, including such services as protection that should be provided by law
enforcement.
19. The fear of criminal sanctions – and the related stigmatization and discrimination that it
encourages – impedes the Claimant, and impedes some other gay men and MSM, from using
public health facilities geared towards the treatment and prevention of sexually transmitted
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 infections, including HIV. Moreover, public health campaigns and facilities geared towards
HIV prevention, treatment, care and support are impeded in effectively reaching and engaging
gay men and other MSM because of these criminal laws, even though gay men and other
MSM are identified as a “key population” disproportionately affected by HIV and in need of
evidence-based prevention, care, treatment and support as a matter of good public health
practice.

Constitutional rights affected by the impugned provisions
20. Pursuant sections 13(1) and 13(2) of the Charter, as a matter of “inherent dignity” of the
person and as “citizens of a free and democratic society,” “all persons in Jamaica” are entitled
to the fundamental rights and freedoms recognized in the Charter “to the extent that those
rights and freedoms do not prejudice the rights and freedoms of others” and subject only to
those limitations of said rights that “may be demonstrably justified in a free and democratic
society.” In particular, the Constitution guarantees to the Claimant the following rights, which
are infringed by the impugned provisions as described below:

a. Rights to liberty and freedom of the person, pursuant to sections 13(3)(a), 13(3)(p)
and 14 of the Charter:

Through these inter-linked provisions, whose wording

indicates they must be read together, the Charter guarantees the right of each person
not to be deprived of their personal liberty through imprisonment except (1) in
accordance with fair procedures established by law (s. 14), (2) in the execution of a
court sentence following criminal conviction (s. 13(3)(a)); and (3) on reasonable
grounds (s.14). These provisions protect an individual's freedom to act without
unreasonable physical restraint, particularly by the state. Such rights include the
power to make important personal choices, that cause no harm to others, without the
threat or reality of deprivation of liberty by the state, including through imprisonment;

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 it touches the core of what it means to be an autonomous human being blessed
with dignity and independence in matters that are fundamentally or inherently
personal. Sections 76, 77 and 79 of the OAPA infringe the liberty and freedom of the
person of consenting adults, and in particular gay men and other MSM, by criminally
punishing them for their acts of consensual intimacy that harm no one. These cannot
be considered “reasonable grounds” for deprivation of liberty and freedom of the
person, as is required by section 13(3)(a), 13(3)(p) and 14 of the Charter, and cannot
be demonstrably justified in a free and democratic society that values these
constitutional rights.

b. Right to security of the person, pursuant to section 13(3)(a) of the Charter: The right
to security of the person is engaged when the state either violates the physical or
psychological integrity of the individual, including by denying personal autonomy
over one’s body, or damages or risks damaging the individual’s health. For reasons
stated above, the existence of OAPA sections 76, 77 and 79, and the penalties that
flow from them under the law of Jamaica (including the SOA and the SOA
Regulations), violate the right to security of the person of any person engaging
consensually in the prohibited activities, particularly for the Claimant and other gay
men and MSM, in multiple ways. Prosecution and imprisonment for consensual sex
denies the individual’s bodily autonomy in a manner than inherently and inevitably
violates physical and psychological integrity. Such criminalization also impedes
access to critical health services, including prevention, treatment, care and support
vital to health and even life (e.g., in relation to HIV). Finally, these provisions invite
and incite violence and discrimination that, directly and indirectly, seriously
compromise physical and psychological integrity – in particular, in Jamaica, of gay
men and other MSM who are the principal targets of this state-sanctioned persecution.

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 c. Right to freedom of expression, pursuant to section 13(3)(c) of the Charter: This
right guarantees everyone can manifest their thoughts, opinions, beliefs, indeed all
expressions of the heart and mind, however unpopular, distasteful or contrary to the
mainstream. Such protection is fundamental because a society cannot be free and
democratic unless its members have the freedom to express a diversity of ideas and
opinions. Expression encompasses both content and form, and the two can be
inextricably connected. Activity is expressive if it conveys or attempts to convey
meaning – including, for humans as social beings, the expression of intimacy and
shared physical and/or emotional pleasure through sexual connection. Restrictions on
this form of expression inherently deprive an individual of self-fulfilment. For reasons
stated above, the existence of OAPA sections 76, 77 and 79 unreasonably and
unjustifiably curtails the free expression of intimacy between consensual adults, and in
particular gay men and other MSM, which is an exercise of personal autonomy that
harms no one and expresses a core aspect of personal identity.

d. Right to equality before the law, pursuant to section 13(3)(g) of the Charter: This
right requires that no individual or group of individuals is to be treated, without
objectively reasonable justification, more harshly than another under the law. An
individual is denied equality before the law if it is made an offence punishable by law
for that person to do something which others are free to do without having committed
an offence or having been subjected to any penalty. For the reasons stated above,
OAPA sections 76, 77 and 79 result in gay men and other MSM in particular being
treated unequally under the law. OAPA section 79 specifically only applies to men
who have sex with other men, criminalizing them and them alone; and while OAPA
sections 76 and 77 appear facially neutral in that they theoretically criminalize any act
of anal sex between any two people, de facto they are widely understood as targeting
sex between men and certainly the criminalization of anal sex disproportionately

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 criminalizes gay men and other MSM for the expression of their sexuality with
consenting partners.

e. Right to freedom from discrimination on the ground of being male or female,
pursuant to section 13(3)(i)(i) of the Charter: Section 79 of the OAPA specifically
prohibits “any male person” from engaging in any “act of gross indecency with
another male person.” [emphasis added] An act of gross indecency with a man is only
a crime if the accused person is male; a woman who engages in the same or similar
acts with a male partner commits no crime under OAPA s. 79. In other words, the
provision specifically singles out gay men for criminal prosecution on the basis that
their consensual sexual activity – and not just anal sex, but other sexual activity
captured under the exceedingly broad term “gross indecency” – is with other men.
This is an application of the criminal law that discriminates explicitly, on the face of
the law, on the basis of being male or female.

f. Right to privacy, pursuant to section 13(3)(j)(ii) of the Charter: The right to privacy or
‘the right to be left alone’ is not simply a negative right to occupy a private space free
from intrusion by others (including the state), but also a right to get on with your life,
express your personality and make fundamental decisions about your intimate
relationships – which do not harm anyone else – without being penalized.

In

particular, s. 13(3)(j)(ii) guarantees “respect for the protection of private and family
life, and privacy of the home.” It is difficult to imagine laws that infringe upon this
more severely than prohibitions of intimate conduct between consenting adults, as is
the case with OAPA sections 76, 77 and 79. The unjustifiable invasion of privacy
inherent in the state penalizing such private personal conduct is further compounded
for those convicted by the operation of the provisions of the SOA and the SOA
Regulations. Furthermore, beyond this direct impact of the law, the criminalization of

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 gay men and other MSM invites and incites conduct by others in Jamaican society that
infringes their privacy, including acts of discrimination and violence as noted above.

g. Right to protection from torture or inhuman or degrading punishment or other
treatment, pursuant to sections 13(3)(o) and 13(6) of the Charter: This right
guarantees that persons are to be treated with dignity and respect as individual human
beings. As confirmed in international law, this right is absolute and non-derogable.
This provision includes protection from the infliction, particularly by the state or its
officials (or with their acquiescence) of pain and suffering, whether physical or
mental, that is either severe (“inhuman” treatment) or aimed at humiliating a person
(“degrading” treatment).

The continued existence in law of the provisions that

criminalize and penalize consensual sex between men breaches this provision of the
Charter in multiple ways. First, the state’s equation of consensual sex between gay
men with bestiality is degrading per se. Second, the state’s imposition of years of
imprisonment for consensual sexual conduct between adults (and with hard labour
mandatory under OAPA s. 76 and possible under OAPA ss. 77 and 79, and mandatory
registration as a sex offender as a consequence of a conviction under any of these
provisions) is per se a grossly disproportionate punishment for conduct that causes no
harm, rendering that punishment both inhuman and degrading. Finally, the state has
an obligation to take steps to prevent inhuman or degrading punishment or other
treatment, especially of vulnerable groups, including through taking legal measures –
and failure on the part of the state to act with due diligence to protect individuals
against widespread and well known conduct of such a sort also amounts to a breach of
the protection against inhuman or degrading treatment. Attacks on the physical or
mental integrity of a person, or a threat to perform any such act that is reasonably
viewed as real and imminent, constitute a violation of the right. For reasons stated
above, OAPA sections 76, 77 and 79 contribute to the vulnerable minority of gay men
(and others perceived to be gay or to engage in conduct prohibited by OAPA) in

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 Jamaica being subjected to extreme (and sometimes murderous) violence at the hands
of others, amounting to torture or other treatment that is inhuman and/or degrading. In
the face of such well-documented, ongoing instances of torture and other ill-treatment,
the state is in breach of its constitutional obligations in maintaining the impugned
OAPA provisions that are a contributing factor to such abuses by non-state actors.
Savings clause does not bar application of Charter provisions to impugned OAPA provisions
21. The Charter of Fundamental Rights and Freedoms came into effect on April 8, 2011. Section
13(12) of the Charter is a “savings” clause, which immunizes from constitutional challenge
certain laws in force before the Charter. Subsequent to the commencement of the Charter in
2011, the SOA and SOA Regulations have made significant changes to the criminal law
applicable in Jamaica to buggery and gross indecency between men pursuant to the OAPA.
The bulk of the SOA came into force on June 30, 2011, and Part VII of the Act specifically
relating to the sex offender register only came into force even later, on October 11, 2011. The
SOA Regulations were adopted in December 2012, coming into effect on December 20, 2012.
Consequently, the law applicable to consensual sexual activity between men in Jamaica is no
longer the “law in force immediately before the commencement of the Charter,” and the law
must therefore comply with the rights protected by the Charter.
This Court should remedy the breaches of the Charter
22. Section 19(1) of the Charter gives the Claimant, as a citizen of Jamaica, whose rights have
been, or are likely to be breached, the right to seek redress from this Court, which he does in
light of the aforementioned violations of numerous provisions of the Charter.
23. The Claimant does not question the validity of the law criminally prohibiting and penalizing
buggery or gross indecency insofar as it applies to non-consensual sexual activity, including
with minors under the age of consent (defined as the age of 16 in the SOA, ss. 4, 8). However,

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 the scope of the impugned provisions as they stand far exceeds this and it is the role of this
Honourable Court to correct this deficiency so as to guarantee the rights under the Charter to
which all persons are entitled.
24. As guardians of the Constitution, the judiciary has a duty to interpret laws in a manner that
gives full effect to constitutional values and principles.
25. Pursuant to section 19(3) of the Charter, the Court has the power to make such orders as it
considers appropriate to vindicate the Claimant’s rights pursuant to the Charter, and this is
especially apposite since the Claimant has no other parallel legal remedy available to him.
Section 4(1) of the Constitution states that laws passed prior to the enactment of the
Constitution remain in effect but shall be construed “with such adaptations and modifications
as may be necessary to bring them into conformity with the [Constitution’s] provisions.”

I certify that all facts set out in this Claim Form are true to the best of my knowledge, information and
belief.

Dated the ___ day of November 2015

___________________________________________________
MAURICE ARNOLD TOMLINSON

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 NOTICE TO THE DEFENDANT

The first hearing of this claim will take place at the Supreme Court, Public Buildings, King Street,
Kingston on the ______ day of ________________ 201__ at _____ a.m.

If you do not attend at the hearing, judgment may be entered against you in accordance with the claim.

If you do attend, the judge may
(a) deal with the claim or
(b) give directions for the preparation of the case for a further hearing

A Particulars of Claim or an Affidavit giving full details of the Claimant’s claim should be served on
you with this Fixed Date Claim Form. If this has not been done and there is no order permitting the
Claimant not to serve the Particulars of Claim or Affidavit, you should contact the court immediately.

You should complete the form of Acknowledgment of Service served on you with this Claim Form
and deliver it to the registry (address below) so that they receive it within FOURTEEN days of service
of this Fixed Date Claim Form on you. The form of Acknowledgement of Service may be completed
by you or an Attorney-at-Law, acting for you. See Rules 9.3 (1) and 9.4(3) of the Civil Procedure
Rules.

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 You should consider obtaining legal advice with regard to this claim. See notes in form 2A served
with this Fixed Date Claim Form.

This Fixed Date Claim Form has no validity if it is not served within twelve (12) months of the date
below unless it is accompanied by an order extending the same. See Rule 8.14 (1) of the Civil
Procedure Rules.

[SEAL]

The Registry is at King Street, Kingston, telephone number (876) 922-8300; fax (876) 967-0669. The
office is open between 9:00 a.m. and 4:00 p.m. Mondays to Fridays, except on Public Holidays.

Dated the _____ day of December 2015

The Claimant’s address of service is that of his Attorney-at-law, ANIKA GRAY, of 43 Seville
Meadows, Phase 3, St Johns Road, Spanish Town, St. Catherine whose telephone number is 5042641.

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 PER:…………………………………………
ANIKA GRAY
Attorney-at-law

Filed by ANIKA GRAY of 43 Seville Meadows, Phase 3, St Johns Road, Spanish Town, St.
Catherine whose telephone number is 504-2641, Attorney-at-law for and on behalf of the
CLAIMANT.

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