I, HARITA KYRIACOU IOANNIDOU of 16a Woodside Road, Wood Green. London N22 5HU, retired, HEREBY REVOKE all former testamentary dispositions heretofore made by me AND DECLARE this to be my last Will as follows:-

1. I APPOINT my eldest son ANDREW YIANNIDES of 65 Abbott’s Park Road, London E10 6HU, Mr SAVVAS SOUPASHI of 18 Richmond Road Ilford Essex IG1 1JF and Mr PLOUTIS PETROU of 4 Yianni Kapitani Street, Dasoupoli Nicosia TT 2024, Cyprus (hereinafter called "my Trustees" ) to be the executors and Trustees of this my Will. And I direct my Trustees to pay all my debts and funeral and testamentary expenses from the funds held in the two accounts I relate to below.

2. I GIVE to my daughter DESPINA SOTIRIOU ENGLEZAKIS of 27 Bawdsey Avenue, Newbury Park, IG2 7TW, in the County of Essex all of my belongings at 16 and 16a Woodside Road (hereinafter refer to as ‘the property’) and such other belongings I have and shall be calling upon the parties who were entrusted with such other personal belongings and properties which I will be specifying in communications demanding the return of same by the parties holding same and or entrusted to them by me with the safe keeping of same.

3. I GIVE to the same daughter DESPINA SOTIRIOU ENGLEZAKIS (as above) all moneys standing to my credit on my Omega Instant Access account (recorded erroneously in the name of HARIDA KYRIACOU JOANNIDES) at the Bank of Cyprus (London) Ltd, 23 Highgate Hill, London N19 5LP, Archway Branch and all moneys standing to my credit on my fixed deposit account with the Popular Bank Cyprus Ltd, 53 Ayiou Andreou Street, Pallouriotissa Branch, Nicosia Cyprus, after payment of my funeral and testamentary expenses.

4. I give also to my daughter DESPINA SOTERIOU ENGLEZAKIS the land and property that was part of my dowry, as I and my family benefited from, from my parents on my marriage, which is situate in the village of Karavas, in the District of Kyrenia, Cyprus and is registered in my name under title/holding 11/24 W.1.E.1 plot 64 D I A K 07-513094, with the Land Registration Authorities in Cyprus. AND IT IS MY EXPLICIT WISH THAT SHE SHOULD HOLD and benefit from and use of same as she shall determine. AND I FURTHER DIRECT THAT MY TRUSTEES do their utmost to ensure that my wishes NOT TO PART WITH, exchange and or accept any moneys in lieu of any agreement consequential to and arising out of any ‘political settlement’ following the invasion of the Republic and island of Cyprus by Turkey and its armed forces in 1974, UNLESS my daughter DESPINA SOTIRIOU ENGLEZAKIS, as beneficiary in title, in accordance with this my Will shall direct and or instruct them for and in respect of her own interests and or as she should determine in accordance with her rights in International Law BUT NOT as any other may or shall seek to impose on her.

5. I DIRECT that my son ANDREW YIANNIDES shall seek, demand and endeavour to secure the return to me (before my demise) and or to my trustees following my demise, ALL OF THE PAPERS that were and HAD BEEN ENTRUSTED to and or were removed from my residence to be held in trust and in the safe of my youngest son SAVVAS KYRIACOU JOANNIDES, as my solicitors had been instructed to demand and secure as of July 1996 but defaulted to act without due consideration of the issues raised with them as of July 1996. AND in the event that Legal Action shall have been instituted and or issued out of court and or be necessitated, warranted and or become essential in order to meet with my present Will and these my directions herewith I stipulate, that my Trustees proceed with and carry with the prosecution of the case for the recovery of my rights in law in order that my Will be done and executed as I hereby direct and instruct. AND I SPECIFICALLY demand that:-

(i) My youngest son, the above named SAVVAS KYRIACOU JOANNIDES, be called to account to my other children:- (a) MARIA YIANNI ANTONIADES, (b) ANDREW YIANNIDES, (c) DESPINA SOTIRIOU ENGLEZAKIS and (d) COSTAS KYRIACOU JOANNIDES for ALL INCOME AND EXPENDITURE in respect of the upper part of ‘the property’ known as 16 Woodside Road, Wood Green, London N22 5HU, through me and in my presence before my demise and or through my trustees following my demise. AND further that my youngest son SAVVAS KYRIACOU JOANNIDES accounts to me while I am alive and or to my Trustees and through them to all of my other children (named above) and qualify to me and or to my trustees (as the case may be) as to how he, SAVVAS KYRIACOU JOANNIDES, ensured I personally benefited from ANY income from the said property in accordance with his late father’s Will which my youngest son SAVVAS KYRIACOU JOANNIDES declared in August 1997 he had been honouring throughout following the demise of his father after he took over and controlled the bank account that was held in the joint names of my late husband and myself, at the National Westminster Bank plc, Hornsey Road Branch, London N19, with my authority because I TRUSTED HIM AND BELIEVED HE WAS ACTING HONESTLY AND HONOURABLY THROUGHOUT THE YEARS and since the demise of his late father. AT all material times my TRUSTEES to consider and act in accordance with the facts I relate to in the Depositions and Affidavits I have authorised and will be executing in connection with all material facts and events I depose of on SOLEMN OATH.

ii. I DESIRE, DIRECT AND DEMAND that all persons who took part in the deceptions, the dishonest activities and the impositions on others and the infringements on the rights of any of my children (who were wronged as a result of the liberties taken by my late husband and any and all others thereafter) BE REMEDIED IN ACCORDANCE WITH THE LAW AND AS THE LAW PROVIDES and not as the dishonest and the collaborating solicitors they relied upon to and impose on their victims and on my person through the deceptions and the misrepresentations I depose of on specific AFFIDAVITS and as I related to solicitors I had cause to contact and visit following disclosure in a bill of charges my solicitor KYPROS NICHOLAS forwarded to me wherein he clearly stipulated that ‘the property’ had been transferred to one of my granddaughters pursuant to instructions he had received from my youngest son SAVVAS KYRIACOU JOANNIDES and acted upon without due reference to me and or within my knowledge and or with my authority at the time when the solicitor was entertaining and acting upon the undisclosed (to any other) instructions from my youngest son SAVVAS KYRIACOU JOANNIDES.

(iii) I further direct that my son, TRUSTEE AND EXECUTOR ANDREW YIANNIDES, who knows of the Law, and was the person who recognised the dishonest scheme that SAVVAS, MARIA AND HER HUSBAND embarked upon at my expense (through the transfer of ‘the property’ to raise funds and moneys for their own private use and benefit) as was evinced in the bill of charges my solicitors were caused to forward (through their intended attempt to stop me from having access to my file of papers in respect of work they had purportedly done for me) and as the solicitors for the ANTONIADES couple exposed through their clients’ arrogant demands following the transfer of the property to their daughter to secure and recover MY RIGHTS IN LAW from the dishonest and deceitful. AND that my son ANDREW YIANNIDES (who uncovered at the Probate Office the documents that exposed the undisclosed and secret deals, agreements and arrangements that were entered into between my late husband KYRIACOS PETROU IOANNIDES, our eldest daughter MARIA YIANNI ANTONIADES, her husband YIANNIS GEORGIOU ANTONIADES, our sons COSTAS KYRIACOU JOANNIDES and SAVVAS KYRIACOU JOANNIDES) to seek remedies from and against the offending parties who wronged me and that my son ANDREW YIANNIDES carries on and proceeds to recovery of all of my papers and properties as I herein stipulate and that he further proceeds to the settling of all claims in respect of the financial and other damages and impositions that the persons I name above and stipulate herein (my children, the solicitors they relied upon and my granddaughter) and the other persons who over the years through non disclosure aided and abetted the dishonest in the promotion and execution of the secret and undisclosed agreements and arrangements that were entered into and existed between my late husband and those who took part in same and the deceptions that followed through non disclosure to my person and or to my daughter DESPINA SOTIRIOU ENGLEZAKIS and or to my son ANDREW YIANNIDES whose rights the dishonest had violated through the initial secret arrangements and the deceptions that ensued thereafter. AND I FURTHER DIRECT that my son SAVVAS KYRIACOU JOANNIDES accounts and justifies the false declarations he had been making in respect of the alleged liabilities and debts of my late husband as he, SAVVAS KYRIACOU JOANNIDES was promoting, relying upon and allegedly meeting from the rents paid into the current account held in my name alone (after the demise of my late husband) at the National Westminster Bank plc. Hornsey Road Branch. AND THAT THESE MY SUCCINCT AND SPECIFIC DIRECTION BE FOLLOWED TO THE LETTER and in any event through any Court action that may have been instituted and or issued out of Court before my demise, with my son ANDREW continuing both as my TRUSTEE, under the terms of this my Will and in accordance with the Power of Attorney Instrument I was caused to authorise, direct and issue following failures and defaults by members of the legal professions to challenge the dishonesties and the deceptions in which my solicitor KYPROS NICHOLAS of Nicholas & Co. entered into and entertained at the behest of my youngest son SAVVAS KYRIACOU JOANNIDES.

6. I direct that my son and trustee ANDREW YIANNIDES proceeds to recovery, as I instructed and authorised him upon the granting of the POWER OF ATTORNEY instrument which I was caused to instigate and issue following the deceptions and the dishonest acts I was victim of and as a consequence of defaults and failures by the solicitors I had cause to contact and instruct (as herein above and below stated). AND THAT MY TRUSTEES on recognition of the violation of my rights as have been violated, were infringed and unjustifiably and inexcusably perpetrated by my sister KATERINA GEORGIOU KRITHARIDOU (or KRITHARI as she may be known/registered) with assistance from her children who have been holding on to the title deeds of land and properties thereon that was to have been officially registered (and with my name recorded on the Deeds as was entered in accordance with our father’s wishes prior to his demise). AND THAT MY SON ANDREW YIANNIDES do proceed in the said matter as he shall have instigated as from the granting of the Power of Attorney instrument I authorised and endorsed in order that he should proceed to deal with the dishonesties and the denials and obstructions of and to my rights and THAT HE SHOULD RECOVER THE DEEDS FROM MY SISTER KATERINA AND OR HER CHILDREN and that IF SHE SHOULD PERSIST THAT HER CHILDREN have misplaced and or cannot find the DEEDS and TITLES TO THE LANDS AND PROPERTIES I REFER to that he should demand and secure from my sister and her children such declarations and acknowledgements as to my rights to the said land, and the endorsements on the DEEDS she has withheld from me unjustifiably and inexcusably safe out of spite malice and or for dishonest gains and or intended attempts to deny me my rights and or through deceptions to cause to be registered the said lands and properties thereon in the name of person and or persons of her choice and or through collaborating other dishonest persons. AND THAT IN THE EVENT my sister KATERINA and or her children continue to obstruct me and or my son ANDREW as my AUTHORISED agent and representative under the General Powers of Attorney I have authorised and granted to my son Andrew, I DIRECT THAT MY TRUSTEES through my son ANDREW, should authorise and institute proceedings against the offending party and or parties, at all material times my son ANDREW being in command and having absolute control and making all legal decisions in respect of the violations of my rights and the infringements in the peace of my mind which the dishonest and maligned disturbed following disclosure by my sister KATERINA as of August 1996 that she and or her children hold the title deeds to the said land and properties thereon but has adamantly refused and or declined to hand over the deeds under various pretexts and or unjustifiably and without due cause and or reason denying me my rights and obstructing me from registering my rights in title with the Land Registration Authorities in Cyprus. AND I INSTRUCT THAT MY TRUSTEES do their utmost to have and or caused to be delivered to them and or to my son ANDREW YIANNIDES the relevant DEEDS TO THE LAND AND PROPERTIES THEREON as I refer to, if not delivered to me and or to my son Andrew prior to my demise, AND THAT MY TRUSTEES should proceed to take all relevant steps to recover all expenses and outgoing from my sister and such others as she may have been relying and or rely upon to promote and or seek personal gain dishonestly through obstructions to my legitimate rights such as my sister and her children acknowledged on many instances; and that if legal action be necessitated and or the matter be taken and or raised in any Court in the United Kingdom and or in Cyprus (where the land is situate) in order that the land, which is rightfully mine as my father specifically provided and stipulated, should be duly registered with and at the Land Registration Authorities in Cyprus, in my name before my demise should my sister and her children recognise that their dishonest and wrongful acts should cease as of the date my son Andrew shall proceed in accordance with my instructions under the General Power of Attorney Instrument I granted to him. AND in the event that the delivery of the Deeds be secured after my demise I INSTRUCT that my TRUSTEES do, after securing the DEEDS to the aforesaid land and properties, act as I instruct herein below.

7. AND IN THE EVENT THAT MY SISTER KATERINA AND OR HER CHILDREN should fail and or persist to act as they have done since August 1996 and decline and or refuse to hand over the DEEDS to the land and properties I refer to above, my son ANDREW should proceed to the necessary investigations in Cyprus to isolate and identify the property such as I described to him and to my daughter DESPINA in respect of the locality and the place in the District of Kyrenia and the vicinity of the village Elia; and that my son ANDREW YIANNIDES after giving notice as to recovery of all expenses and outgoings warranted and or necessitated because of the unjustified and dishonest manner with which my sister KATERINA and her children have acted as of August 1996 should proceed to an appropriate claim against whosoever he shall determine was and or is responsible for the obstructions to my person to secure and regain title proper and ownership of the aforesaid land and properties as my father had stipulated and endorsed prior to his demise. AND THAT at all material times my TRUSTEES should treat the recovery of the DEEDS to the said property as a right denied and or violated by my sister (and or such others who have been assisting and or aiding and abetting her in denying me my rights and in obstructing me to register my legitimate claim to the said lands and properties thereon and that my trustees shall be afforded the opportunity to hear of and recognise that my sister KATERINA having proclaimed, acknowledged and recognised repeatedly my rights to the said lands which matters she was recorded umpteen times recognising and confirming also in the presence of witnesses shall assist and or work with my son ANDREW to bring to a satisfactory conclusion my rightful claim to the said land and properties thereon. AND I INSTRUCT that the said lands and any residual claims in respect of financial awards and or revenues arising thereof following the Titina Loizides ruling at the Court of Human Rights be put in a Trust account to be created by my TRUSTEES in my name and the lands and title to same be registered in the said TRUST AND CHARITY and that all benefit, revenues and or financial gains to be secured from and in respect of the said land and properties be used in accordance with my expressed wishes as I shall direct and instruct my DAUGHTER DESPINA AND MY TRUSTEES prior to my demise and as shall have been put in writing and endorsed by me appropriately and as necessitated in this instance. IN THE EVENT that my demise should precipitate the conclusion of the drafting and settling of the constitution of the said TRUST the LAND and properties thereon to be used as and in accordance with the joint decisions of my daughter DESPINA SOTIRIOU ENGLEZAKIS AND my son ANDREW YIANNIDES, at all material times as and in accordance with recordings that shall be made and kept by them evincing my wishes and determination in respect of the use of the said Land and properties.

8. I GIVE to my daughter DESPINA SOTERIOU ENGLEZAKIS the land in the vicinity and area known as ALOUPATITHES for which land and property my daughter DESPINA has a letter (she has kept for me in safe keeping) whereby my mother ANDRIANOU FIEROU had stipulated she desired for me to go to Cyprus so as for her to transfer the said property to my person and in my name by attending with her the Land Registry as was/is the practice in Cyprus.

9. I INSTRUCT that my son ANDREW proceeds to issue instructions to solicitors and or by himself as my authorised agent proceeds to issue an appropriate Summons and or institute appropriate proceedings and formulates a claim for damages against my son SAVVAS KYRIACOU JOANNIDES, my daughter MARIA YIANNI ANTONIADES, her husband YIANNIS GEORGIOU ANTONIADES, their daughter RITA YIANNI ANTONIADES and my former solicitor KYPROS NICHOLAS and the firm NICHOLAS & CO. in respect of the damages the first three imposed and caused to me through the deceptions and the withholding of material facts they knew of and failed to disclose for years; the secret arrangements they had been party to with my late husband in respect of the agreement they had all entered into, following the declared and acknowledged by all sale of MARIA’S share and her interest in ‘the property’ at Woodside Road, and specifically in respect of the repayment of the loan facility my late husband was caused to secure on ‘the property’ when ‘he bought’ the share of our daughter MARIA in ‘the property’. The sale of MARIA’S share in ‘the property’ to my late husband was repeated and acknowledged on countless instances within the family circle and friends; many became aware of and knew of the acknowledgements and statements as to the ‘sale of MARIA’S share to her father’ and most knew of the circumstances under which my late husband was caused to seek a loan facility in order to do so. AND that my son ANDREW should seek such damages as were caused and imposed on me through deceptions and misrepresentations by those who were party to the undisclosed and secret arrangements between my late husband, my eldest daughter MARIA, her husband YIANNIS ANTONIADES and my sons COSTAS and SAVVAS who withheld the aforesaid arrangements and through the years and through fraudulent misrepresentations and deceptions all acted in breach of trust and used the rents that SAVVAS was entrusted with and in control of through authorisation I granted him (as an illiterate and trustworthy mother) for other purposes than the alleged liabilities of my late husband. AND THAT MY son SAVVAS do either satisfy my trustees as to the use of all funds he had been in control of and never accounted to me even when demanded of him by me in the course of the latter part of 1996 and throughout 1997. AND THAT there be a claim formulated against the four parties to the conspiracy who caused damages to me through the deliberate and with intent failure of my son SAVVAS to renew the insurance on the property and his failures to maintain the property as he ought to have done with the funds he was receiving and in control of being the rents due and payable as he had been arranging and managing throughout the years 1971-1992 on his own and without any reference to me and or to any other because of the implicit trust I had placed in him. AND THAT THERE BE A CLAIM AGAINST my solicitors and the four who conspired to transfer the property, through reliance on an alleged sale by me (aided and abetted by my solicitor KYPROS NICHOLAS and his FIRM) which sale another firm of solicitors acting on instructions from the ANTONIADES three I name above, disclosed and relied upon to order me and my daughter DESPINA SOTIRIOU ENGLEZAKIS not to repair renovate and or rent the property as the Will of my late husband had stipulated (and the four allegedly respected and honoured from the onset) and through the implied sale of the property securing at my expense loans and funds to facilitate a business venture my youngest son SAVVAS KYRIACOU JOANNIDES embarked upon with and or without his brother-in-law and or the ANTONIADES couple jointly with assistance from my solicitor KYPROS NICHOLAS and his firm NICHOLAS & CO. without due consideration to the breaches of trust all had embarked upon, the violations of my rights through deceptions and fraudulent misrepresentations and through reliance on the police to default to take any steps and or action in respect of the fraudulent conversions, the misappropriation of funds and the transfer of the property to the daughter of the ANTONIADES couple through an alleged sale of which I was not aware of and or notified because of the misappropriation of the funds the ANTONIADES trio, my son SAVVAS and my solicitors were fully aware of had been secured with contemptuous indifference to my circumstances and what all had imposed on me inclusive of the damages to the property following the defaults and failures of my son SAVVAS to renew the insurance on the property he and others were benefiting from for years while advancing falsehoods and lies as to liabilities and the loans my late husband had secured on the property. AND THAT ALL FUNDS CLAIMED AND SECURED AGAINST THE DISHONEST (even if there be need to institute the proceedings solicitors failed to institute because of the involvement in the deceptions by members of their profession (my solicitors) should be applied to the renovation of the property which my son SAVVAS KYRIACOU JOANNIDES and his accomplices sought to and benefited from throughout the years (SAVVAS using the rents I entrusted him with and which he had absolute control of and used as he alone chose but has adamantly failed to account to me for, notwithstanding my demands to do so since disclosure by my solicitors that he had instructed them to transfer the property to his niece RITA ANTONIADES) and the ANTONIADES couple through use of the DEEDS they secured on settlement of the loan my late husband had secured on the property in order for the couple to buy another property in East London, at 739 High Road Leytonstone E11 when MARIA sold her share in ‘the property’ which matters my son ANDREW YIANNIDES deposed of and stated in a Section 9 statement he prepared after my solicitors disclosed the transfer of the property to my granddaughter RITA ANTONIADES as my solicitors were instructed by my son SAVVAS KYRIACOU JOANNIDES, subsequently disclosed to be used and relied upon by the co-operating dishonest solicitors in order to ‘create lien conditions’ resting on the file of papers the solicitor and his firm created in co-operation with the dishonest and deceitful. Mr KYPROS NICHOLAS and the Firm Nicholas & Co. having failed to inform and or notify me that they had acted upon instructions from my son Savvas Kyriacou Joannides, my solicitors (without any reference and or authorisation from me) knowingly and or consciously were involved in the deceptions and the fraudulent conversions that are matters for the police which matters necessitated the Section 9 Statement that my son Andrew was asked to deliver to the police, matters which I now reiterate ought to be investigated properly and thoroughly by the police because the issues are but criminal offences falling within the public duties of the police.

10. AND I DIRECT my trustees to ensure that any residue of funds secured from the five offending and dishonest persons (and the firms of solicitors) I named and stipulate above consequential to and being losses and damages imposed on me founded on the loss of rents that I would have benefited from had my son SAVVAS acted honestly, honourably and with due consideration of the provisions of the Will of my late husband, such as my son SAVVAS KYRIACOU JOANNIDES proclaimed and was relying on (while he was deceiving me and acting in contempt of MY RIGHTS through abuses of the trust I placed in him) AFTER RENOVATION OF THE PROPERTY, be used towards and in the set-up and initial running of the Charity my daughter DESPINA SOTIRIOU ENGLEZAKIS is establishing in the name and in memory of my granddaughter RITA ENGLEZAKIS (the Rita Englezakis Deserving Students Accommodation, REDSA) who took her own life consequential to the neglect and indifference to her needs by her father SOTIRIS NEOPHYTOU ENGLEZAKIS who was otherwise preoccupied throughout her life than to consider and or deal with her needs as a daughter born of my caring and loving daughter DESPINA whose character and gifts the departed inherited and like her mother was admired and loved by all who knew and had contact with her in her brief life.

IN WITNESS whereof I have hereunto set my hand this the ........ day of ...................One Thousand Nine hundred and ninety-eight

SIGNED by the above named )

HARITA KYRIACOU IOANNIDOU )

as her last Will )

in the presence at her request and in )

the presence of each other have )

hereunto subscribed our names )

as witnesses )

NAME.................................................... Signature..........................................

ADDRESS..............................................

...............................................

OCCUPATION .......................................

NAME .................................................... Signature .........................................

ADDRESS .............................................

..............................................