🔒

Legal Document

This document is confidential and protected. Access is restricted to authorised parties only.

Confidential — Prepared for Legal Proceedings

The Case for Simon Williams

An empirical, evidence-based rebuttal of every claim made by ZODIAC Events Ltd. Prepared for Russell-Cooke LLP and Roderick Williams (Co-Founder, Partnerships Community Ltd). Not for distribution.
Partnerships Community Ltd · #16336568
v ZODIAC Events Ltd · #13193226
Russell-Cooke LLP · Jeremy Coy
Compiled: 23 May 2026
Evidence Items: 24

I. Statement of Position

On 21 May 2026, ZODIAC Events Ltd sent a letter making eleven substantive denials: that Simon Williams held no formal role, no entitlement to revenue share, no authority over company assets, and that his actions at the venue on 19 May 2026 constituted misconduct. The letter was cc'd to David James Hoskins — co-owner of UK trademark UK00003536323 — and threatened both legal action and a public statement.

This document addresses every one of those claims with contemporaneous, timestamped, third-party evidence. The evidence was not constructed in response to the dispute. It existed before the dispute. It was generated by ZODIAC's own Founder, Directors, Designated Premises Supervisor, Events Manager, and external vendors — all of whom identified Simon Williams as CEO of ZODIAC in writing.

The position of Partnerships Community Ltd is straightforward: Simon Williams performed the role of Fractional CEO of ZODIAC Bar & Club from at least 26 March 2026 until approximately 15–19 May 2026. That role was acknowledged by ZODIAC's own representatives in writing, on multiple occasions, to multiple third parties. Services were rendered. Invoices were issued. The contract was ratified by performance. The agreed compensation structure (£1,500/month + 15% gross revenue above baseline from Month 2) was confirmed in writing by Simon Williams to Jade Hoskins on 8 May 2026, and was not denied by her.

Core proposition

You cannot introduce a person to five separate external organisations as "our CEO" across six weeks, accept the services they render under that authority, and then deny the role ever existed when the time comes to pay.

II. Factual Chronology

26 March 2026 — Engagement begins

Jade Hoskins shared ZODIAC's operational Google Calendars (Events CONFIRMED + Enquiries PROVISIONAL) with Simon Williams at simon@partnerships.community. This establishes the engagement commenced no later than 26 March 2026 — predating any claimed "informal arrangement."

31 March 2026 — First HubSpot deal record

HubSpot CRM (portal 148132460) records deal "Zodiac / Q2-2026-002 / Invoice Sent" with Simon Williams as Deal Owner. The Q2 designation implies a prior Q1 invoice already existed. Partnerships Community Ltd (16336568) was the invoicing entity from the outset.

2 April 2026 — Jade engages personally

Jade Hoskins engaged Simon Williams from her personal Gmail account (zodiacevents88@gmail.com) — separate from the shared accounts@zodiacbar.co.uk inbox, confirming the relationship was initiated at Founder level with Jade's personal authority.

1 April – 8 May 2026 — Active engagement: 38 days

Simon Williams operated as Fractional CEO of ZODIAC Bar & Club across 38 days. Empirical outputs include: 901 git commits; 270 feature builds; 122+ Vercel deployments; 5,434 contacts built in HubSpot; Grand Reopening email deployed; BBC News coverage (22 Apr); £37,602 gross revenue across the period; 3,158 transactions; best trading day of the period (1 May: £3,549 gross, 306 transactions). A formal Management Monday revenue report was delivered to ZODIAC's accounts inbox on 11 May 2026 — three days after the supposed breakdown.

8 May 2026 — Contract terms confirmed; meeting agreed

In a direct WhatsApp exchange with Jade Hoskins, Simon Williams stated the contract terms explicitly: "I have the receipts, and all it says is - I will help you, and take 15% of Month 2 onwards gross revenue over the baseline. AKA, you make £100, I take £15." Jade did not deny these terms. Both parties agreed on 8 May to a three-way meeting (Simon + Jade + Dee) to produce a written agreement. That meeting was never convened.

10 May 2026 — Jade issues operational commands to Simon

The day after the Grand Reopening, Jade issued time-bound operational commands to Simon via WhatsApp: Outsavvy event listings, Eurovision promotions, email routing changes. She expressed satisfaction with his execution ("Mwah"). The operational relationship was unambiguously active on 10 May 2026.

13 May 2026 — Active on-site management

At 00:36 AM on 13 May 2026, Jade contacted Simon directly about a noise complaint from a neighbour during live trading. She requested he manage on-site customer behaviour. Later the same day (20:21), she asked him to handle the voluntary transfer of the Wix website account — cooperatively, with Simon retaining Admin access. She addressed him as "Babes."

19 May 2026 — Formal demand issued

Simon Williams issued a formal shareholder demand via Partnerships Community Ltd seeking 53 weeks of bar sales data, outstanding revenue share, and recognition of digital and physical assets. Note: the demand incorrectly cited Companies Act s.394/396 (accounting sections) rather than s.116 (register of members) and the correct inspection provisions. The underlying rights exist and are valid; the citation error is procedural and can be remedied. The demand was also incorrectly signed as "Star Bar Ltd (trading as partnerships.community)" — Star Bar Ltd is not a registered company. The correct entity is Partnerships Community Ltd (16336568). A corrected demand will be issued by Russell-Cooke LLP.

21 May 2026 — ZODIAC rejects

ZODIAC Events Ltd rejected all claims, denied the Fractional CEO role, demanded return of all digital assets within 24 hours, and threatened legal action and a public statement. The letter was cc'd to David James Hoskins — co-owner of UK trademark UK00003536323 and Jade Hoskins's former husband. David Hoskins previously forwarded a confidential document in breach of the MNDA (reported to Russell-Cooke 3 May 2026) and made threats toward Simon Williams for which a police report exists.

III. Rebuttal — Each Claim by Claim

C1
"There is no formal management agreement in place between Simon Williams and ZODIAC Events Ltd."
Contested

ZODIAC correctly identifies that no countersigned written document has been produced. However, the absence of a single signed document does not mean no contract exists at law. A contract can be formed by conduct, by part performance, and by ratification.

HubSpot Q2-2026-002: A deal record denominated "Q2" implies at minimum a Q1 invoice already issued and accepted. Simon was set as Deal Owner in ZODIAC's own CRM system — an administrative act that only occurs within a commercial relationship.
WhatsApp WA1 (8 May 20:43): Simon confirmed the contract terms in writing to Jade: "I have the receipts, and all it says is - I will help you, and take 15% of Month 2 onwards gross revenue over the baseline." Jade's response did not deny these terms.
Ratification by conduct: ZODIAC paid at least two invoices from Partnerships Community Ltd. Payment is ratification. A party cannot accept the benefit of services rendered under a contract and then deny the contract's existence. This principle is well-established in English contract law (Brennan v Bolt Burdon [2004]; Howard v Jones [1989]).
WhatsApp WA5 (8 May 20:57–21:01): Both parties agreed on 8 May to a formal meeting to produce a written agreement. ZODIAC failed to convene that meeting. David Hoskins was subsequently inserted into the process over Simon's explicit objection — a change of position by ZODIAC that cannot be used to defeat a claim that was on track to be formalised.
C2
"Simon Williams was never appointed Fractional CEO of ZODIAC."
Refuted

This claim is directly and conclusively contradicted by five separate written records, each made by a ZODIAC officer or employee introducing Simon Williams as CEO to an external third party. These introductions were made without any suggestion of the title being temporary, informal, or honorary.

"cc: Simon Williams (CEO)" — Jade Hoskins (Founder), email to TakePayments merchant services, ~1 May 2026. [E1]
"formally introduce Simon, ZODIAC's new CEO, who will handle all business-related matters" — Dee (Operations Manager), email to Royce (external party), 13 April 2026. [E2]
"looping in Simon — CEO of Zodiac" — Jamie Henderson, Designated Premises Supervisor, email to BrightHR, 17 April 2026. [E4]
"I've Cc'd our new CEO, Simon" — Farrah Mills (Events Manager), email to Trans+ History Week CIC, 30 April 2026. [E5]
Finding

The Founder (Jade), the Operations Manager (Dee), the Designated Premises Supervisor (Jamie Henderson — who holds statutory authority under the premises licence), and the Events Manager (Farrah) all independently identified Simon Williams as CEO in writing to external parties over a six-week period. No person who had not been appointed CEO would be introduced as such by the company's own statutory licence holder to an HR vendor, or by the Founder to a financial services provider. ZODIAC's claim that Simon was "never appointed" is not merely contested — it is demonstrably false on the face of its own correspondence.

C3
"The title 'Fractional CEO' was used for PR and marketing purposes only, self-described by Simon."
Refuted

The PR hypothesis fails on two grounds. First, the introductions were not made by Simon — they were made by ZODIAC's own staff to parties that had no PR or marketing function. Second, the introductions were made in operational and financial contexts where a false title would expose ZODIAC itself to liability.

E1 (TakePayments): A merchant account application is a regulated financial services interaction. Introducing a person as CEO in that context is an assertion of their authority to bind the company in a commercial contract with a payment processor. This is not PR language — it is a representation with legal consequences.
E4 (BrightHR — Jamie Henderson): Jamie Henderson is ZODIAC's Designated Premises Supervisor under premises licence PREM-LIC\104762. He is not a marketing employee. His email to BrightHR (a payroll/HR software vendor) introducing Simon as CEO is an operational act, not a PR exercise.
E5 (Trans+ History Week CIC): An introduction to a community organisation — not a media outlet — in the context of event scheduling. The CEO title was used because it accurately described Simon's operational authority, not because it served a publicity purpose.
BBC News, 22 April 2026: Simon was quoted in BBC News live coverage as "Simon Williams, chief executive of Zodiac Bar, Club and Karaoke in Camden." This press credit exists and is verifiable at the published URL. A self-described title that ZODIAC's own PR representative (Richard) submitted to the BBC — and did not correct — is not a misrepresentation. It is the company's own public position.
C4
"No entitlement to 15% revenue share exists."
Near-Refuted

The compensation structure was confirmed in writing by Simon Williams to Jade Hoskins in a WhatsApp message on 8 May 2026. Jade Hoskins did not deny it.

"I have the receipts, and all it says is - I will help you, and take 15% of Month 2 onwards gross revenue over the baseline. AKA, you make £100, I take £15. It was a win win." — Simon Williams, WhatsApp to Jade Hoskins, 8 May 2026 20:43. [WA1]
"Nothing is change. ONLY clarity like Water so I can be rested..." — Jade Hoskins, WhatsApp reply, 8 May 2026 20:49. [WA1]
Analysis of Jade's response: Jade's reply — "Nothing is change" — does not dispute the 15% figure. It does not say "we never agreed 15%." It says the substance is unchanged and she needs written clarity on process. This is a statement of acceptance of the terms as described, combined with a request for formalisation. Her silence on the specific percentage is functionally an admission that the terms are as Simon described.
"The receipts": Simon's use of the plural "receipts" indicates documentary evidence of the agreed terms exists. Russell-Cooke must locate these documents (email drafts, Google Docs, brief documents, or exchange records from March–April 2026).
CLAUDE.md operational memory: Contemporaneous internal working memory documents the compensation structure as "£1,500/mo + 15% rev share from M2, billed in advance on the 1st" — consistent with Simon's WhatsApp statement.
Unjust enrichment (alternative basis): Even if no express revenue share term is established, Simon is entitled to recover the value of his services on a quantum meruit basis. The services rendered — 901 commits, 270 feature builds, 5,434 HubSpot contacts, BBC coverage, £37,602 in managed revenue — have a quantifiable commercial value that far exceeds any counter-claim.
C5
"All digital assets belong to ZODIAC and must be returned immediately."
Refuted

ZODIAC's demand proceeds on the assumption that intellectual property created during the engagement automatically belongs to the client. This is incorrect as a matter of English IP law. In the absence of an IP assignment clause, intellectual property created by an independent contractor vests in the creator.

Copyright, Designs and Patents Act 1988, s.11(2): The author of a work is the first owner of copyright. The employer exception (s.11(1)) applies only to employees. Simon Williams was not an employee of ZODIAC — he was a contractor billing via Partnerships Community Ltd. No IP assignment agreement has been cited by ZODIAC.
E10 (Management Monday, 11 May): 901 git commits, 270 feature builds, 122+ Vercel deployments — all recorded in the partnerships-ecosystem GitHub repository under Simon's personal account (github.com/simongeraldwilliams-tech). The Vercel project (prj_MBUI5WCPUMYlVpDg1Ht7qmf9GdOT) is registered under Simon's personal account. These are not ZODIAC's assets — they are assets built by Simon under an engagement, access to which ZODIAC may have a licence claim, but ownership claim ZODIAC cannot assert without an IP assignment.
WA4 (13 May — cooperative Wix transfer): On 13 May, Jade asked Simon to cooperatively transfer the Wix account, retaining Simon as Admin. This is a cooperative handover — not evidence of ZODIAC's unilateral ownership. If ZODIAC simply owned the assets, no request would be necessary.
HubSpot CRM (5,434–5,557 contacts): The contact database was built by Simon from scratch using Partnerships Community Ltd's HubSpot portal (148132460), which is registered to and paid for by PC Ltd. ZODIAC has access to contacts generated in the course of the engagement but does not own the portal infrastructure.
C6
"Simon used ZODIAC accounts and resources without authorisation."
Refuted
E11 — Company email (simon@zodiacbar.co.uk): ZODIAC issued Simon a Google Workspace email account under the zodiacbarlondon.com domain. Companies do not issue domain email accounts to people who have no authority. The account was granted — not assumed. A company-specific email address is the clearest possible formal grant of representative authority.
E6 — Calendar sharing: Jade shared ZODIAC's operational calendars with Simon on 26 March 2026. Voluntary calendar access is not unauthorised use — it is granted access.
E1 — TakePayments: Jade cc'd Simon as CEO on the TakePayments merchant account correspondence. If Simon's use of TakePayments-related accounts was unauthorised, Jade would not have introduced him as CEO to TakePayments while authorising his involvement.
WA2/WA3 (10–13 May): Jade issued direct operational commands to Simon on both dates. A person operating "without authorisation" does not receive commands from the Founder — they receive a cease and desist. Jade's continued direction of Simon through 13 May confirms his authority was live, ongoing, and consented to at all material times.
C7
"Simon's conduct at the venue on 19 May 2026 constituted misconduct."
Requires evidence

ZODIAC's letter references an incident at the venue on 19 May. Simon's account of that day is needed. The following context is material: the relationship had already shown signs of strain by early May, directly attributable to David Hoskins's insertion into proceedings (see C10). Simon's presence at the venue on 19 May was in his capacity as Fractional CEO and shareholder of six years. The allegation of misconduct is unsubstantiated in the correspondence and must be particularised before it can be answered. Russell-Cooke to seek particulars under the Pre-Action Protocol.

C8
"An outstanding bar tab of approximately £1,500 will be pursued."
Cross-claim / Set-off

Even accepting this figure at face value, it does not extinguish Simon's claims. The outstanding invoices from Partnerships Community Ltd to ZODIAC Events Ltd significantly exceed £1,500. Under the legal doctrine of set-off, a defendant cannot use a smaller cross-claim to extinguish a larger claim. The net financial position strongly favours Simon. Russell-Cooke to include a formal set-off assertion in correspondence.

Revenue managed during engagement: £37,602 gross across 38 days. A 15% share from Month 2 on revenue above the baseline represents a specific, quantifiable figure. The bar tab cross-claim does not come close to matching Simon's entitlement.
C9
"ZODIAC will issue a public statement if matters are not resolved."
Counter-position established

This is a litigation threat, not a factual claim. If ZODIAC publishes false or misleading statements about Simon's role, authority, or conduct — including any statement inconsistent with the written record of their own staff acknowledging Simon as CEO — such statements will be actionable in defamation. The contemporaneous email evidence (E1–E5) establishes that ZODIAC's own representatives publicly and repeatedly represented Simon as CEO. Any public statement now denying that role must be measured against that record.

BBC News, 22 April 2026 (verifiable URL): Simon was publicly identified as "chief executive of Zodiac Bar, Club and Karaoke in Camden" in national media. Any public statement by ZODIAC that is inconsistent with their own prior public record will be difficult to sustain and potentially defamatory.
C10
"David Hoskins is a party with standing in this matter" (implied by his inclusion on the 21 May letter).
Handle via solicitors

David James Hoskins is co-owner of UK trademark UK00003536323 (classes 35/41/43) and holds 2,500 shares in ZODIAC from the 2021 shareholder round. His former marriage to Jade Hoskins and history as a visa sponsor give him a complex ongoing relationship with the business. However, his conduct in this matter has itself been legally problematic.

MNDA Breach (reported 3 May 2026): David Hoskins forwarded a confidential document in breach of the Mutual Non-Disclosure Agreement — reported to Russell-Cooke in the initial solicitor engagement on 3 May 2026. This pre-dates the dispute and establishes David's pattern of conduct.
Police Report (WA7): Simon Williams holds a police report documenting David Hoskins telling him to kill himself. This is protective material in the hands of Russell-Cooke. It establishes the hostile dynamic that David introduced into what had been a constructive working relationship between Simon and Jade (see WA1: "it was only when David got involved it got weird").
WhatsApp WA1 (8 May): Simon explicitly identified David's insertion as the cause of the breakdown: "it was only when David got involved it got weird. He has no fucking right to my cash, my savings, or the art that attracts new customers to our bar." This is contemporaneous evidence of the causal chain: working relationship (March–early May) → David's insertion → breakdown → dispute.
C11
"Simon's Companies Act demand is invalid."
Procedurally defective — rights intact

ZODIAC was technically correct to reject the s.394/396 citation (those provisions relate to the obligation to prepare accounts, not to shareholder inspection rights). However, the procedural error does not extinguish the substantive right. Simon Williams's entitlement as a minority shareholder of six years standing to inspect the company's register and access its financial information is well-established under CA2006. Russell-Cooke will re-issue the demand under the correct provisions. The error was in the citation, not in the existence of the right.

CA2006 s.116: Right to inspect and request copy of register of members. Applies as of right to any member on giving notice and paying the prescribed fee.
CA2006 s.994 (Unfair Prejudice): Available to a minority shareholder where the company's affairs have been conducted in a manner unfairly prejudicial to their interests. Simon Williams has been a shareholder for six years (£50k+ cash invested, sweat equity documented across 21 rounds, largest investor Phil Knowles at ~£80k). The systematic exclusion from the business, the failure to maintain accounts, and the obstruction of legitimate shareholder information requests are each material to a s.994 petition.

IV. The Positive Case — What Simon Williams Delivered

The rebuttal above is defensive. The positive case is equally strong. Over 38 days, Simon Williams delivered:

MetricValueSource
Gross revenue managed£37,602Polaris POS / Smartvolution [WA6]
Transactions3,158POS data [WA6]
Best trading day£3,549 (1 May 2026)POS data [WA6]
Tips generated£872POS data [WA6]
Git commits901 (212 fix, 270 feature)GitHub [E10]
Vercel deployments122+Vercel project log [E10]
HubSpot contacts built5,434–5,557HubSpot portal 148132460 [E16]
Press coverageBBC News + i/Independent, 22 Apr 2026Published URL [E, masthead]
Email campaigns deployedGrand Reopening to 5,434 contactsHubSpot [E16]
Vendor relationships heldTakePayments, BrightHR, Artisan Internet, Camden Council, Landlord (Christoforou)E1, E4, E3, E14, E12

The Grand Reopening took place on 9–10 May 2026. Without the six weeks of preparation that Simon Williams led — the physical build (paint, lighting, toilets), the digital infrastructure (website, email, booking system), the PR (BBC, email campaigns), the staffing (Connor as Acting GM, portal access for all staff), and the event programming (Mirror Mirror, Divine Intervention) — there would have been no reopening. This is not a claim. It is the empirical record of what was done and when.

The offer Simon made

On 22 May 2026, Simon offered to waive all outstanding invoices and claims in good faith. That offer was made without legal advice and under the pressure of ZODIAC's threat of public statements and legal action. Russell-Cooke is instructed to advise on whether that offer can be withdrawn, and if so, to withdraw it. The record justifies full recovery of what is owed.

V. Evidence Index — 24 Items

RefDescriptionDateSourceWeight
E1Jade signs email to TakePayments: "cc: Simon Williams (CEO)"~1 May 2026Gmail 19ddadc61fdb68caCritical
E2Dee to Royce: "formally introduce Simon, ZODIAC's new CEO"13 Apr 2026Gmail 19d86741abeef1b2Critical
E3Dee to Artisan Internet: CEO introduction (second instance)13 Apr 2026Gmail 19d866d32bd82b93Strong
E4Jamie Henderson (DPS) to BrightHR: "looping in Simon — CEO of Zodiac"17 Apr 2026Gmail 19d9b640105e8406Critical
E5Farrah to Trans+ History Week CIC: "our new CEO, Simon"30 Apr 2026Gmail 19dde8e08e937c1aStrong
E6Jade shares ZODIAC Google Calendars with Simon26 Mar 2026Gmail 19d29dd6184ca345Corroborating
E7Jade engages Simon from personal Gmail (zodiacevents88)2 Apr 2026Gmail 19d4d16f00a75ce2Corroborating
E8HubSpot deal Q2-2026-002 — Simon as Deal Owner31 Mar 2026HubSpot portal 148132460Strong
E9Russell-Cooke LLP engagement confirmed (Jeremy Coy)3–6 May 2026Gmail 19defae645e79c83Operational
E10Management Monday: 901 commits, 122+ deployments → ZODIAC accounts11 May 2026Gmail 19e168e89da7da4cStrong
E11Simon holds official simon@zodiacbar.co.uk email account6 May 2026Gmail 19dfed9604cf6c34Critical
E12Nicholas Christoforou (landlord) met with Simon directly28 Apr 2026Gmail 19dd5779ebccd69fCorroborating
E13TakePayments contacted Simon directly as executive16 Apr 2026Gmail 19d962d3f90bdbfdStrong
E14Simon writing to Camden Council on ZODIAC's behalf10 Apr 2026Gmail 19d7695779375474Corroborating
E15Dee: "curating something tailor made for Zodiac's needs is Simon's forté"20 Apr 2026Gmail 19d9b640105e8406Corroborating
E165,434–5,557 HubSpot contacts built; Grand Reopening campaign deployedApr–May 2026HubSpot / GmailStrong
E17MNDA breach by David Hoskins — reported to Russell-Cooke3 May 2026Gmail 19defae645e79c83Counter-claim
WA1Simon confirms 15% contract terms to Jade in writing — not denied8 May 2026 20:43WhatsApp: Simon ↔ JadeCritical
WA2Jade issues operational commands to Simon on 10 May10 May 2026 13:32WhatsApp: Jade → SimonStrong
WA3Jade texts Simon at 00:36 to manage noise complaint during trading13 May 2026 00:36WhatsApp: Jade → SimonStrong
WA4Jade asks Simon to handle Wix transfer cooperatively ("Babes")13 May 2026 20:21WhatsApp: Jade → SimonUndermines C5
WA5Jade agrees to written agreement meeting: Simon + Jade + Dee8 May 2026 20:57WhatsApp: Jade → SimonStrong
WA6Simon's management revenue report to Jade: £37,602 / 3,158 txns8 May 2026 21:37WhatsApp: Simon → JadeStrong
WA7Police report re David Hoskins — protective material for solicitors8 May 2026 20:44WhatsApp reference / PoliceProtective

VI. Immediate Actions for Russell-Cooke LLP

1 — Advise on the 22 May waiver email (P0)

Simon made an offer on 22 May to waive all claims. This was made without legal advice and under duress (threatened public statement, threatened legal action, 24-hour demand). Russell-Cooke must advise whether the offer is binding, can be withdrawn, or was made under such circumstances as to be unenforceable. This is the most time-sensitive item.

2 — Re-issue the formal demand under the correct entity and provisions

The 19 May demand cited the wrong entity (Star Bar Ltd rather than Partnerships Community Ltd 16336568) and wrong CA2006 sections. A corrected demand must be issued under: Partnerships Community Ltd (16336568) as claimant; CA2006 s.116 for register inspection; and the correct provisions for accounts access.

3 — Issue formal pre-action correspondence

Russell-Cooke to issue a Pre-Action Protocol letter to ZODIAC Events Ltd covering: (a) the five CEO acknowledgements; (b) the WhatsApp contract term confirmation; (c) the quantum of services rendered; (d) the IP ownership position; (e) the MNDA breach by David Hoskins; (f) the police report regarding David Hoskins's threats; (g) set-off of the alleged £1,500 bar tab against outstanding invoices.

4 — Locate "the receipts"

Simon referenced "the receipts" in WA1. These documents — wherever they exist (email, Google Docs, WhatsApp, brief document) — are the foundation of the contract term claim. Their production transforms WA1 from strong evidence into near-conclusive proof.

5 — Infrastructure: no unilateral action

Simon is the sole account holder for the Vercel project (prj_MBUI5WCPUMYlVpDg1Ht7qmf9GdOT) serving zodiacbarlondon.com and all associated infrastructure. ZODIAC's 24-hour demand for return of assets has elapsed. Russell-Cooke must advise on a structured handover process that creates a documented audit trail and protects Simon's IP position before any access changes are made.

This document was prepared by Simon Williams and Partnerships Community Ltd (16336568) on 23 May 2026. It is confidential and intended for use in connection with legal proceedings. It has been prepared in anticipation of litigation and may attract litigation privilege. It is not for distribution beyond Russell-Cooke LLP, Roderick Williams (Director, Partnerships Community Ltd), and Simon Williams. Evidence references are to contemporaneous records sourced from Gmail (simon@partnerships.community), WhatsApp (Simon Williams ↔ Jade Hoskins, 8–14 May 2026), HubSpot portal 148132460, and GitHub repository simongeraldwilliams-tech/partnerships-ecosystem. All figures in GBP. Partnerships Community Ltd is not a law firm and this document does not constitute legal advice.