“is accused of abusing, exploiting and fleecing vulnerable victims.”

Please provide specific evidence and provable details for:

1. 1. Exactly what supposed abuses have taken place.
   2. Who conducted the abuse and against whom and when?
   3. What the effect of the alleged abuse was?
   4. How have people been supposedly exploited?
   5. To what end people have been exploited?
   6. In what ways has anyone been supposedly ‘fleeced’, how this happened and what they were fleeced for?

“Former members said Lighthouse International Group ‘groomed’ them with promises they would find personal fulfilment and a dream career through its up to £100-an-hour mentoring programmes.”

Please provide specific evidence and provable details for:

1. 1. How you justify the use of the term ‘groomed’. 
   2. How exactly these former members were supposedly ‘groomed’.
   3. What purpose they were supposedly groomed for.
   4. The alleged promises described here, who made them and when and to whom. 
   5. Justification of the use of the term ‘promise’ with examples that clearly establish a promise was made. 

“But they say they ended up in thrall to its leader Paul Waugh, who lives in a £2 million country estate, drives a Range Rover with plates bearing the initials of his group and boasts of ‘numerous’ celebrity friends and of being ‘very connected’ in government.”

Please provide specific evidence and provable details for:

1. 1. Who those were that are ‘in thrall’ to Paul Waugh and how, if this is the case, this is anyone’s responsibility but their own
   2. How the details of Mr Waugh’s living standards and possessions are linked to the accusations made by these sources

“New recruits, who are often vulnerable because of divorce, depression or previous abuse, are assigned a mentor who becomes like a ‘brother’ to them and to whom it is claimed they are encouraged to share their ‘inner most secrets’ in sessions which are recorded and stored by the group’s leaders.”

Please provide specific evidence and provable details for:

1. 1. What basis you state and can substantiate that ‘new recruits’ are ‘often vulnerable’ 
   2. Any legitimate and verifiable physical, mental, emotional or spiritual damage that has been done to anyone during their time with Lighthouse that was not previously existing or caused by people outside Lighthouse
   3. Anyone working and being mentored by someone at Lighthouse who was not freely chosen by them, the client
   4. That any ‘inner most secrets’ were shared with Lighthouse or obtained without that person’s open and wilful decision to do so 
   5. Examples of any person’s ‘inner most secrets’ at Lighthouse being extracted from them by force, intimidation or any other unethical or immoral means
   6. Recordings that have been made and ‘stored’ without the full awareness, permission and agreement of those involved
   7. That ‘leaders’ of Lighthouse International Group store recordings of ‘new recruits’ sharing ‘inner most secrets’  
   8. Anyone who has been denied a copy or access to any relevant recordings of them on an illegitimate basis

“But these turn into ‘abusive relationships’ with members later ‘pressured’ into ‘investing’ tens of thousands of pounds, often by taking a loan which plunges them deep into debt, without any formal written financial agreement or receipt, it is alleged.”

Please provide specific evidence and provable details for:

1. 1. Which relationships have supposedly became abusive, how exactly they were supposedly abusive and how that can be proven / substantiated as the responsibility of anyone at Lighthouse
   2. Which individuals were supposedly ‘pressured’ and exactly how they were supposedly ‘pressured’ into investing anything they were not fully aware of, in mutual agreement to and did not freely want to invest themselves
   3. Situations where an individual did not wilfully and freely choose and decide to take out loans

“Some members asking for their money to be returned were reminded their innermost secrets had been recorded in coaching sessions — which made them feel as if they were being threatened.”

Please provide specific evidence and provable details for:

1. 1. Where Lighthouse have used the phrase or term ‘innermost secrets’ 
   2. How ‘members’ being reminded that factual evidence exists of their actual comments and statements should they try to lie or twist the truth about any of their experiences can be deemed threatening or unethical
   3. Lighthouse intending to or actually threatening anyone asking for their money to be returned that can be reasonably shown to be a threat or threatening in its nature. 

“In one case, a mother says she remortgaged her family home to help raise over £200,000 for her two sons to invest in the group, which they were promised would be repaid. She says she has not received a penny back.”

Please provide specific evidence and provable details for:

1. 1. This mother raising the money against her “family home” rather than a property she rents out (we have evidence that this money was raised against two ‘rental’ properties she inherited.
   2. The mother NOT receiving any payments from her sons (we have evidence and bank statements that she did until the sons were unable to pay due to circumstances beyond their control.
   3. This mother having any objection or reservations to what her sons chose to do with their money at the time she agreed to it.

“Ex-members said they were told to isolate themselves from friends and family who criticised Lighthouse, with the group’s leaders even urging husbands to sue wives and children to sue their parents.”

Please provide specific evidence and provable details for:

1. 1. Lighthouse having any form of membership status 
   2. Any “Ex-members” being specifically “told” to ‘isolate’ from friends and family by someone at Lighthouse.
   3. Any “Ex-members” being ADVISED by someone at Lighthouse to ‘isolate’ from friends and family that wasn’t deemed to be in their best interests at the time and for provable, legitimate reasons. 
   4. Any isolation from friends and family by someone at Lighthouse which was not done out of their own free will and choice.
   5. Anyone from Lighthouse who has ‘isolated’ themselves from friends and family without a legitimate and provable reason to do so, in line with protecting themselves from their abusers. 

“An environmental consultant* who questioned the value of the mentoring with other members said she was left ‘terrified’ and in tears after Mr Waugh bombarded her with abuse during a two-hour phone call.”

-This environmental consultant is referenced throughout the article and for legal reasons is referred to as ‘Mrs X’ by Lighthouse.

Please provide specific evidence and provable details for:

1. 1. The recording attached to the Daily Mail Online publication of this 2 hour phone call NOT being tampered with and significantly edited out of context
   2. The context and details given by the Daily Mail to this 2 hour conversation, as presented in the attached short video excerpt of the recording, being factually and provably accurate
   3. This consultant’s legitimate and innocent questions, conversations and interactions with the supposed other ‘members’
   4. Other ‘members’ this consultant ‘questioned’ the mentoring with who will verify the legitimacy and innocent nature of her claims 

N.B. We would ask in addition to these points what reason the full 2 hour audio and transcript of this call cannot be publicly released as evidence of such ‘bombardment’ of abuse by this person’s permission and we ask her for such permission as proof of her claims. 

“When she later politely emailed requesting a refund on her £25,000 investment, Mr Waugh refused and reminded her that the group had recordings of her describing the ‘long-term sexual abuse’ she suffered as a child — which she felt was a threat.”

Please provide specific evidence and provable details for:

1. 1. Her valid and legal entitlement to a refund
   2. Mr Waugh’s alleged statements referred to here and the context to these being anything other than holding her and himself accountable to truth and reality and to prevent lies, falsehoods and misconstrued statements being made by either him or her in relation to this. 

“Her mentor told her that for several years when he was being ‘negative’ with other Lighthouse members and clients, Mr Waugh ‘helped’ him by arranging a senior group member to chaperon him whenever he wasn’t alone and to check his text messages because: ‘Paulie couldn’t trust me, I couldn’t trust myself.’”

This is partially correct but lacks context and is worded in order to mislead opinion

1. 1. While it is written to sound strange and manipulative, her mentor was in actual fact given close guidance and support (with his full consent) in order to help him better identify and reform his destructive character and behaviours that were a threat first and foremost to himself, as well as others. 
   2. Her mentor is one of the most distinctive and remarkable transformational success stories in our work here at Lighthouse, which he himself can attest to. In conventional workplace environments this person may well have been fired rather than given additional support to work through their personal challenges.

Please provide specific evidence and provable details for:

1. 1. This or any other incidence showing manipulative or coercive control 
   2. How this individual in question has been damaged or harmed as opposed to becoming significantly healthier and emotionally and mentally stronger because of this care and support 

“Ex-members said Lighthouse implied part of their cash was going into African water purifying programmes — but it never produced firm evidence of this and the published company accounts give no indication of where the cash has gone.”

Please provide specific evidence and provable details for:

1. 1. Ex members ever being given any palpable reason to believe this was a current event 
   2. Where Lighthouse has stated anything specifically to this effect
   3. Where and how Lighthouse has broken any laws in relation to financial regulation 

“Primary school teacher Jo Holmes asked for a receipt for her £19,000 ‘investment’ and evidence of what it had been spent on, only to receive a reply from Mr Waugh calling her a ‘psychopath’ and ‘malevolent’ and implying her behaviour made her a danger to the children she taught.”

Please provide specific evidence and provable details for:

1. 1. Ms Holmes asking for her receipt 
   2. Ms Holmes investing her £19,000 in anything other than the Associate Partner Elect Program
   3. Mr Waugh referring to Ms Holmes as a psychopath as opposed to her behaviour being psychopathic in nature

N.B. In line with this we would like to ask why the full recording and transcript of Ms Holmes’ phone call with Mr Cooper and Mr Waugh cannot be published to clear up this matter and for the Daily Mail to gain her permission for us to do so as a matter of public interest

“A computer graduate mentored for anxiety and depression who shared his concerns with other members when he left was deluged by messages from Lighthouse leaders, initially suggesting he was having a ‘paranoid episode’, then warning they would take out a restraining order against him and finally saying they would be giving police ‘various recordings and communications’ he’d had with his mentor.”

The above is all factual, however it is also twisting the truth of the reasons why this happened. 

1. 1. Mr Church was threatening other members who feared for their safety after Mr Church’s emails and came to us. We took defensive action to protect them.  Because Mr Church stopped his threats, after consideration no recordings were shared with the police or lawyers. 

Please provide specific evidence and provable details for:

1. 1. The computer graduate’s (Mr Church) concerns that was shared with other ‘members’ and what they were tangibly based upon
   2. Justification for use of the term ‘deluge’ 
   3. The number of messages sent to Mr Church, by whom and their contents. 
   4. The warnings given to Mr Church not being reasonable and justified by his behaviour. 

“The group says it has ‘mentored’ individuals who have ‘suffered from the most terrible abuse’, but senior Lighthouse counsellors are not part of any professional body, have no academic qualifications in their field and said their only expertise comes from the ‘university of life’.

• It is true that we have mentored people who have ‘suffered from the most terrible abuse’.

1. 1. Where that has been the case and when necessary, we have often referred and supported people to seek professional counselling and therapy services and can categorically prove this. 

Please provide specific evidence and provable details for:

1. 1. Any legal requirement for qualifications in order to provide mentoring services here in the UK
   2. Lighthouse claiming to be professional and fully qualified counsellors 

“’I believe they are a dangerous group’” 

Please provide specific evidence and provable details for:

1. 1. The danger that Lighthouse would pose to Mr Church other than holding him legally accountable for defamation

“A web designer said Lighthouse threatened to sue him and send personal details from his ‘therapy’ to the police after he quit.”

Please provide specific evidence and provable details for:

1. 1. Lighthouse providing or claiming to provide Mr Church with professional therapy
   2. The ‘threats’ to sue Mr Church referred to in this statement and how they constitute a threat and/or threatening intention

“Anthony Church, of Peterborough, started volunteering with Lighthouse in late 2017, a year after completing his master’s degree in applied computing.”

• Factually correct

1. 1. This accurately describes the circumstances of Anthony Church beginning his involvement with Lighthouse 

“He later joined one of its therapy groups and was assigned a mentor to help with anxiety and depression, which he had struggled with since a teenager.”

• It is true that Mr Church joined a group but this was NOT a therapy group 

1. 1. The group Mr Church was actually part of was a mastermind group to share, learn and apply teachings and methodologies from the book ‘The 7 Habits of Highly Effective People’ by Dr. Stephen R. Covey. It is a book studied within many companies and corporations and is not associated with any kind of therapy. 

Please provide specific evidence and provable details for:

1. 1. The group that Anthony Church was part of was a therapy group
   2. Mr Church being ‘assigned’ a mentor rather than him choosing one of his own free will
   3. The support from his mentor not being helpful with his anxiety and depression
   4. Mr Church being charged or paying for ‘therapy’ as opposed to mentoring, coaching and counselling.

“He paid £13,700 in mentoring fees, but said as he began to look into the group, he grew concerned about how it operated. He wrote a polite email explaining he was leaving and raised warnings with some other members.”

This is factually correct:

1. 1. Over the course of 4 years, Anthony Church invested £13,700 and received an average of 3 hours mentoring a week which would have cost substantially more on the open market through counselling and/or life coaching  

Please provide specific evidence and provable details for:

1. 1. Mr Church’s warnings to other ‘members’ and what he was ‘warning’ them about (we can provide tangible evidence that Mr Church was harassing other members and sharing web links spreading malicious information that led to their legitimate concern for their own private information being abused by him) 
   2. What Mr Church based his ‘concerns’ upon and his reason and rationale for wanting to ‘warn’ his group.

“His actions triggered a series of increasingly desperate and then aggressive responses from Lighthouse, threatening to report him to police and take out a restraining order.”

It is true that Lighthouse legitimately warned (not threatened) they would report Mr Church to Police and take out a restraining order

1. 1. We can provide tangible evidence that Mr Church was harassing other members of his mastermind group, sharing web links and spreading malicious information that led to their legitimate concern for their own private information potentially being abused by him
   2. The other members of Mr Church’s mastermind group asked Lighthouse to intercede on their behalf with Mr Church due to the levels of their concerns for his behaviour towards them. Lighthouse was acting in their interests, as well as its own. 

Please provide specific evidence and provable details for:

1. 1. Lighthouse’s apparent ‘desperation’ and how it’s responses were ‘aggressive’ that can be objectively upheld 
   2. Why reporting Mr Church to the police and taking out a restraining order against him would NOT have been justified, given his behaviour. 

“It culminated in a message from one of Lighthouse’s senior directors, saying they would be sharing the correspondence with their solicitors and the police ‘along with various recordings and other communications’ he’d had with his mentor over the years. This, they said, was to ‘ensure that they have an accurate take on your highly questionable character and behaviour’. It added he would be liable for Lighthouse’s legal bills.”

These facts are accurate but lacks the proper context and reasons for this being the case 

1. 1. Mr Church was warned that if his behaviour continued we would share what he has done with the police and lawyers. 
   2. An email does exist with this wording but again the context is left out. No recordings were shared with the police or lawyers but we had to take steps to ensure our clients were protected as they expressed their fears and concerns to us. 

Please provide specific evidence and provable details that:

1. 1. Mr Church’s ‘warnings’ of his mastermind group members were legitimate, reasonable and well founded
   2. Lighthouse had no reasonable grounds and evidence to notify police and consult solicitors bein being in relation to Mr Church’s behaviour
   3. Lighthouse was wrong to act on its duty of care for its other clients who felt threatened by Mr Church’s behaviour in this instance

“Mr Church said: ‘In my opinion, they are dangerous group disguised as a business opportunity, charity or community interest company. They try to hide what Lighthouse is really about, but what it’s about is money and power.’”

Please provide specific evidence and provable details for:

1. 1. What objective evidence and legitimate basis Mr Church can show for holding these opinions?
   2. The investigation the Daily Mail did to question and verify Mr Church’s opinions were reasonable and could be backed up

“Graham Baldwin, of Catalyst, a charity that deals with abusive groups and the victims of psychological manipulation, said: ‘In the past year, 10 per cent of our calls have been about Lighthouse, from families and individuals.”

Please provide specific evidence and provable details for:

1. 1. Mr Baldwin’s and Catalyst’s statistics being objectively verifiable 
   2. Mr Balwin’s process for verifying the validity of his callers and the proof given by his callers to back up their claims 
   3. Mr Baldwin’s reasons and evidence for trusting those who have called his organisation
   4. The investigation the Daily Mail conducted into challenging and verifying Mr Baldwin’s claims

“’In my opinion, they are one of the nastiest and most dangerous groups we have come across in 30 years of working in this field.’”

Please provide specific evidence and provable details for:

1. 1. The number of calls Mr Baldwin has received in relation to Lighthouse over the last 18 years, by whom and for what reasons
   2. The number of reports and public statements of warning Mr Baldwin has made to the proper authorities and press about Lighthouse during our 18 years. (Given this would be his public duty and responsibility) 
   3. Mr Baldwin’s level of direct investigation into Lighthouse and his conversations with Mr Waugh and the organisation itself to validate his claims. 
   4. Mr Baldwin having not based his conclusions on second hand hearsay and conjecture alone. 

“But a 48-year-old consultant who borrowed £10,000 to invest in the group after joining in 2019 said she eventually felt she had to move abroad to escape them.”

Please provide specific evidence and provable details for:

1. 1. Justifying the statement “she eventually felt she had to move abroad to escape them” given there was no contact with this person after her departure from the company, other than to respond to her communications. (Lighthouse International Group can prove this via evidence of communications and that we continually offered her win-win solutions until her departure that she failed to take up.)
   2. Her not expressing a desire to move overseas for many years, prior to leaving lighthouse. (Lighthouse has evidence that we encouraged and supported this person to move overseas when they were ready and before they became hostile.) 

“They encouraged us to use LinkedIn, for us to connect with people, so it is just like multi-level marketing.’”

It is correct that many Lighthouse Associates use the LinkedIn platform 

1. 1. It is an advisable platform for use in ANY company in order to network and meet other professionals for legitimate professional purposes

Please provide specific evidence and provable details for:

1. 1. How using a business networking platform for business networking is in any way untoward
   2. How any Lighthouse Associates have used LinkedIn for immoral or unethical purposes
   3. How Lighthouse uses a multi-level marketing system
   4. Where and how a multi-level marketing structure exists at Lighthouse 

“But when she raised concerns about the mentoring with other members, Mr Waugh turned on her and during a two-hour call branded her ‘nasty’, ‘pernicious’, ‘selfish’, ‘horrible’, ‘vindictive’, ‘broken’, ‘very damaged’, ‘stupid’, ‘dishonest’, ‘duplicitous’, ‘misleading’, ‘f*****g deluded’, ‘seriously f****d up’, ‘sinister’, a ‘cynical little old witch’, a ‘weasel’, a ‘negative, self-defeating, self-sabotaging automaton’, ‘the worst, weirdest, sickest f**k’, having ‘an ego like a feral dog’ and being an ’emotional, mental and spiritual toddler”

Please refer to point No. 10

“He also reminded the woman that every conversation she’d ever had at Lighthouse was taped and ‘every journal you’ve ever written is stored’.”

Please refer to point No. 11 

“The woman said: ‘It is terrifying. We need to stop them.’”

Please provide specific evidence and provable details for:

1. 1. This woman (Mrs X) leaving Lighthouse in acrimony and not under mutually agreeable conditions. 
   2. Mrs X’s main reason for leaving Lighthouse, at the time that she did, being provable as anything other than financial reasons and pressure from her family to do so. (Lighthouse can prove through private communications that these were the main two reasons for her departure)
      

“Lighthouse initially told the Mail that active police investigations were under way against former members, but when asked which forces, it said it had not yet reported them to the police.” 

Please provide specific evidence and provable details for:

1. 1. The lack of police reports made against those involved with the constructive sabotage and smear campaign of Lighthouse International Group before 19th April 2022.

“Boss who loves to boast about wealth”

Please provide specific evidence and provable details for:

1. 1. Paul Waugh’s boasts about wealth

“Paul Waugh’s online profile describes his habits as including ‘impromptu random dances’ and ‘outbreaks of deep laughter’.”

This is factually correct

1. 1. It was taken from Paul Waugh’s profile on the Lighthouse International Group website

“And the leader of the Lighthouse International Group has much to be merry about. He lives in a £2 million, six-bedroom, secluded country home — complete with a sauna — set on the northern edge of the Cotswold Hills and drives a Range Rover.”

Please provide specific evidence and provable details for:

1. 1. Why this information and invasion of privacy is in the public interest and/or relevant to the article, especially given the provable levels of inaccuracy, misinformation and deception in what has been reported. 

“The 57-year-old father-of-two, who moved from South Africa to the UK in 1999, is a regular at his local golf club, where he plays off a ten handicap, and claims to have many famous friends and to have previously mentored a Premier League and England footballer.”

This is factually correct, but also incorrect

1. 1. The information sent to the Daily Mail stated Mr Waugh’s golf handicap as 10, but this was an internal error. Mr Waugh’s handicap is in fact 5
   2. Mr Waugh’s claims about his connections are not an exaggeration 

“Mr Waugh has told Lighthouse members he is very connected in government — both in the Commons and the Lords — and has helped to get laws passed.”

This is factually correct 

1. 1. Mr Waugh explained this in the Waugh Rooms videos responding to the article to the level he was able to reveal; helping to pass laws designed to protect children 

“And he says he is now so personally wealthy that other nations have ‘courted’ him to try to get him to emigrate and take his money into their country.”

This is partially true.   

1. 1. Mr Waugh like any wealthy individual has had offers from countries to emigrate however the context in which this is written is twisted to paint him as boasting about wealth. 

“Current Lighthouse members told the Mail Mr Waugh had generously supported them financially in times of need and they had benefited greatly from his mentoring.”

This is factually correct

1. 1. There are numerous signed testimonials which were sent to the Daily Mail from Lighthouse Associates regarding this, however, none of these were quoted or printed in the article. 
   2. There are also many other families and individuals who could attest to this also who weren’t included in the Daily Mail response to protect their privacy 

“Given his expertise, on the open market, his time would be worth up to £5,000 an hour, he adds.”

This is factually correct

1. 1. Mr Waugh has a long history of this which can be factually proven and backed up substantially. However, Mr Waugh dedicates most of his time now (instead of earning such amounts) helping to mentor and develop a new generation of leaders and entrepreneurs at a level.  

“In YouTube videos, he describes himself as deeply ‘spiritual’ with a ‘very sophisticated and advanced understanding’ of what can be known compared to most people.”

This is factually correct

1. 1. Anyone is welcome to legitimately and respectfully challenge him on this and hold a discussion with him about it.

“This, he believes, sets him apart from the group’s new members, some of whom he says are of ‘exceptionally low emotional intelligence’ and ‘know nothing about how to succeed in life.’”

This is factually correct 

1. 1. This is backed up by primary and secondary research conducted by Paul Waugh and Lighthouse International Group; particularly from psychologists. 
   2. This is based on many many years of tried and tested experience across the board with people from various cultures, backgrounds and beliefs. 
   3. This is agreed and attested to by existing Lighthouse Associates who have written publicly about their experiences and desire / need to learn what they didn’t learn or receive growing up. 

“His life’s work, as he explains it, is to empower and unite them in a ‘genuine state of family and community’ through mentoring and coaching.”

This is factually correct 

1. 1. Mr Waugh has been more dedicated and committed to the learning and development of his Associate Partners and their success than the majority of their own family members and friends. A number of whom have deliberately tried to impede or sabotage their relative’s development and progress. 

“But recordings shown to the Mail show that when people start questioning the value of the group’s methods, Mr Waugh’s happiness vanishes and he turns to abuse.”

Please refer to point No. 10

“Mr Waugh classifies members from level 1-4, depending on how ‘evolved’ they are.” 

Please provide specific evidence and provable details for:

1. 1. Paul Waugh’s belief in evolution to make such a statement
   2. Examples of this that are factual, rather than subjective conjecture 

“But former members said only he and his partner were ever ‘very high level 4’, while others were ‘bullied’ and ‘intimidated’.”

Please provide specific evidence and provable details for:

1. 1. How and when ‘former members’ were supposedly bullied and intimidated.

“Money is a major source of dispute. From four ex-members and the relatives of two members, the Mail has identified at least £300,000 given to Lighthouse, all without a formal written agreement because the group says it operates on ‘trust’.”

Please provide specific evidence and provable details for:

1. 1. The calculation breakdown of the £300,000 that was given to Lighthouse as well as the number of relatives in this calculation  
   2. Ex-members requesting and being denied a formal written agreement 
   3. Any single legitimate legal case for an ex-member being due a refund
   4. Any legitimate legal case for financial malpractice by Lighthouse International 
   5. How this money was “given” to Lighthouse rather than legitimately paid for its products and services 
   6. Please refer to point No. 8 

“They say they were told some of the money was going towards investment in a clean water scheme in Africa, a plan Lighthouse stresses on its website is a central tenet of the group.”

Please provide specific evidence and provable details for:

1. 1. Who this was supposedly told to and what evidence they have to back this up?
   2. This being anything other than an aspirational future goal of the company.

“One post by a Lighthouse member in January says: ‘We are currently launching a global initiative to help look after our children, giving them hope and a glass of water.’”

This is factually correct

1. 1. Lighthouse’s initiatives are focused on finding and bringing together the right human resources necessary to help alleviate the global water crisis. Many aid companies and charities have shown that finances are not the primary issue or solution.

“But Lighthouse told the Mail it has ‘never claimed to be currently providing funds to clean water in Africa’ and the initiative was an ‘aspirational long-term goal’.”

This is factually correct

1. 1. It is an aspirational goal and Joanne Holmes has completely misunderstood our 3-phase approach to addressing the lack of clean water on a global scale which is on the front page of our website.
   2. We help people understand our human potential
   3. We help people build human, material & financial value
   4. We help people be benevolent by giving children hope through clean water

“They said members’ investments funded their ‘growth and development’ through mentoring and training, and that members who chose to leave were not legally entitled to a refund.”

This is factually correct

1. 1. This is in line with the point above that realising our human potential increases our ability to build value and be in a better position to be benevolent.
   2. Mentoring and training are the means to helping someone with this development journey.

“Mr Waugh and other group members are directors of registered businesses Lighthouse International Group Holdings and The Lighthouse Self-Leadership Society, and community interest company Lighthouse Kidz [sic], all of which have shown £0 in every return filed with Companies House since their incorporations in 2012 and 2013. Lighthouse said it had no property or fixed assets and thus is not required to publish any profit and loss accounts.”

In relation to the above, Lighthouse told the Daily Mail in February 2022 the following

1. 1. “In line with financial regulatory obligations, Lighthouse International Group Holdings Tradings is a Limited Liability Partnership. Because of this, we are not obliged to put our financial records up in the public domain, nor do we have a legal requirement to be audited.”
   2. “We do have certain regulatory obligations that have been fulfilled annually and we have specialist advisers in regards to our financial reporting requirements who will advise us if any changes become necessary in the future”

“It added that ‘any income has simply been reinvested in cost-covering research’.”

This is factually correct

1. 1. Lighthouse International has operated on a research and development cost covering only basis

“The group did tell the Mail that some of the cash had been invested into ‘research papers and retainers for PhD students’. But when asked at which universities, it said it did not fund any PhDs.”

This is a misunderstanding due to a lack of care and thoroughness in research

1. 1. On 8th February 2022, Lighthouse informed Tom Kelly that it invested in research papers and retainers for PhDs, not PhD students. 
   2. In reply, Tom Kelly asked which PhD students were funded, but this is an irrelevant question given our previous communication. 

“It said other cash went towards business infrastructure costing £10,000 a year, legal expenses, a house in Rugby, Warks, for nine of its members and supporting vulnerable members.”

This is factually correct

1. 1. Lighthouse International Group has operated on a research and development cost-covering only basis and has often struggled to do so. 
   2. Mr Waugh has greatly supported the organisation and those within it from his own private funds, enabling both it and them to continue its research and discovery work. 

“It said verbal financial agreements with members were ‘sufficient and legally binding’ under UK law.” 

This is correct. 

1. 1. If this is not the case  – that verbal financial agreements are not ‘sufficient and legally binding’ under UK law- we invite the Daily Mail and its sources to show this, as well as where and how Lighthouse is guilty of any financial malpractice

“It added that Mr Waugh was very supportive of ‘healthy families’ and personally devoted to his partner, ****** and their two children. It said: ‘He is a strong man, physically, emotionally, mentally and spiritually.’” 

This is factually correct 

1. 1. There are many numerous families whom Mr Waugh has supported in many ways, either financially or otherwise

“’They threatened to sue my wife. They need to be stopped’. Lighthouse leaders branded an e-commerce accounts manager’s wife ‘destructive’ and wanted to sue her after she supported her husband’s decision to quit the group.”

Please provide specific evidence and provable details for:

1. 1. That Mrs Thomas’s behaviour was not destructive in relation to Mr Thomas’s involvement with Lighthouse
   2. That Mr Thomas’s wife was not, by his own admission, instrumental in harassing him to leave Lighthouse International Group, as he eventually did. (Proof of his admission to this fact is held on record by Mr Cooper)

“Father-of-two Richard Thomas, from Essex, became involved in Lighthouse in 2015 when his then company offered to pay for a mentor. One of his colleagues was already being mentored by one of Lighthouse’s leaders, Shaun Cooper, and so he did the same.”

This is factually correct

1. 1. In fact Mr Thomas was so impressed with Mr Cooper, he stopped working with another mentor he had at the time
   2. By the Time Mr Thomas parted ways with Lighthouse in late 2021, he had been involved for approx 6 years  
   3. Mr Thomas said himself he did ‘not prescribe’ to any anti-Lighthouse agenda or sentiment as late as October 2021

“But things started to go wrong when he invested thousands of pounds in the group.”

Please provide specific evidence and provable details for:

1. 1. How things “went wrong” given Mr Thomas invested his money in 2019 and did not express desire to leave Lighthouse until October 2021 
   2. Any investments made by Richard Thomas in Lighthouse International Group as opposed to his own growth development through mentoring and the Associate Partner Elect Program. 
   3. That show Mr Thomas was against leaving Lighthouse or held any anti-Lighthouse sentiments before October 2021 (We can prove from text communications that Mr Thomas stated on 16th October 2021 that he did not prescribe to those criticising and attacking the company) 

“’It took me months and months to actually do this because there was no actual financial agreement,’ he said.”

Please provide specific evidence and provable details for:

1. 1. That Mr Thomas was denied a formal agreement 
   2. That Mr Thomas made his investment without full knowledge and responsibility of what he was paying for

“’But Shaun said: ‘Rich, you’ve been working with me all these years and you say you do not trust me? Are you invested in me?’ ‘So, ultimately, I was stupid, obviously, because I did hand over the money.’”

Please provide specific evidence and provable details for:

1. 1. Shaun Cooper’s permission for contents of a private text message from him to be printed in the Daily Mail without his knowledge and full context

“Mr Thomas says after investing he was expected to attend group calls lasting up to six hours with Lighthouse leader Paul Waugh. ‘We had to listen to him ranting on about what he thinks is happening to the world.”

Please provide specific evidence and provable details for:

1. 1. Mr Thomas not being free and perfectly able to leave these meetings at any time or not even join them
   2. For Mr Thomas being prevented from leaving a meeting early or not attending one.
      

“’There was so much love and reverence for him from the group. But the interesting thing is that Paul classifies people individually in terms of levels. If you are evolved, you move from level 1 to 4.”

This is factually correct 

1. 1. These ‘levels’ are not unique to Dr. Peck either, who drew upon the work of other leading academics like James W. Fowler, Jean Piaget and Erik Erikson. These levels are objectively self-evident to substantiate. 

“’Only Paul is ever at level 4. Everyone else is broken, you’re wrong, and it became very, very transparent.’”

It’s factually correct 

1. 1. We all have flaws, fallibilities and imperfections – Paul Waugh would share and admit to his own on a regular basis

Please provide specific evidence and provable details for:

1. 1. The statement that only Paul Waugh is ever at level 4

“It was only after Mr Thomas became ill last year that he reflected on his involvement and with the encouragement of his wife decided to quit.”

Please provide specific evidence and provable details for:

1. 1. Backing up the claim Mr. Thomas decided to leave Lighthouse after his illness, given Mr Waugh had offered him a full compassionate refund (on the basis of his illness) for £25,000 and to support his transition out of the company, which Mr Thomas ignored for a full 5 months. 

“He says: ‘I went back to Lighthouse respectfully and said: ‘I would like to ask for my investment back.’”

Please provide specific evidence and provable details for:

1. 1. Mr Thomas having any legal case or entitlement to having his money returned to him 
   2. Legal action being taken by Mr Thomas against Lighthouse International in order to legally retrieve the money he believes he’s entitled to
   3. Mr Thomas maintaining his ‘respect’ when he was told, after 5 months of his ignoring all communication from Mr Cooper and Mr Waugh that a compassionate refund decision would be suspended, pending investigations into the anonymous online trolling against the company at that time. (We have text message evidence of Mr Thomas’s respect quickly evaporating when he didn’t immediately get what he wanted)    

“The request prompted a message on November 11 last year, in which Mr Cooper blamed the decision on the ‘animosity and destructiveness’ of his wife towards the group. He added, if Lighthouse had to refund the cash ‘we would have to make a legal compensatory claim for that money’ from his wife ‘plus legal costs’. ‘Do we hold [your wife] accountable for that or you? Let us know because with your permission (in writing to our solicitors) we will hold her accountable by law.’”

Please provide specific evidence and provable details for:

1. 1. Mr Thomas’s wife having nothing to do with his decision to leave the company. (We have evidence of Mr Thomas stating on several occasions that his wife and her animosity towards Lighthouse was a central reason for his leaving the company). 
   2. Mr Thomas accepting the May 2021 compassionate refund offer from Mr Waugh, due to Mr Thomas’s health challenges, anytime prior to October 2021.
   3. That Mr Thomas replied to any of the numerous messages and attempts to meet with him that Mr Waugh sent to him in the summer of 2021. (We have evidence that Mr Thomas to this day has not replied to 9 separate messages and pleas from Mr Waugh asking to speak and help settle his situation)

“On November 24, Mr Cooper messaged to say no refund was possible and Lighthouse would be passing the content of Mr Thomas’s texts to their solicitor, whom he said would ‘act accordingly in connection with yourself as they have with others who have behaved unlawfully as you are behaving’.”

Please provide specific evidence and provable details for:

1. 1. That Mr Thomas had any viable or legal entitlement to a refund were it not being offered compassionately to him by Mr Waugh
   2. That Mr Cooper and Lighthouse did not try every attempt to find a fair and reasonable resolution with Mr Thomas, which at every point he resisted and rejected. 
   3. That Mr Thomas’s request to receive a refund was immediately rejected. (On 19th October 2021, Mr Cooper stated that,  “until we know that no damages and or loss to Lighthouse or its people have been caused by anyone from your quarters, we cannot calculate a refund at all or any part thereof.”)

“Mr Thomas branded the threats made in the messages ‘ridiculous’. He said: ‘These people need to be stopped.’”

Please provide specific evidence and provable details for:

1. 1. Communications that show Lighthouse were supposedly “threatening” Mr Thomas rather than holding him accountable for his behaviour 
   2. On what basis Lighthouse’s position with regards to Mr Thomas can be described as “ridiculous” when he a) ignored all attempts to reason and help refund his money for months and b) admitted more than once in messages that his wife was the central reason for his leaving the company. 

“Lighthouse said it encouraged ‘healthy families’ and only advised legal action against members’ relatives or partners to protect them or when ‘all other options had failed’.”

This is factually correct 

1. 1. Most of the attacks on Lighthouse International Group over the last 18 months have come from the family members of Associate Partners
   2. Tragically Lighthouse Associate Partners and clients have suffered abuse inflicted by family members. Lighthouse has encouraged these people to reconcile with relatives and partners as much as is humanly possible and safe.

“Accused of being hateful and toxic. A primary school teacher persuaded to take out a loan to fund a £19,000 ‘investment’ in Lighthouse was branded ‘malevolent’ and a ‘psychopath’ when she asked how her money had been spent.”

It’s factually correct 

1. 1. Ms Holmes was accused of being hateful and toxic when she behaved this way 

Please provide specific evidence and provable details for:

1. 1. How Ms Holmes was able to access a £25,000 programme with a £19,000 investment
   2. Ms Holmes being branded malevolent and a psychopath when asking how her money has been spent

“Jo Holmes, 50, was introduced to Lighthouse International Group in early 2018 by a friend who had been mentored by Shaun Cooper. She hoped it would help her self-development and professional relationships with colleagues and pupils.”

It’s factually correct 

1. 1. Ms Holmes was introduced to Lighthouse International Group by her friend Mr Thomas (another source in the Daily Mail article) on the basis of helping her with her self-development and professional relationships

“’My marriage was breaking down at the time,’ she said. ‘Shaun became like a brother and it felt like he was really helping me.’” 

It’s factually correct 

1. 1. Ms Holmes’s marriage was breaking down (through her own admission in the article) and that Mr Cooper was committed to helping Ms Holmes through this challenging situation 

“After a few months, he made ‘very subtle’ suggestions that she should invest in the group. ‘He said I could build on my existing work with pupils and teachers and make a difference for them and said the charity part of Lighthouse would invest in purifying water in Africa.”

It is factually correct that…

1. 1. Ms Holmes was offered the opportunity to be involved with Lighthouse International Group to build on her existing work with pupils and teachers
   2. It is also true that Ms Holmes ignored and absconded from realising these opportunities when offered to her
   3. It is also true that Mr Thomas encouraged and was instrumental in her joining the Associate Partner Elect Program with him

Please provide specific evidence and provable details for:

1. 1. Mr Thomas not encouraging and playing an instrumental role in her involvement with Lighthouse 
   2. The ‘very subtle’ suggestions for Ms Holmes to invest any money 
   3. Ms Holmes having any outstanding questions or lack of clarity before joining Lighthouse and 
   4. Ms Holmes joining Lighthouse against her will or having any reservations for doing so, or having been coerced into doing so 
   5. That Lighthouse has a charity part in additional to Lighthouse Kidz which is a Community Interest Company
   6. Lighthouse investing in purifying water in Africa

“’Because a friend had invested, it seemed feasible. ‘I invested £19,000 in instalments, but I had to get a loan out to fund it. But they knew I had a big asset with my house. I think they saw the long term. Now I feel stupid, but they build a relationship with you and they know your secrets, you trust them and believe in them.’”

It is correct Ms Holmes paid £19,000 toward her Associate Partner Elect Program fee and that she decided to fund this using loans. 

1. 1. It is also correct that £6,000 of this was funded by another Associate Partner, interest-free, who is still at Lighthouse International and that Ms Holmes has made no attempt to contact or take responsibility for repaying this money. 

Please provide specific evidence and provable details for:

1. 1. What Ms Holmes felt was feasible because of her friend (Mr Thomas) investing
   2. Anyone at Lighthouse wanting Ms Holmes to be involved because of her house
   3. Lighthouse making any significant long term financial gains from its Associate Partners in the 18 years of its operation. 
   4. The efforts to build a trusting relationship with Ms Holmes not being genuine

“Because of her investment, she became an ‘associate elect’ and part of a ‘business unit’ of members. This meant, during lockdown, she was expected to join calls lasting hours on Saturdays, during which Lighthouse leader Paul Waugh would spout his wisdom and grill other members.”

It’s factually correct 

1. 1. Ms Holmes had access to the support and training through her investment in the Associate Partner Elect Program. 

Please provide specific evidence and provable details for:

1. 1. How Paul Waugh would ‘grill members’ 

“’I began to question these calls. I did not like the way they spoke to people, it was quite aggressive bullying. I was a bit scared of Paul,’ she adds. ‘He pulled me apart and talks over you all the time . . . Paul was intimidating.’ ‘Paul was intimidating to the point you felt you had to give positive feedback.’”

Please provide specific evidence and provable details for:

1. 1. The “aggressive bullying” by Paul Waugh. 
   2. Why Ms Holmes was scared and intimidated by Paul Waugh and what she did with those fears

“After the calls, members were sent edited audio recordings to listen to in the evenings — which they were then expected to provide feedback on so that Mr Waugh could assess their ‘level of understanding’. But after speaking to another alienated member, Ms Holmes began to research the group and eventually decided to ask for evidence of where her cash had been spent.”

This is factually correct 

1. 1. Edited audios (cut with the key points) from the daily training sessions were shared and feedback was requested in the same way that any teacher would want to see the progress of their students 
   2. Audios were edited in order to reduce the length of the recording. This was out of consideration for those listening in the evenings.
   3. Ms Holmes made no official enquiry or request about any finances until her message to Mr Cooper on 18th April 2021. She left after her phone call with Mr Cooper and Mr Waugh the following day on 19th April. 

Please provide specific evidence and provable details for:

1. 1. The other alienated member Ms Holmes was speaking to and the evidence that seemed to change her whole attitude towards her involvement with Lighthouse International Group.

“She adds: ‘Lighthouse bears all the hallmarks of a group that takes advantage of people by promising to transform your life and the world. But I have seen no evidence that any of their global initiatives have ever happened and it begs the question where the money goes.’”

Please provide specific evidence and provable details for:

1. 1. How Lighthouse supposedly and specifically ‘takes advantage’ of people, including verifiable and practical examples of this from Ms Holmes and/or others
   2. The promises supposedly made by Lighthouse in relation to personal transformation and changing the world, that genuinely constitute a promise. 
   3. The depth and level of Ms Holmes’s accurate understanding of the the global initiatives that Lighthouse is undertaking, the critical success factors, biggest obstacles and our approach to overcoming these based on 18 years of research 

“She has yet to receive any cash.”

Please provide specific evidence and provable details for:

1. 1. The amounts of ‘cash’ Joanne Holmes is expecting and on what legal basis she would be entitled to this ‘cash’ 
   2. Why, in over 18 months, Joanne Holmes has not taken any legal action to obtain monies owed  to her, if that is the legally the case

“Lighthouse said the recording had been shared in ‘full compliance’ of the law and with Ms Holmes’s details anonymised.”.

This is partially correct but omits key details; please see above points in relations to this

“It accused Ms Holmes of trolling the group after leaving and said it had contacted the police and the school where she worked to complain.”

This is factually correct and can be substantiated by evidence

1. 1. We have all police reports and correspondence with the school to prove this

Please provide specific evidence and provable details for:

1. 1. Ms Holmes having NOT trolled Lighthouse International Group consistently since April 2021

“When she later posted her concerns about Lighthouse online to try to warn others, the group complained about her to the headteacher of her school and threatened legal action.”

This is factually correct and was a justifiable course of action 

1. 1. Miss Holmes was maliciously sabotaging and trolling Lighthouse, Paul Waugh, our people and our children for 11 months before we took action to hold her accountable.
   2. We did this to avoid going down a more serious and potentially damaging legal route or speaking to the police. Something we were later also forced to do due to the unrelenting nature of her online anti-Lighthouse activity.   
   3. We had to take action to protect ourselves and so reported her to her employers after multiple offers to her to sit down and reconcile her differences. 
   4. This context is completely left out of the article.

“Lighthouse said it had not shared the private and personal details of members with the police”

This is factually correct 

1. 1. Mr Church was warned (not threatened) about this and because his behaviour stopped we took no further action. 
   2. Other members in the group felt very threatened by him so we had to take steps to protect them. Evidence of this is available in text messages held by Lighthouse International Group.
   3. There is an email with proof of this warning
   4. We invite the Daily Mail to prove anything to the contrary of this statement

“Parliament has heard calls for statutory regulation for counselling groups after peers described hearing how lives had been destroyed by an explosion of unqualified and unregistered counselling, mentoring and life coaching groups in recent years.”

This is factually correct

1. 1. Lighthouse fully support this and have themselves petitioned government for this.

“Lighthouse was set up in 2012 by Mr Waugh to ‘inspire, empower and unite’ through coaching and mentoring programmes which mix self-help and spirituality.” 

This is factually correct

1. 1. Lighthouse International Group was originally FranklinWaugh which was started in 2004. The name changed to Lighthouse International Group in 2012 as stated on our website. 
   2. Mr Waugh and the founders of Lighthouse have been on an 18 year process and journey to discover how to help the average person to follow through on the things necessary to complete their goals consistently and on an upward spiral of growth. 

“Espousing his philosophy, Mr Waugh frequently references self-improvement books, especially the 1989 bestseller The 7 Habits Of Highly Effective People.”

This is factually correct

1. 1. Mr Waugh attributes this book to having helped him to succeed in building and selling multiple businesses and he wanted to help others emulate his success using its material.  
   2. However, Mr Waugh found early on in his mission that, despite selling 10’s of millions of copies, only a fraction of 1% of people who read the book could actually apply and live what it taught. Remarkably few could even remember what the 7 habits even were when asked at an event held by FranklinCovey, Dr Covey’s company. 

“He also regularly discusses the teachings of Christ — though Mr Waugh told the Mail he often stresses to members that they should not ‘idolise’ him or paint him as a modern-day ‘fat, bald Jesus’.”

This is factually correct

1. 1. Mr Waugh has become an ardent student and disciple of Christ after many years studying the Bible and its teachings in relation to his own life and experiences
   2. His self effacing humour is a description of his humility and he has deliberately avoided the spotlight for many years in order to not be put on a pedestal while he taught and led others  
   3. Mr Waugh has recently stepped down from Lighthouse International chairmanship, fulfilling his desire for others to step into his shoes and one day surpass his achievements.

“The group, which claims to have helped thousands of people in their personal and professional lives, has global ambitions and plans to launch in India, the U.S. and China.” 

This is factually correct

1. 1. The founders of Franklin Waugh and Lighthouse International conservatively estimate to have interacted at some level with over 70,000 people in the last 18 years. 

“A sister organisation called Lighthouse Kidz, which claims to help children and their parents, has previously enjoyed glowing coverage in The Guardian.”

This is factually correct

You can find the article here.

“A senior member of the main group has said one aim is to get a ‘Lighthouse beacon’ in every UK school and have teachers reporting to the group.”

This is factually correct

1. 1. In its long 18 years of research and discovery into human behaviour and people’s struggle to follow through at the level they desire, it’s become very apparent there are significant gaps in children’s development that significantly affect and limit them in later life. 
   2. The purpose of this is to support and enable teachers to make quantum improvements in their results with children they are teaching by passing on what we have learned

“The woman, who did not want to be named because her counselling involved discussing previous childhood sexual abuse, said: ‘I was going through a divorce at the time and it felt extremely positive to begin with.

This is factually correct in that 

1. 1. The woman (Mrs X) had suffered childhood sexual abuse and this had been voluntarily disclosed to her mentor who was supporting her. 
   2. She had been going through a divorce when she got involved and was full of praise for the help, care and support she received for many  years. 
   3. This was before her cynicism and negativity became a toxic factor in her involvement with Lighthouse. All of which we have privately on record in various messages and recordings she was consenting to.

“And he told her that if she had behaved with her children the way she had been behaving in the group he would immediately have reported her to social services — where he claims to have connections. When she broke down in tears, he berated her for ‘crying for herself’, saying: ‘It’s all about you.’”

This is partially accurate 

1. 1. The above descriptions are missing crucial context: Please refer to point No. 10

“Fiona Ballantine Dykes, Deputy Chief Executive of the British Association for Counselling and Psychotherapy, said: ‘We’re concerned that vulnerable members of the public looking for support with their mental health don’t realise the risks of seeing unqualified, unregistered practitioners.”

Lighthouse do not contest this statement 

Lighthouse support and have even campaigned for this proposal by petitioning the UK government.

“’Our fear is that clients working with unregistered therapists are more at risk of harm, as their practitioner won’t be required to meet the training, proficiency and ethical standards of a recognised professional body.’”

Please refer to point No. 16

“In a 17,000-word response to the Mail, Lighthouse described the allegations as ‘false and baseless’, said it was a ‘healthy community’ that does not tolerate abuse or bullying and was a victim of ‘persecution’ and ‘trolling’ from ex-members with whom it had financial disputes. It said the group offered ‘life coaching’ rather than therapy, and was supportive of stronger regulation for the ‘personal development industry’.”

This is factually correct

1. 1. A comprehensive 17,000-word response was sent to the Daily Mail
   2. Lighthouse offers life coaching rather than therapy
   3. Lighthouse is supportive of stronger regulation for the ‘personal development industry’
   4. The Daily Mail could not substantiate the allegation that, “Ex-members say LIG behaves like a cult”
   5. Almost 3,000 anti-Lighthouse anonymous posts and comments have been made online in an 18-month period that includes hate speech relating to race and religion
   6. Financial disputes are a major reason for the attacks on Lighthouse International Group
   7. Lighthouse strongly supports reforms and stronger regulations for the personal development industry

“It said police had twice visited Lighthouse members at their homes after warnings from concerned relatives that they were being ‘manipulated and held hostage financially’, but in both occasions the officers left without taking any action.”

This is factually correct 

1. 1. There have been two visits by the police to the homes of Lighthouse Associates instigated by family members
   2. On one occasion the police officers left apologising and saying they felt ‘embarrassed’ for being called out in this regard

“Mr Waugh acknowledged hostility from some relatives of Lighthouse members, and in a YouTube video he denounces ‘toxic parents’ who try to stop their children from continuing with the group.”

This is factually correct

1. 1. Lighthouse International has substantial evidence of this being the case in multiple families across multiple cultural and religious backgrounds. 

“’I just couldn’t believe the narcissism in families. It’s a real problem,’ he said. ‘It’s huge.’”

This is factually correct

1. 1. Many of the people who have become Associate Partners at Lighthouse International have struggled with very controlling and narcissistic family backgrounds. The evidence and data that has been collected in these cases is substantial. 

“The response, following an email and a call, was a long message from Mr Waugh in which he accused her of being hateful, toxic and disturbed, claiming it was ‘downright terrifying . . . that you are a schoolteacher with delicate little and innocent children in your care’.” 

This is factually correct 

1. 1. Mr Waugh and Mr Cooper were shocked by Ms Holmes’s behaviour. This audio can be released with Ms Holmes’s permission or in court as evidence. 

N.B. We ask for the Daily Mail to seek permission from Ms Holmes to release the recording and its transcript into the public domain to clear up any disputes over this incident. 

“He also said he had sent a report and a recording of the phone call with her to PhD students who ‘work specifically with teachers and their pathology in relation to their profession for observational analysis.’ Ms Holmes said: ‘I took that as a clear threat to my professional reputation.’”

This is partially correct but omits key details

1. 1. Mr Waugh did tell Ms Holmes by text at the time that he ‘sent’ the recording in a manner legally permissible and we do not deny this. 
   2. HOWEVER, Mr Waugh wrote this with the full intention of sending it after legal consultation, but having not actually done so and ultimately decided not to send the recording.  
   3. Lighthouse categorically confirmed this in response to Mr Kelly on 24th February 2021, stating “We have also not passed on any information to PhDs. We were considering it at one point, so you may have heard that from one of your sources, but we decided against it subject to our discussion with our counsel”

We invite the Daily Mail to prove the following:

1. 1. The audio of Ms Holmes was definitely sent to PhD students 
   2. Why and how the content of this recording being shared with PhDs would be a ‘clear threat to her professional reputation’ if she has nothing to hide with regards to her actions and behaviour.