High Court Issues General Civil Restraint Order in Cheryl Plummer v Joshua Jacob Friedlander Case

Citation: [2023] EWHC 3241 (Ch)
Judgment on


In the case of Cheryl Plummer v Joshua Jacob Friedlander [2023] EWHC 3241 (Ch), the High Court was tasked with determining whether a general civil restraint order (GCRO) should be issued against Cheryl Plummer. The Honourable Mr Justice Miles meticulously reviewed the series of vexatious litigation brought forth by Plummer and evaluated the pattern of her litigation behavior. This article delves into the key facts of the case, outlines the legal principles applied, discusses the outcomes of the application for a GCRO, and concludes with the implications of this decision for legal professionals and the court system.

Key Facts

The key facts of this case revolve around multiple failed legal proceedings initiated by Cheryl Plummer against Joshua Jacob Friedlander and others, following a property transaction in 2016. Plummer’s claims alleged a “joint enterprise” involving misrepresentation by Friedlander and various solicitors. Across five separate County Court actions, the claims were struck out as either hopeless or totally without merit.

The case analysis was impeded by non-participation from Plummer and further complicated by her apparent association with a known vexatious litigant, Leslie Gayle-Childs, and the use of various entities and accommodation addresses, including Nathan Paralegals and Tuscany Trust Holdings Trustees.

The central legal principle in this case is the criterion for issuing a GCRO, as established in Sartipy v Tigris Industries Inc [2019] EWCA Civ 225. The court must be satisfied that the party against whom it is sought has persistently issued claims or applications that are totally without merit and that an extended civil restraint order would not suffice.

Civil Restraint Order (CRO)

A civil restraint order curtails a litigant’s ability to bring new litigation to prevent vexatious or frivolous actions. It is categorized into Limited (LCRO), Extended (ECRO), and General (GCRO), with each imposing varying degrees of restriction.

Application of CRO Criteria

Mr Justice Miles evaluated Plummer’s history of unsuccessful proceedings, noting the striking similarity in conduct, connection with vexatious litigants, and the apparent misuse of legal representation. The standards from the Sartipy case regarding persistent issuance of meritless claims were met. Additionally, the behavior involving these actions, such as the failure to adhere to procedural requirements, bolstered the case for a GCRO.

Precedent from Other Judgments

Justice Miles referenced other cases involving Mr. Gayle-Childs, including a Divisional Court order and a decision by HHJ Paul Matthews, to draw parallels on the misuse of legal processes. These cases established patterns pointing to vexatious litigation behavior linked to Plummer.


The final outcome of this case is the issuance of a General Civil Restraint Order against Cheryl Plummer. The court determined that Plummer had engaged in repetitive, meritless litigation that not only imposed unnecessary costs on the defendant but also abused the court process. The court reviewed six applications or claims brought forth by Plummer and found each either certified as without merit or, retrospectively, totally without merit.


The case of Cheryl Plummer v Joshua Jacob Friedlander represents a comprehensive application of legal principles concerning vexatious litigation and the protective measures courts can take. The High Court, bound by the established precedent, appropriately issued a GCRO against Plummer to prevent the continuation of frivolous litigation, which undermines the administration of justice. The judgment serves not only to halt Plummer’s vexatious conduct but also as a warning to other potential vexatious litigants that similar behavior will be met with stringent judicial responses. For legal professionals, this case underscores the importance of recognizing patterns of vexatious litigation and knowing when and how to request a civil restraint order. It also reaffirms the judiciary’s role in preserving the integrity of the court process.

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