Partnership”) and the Partnership owned and operated a number of department stores. Some of the real estate on which the stores were run was in separate ownership from the partners. Heinrich owned one of these properties in particular was a department store in Kesseldorfstrasse Dresden-Lobtau, Germany (“the Lobtau Store”). 12. The Partnership formed a purchasing consortium with stores owned by other members of the extended family. This was known as Wollwarenhaus Saxonia Falk & Posener (“WSF&P”) with headquarters in Dresden and servicing 18 stores. In 1936 Heinrich died, leading to the liquidation of the stores. The proceeds of the liquidation were deposited at East German banks and were subsequently confiscated by the Nazis. 13. In 1957 Moritz Falk’s 2 daughters, Edith Ostreicher and Margot Weiss (the Falk daughters), who lived in Rio de Janeiro, made claims for both the Falk and Posener heirs in the West German compensation scheme. It was said that this claim was erroneous, because it was based on an assertion that Moritz owned all the business assets of the Partnership, which is said to be untrue. The effect of this claim was to create a “cloud” (The Falk cloud”) on the title of Heinrich’s heirs to claim compensation. 14. In 1990 Siegbert Posener made claims in the East German compensation scheme and after his death his sons, the Defendants, made claims for the real estate owned by Heinrich, using a German lawyer called Dirk Plagemann. Mr. Plagemann obtained compensation for the real estate of the Dresden Store but not for the business assets. 15. The Claimant is the grandson of Josef Lenczynski and his wife Margarethe. Margarethe was Heinrich’s sister. Unsurprisingly, he took a great interest in his family’s experience in Germany before the war, but equally unsurprisingly, his parents would not talk about it. 16. The Claimant became aware of the JCC in about 2004 and the list on its website of properties which had been owned by his grandfather, Joseph. He engaged Mr. Chudson to assist him in making a claim. Mr. Chudson is also distantly related to the parties. He has been involved in researching Holocaust archives since the 1950’s and as carried out research in several countries, including Germany. From 2002 he started to work closely with Dr. Arndt Surner, a German lawyer in the firm of Hirsch Thiem & Collegen, dealing with claims to the BADV, the JCC and appeals from their decisions to the German courts. 17. Mr. Chudson became aware that claims had been filed by Siegbert Posener in relation to Heinrich’s assets. He says he found this out in 1998. These were under the West German programme and later under the East German programme. 18. Mr. Chudson and Dr. Surner were able to recover compensation for the Claimant in respect of an East Berlin property, and another department store owned by his paternal grandfather, Joseph Lenzcynski. Mr. Chudson says that Joseph Lenczynski was Heinrich’s executor and also one of the liquidator of the department stores. 19. In 2014, in the course of his investigations on behalf of the Claimant, Mr. Chudson became aware that Siegbert Posener had 2 sons by his second marriage, namely the Defendants. He wrote to the Claimant on 28th September 2014 telling him that he had made contact with the First Defendant, but that the latter was not responding to recent