The children of Sean Quinn, the former billionaire, will seek this Thursday to have the injunction order freezing their bank accounts and preventing them controlling their overseas assets lifted in the High Court.
In a new affidavit, Aoife Quinn, the daughter of Ireland's once richest man, states that she believes an offer by the special liquidator to put up €5m towards covering any damages they may be awarded in the future is "wholly inadequate."
She argues that a multiple of this ring-fenced figure is needed to cover the legal costs as well as damages the Quinn family are seeking as part of their complex actions against the former Anglo Irish Bank.
She also argues that the family has lost millions since two of the family's most prized assets in Russia, worth $210m (€160m), have been taken out of its control by a court order telling them in June 2011 to no longer interfere in them.
This interference helped lead to IBRC losing control of the family's overseas assets when it went to seize them.
Aoife Quinn also states that KBC bank has appointed a receiver to the house of Sean Quinn Jr and his wife Karen as a result of the family being unable to access funds from their bank accounts to meet mortgage payments.
Ms Quinn claims that Karen managed to get just one monthly mortgage payment released before all further payments were halted.
As a result, she said a loss of €700,000 was crystallised for her brother.
The family claims that Niall McPartland is facing similar losses on a house he co-owns with another family member.
Ms Quinn also claims that the Mareva injunctions freezing their bank accounts were making it "extremely difficult to carry on our lives," despite the courts allowing them significant allowances.
She said the family were unable to obtain any loans to allow them to start a new business.
"The stress and anxiety caused to each of us in our attempts to provide for ourselves and our families is incalcuable," she claims, and that the family has been "demonised".
Ms Quinn also claims that the family's International Property Group assets are worth $700m, much more than valuations by the bank and its former special liquidator of between $500m and $380m.
Ms Quinn states she believes that assets worth close to $100m are not included in these valuations, including assets in Turkey worth $56m relating to a shopping centre in Istanbul.
Ms Quinn also claims the family's ownership of a site which was once intended to house a massive power station in Louth is valued at zero when the family believes it is worth €20m.
KPMG, the special liquidator to IBRC, has rejected all the family's claims and argued that their predicament is a result of actions required as a result of the family's actions.
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