Page 248 - Bundle for MF Final

Bates no 247

Dear Lou.

I suggest you send this note to HFC Law over the Bank Holiday and get their response in time
to meet the disclosure deadline of 16.00 on 14 April 2020. If you cannot achieve this. I
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recommend that you send an email to Dawson Hart along the lines of Attachment 1, below.
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A response must go to Dawson Hart before 16.00 on Tuesday 14t April 2020.
As you know. I have kept out of your relationship with HFC Law and Marina Faggionato of
QEB except when you specifically asked me to provide information. It seems to me that we
are being dragged back onto the Grosvenor Law route of taking this case to a full trial. I am
not going to fund an esoteric fight over the rights and wrongs of TOLA TA: END OF.

I agree with Counsel's recommendation that we should see Mr Solheim's documentation and
then arrange a round table meeting to try and reach a settlement. However, it is critical that
we first establish the legitimacy of his funding and ensure that any settlement reached is not
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unravelled by proceeds crime action by insurers or National Crime Agency •
I agreed to lend you limited funds to pay HFC's legal fees and have repeatedly asked you for
hourly rates. budgets and timetables. With a couple of small exceptions these have not been
forthcoming, and I was amazed to discover from recent correspondence that there is an
outstanding bill of around £15,000 for what should have been a routine disclosure listing
operation and a further bill from counsel of fxxxxxx.

These fees were accumulated. in the main. for amending the hyperlinked discovery list I had
produced on 2 nd March 2020. miscellaneous correspondence and for a conference with
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counsel which was reported. in what was admitted being. a rough and ready file note •
On the other side, on xxxxxx Mr Solheim asked for a further 14 days to produce his list and
when an extension to xxxxx was agreed, Dawson Hart cynical whacked in an incomplete and
anodyne Form N265 for "standard disclosure" that may have ticked a compliance box but
which is totally meaningless and not in the spirit of a full and frank discovery.

HFC now proposes that you should accept Mr Solheim's Form N265, pay their outstanding
fees . make a further advance of funds and once this is done, they will ask to inspect his vague
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list of documentation and to specify further documents that they wish to review. Implicit in
the above is that your solicitors appear to accept that all evidence relating to Mr Solheim's
insurance claims and source of funding is privileged. IT IS NOT. The request for specific
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disclosure has to be made by 16.00 on 14 April 2020 and HFC will not be able to meet this

1 Counsel says she does not see how this could happen. With respect. I suggest I know more about this risk than
she does.
2 But which will be basis on which HFC's partner makes his recommendations
3 As I understand it, you have not received the supposedly outstanding invoice, timesheets nor a budget for
possi future work.