Page 255 - Bundle for MF Final

Bates no 254

Nutley Place
School Lane
Nutley
East Sussex
TN 22 3PG

13 April 2020
th

Dear Mr Abey,

As you know, I am currently represented by HFC Law and have to provide you with a list of
documents I require Mr Solhiem to disclose by 16.00 on Tuesday 1 4th April 2020. I refer to
your Form N265 dated 26 March 2020 which is incomplete and not in the spirit of a fair,
th
full and frank disclosure.

I do not accept that the documentation relating to your client's insurance claims are
privileged. In fact, most of the documents I need to review are between him and his insurers
or easyJet and are dated before any legal action was commenced.

Because of the Wuhan virus lock down and the Easter Bank Holiday, I have been unable to
contact HFC and I therefore attach a preliminary list of documents I require Mr Solhiem to
provide for my inspection.

The documents I need to inspect are fundamental to this case for three main reasons:

1. They are central to Mr Solheim's credibility and his current but untruthful assertions
that the £500,000 was an "agreed in writing", under a 'Joint understanding",
TOLATA "contribution which was "secured on Nutley Place". I note that his Form
N26S fails to list any such agreements.

2. They support my contention that the £500,000 was in every legal and other sense a
"gift" involving an unconditional transfer of title to me;

3. It is critical that the Court confirms the provenance of the Claimant's funds and
ensures that any settlement we might reach is not liable to proceeds of crime or
"fundamental dishonesty" reversal.

A provisional annotated list of documents I need to review is attached. This will be subject
to amendment.

If you have an alternative suggestions through which Mr Solheim can establish to your
satisfaction and mine that the monies transferred to me are not liable to seizure under
proceeds of crime or related legislation I would be willing to move towards a negotiated
settlement.

Your sincerely,

Louise Siggers