Page 272 - Bundle for MF Final

Bates no 271

■II■ Hughes Fowler Carruthers Academy Cou rt, 94 Chancery Lane, London WC2A IDT
T +44 ( 0 ) 20 7421 8383 F+44 ( 0 ) 20 7421 8384
HUGHES FOWLER CARRUTHERS HARPER LABI E mail@hfclaw.com DX 251 London/Chancery lane
----SOLICITORS---- www.hfclaw.com

Your ref:
Our ref: AC.pr.SIG00I.I

Mahie Abey 8 June 2020
Dawson Hart Solicitors
DX 39050 Uckfield

By email only: jlw@dawson-hart.co.uk and ma@dawson­
hart.co.uk

Dear Sirs

Mr Sigve Solheim and Ms Louise Siggers

We refer to your letter of 20 May 2020 and our reply of 22 May 2020. Our client's position on
disclosure and inspection has already been made clear in previous correspondence but we will
nevertheless deal with the various points you have raised. This letter is a formal response which will
be produced to the court if we are unable to agree matters at the proposed round table meeting.
To that end, we remind you that we are waiting for a response to our email to Jamie Wood of I
June 2020 with confirmation of which dates between 27 to 30 July 2020 would be convenient for a
meeting to take place.

Turning now to the matters raised in your letter of 20th May 2020.

Disclosure

Our client is not seeking "additional disclosures" as you well know. She requires your client to
comply with the standard Civil Procedure Rules in respect of disclosure and the Orders that have
been made. These required both parties to (a) engage constructively in dispute resolution with a
view to settling matters and (b) disclose all information that may be relevant, including electronic
records. Our client has complied in good faith throughout.

Your client, on the other hand, has wilfully evaded his obligations by, among other things:

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