Page 275 - Bundle for MF Final

Bates no 274

• Although AIG appears to accept that your client's compensation of £52Sk for a lifelong
debilitating injury was bona fide, a suspicion remains that he may have paid an inducement to
one or more of its agents to approve the claim. The disclosures we have requested are vital
to clarify this position and are in your client's interest to produce if those suspicions are
unfounded;

• Our client's position is that the £500,000 was a gift primarily from a bona fide AIG claim.
However, if it transpires that it was in fact from the proceeds of crime, she will unhesitatingly
support its return to the insurance company or companies concerned;

• You client's actions within his insurance claims reveal his propensity for misleading his legal

advisers, making false claims for compensation and committing perjury. They are central to
his credibility.

Your client has repeatedly tried to reclassify and misdescribe what were unquestionably "gifts" to
our client (such as 50% of the shares in CRS Aviation Ltd, a horse and, of course, the £500,000) as
loans or subsequently as "contributions towards property.

Incomplete disclosures

Your client has still not provided a detailed list of the documents referred to in his N265. At various
times he has stated or implied that the funds he transferred to our client were fully documented
and agreed as "loans" or "contributions to property". He has not however produced a shred of
evidence about this.

Further, your client's denials regarding the discussions he had with our client over their respective
wills are entirely false.

Previous requests for evidence of source of funds

It is incorrect to state that our client has only recently raised her concerns about the source of your
client's funds. I understand that the matter was first raised with Grosvenor Law on 12 August 2019
and has been repeated on various occasions since.

The way forward

Your client is presently pursuing an application which has been made under the wrong statute and
which will inevitably have to be withdrawn. Our client is nonetheless prepared to be pragmatic and
is agreeable to discussing a fair and constructive solution in a round table meeting. However, if that
meeting cannot resolve matters, she will pursue an application for specific disclosure against your
client and take whatever action is necessary to establish the truth.