Page 276 - Bundle for MF Final

Bates no 275

Our client suggested to you in her letter of 14 April 2020 a possible way through which your client
might provide certainty over the legitimacy of his funds and his motivation for gifting the £500,000
to her. A starting point would be for your client to provide a copy of a complete schedule of the
insurance claims made (along the lines of the enclosed document) to Kingsley Napley, Diamond
Insurance, Cirencester Insurance and Hiscox and any other insurers and obtain their written
confirmation that all the proper disclosures were made and subrogation conditions honored. As was
made clear in our letter to you of 13 May 2020, our client will agree to inspection taking place upon
your client agreeing to rectify the omissions in his own disclosure and provide all documents which
are relevant to his claim, including those requested by our client in her letter of 14 April 2020. We
trust this letter deals with the points you have raised and await the detailed list of documents
referred to in your client's N265 which makes a mockery of your client's disclosure obligations.

Yours faithfully

HUGHES FOWLER CARRUTHERS

Encl.