Page 96 - Bundle for MF Final

Bates no 095

that information now they would no doubt revive their argument that we should provide specific disclosure of the
earlier witness statements {which, as above, would not be beneficial). Ms Siggers agreed. Ms Benson made a specific
point of asking for clarification on the final paragraph of Grosvenor's recent letter and asked me to remind my client
that fraud should not be alleged accept in accordance with the SRA/BSB rules. I conveyed that point to Mr Siggers
and intend to mention it to Ms Siggers again.

Mr Siggers seemed to think that we are obliged to disclose the witness statements produced in the maintenance
proceedings. I said that I wasn't sure if that was correct, but that further advice should be obtained if needed. I
explained that my view was they would not assist our case, although the ultimate order may be of use, since it
tacitly acknowledges that the money provided by Mr Solheim was part of Ms Siggers' assets.

Mr Siggers also stated that if the £500k was proved to have been the product of a fraudulent claim then Ms Siggers
would have to return it to insurers regardless of the outcome of the proceedings. I explained, again, that I did not
know whether that was correct as a matter of law but, as a first reaction, it did not sound correct. Mr Siggers then
said that if Mr Solheim could prove that the £500k was legitimate, then he would accept that it should be repaid. I
explained that was somewhat contrary to earlier information provided by both Mr and Ms Siggers. /f;vl1,,bf JI

After the hearing, Mr Solheim's counsel asked for Ms Siggers to provide him with copies of his flying records, which
are apparently still at the Property. He said it was required for a regulatory inspection. I told them to send proof of
the inspection and the matter would be considered.

With respect to the order, I would like to highlight to action points. Firstly, dates to avoid are required within a
reasonable short time frame. Secondly, the 'FOR-type' hearing will also stand as a costs and case management
hearing (if the matter does not settle). As such, costs budgets etc will need to be prepared in the usual way.

If you have any further questions please do not hesitate to contact me in Chambers.

With thanks,
George

George Mallet I Barrister

2 Harcourt Buildings I London I EC4Y 90B
Tel: 020 7583 9020 I Fax: 020 7583 2686
DX: 1039 CHANCERY LANE

www.hendersonchambers.co.uk

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