Page 77 - RBK&C Attachments 28-5-16 (77pp)

UK on or around 1st April 2016 which were used as reasons for not acknowledging our client’s offer to fully comply with your request for documents? We are advised that no response has been received regarding queries raised over these convenient dates to fully confirm their authenticity as to why, in Mr. Begg’s alleged absence you, yourself, could not have been advised to accept our client’s offer; unless, of course as advised by Mr Begg, you were unavailable (genuinely) in The Sahara?
We must insist you desist from making any further baseless, spurious and ill-informed accusations against our client, Mitre House Management Limited, its officers or Mr. Brown- Constable and request your solicitor confirms with RBK&C that all accusations levied against our client to date are disproven and your request for documents on 17th December 2015 was in fact the only request made by any lessee since 1st January 2012.
If considered not adequately disproven, or not satisfactorily addressed, your accusations should be further substantiated if still considered unproven, as has been requested by Mr. Brown-Constable in all his correspondence with both your solicitor and RBK&C since your solicitor’s initial letter of the 23rd March 2016 and RBK&C’s involvement since 22nd April 2016.
Libelous comments are punishable in English law and we consider many of your baseless, spurious and ill-informed statements to date, levied against Mitre House Management Limited, and their officers including Mr. Brown-Constable, to be libelous in the light of explanations and evidence so far supplied by Mr. Brown-Constable which thoroughly refutes and disproves your accusations to date.
As regards the dates of Mr Begg’s pneumonia and your Sahara trip, both remain contentious given the importance of our client’s offer to comply despite your request being out of time as regards the Landlord & Tenant Act 1985 s.22 statutory limit of six months. As is now estab- lished, due to the baseless, spurious and ill-informed statements made by your solicitor in his initial letter of 23rd March 2016 which required comprehensive denials with supporting evidence, it could only have been expected that our client receive due notification of the veracity, or not, of the denials and confirmation of same. None has been forthcoming and our client understandably withdrew their offer to comply, relying on their legal rights as stated in your lease and Section 22 of the Landlord & Tenant Act 1985
Yours sincerely, Wainwright & Cummins