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have never ever been in default on received invoices, ever, as indeed our prompt by return payments to AR Lawrence and our Surveyor and indeed any of our sub-contractors will attest to. It would hardly be acceptable to our Freeholder, nor indeed to my fellow directors, or our lessees, if we ran up a bad credit rating or ended up in the small claims court – or worse! Supporting documents in support (Bank Statements etc) were supplied. (Folder_00 Item_18, 19, 20, 21)
(b)_in a letter from “PBC” dated 27 october 2016 to “mH’s” Solicitor he writes: Both Mr White’s (revised) and Mrs Hillgarth’s Witness Statements contain the same erroneous innuendo that Mr. Nigel Brooks was owed money. I can confirm yet again that is not true. Mr Brooks was paid £1200 on 11th August 2014 and a further £1200 on 4th September 2014, and I would suggest you get that con- firmed and desist in repeating what I had previously advised was untrue yet you still allowed your client to repeat the slur and indeed distributed Mr White’s Statement to multiple third parties. I have a feeling that doing so in the knowledge of it being untrue once denied by me in correspondence (and easily checked with Mr Brooks) is pretty despicable, yet you still distributed it to third parties which you might also recall you initially neglected to send me a copy of Mr White’s Statement, relying on third parties to advise me.Your editing of his Statement does evidence your acceptance of my initial comments, but you retained the “Brooks” reference and included it in the Witness Statement you drew up for Mrs Hillgarth as she readily admits you did for her. (Folder_00 Item_22)
(c)_“PBC” also attached comment on mrs Hillgarth’s Statement dated 10 august (comment/reply) (Para 85) as returned to “mH’s” Solicitor on 27 october 2016 stating: all com- prehensively covered in previous correspondence - at least 8 times...References such as non pay- ment to “an electrician Nigel Brooks” is a proof perfect example of Mrs Hillgarth’s imagination..... I can confirm, for the umpteenth time, that Mr Brooks was paid £1200 on 11th August 2014 and £1200 on 4th September 2014 - this particular accusation has been repeated by you and Mr Begg and in Mr White’s Witness Statement - it’s a lie, it’s not true and as previously made clear I suggest you check with Mr Brooks and refrain from repeating it.
It is noted that Mr White’s initial Witness Statement was edited following my initial comments and re- issued but still contains the Mr Brook’s non payment accusation - just where do you get your informa- tion from and why don’t you check it first prior to repeating it to all and sundry making you look even more devious and untrustworthy that you have been shown to be to date? (Folder_00 Item_23)
(d)_in a letter (addendum) from “PBC” dated 1 November 2016 to “mH’s” Solicitor he writes: Witness Statements from Mr. White (his initial and the revised) and Mrs Hillgarth’s both maintain that monies due to our initial electricians, BES/Nigel Brooks, was not paid and it was inferred that re- quests for payment were ignored (following the same comment as attributed to Mr White’s outstand- ing £1590).
In my reply to you dated 14 June 2016 (with my comments attached to your letter (which you mistak- enly dated 14 May 2016 but actually 14 June) referencing, amongst multiple other references, Mr White’s Witness Statement’s inaccuracies, one of which was the above reference to non payment to BES/Nigel Brooks.
You will note that this very same accusation was raised again (two months after my denial above on 14 June) in Mrs Hillgarth’s Witness Statement dated 10 August where she not only repeats the accu- sation but now also confirms “I have subsequently been able to verify this information from Mr Brooks himself.”
Does begg the question of why she did not verify at the time she tutored Mr White’s Witness State- ment - see attached (Ref A)
Her full statement was (para 85) “According to Mr White the same scenario happened with an electri- cian Nigel Brooks who carried out some electrical work at Mitre House in July 2014. He submitted an invoice for £2,095.20, but only got paid £ 1,200, and remains unpaid. I have subsequently been able