Page 10 - 2-6-17 Disclosure & Reply 3-6-17

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In Summary: We had offered to comply on 1 April 2016 despite not being legally required to do so under the terms of all our leases. The offer was ignored but as “MHML” and (“PBC”) had also been accused of a multitude of sins too many to mention again but included such serious ones as Blackmail and Fraud we decided to with- draw our offer to comply until such time as we be confirmed as exonerated based on our replies with supporting evidence in support of our denials. None was ever forthcoming, in fact further accusations were added and those, too, were dismissed as fictitious with again supporting evidence and documentation.
As regards the Application for Disclosure (full and comprehensive accounts information from 2014 to date), we consider to have no relevance to the points under contention and most especially, if indeed an Application for Disclosure were successful we, MHML and “PBC” will have spent over 12 months fielding accusation after accusation which continue to be levelled against us and would remain unresolved, despite our fair responses with supporting evidence, and consequently we would therefore be left with all alleged malfeasance or indeed misfeasance, still to be adjudicated, which we hope we can do when attending the Tribunal on 26 and 27 July with our (exact same) evidence as that notified to “MH” and her Solicitor since 23 March 2016 (and our Freeholder’s Solicitors, Macfarlanes and RBK&C legal team - both of whom were content with our truthful expla- nations with again supporting evidence). It is only “MH” who stubbornly remains unconvinced because of MHML’s stated insistence she conforms to her various lease covenants which again she stubbornly refuses to do despite requests to do so.
As such please be advised we oppose the application made by Mr B R Maunder Taylor in his letter dated 26 April 2017 for a formal order under Rule (20)b of the Tribunal Procedure (First-Tier Tribunal) (Property Chamber) Rules 2013 for the reasons stated above with supporting documents. If indeed the accusation of fraud were still to be progressed it would seem somewhat obtuse seeing as there remained in the bank on 31 December 2014 funds well in excess of those expected and certainly impossible for “MH” to profer the possibili- ty that none exist, which is what she has reiterated to date and still does in correspondence from her Solicitor..
I am hopeful the Tribunal will appreciate I am not legally proficient and as such allow me some latitude if indeed my presentation of correct wordings here and there are incorrect and not as legally proficient as normally pre- sented. And my apologies for what might appear to be a tardy response but I did inform the Tribunal of the rea- son and understood it was accepted. (items 1, 2 and 3):
We also comment with reference to (b) and (c) on the Tribunal letter (item 1):
(b) we do not agree to allowing access by Mr Maunder Taylor to inspect the financial documents listed at a rea- sonable time in office hours by 15 May 2017 for the reasons as described above in Paras 1-16 and in the Summary.
(c) we do object to an order for production of the listed documents being made under Rule 20 for the reasons as described above in Paras 1-16 and in the Summary.
I confirm that I make all the above statements concientiously believing all to be true and I am fully authorised to make these statements on behalf of Mitre House Management Limited (the company and respondent).
Yours faithfully,
Paul Brown-Constable
c.c Mr B R Maunder Taylor