Page 7 - 2-6-17 Disclosure & Reply 3-6-17

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This 23 March 2016 letter made clear demands and statements (item 4c): Inspection of Invoices
Under Section 22 of the Landlord and Tenant Act 1985 Mrs Hillgarth has the right to inspect accounts, receipts, and other documents supporting the accounts summary, and you are obliged to afford her reasonable facilities to do so, including the ability to take copies or extracts. Since you have consistently denied her this information she has asked me to undertake this on her behalf.
And further insisted (item 4d): In any event please respond to this letter by no later than close of business on Thursday 31 March 2016. Should you fail to do so the consequences referred to above will ensue.
3_ Nevertheless, in a reply from MHML )”PBC”) dated 1 April 2016 to “MH’s” Solicitor we offered to fully comply as requested, stating:
(item 4): We have all original invoices referred to in your 23 March 2016 letter available for inspection. We also have photocopies of all invoices. I suggest we have both originals and copies couriered over to your office requiring only the originals to be returned after satisfaction.
4_ Despite our offer to comply and the tight deadline, no acknowledgement was received as stated in a further reply from ourselves (“PBC”) dated 8 April 2016 making clear our robust denial of the various accusa- tions which accompanied the simple request for documents in the 13 page letter of 23 March 2016:
(item 5): In the absence of a reply to my [“PBC”] letter of 1 April 2016, midday Friday 8 April], offering to courier over the requested (in your 23 March and 29 March 2016 letter) original invoices and copies to meet your dead- line of 8 April 2016 close of play, we are presuming this is not acceptable in this instance.
This does somewhat evidence what we have experienced with Mrs Hillgarth to date as no doubt we will be fur- ther chastised for something or other despite our best efforts to oblige.
In the interim it would be appreciated to receive confirmations and apologies for some of the various and untrue accusations which we list below evidencing an incompetence on an industrial scale by Mrs Hillgarth.
As such and until you have progressed our reply with Mrs Hillgarth to ascertain the invalidity of her various accusations against the validity of our replies below we are not willing to entertain further requests for any infor- mation from you or Mrs Hillgarth until such time as we receive a satisfactory response, [an admission that she was incorrect on each item as mentioned] as it is ourselves [MHML] it would appear, who are being vilified for no other reason than Mrs Hillgarth’s inability to comprehend replies, facts as stated, explanations and relevant documents as requested and supplied.
5_ Subsequent to these two letters another 68 have been sent and replied to (including “MH’s” Solicitor contacting Royal Borough of Kensington & Chelsea legal dept., and our Freeholder’s legal dept., both of whom were satisfied with our responses with documentary evidence). We have made the same denials to the various accusations made in the initial 23 March 2016 letter, with the same attachment evidence (as indeed will be exactly the same in our “bundle” of Statement of Case (our defence). All the correspondence from both “MH” and her Solicitor kept insisting on ourselves MHML (“PBC”) having refused or ignored requests from “MH” and other Lessees to view documents from our year ended 2014 Accounts, all of which we continued to deny and when evidence of such was requested, it was ignored.
6_ On receipt of “MH”s” Solicitor’s initially supplied Section 22 Notice dated 10 August 2016 on 26th August 2016 (well prior to that issued to the Tribunal on 7 April 2017) it included “MH’s” Witness Statement dated 10 August 2016 and on Paragraph 73 she admits (item 4): I think many of the lessees, including myself, were so completely exasperated and exhausted with dealing with him that we failed to take advantage, within the prescribed period of six months from the date of the service charge accounts, of section 22 of the Landlord and Tenant Act 1985 to inspect the invoices supporting MHML's service charge accounts summary.
7_ MHML (“PBC”) had spent five months (23 March 2016 to 26 August 2016) maintaining that no requests had been made within the allotted period despite multiple references from “MH’s” Solicitor maintaining there were numerous. “PBC” also responded with requested information over other matters (which in truth he did not legally have to supply if relying on the 6 month statute) but continued to insist on the various serious allegations made by “MH” be confirmed as disproved. None was forthcoming.