Page 586 - NEW FINAL 616 BIG BAD BEGG

-10-
in THe WesT London CoUnTY CoUrT - Case No: [ ]
Mrs MiCHeLe HiLLGArTH - Claimant
versus
MiTre HoUse MAnAGeMenT LiMiTed - First Defendant and
pAUL BroWn-ConsTABLe - Second Defendant
and
seGAr KArUpiAH - Third Defendant
and
JAMiL rAJA - Fourth Defendant __________________________________________________________________________________
pArTiCULArs oF CLAiM
__________________________________________________________________________________
WHiCH THeY HAd Been soMe eiGHTeen MonTHs previoUs. As For FrAUd, We Consider THAT LiBeLLoUs. THe Mrs HiLLGArTH WAs AsKed TWo qUesTions on oATH, BoTH oF WHiCH sHe denied, nAMeLY HAd sHe soUrCed TWo qUoTes FroM WAde (Yes sHe HAd) BUT denied sHe HAd, And seCondLY, HAd sHe AGreed in A MHML BoArd MeeTinG on 23 MAY 2014 in THe presenCe oF Her TWo Co_direCTors, Mr seGAr KArUpiAH And Mr pAUL BroWn-ConsTABLe THAT sHe exCLAiMed “WeLL THen everYBodY WiLL Be HAppY” WHen iT WAs expLAined To Her THAT sAvinGs CoULd Be MAde FroM THe WorKs’ Tender CosT To spend on iTeMs noT sCHedULed To Be done As THeY Were iniTiALLY Considered UnAFFordABLe As Her WAde qUoTes MAde ABUndAnTLY CLeAr?
31. Nor did the internal scheme of work as ultimately carried out by the First and Second De- fendants and their sub-contractors comply with the scheme previously agreed with the Claimant and other leaseholders. it involved an entirely different colour scheme, included certain addi- tional works which had not been approved, but excluded certain works which had been ap- proved and which the leaseholders had expected to be undertaken.
A Considered response: AnsWered ABove And TrUe THAT As LAndLord, MHML proCeeded And proGressed THe WorKs To A sATisFACTorY ConCLUsion on BUdGeT on sCHedULe To THeir FreeHoLder’s sATisFACTion
32. When the leaseholders discovered that the Second Defendant had been carrying out work on the project himself they demanded details of who had been paid how much and for doing what in relation to the 2014 project. The Second Defendant consistently refused to supply this information.
A Considered response: AnY reqUesT For inForMATion MAde dUrinG THe WorKs’ proGrAMMe WAs repLied To BY reTUrn AdvisinG enqUirers To AWAiT pUBLiCATion oF THe Ye2014 ACCoUnTs And THen perUse And MAKe qUeries AT LeisUre
Mrs HiLLGArTH’s sCUrriLoUs ACCUsATion THAT MHML iGnored or reFUsed Her And oTHer Lessees reqUesTs To vieW Ye2014 ACCoUnTs inForMATion Were reFUsed or iGnored WAs ALWAYs denied BY Me And MY deniAL proved TrUe in Mrs HiLLGArTH’s oWn WiTness sTATeMenT WHere sHe sTATes in pArA 73 THAT neiTHer sHe nor AnY oTHer Lessee MAde A reqUesT WiTHin THe sTATUTorY six MonTHs period As sTATed in Her LeAse - And everYBodY eLse’s LeAse
PleaSe reFer To aTTaCheD “AddendA/FUrTHer reFerenCes” iN SuPPorT oF argumeNT