1_Letter from Begg 23-3-16 (13pp)

Paul Brown-Constable Esq; Flat 7, Mitre House
124 King’s Road,
London SW3 4TP
23 March 2016
Dear Mr Constable,
Mitre House Management Limited
I act for Mrs Michele Hillgarth, the leaseholder of Flat 5, Mitre House, and am writing to you formally on her behalf.
I am writing to you in your capacity as a director and shareholder of Mitre House Management Limited (“MHML”), the owner of the head lease and the manager for the time being of the nine leasehold flats in the block. I am also copying this letter to your co-directors Segar Karupiah (Flat 2) and (through Dima International Limited) Jamil Raga (Flat 6).
Mrs Hillgarth bought her flat in August 1985 and is the longest-serving leaseholder in Mitre House. You will be aware that since January 2012, when MHML assumed responsibility for the management of the block, she and other leaseholders in Mitre House have been extremely dissatisfied with the manner in which you and MHML have conducted its management. And they remain extremely dissatisfied with the way you are continuing to conduct it now. This has to stop.
I hope to convince you and your co-directors to step aside from the management of the block without the necessity for a court order. However Mrs Hillgarth and other leaseholders intend (should this prove necessary) to pursue the legal process provided for in Sections 22-24 of the Landlord and Tenant Act 1987 to have a new manager appointed. The issues laid out below in this letter will provide the “matters relied on by the tenants” in support of a formal application to the First-tier Tribunal (Property Chamber). (This body has replaced the old Leasehold Valuation Tribunal). By this letter I am inviting your response to these issues, in the absence of which they will be presented to the Tribunal as fact.
I have recently completed a detailed review of the files retained by Mrs Hillgarth of her voluminous correspondence with yourself and other leaseholders over the past few years. I am
PFC Begg
Solicitor
9th Floor
Metro Building
1, Butterwick Hammersmith London W6 8DL Tel: 020 8846 2705