Page 1 - D-Day 6-6-17

From: Bruce R. Maunder Taylor brmt@maundertaylor.co.uk Subject: MITRE HOUSE, SW3
Date: 6 June 2017 at 10:32
To: Paul B_C studio@graffiti.biz
Dear Mr Brown-Constable,
Thank you for your email of 5 June addressed to Mrs Cook. The problem with the Management Plan is that, without seeing the detail of the financial history as previously requested (and now directed), we are not sure what provision to make in both the Plan and the draG Order about the financial situaIon which Michael Maunder Taylor will take on if appointed.
Having seen your latest leKer to the Tribunal, I have asked Michael Maunder Taylor to provide a Plan and draG Order on the assumpIon that any such Order (if made) will start with a “clean sheet” on the basis that no money or financial informaIon will be provided by you at the point of takeover. The draG Order should further provide for appropriate acIon to be taken to enforce disclosure of the missing documentaIon which you have now been directed to provide, which is likely to involve:
Firstly, asking the Tribunal to issue a Penal NoIce for the producIon of the documents. Second, an applicaIon to the County Court for a Court Order and costs.
Thirdly, if necessary (and I know of only one case in which it has been necessary) to make an applicaIon to the Courts on the grounds of contempt of court.
The Plan will therefore propose that the management funcIon will therefore be divided into the two aspects of this case:
1. Future management from the date of appointment (if appointed).
2. Past management concerning those relevant maKers which have occurred before any
such Order is made.
That should now therefore be concluded during this week and send to you.
Yours sincerely,
Bruce Maunder Taylor