Page 438 - FINAL MASTER 616pp 20-6-19 SOUND

what he says, has actually not been touched. I have no idea what is meant by “artefacts grills” – again that could mean anything - but if this refers to the painting work on parts of the lift (which was a very cheap DIY job), I know this cost him only £120 in total. He claims to have “replaced all brassworks throughout the building” but mostly they have just been polished. What brasswork has been added is of very poor quality. Some of the items are hardly worth mentioning because they cost, or should cost, so little. For example “changing the rear locks” could only have cost some £20, and “buttoning on interior cupboards” can hardly be a big deal either.
Mrs Hillgarth continues: “Some of the items (eg “the BT wiring” and “the lighting and electrics [by qualified NICIEC electrician]”) were possibly in the original specification under the elusive heading of “various joinery and re-wiring”, and if they were not, they should probably have formed part of the normal running of the building, and have been included in the regular annual service charge. He [Paul Brown-Constable] talks about “installation of signage throughout the building” but most of the signs and notices existed already and they are very cheap. I am not clear what he [Paul Brown-Constable] has done to “the handrails”, (which were also included in the specification) but according to one of the other leaseholders the handrail is too short and discontinuous, and actually quite dangerous”.
Mr Brown-Constable concluded his list airily “and probably a lot more”. This seems a necessary addition because, even on the most generous interpretation, the entire list of items he has referred to above could not conceivably, in the view of Mrs Hillgarth, have cost more than, say, £5,000. It could not possibly have amounted to the sum of £31,765.21 which Mr Brown- Constable admits (in his letter dated 30 June 2016) to have been charged by “MHML and their various sub-contractors”.
Reply: Statements, opinions, observations and innuendos above are typical examples of Mrs Hillgarth’s ignorance, spite and contrariness directed towards Mr Brown-Constable and MHML since June 2011 when it was proposed to attempt the purchase of the Head Lease at auction.
By way of explanation of his role (and no doubt to justify the lack of disclosure to the leaseholders) Mr Brown-Constable claimed in a letter to myself dated 10 June 2016 – see Item 12 of the Schedule) that he was doing the work as a sub-contractor of AR Lawrence or under their supervision. He says that had his work been of “substandard or unprofessional quality .....it would have been required to be corrected by both AR Lawrence and our Surveyor.” This is denied absolutely by Tony White (see Mr White’s Witness Statement at Item 5 of the Second Schedule). According to Tony White, Mr Brown-Constable was not in fact, as he had claimed, working as a sub-contractor of AR Lawrence or under their supervision. AR Lawrence operatives may well have seen what Mr Brown-Constable was doing, but they were in no way responsible for his work in the way Mr Brown-Constable had suggested. Nor were they in a position to object to the person who was employing them.
Furthermore in an e-mail dated 2 April 2015 at 14.17 the surveyor employed by Mr Brown- Constable for the refurbishment (from Boyce, Evens & Carpenter) wrote that he could only sign off “in respect of those works carried out by AR Lawrence under my direction as contract administrator”.