Page 591 - FINAL MASTER 616pp 20-6-19 SOUND

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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
__________________________________________________________________________________
sUBseqUenT To THe order For disCoverY ALL THe serviCe CHArGe ACCoUnTs 2014 To dATe (JUne 2017) Were ALL sUppLied To MAUnder TAYLor on 23 JUne 2017 And inCLUded A FULL And CoMpreHensive 2012-2017 BreAKdoWn AnALYsis oF ALL inCoMe And expendiTUre inCLUdinG THe invoiCe FroM MHML To THe serv- iCe CHArGe ACCoUnT For £15,572.85 And noT £31,756.21 And A CoMpreHensive LisT AnALYsis oF THe £16,183.36 sUppLiers’ CosT
THis is noT THe FirsT TiMe YoU HAve repeATed THis erroneoUs ACCUsATion THAT “Paul Brown-Constable eventually admitted in writing that the sum of £31,765.21 had been “charged to the leaseholders by mhml in respect of the project” - on eACH previoUs oCCAsion iT WAs ALso denied As inCorreCT & AMBiGUoUs To ConFUse - And despiTe reqUesTs To evidenCe WHen And HoW i MAde THis sTATeMenT none HAs ever Been ForTHCoMinG - iT’s pATHeTiC JUveniLe or seniLe in YoUr CAse And pre- diCTABLe...iF YoU CAn’T FiGHT FAir...?
MHML proGressed “sAvinGs” As AGreed To Be ATTeMpTed AT THe 23 MAY 2014 BoArd MeeTinG. MHML spenT £16,183.36 on sUppLies And MATeriALs CosTs viA THe serviCe CHArGe. MHML invoiCed THe serviCe CHArGe £15,572.85 For WorKs And serviCes perForMed. Mr BroWn-ConsTABLe invoiCed MHML £7500 For THe CosTs He inCUrred & For THe WorKinGs He perForMed
35. The Second Defendant subsequently maintained in correspondence that, in so far as he had personally carried out and had been paid for work on the 2014 project, he had been acting as a sub-contractor of ar lawrence and Sons limited. This was not true, as has been con- firmed both by the managing director of ar lawrence and Sons limited and by the surveyor to the project.
A Considered response: i THinK YoU’LL Be More ACCUrATe in sAYinG THAT ALL AnY WorK THAT i personALLY perForMed WAs Under THe WATCHFUL eYe oF oUr sUrveYor, oUr FreeHoLder’s sUrveYor And oUr ConTrACTor’s siTe ForeMAn, siTe sUrveYor And THeir Boss, Mr TonY WHiTe, WHoM YoU HAve seen An eMAiL FroM HiM sAYinG He WoULd Be More THAn HAppY To ConFirM THe Good qUALiTY oF MY WorKinGs
35. in the circumstances, namely:
(a) that the scheme of work for the 2014 project was not carried out exclusively by the agreed contractor, namely ar lawrence and Sons limited, and
(b) that the Defendants had not tendered to carry out work in respect of the 2014 project, and
PleaSe reFer To aTTaCheD “AddendA/FUrTHer reFerenCes” iN SuPPorT oF argumeNT