Page 1 - 4_Begg to PBC 31-3-16 (2pp)

Paul Brown-Constable Esq; Flat 7, Mitre House
124 King’s Road,
London SW3 4TP
31 March 2016
Dear Mr Constable,
Mitre House Management Limited
I acknowledge receipt of your letter dated 29 March 2016 in which you ask for copies of various e-mails and letters referenced in my letter to you of 23 March 2016.
I have no intention of indulging you in what is plainly an attempt to delay matters. Most of the documents referred to are your own e-mails, or e-mail exchanges between yourself and other lessees at Mitre House. These should still be on your computer system. Failing that, they will no doubt be on the computer systems of your fellow directors. Should we find ourselves in civil litigation there will be a formal “discovery” period – subject to legal sanctions - allowed for disclosure and inspection of all relevant documents.
In my letter of 23 March 2016 I cited a number of instances which (in the absence of a proper explanation) suggested the possibility of fraud on the part of MHML and its directors. In offering you the opportunity to avoid criminal investigation by providing those explanations, I recognise the serious implications for yourself and your fellow directors. Therefore if you need further time to prepare a full explanation, you may have until close of business on Friday 8 April 2016.
On the other hand I am not prepared to postpone proceedings for an order for inspection of documents. Nor for an order under Sections 22-24 of the Landlord and Tenant Act 1987. Therefore I would be grateful if you would make clear, by no later than close of business on Tuesday 5 April 2016:
1. whether or not you are willing to allow inspection of the original invoices referred to in questions (a) to (d) of my 23 March 2016 letter, under the heading “Information”. (This inspection would need to take place at some time before close of business on Friday 8 April 2016, and to allow facilities for taking photocopies of relevant documents), and
PFC Begg
Solicitor
9th Floor
Metro Building
1, Butterwick Hammersmith London W6 8DL Tel: 020 8846 2705