Page 2 - 63_PBC to Begg_20-10-16 (2pp)
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“.....Christopher Lee Pemberton from Flat 8 (since May 2015) ....pressed Mr Brown-Constable, without success, to provide relevant details of the refurbishment work carried out and a proper breakdown of the "reserves utilised" figure”. (Your same type reference to Mr Fortunati’s alleged request was also denied and dis- proved with evidence as being totally false, in previous correspondence).
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Organising and canvassing other lessees for an RTM application in full knowledge (one supposes) of the 25% ruling. Or one might have expected her Solicitors to have reminded her before involving her and other lessees in futile costs.
And in truth her recall of actual events has been proved suspect anyway but is further brought into doubt by her recent email demand to attend my flat with her Solicitor on Wednesday 11 October. It was actually Wednesday 12 October.
References such as non-payment to BES/Nigel Brooks (untrue, he was fully (over)paid), misappropriating lessee Window monies, informing lessees that I am using AR Lawrence for my flat refurb, informing lessees that our Fire Safety requirements are not fully complied with, maintaining that no additional works were expected....need I go on?
Mrs Hillgarth’s credibility is suspect on almost all points raised but I do note she admits in her Witness Statement that her request to view invoices from our 2014 accounts was well out of permitted time, but then accuses me of wandering about in my underwear frightening her tenant!
I would also remind you of your telephone call to me on 28th July in response to my 20th and 27th July letters requesting to peruse Mrs Hillgarth’s alleged Witness Statement (subsequent to the fiasco of Mr. White’s somewhat con- fused version) when you made quite clear that “I am not prepared to send you the Witness Statement [Mrs Hillgarth’s] or wait any longer etc.”
I note that Mrs Hillgarth’s 20pp Witness Statement is dated 10th August (and signed and sent from abroad) meaning it wasn’t even in existence on or around 20 July, and certainly not when you refused my request to view on 28 July hav- ing stated in was in existence as way back in mid July. I note also the editing and re-issuing of Tony White’s Statement, but alas, both Mrs Hillgarth’s and Tony White’s (revised) both contain errors and untruths which I will respond to in and on your Preliminary Notice with as usual supporting documentation.
I fully appreciate that your stated focus of interest is (recently, if I’m to believe your three phone messages) only the demanded “works 2014” invoices (originals not copies) but seeing as your client made her request outside of the 6 month statutory period and also added insult to injury by making scurrilous and totally untrue accusations all of which you have repeated yet again in your Crime Report and yet again in your Preliminary Notice (on which I will be making my replies and responses) despite previous correspondence from me with fully supporting comprehensive denials, I am yet again required on behalf of MHML to robustly make clear yet again comprehensive responses to all your points made in all correspondence to date, including your Crime Report and the Preliminary Notice, and again with fully sup- porting documentation. If it is simply sight of documentation of the “siphoned off” monies, as you infer in a particularly inflammatory and totally erroneous vernacular, then I suggest you further refrain from repeating the same accusations and innuendos initially levied in your 23 March 2016 letter (and all denied/explained/in detail with supporting evidence), and subsequently in all other correspondence including your Draft Crime Report and Preliminary Notice. We, too, have made requests which have all been totally ignored as was our initial offer to comply. A compliance which would hardly indicate any reservations on our part in supplying your requested invoices. Your other insinuations were unnecessary.
I note you have now added “Blackmail” to your list of misfeasances or is it more a malfeasance, which wandering around in my underwear to the discomfort of your client’s illegally installed tenant, would certainly be considered.
If true?
And finally having to put up with Mrs Hillgarth’s risible attempts at involving Mitre House Lessees, yet again, in her futile attempt at maligning MHML and myself in pursuit of her own selfish agenda to better benefit her business of sub-letting Flat 5 Mitre House despite being in contravention of her lease covenants and quite possibly passing-off fraudulently signed Tenancy Agreements.
You’ll have my comments on your Preliminary Notice and our response to your demands before next Friday 28th. Yours sincerely,
Paul Brown-Constable
cc Segar Karupiah/Dima International Ltd
encl. Crime Report+supporting docs
Misc recent correspondence from and to Mrs Hillgarth


































































































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