Page 2 - 17_Begg 11-5-16 to PBC to Begg OCR_11-5-16 (5pp)

Rubbish. The offer was not withdrawn it was ignored by you and Mrs Hillgarth. The offer is still and always was offered save for your confirmation that all nefarious malicious and untrue statements made in your thoroughly inappropriate and lengthy 13pp diatribe of 23 March 2016 are withdrawn and confirmed as such following the evidence we’ve conclu- sively provided to the contrary which is indisputable.
2. You are deluding yourself if you think Mrs Hillgarth will pay for your "time and costs" for dealing with this correspondence. And if you seek to offset your spurious "charges" against dividends owed to her, as you did before, this matter is headed for the courts. Once proceedings have been started, the courts have discretion to award costs (from the start of proceedings only) in line with the merits. But for the time being Mrs Hillgarth has no more obligation to pay your costs than you have to pay mine.
I think not. You are delusional if you think you can make the accusations you have done against myself and MHML without we recovering our costs in defending our positions and supplying at our expense the evidence to disprove your claims, not for the first time as all were in the voluminous correspondence you have so unwisely perused.
3. You refer to certain alleged breaches of covenant on the part of Mrs Hillgarth which are apparently concerning you. These appear to relate to a letting without consent (which you correctly assess as waived by your acceptance of service charges), a cat which has long since gone, a floor which by agreement with the tenant below is covered by rugs in lieu of a carpet (a trivial issue which again has effectively been waived by lapse of time), and bizarre references to dilapidations and to breaches of the headlease which are unparticularised.
I will leave that to the courts to decide thank you. Mrs Hillgarth has until 5 June to comply I believe with reference to our solicitor’s letter dated 29th April 2016
You are correct in your assessment that the court will not order forfeiture for any of this and I await with curiosity to see what the court will make of your action for "specific per formance". (Performance of what exactly?!) If you choose to waste your money on legal fees in this fashion there is little I can do to stop you.
I can assure you it’s not my money, as your client is, as you well know in breach and all costs incurred will be hers without a doubt, so please no more futile observations. As regards the point of law, I have not got the faintest idea, it’s just the advice given to me.
4. You have charged the leaseholders a total of £105,877 for the 2014 refurbishment and the leaseholders are entitled to see the relevant invoices (by which I mean the supplier invoices rather than your MHML invoices) and to verify that their money was spent in the agreed manner. I note that you are now raising a technical defence to justify your refusal to hand over these invoices, which have been requested on more than one occasion (and by leaseholders other than Mrs Hillgarth).
Well noted. It’s call legal advice. And to be perfectly truthful, I haven’t got the faintest idea whether this “technical defence” is valid or not. I’m simply advised it is in this instance. Maybe you know better in which case let me know and you’ll have your famous (now)13.
Whether or not this latest ploy will buy you a temporary respite from the obligation to pro- duce the invoices is a matter for RBKC and Mr Belafonte. However you must appreciate that your determination to avoid showing the leaseholders how their money was spent (including your recourse to legal advice in support of your stance) simply fuels their suspicion that an offence has been committed.