Page 4 - 81_COURT ORDERS OCR _1-11-16 (from 8-8-16)

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11 Mr Brown-Constable (one of the directors of MHML) blackmailed and intimidated, or attempted to black- mail and intimidate, one of the leaseholders at Mitre House
(comment/reply) already well covered in previous correspondence - Blackmail & Intimidation - refer to your client’s Witness Statement for further clarification - if ever the Tribunal needed an excuse to throw this application out for wasting its time - this too will do it.
12 The said refurbishment of the Property has demonstrated the gross incompetence and negligence of MHML and its directors, and their unsuitability/inability to manage this Property or any other property.
(comment/reply) rubbish - an uneducated and subjective personal opinion and totally unsubstan- tiated by any other person known to MHML
13 MHML (through one of its directors Mr Brown-Constable) has been grossly and persistently rude and abusive to individual tenants and leaseholders.
(comment/reply) already well covered in previous correspondence - inappropriate language - fully apologised for but made clear than there were extenuating circumstances all as previously ex- plained in previous correspondence and by the end the Tribunal gets to the end of this report they will most likely concur!
14 The leaseholders/tenants have reasonable grounds for suspicion that in the course of the said refurbish- ment Mr Brown-Constable (one of the directors of MHML) enjoyed a private benefit at the expense of other leaseholders/tenants.
(comment/reply) already well covered in previous correspondence - an example of your client’s dishonesty in spreading malicious, vexatious, false information.
15 One of the directors of MHML (Mr Brown-Constable) has used certain common parts of the Property as his personal office and for running a business contrary to the terms of his own lease and the head lease.
(comment/reply) already well covered in previous correspondence - another example of your client’s dishonesty in spreading malicious, vexatious, false information.
16 Directors of MHML have improperly remunerated themselves at the expense of the leaseholders for time incurred by MHML and its Directors in dealing with a “Right to Manage” application (the purpose of which was to displace MHML as manager of the Property).
(comment/reply) already well covered in previous correspondence - you mean debiting your client from monies due from her to MHML from monies due to her from MHML - your client’s credit rat- ing will be further examined at the Tribunal as we experienced previous defaults from your client
17 as previously advised.
The landlord is in breach of many aspects of the Code of Practice approved by the Secretary of State under Section 87, Leasehold Reform, Housing and g Urban Development Act 1993 - see in particular the Service Charge Residential Management Code - some of these breaches being listed in Schedule Three below.
18 Other circumstances exist which make it just and convenient for the appointment of a properly qualified professional manager to manage the Property.