Page 3 - 37_PBC to Segar_16-6-16 (1pp)

of required dry weather for the solar painting to be applied to the whole roof area. Foreman Eddie will confirm I’m sure. I do remain somewhat suspicious of Tony’s Witness Statement, reading as it does, like he’s simply signed a document conveniently composed in part by you?
b) reference to not paying our Electrician, Nigel Brooks. I think it can be established and confirmed by Tony White that AR Lawrence were so impressed with our Electricians, that they purloined them leaving us high and dry. Our extensive new electrics were finished off by our backup sparks with supporting invoices obviously. Nigel Brooks accepted our explanation (I am presuming) as we did not hear back following his request for final part payment in April 2016 – and yes I have full supporting evidence. Again, this is an extraordinary additional item on the Witness Statement as surely both AR Lawrence and Nigel Brooks could have both been in their rights to pursue us legally for unpaid debts. We were never further contacted over and above my email reply to Leo White on 8 September 2015 and to Nigel’s bookkeeper on 16 April 2016 (some two years after we had initially paid Nigel his first invoice). We have never ever been in default on received invoices, ever, as indeed our prompt by return payments to AR Lawrence and our Surveyor and indeed any of our sub-contractors will attest to. It would hardly be acceptable to our Freeholder, nor indeed to my fellow directors, or our lessees, if we ran up a bad credit rating or ended up in the small claims court – or worse!
c) Most importantly, the reference to the replacement main Water Tank is thoroughly disputed as a perusal of our Surveyor’s Schedule of Works does NOT indicate inclusion and I think Tony White can reconfirm that the Water Tank was not in their remit nor were they participants in its replacement. The Schedule of Works was drawn up in December 2013, yet the Water Tank wasn’t inspected by Houseman’s until mid way through the works in 2014 so could hardly have been an item listed in the Schedule of Works drawn up almost 10 months earlier. This particular point adds further suspicion to the Witness Statement’s veracity and authenticity I would propose.
d) Why you would send a Witness Statement to only my fellow co-directors but not to me is also rather unethical under the circumstances. It was established from day one in your letter 23 March 2016 that I have the responsibility for any misfeasance and indeed you make it again abundantly clear in your covering letter with the Witness Statement to both my fellow directors. As such, how did you expect them to reply with the same detailed comprehensive rebuttals as I have done, yet again, to your scurrilous innuendos? And to meet a deadline that Frankie Dettori would have had trouble meeting? Divide & Conquer or another devious ploy?
Further references in Tony’s Witness Statement to finances and shortages etc are pretty much as explained ad nauseum in previous correspondence not only with you but in reams of previous emails
with lessees
i) ii)
iii) iv) v) vi)
most pertinently Mrs Hillgarth namely:
the final amounts for all tenders on the final approved Section 20 included vat and fees. all tenders were made from the exact same Schedule of Works dated December 2013 drawn up by our Surveyor.
all tenders, costs and companies were posted on our website with all our Surveyor’s correspondence from day one – and notified to all lessees including Mrs Hillgarth
the December 2013 Schedule of Works was posted on our website and sent to lessees on request including Mrs Hillgarth four or five times
a full and comprehensive analysis of all tenders/costs per item was supplied to lessees (without request) and posted on our website
full and explicit instructions was relayed to all lessees including Mrs Hillgarth as to how to read the Schedule of Works against the full analysis of all tenders (ie – if you wanted to