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pBc PAUL N. BROWN-CONSTABLE
DESIGN & PROJECT CONSULTANT
7 MITRE HOUSE • 124 KINGS ROAD • CHELSEA • LONDON SW3 4TP TELEPHONE +44 (0)20 7589 2764 • MBL +44 (0)798 33 33 543 EMAIL: PAULBROWNCONSTABLE@ME.COM
composed 1 March 2019 with subsequent edits
I would make the following initial observations (most probably for the umpteenth time) of which most if not all are again covered somewhere in this tôme along with as ever comprehensive indisputable evi- dence in support of our denials to both your’s and your client’s ridiculous and vapid accusations.
PFC Begg Esq
Solicitor
9th Floor. Metro Building 1 Butterwick, Hammersmith
London W6 8DL
Dear Mr. Begg,
Further to all your substantial correspondence, threats, queries and innuendos since 1st January 2019 please find attached my equally substantial response to all accusations, queries and innuendos.
There are so many so I am only concentrating on a few crackers ignoring those that don’t even war- rant consideration, basement office, wandering around in my underwear, blackmail, intimidation, steal- ing lessees window monies, panelling my flat without permission, indeed using our AR Lawrence contractors to refurbish my flat as a benefit in kind etc etc to name but a few? Oh forgot, requiring Mrs Hillgarth to have a Police escort to collect some keys because I had told her we should always have a third party present as I didn’t trust her due to her constant denials of discussions and statements made - I still can’t believe she didn’t add sexual harassment, physical abuse or more likely racist innu- endos? Frighteningly I would have had no way of disproving unless in company....!
It appears from your recent faux-pas re: Wade (“Neither Mrs Hillgarth, nor anyone else, requested METER CUPBOARDS, PIGEON HOLES, SIGNAGE”. You seek to demonstrate that there were a number of items in the Wade quote (which you say – incorrectly - that Mrs Hillgarth sourced) which she was effectively insisting on, and with which you felt some obligation to comply. That, as you are well aware, is a misrepresentation of what actually took place.”
“Mrs Hillgarth introduced Wade as a good contractor, and that is all. She never requested any particular work to be done by them. The Wade quote (as also the one supplied by Hemi) were based on information which you gave to the individual suppliers. Mrs Hillgarth never worked on any of these schedules. You were in charge of the project and you were (exclusively) deal- ing with that process.”
Wrong on both erroneous observations as comprehensively proved in this tôme.
Your 21 January 2019 email: “As regards your point about the Property Redress Scheme, I can inform you that this was, as you might expect, our first port of call. However when they learned that the matter was the subject of civil litigation and potentially the subject of criminal proceedings, involving allegations of fraud, they said they had no authority to consider the matter. It was an issue for the courts to resolve.”
First port of call should have been both your’s and Mrs Hillgarth’s for our alleged refusal to supply year end accounts information having zero to do with fraud, embezzlement, stealing £29,000...? Mind you even that approach to PRS (something you accused us, along with Indemnity Insurance, or NOT hav- ing?) would have ended in a rebuttal as untrue as your client admitted in para 73 of her Witness Stmt.
Your 21 January 2019 email: “I have (re)read all the material you have (re)sent me with your e- mail of 20 January. The fact that you may have restated your position a substantial number of