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“HOW DID YOU THINK MHML WERE FUNDING THE NEW LIGHTING?”
duced the 2014 works’ programme of items not considered required or could be done more eco- nomically to make savings to be spent (not refunded) on items initially considered unaffordable and not listed nor costed for progressing within an agreed s.20 Notice dated 22 June 2014 without pre- advising leaseholders etc etc - previously denied and here again.
c) We (MHML but notably and only Paul Brown-Constable) allegedly ignored or refused lessee re- quests for information both during the works and subsequently to view YE2014 accounts documentation or indeed any year end accounts - previously denied and here again.
d) We (MHML but notably and only Paul Brown-Constable) allegedly “stole” leaseholders monies by progressing certain workings and charging for same to the Service Charge account
- previously denied and here again.
e) We (MHML but notably and only Paul Brown-Constable) allegedly attempted to hide the “stolen leaseholders money” by falsifying the YE2014 accounts - previously denied and here again.
f) We (MHML but notably and only Paul Brown-Constable) allegedly denied Mrs Hillgarth an alleged £3500 Dividend by winding up MHML - previously denied and here again.
g) We (MHML but notably and only Paul Brown-Constable) have some queried banking actions re- quiring explanation which allegedly indicate a possible theft of £29,000 from leaseholders - previ- ously denied and here again.
h) We (MHML but notably and only Paul Brown-Constable) are therefore allegedly in breach of “fraud by false representation”, fraud by failing to disclose information” and “fraud by abuse of posi- tion” and “making misleading, false or deceptive in a material particular” - previously
denied and here again.
Added to which can be added (again for the sake of simplicity) your “Particulars of Claim” which ap- pears to add”
ii) We (MHML but notably and only Paul Brown-Constable) reneged on a contract dated 26 June 2017 to the financial detriment of Mrs Hillgarth and other leaseholders - previously explained
jj) We (MHML but notably and only Paul Brown-Constable) failed to follow statutory requirements in respect of a consultation notice - previously denied and here again.
k) We (MHML but notably and only Paul Brown-Constable) departed radically from the scheme of work referred to in the s.20 Notice without the knowledge or consent of the leaseholders - previ- ously denied and here again.
ll) We (MHML but notably and only Paul Brown-Constable) performed works that had not been costed/quoted/tendered, were not authorised to do, nor be paid for doing, and the decor was not consistent with the scheme approved by the leaseholders, some workings not carried out to the re- quired standard or at all and finally, workings that were carried out were “shoddily performed” and not up to the standard which leaseholders were entitled to expect from professional craftsmen and contractors? - previously denied and here again.
m) We (MHML but notably and only Paul Brown-Constable) are therefore required to compensate Mrs Hillgarth £25,000 for costs and expenses to date but do not include Damages in tort for deceit (TBA) nor her legal fees to date nor indeed, were her accusations and innuendos true, one might expect the other leaseholders to also make claims for their fair shares too,
resulting in an additional £11,514 paid to another eight leaseholders including myself...?
Best of British luck “as I’m having trouble paying the £10,000 a year annual outgoings?”
n) We (MHML but notably and only Paul Brown-Constable) was reminded of all above in an email
from Mrs Hillgarth dated 2 Jan 2019 copied to all lessees stating libellously:
“I suspect that with all the amount of money you stole from your [the] leaseholders over the years of your management you have plenty of money to survive “
PLEaSE rEFEr to variouS attaCHED “PDF/FuRtheR ReFeRenCes” in SuPPort oF arguMEnt