Page 378 - FINAL MASTER 616pp 20-6-19

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swer any questions about how our money was spent on the 2014 refurbishment, and have failed to show any interest or to address the problems that have arisen.
91I am aware that this is not only my own view but is shared by many of the other leaseholders who attempted, back in 2014, to take over the management of the block via an RTM application. Sadly the nature of the building did not allow us to do so at that time, but the way the building is currently being managed is poten- tially very damaging to the value of our individual property interests as well as to the value of the freeholder's reversionary interest. This situation has now become intolerable and in the interests of justice it must be stopped.
92 Finally I should point out that I was born a French citizen and English is not my first language. I have there- fore been assisted in the preparation of this statement by my solicitor Mr Begg. However I am satisfied to the best of my information, knowledge and belief that the contents of this statement are true and accurate, being based on the facts and information I have provided to Mr Begg, and an extensive file of correspondence that I have accumulated over this difficult period.
(comment/reply) this Witness Statement is dated and signed 10 August 2016 - consequently all and any correspondence, emails, telephone conversations pre 10 August 2016 (of which there are many) of which all totally refutes what Mrs Hillgarth has stated in this signed and dated Statement yet Mrs Hillgarth has simply repeated all erroneous remembrances, accusations, innuendos, errors etc de- spite the evidence we have supplied in accompanying correspondence in support of our denials, all of which supplied prior to 10 August 2016....and this Witness Statement from Mrs Hillgarth.
This indicates either that our denials were not considered true or Mrs Hillgarth has not properly pe- rused our correspondence sent to her Solicitor prior to 10 August 2016 - it is simply not possible to have yet again made these same comments, observations, accusations and innuendos following all our correspondence with supporting evidence pre 10 August 2016 - in fact it’s quite incredible that Mrs Hillgarth has not confirmed that accusations she made via her Solicitor in his letter dated 23 March 2016 and subsequently, have all been thoroughly disproved with supporting evidence and not with generalities of hearsay, gossip, conversations etc.... but only with hard copy written emails etc.
And I make this statement conscientiously believing the same to be true.
(comment/reply) if and when examples of obvious lies, misinformation, false accusations, innuendos etc are exposed from our supplied correspondence with supporting evidence to date (or at least up until 10 August), Mrs Hillgarth’s “statement conscientiously believing the same to be true.” will be shown for what it is - a mish-mash of spiteful, vexatious and scurrilous observations all or most of which have previously been thoroughly disproved, or explained, or apologised for, or denied.
It should also be noted in further disputing Mrs Hillgarth’s credibility, that even whilst a Director of MHML she refused to comply with her lease covenants and by all accounts was also signing off her Tenancy Agreements thereby placing herself in a position of unlawful pecuniary advantage by claim- ing that such required consents had been received to sub-let.
It is not disputed by her that they had not been requested nor received.
Michele Hillgarth - signed and dated 10 August 2016
27 October 2016
Comments & Replies made by Mr Brown-Constable on behalf of MHML (Mitre House Management Limited)