Page 383 - FINAL MASTER 616pp 20-6-19

From: Paul B_C studio@graffiti.biz
Subject: Re: Mitre House SW3 LON/00AW/LAM/2017/0011 BRMT/BHC
Date: 22 May 2017 at 12:01
To: Bruce R. Maunder Taylor brmt@maundertaylor.co.uk
Dear Mr. Maunder Taylor -
Yes indeed, and my apologies but to be fair I did advise you in my email of 27 April 2017.
You will note from that email a vast amount of references supplied to Mr Begg in reams of correspondence since 23 March 2016 for the sole purpose of disproving the multitude of accusations levied against MHML and myself in his thirteen page letter of 23 March and subsequently including the s22 Notice as served on ourselves by the Tribunal dated 7th April 2017.
What is significant about Mr Begg’s s22 Notice is that it only includes the following references; 55 pages of our website plagiarism: Mrs Hillgarth’s and Mr White’s Witness Statements; the 23 March 2016 letter from Mr Begg to PBC; Section 20 Notice dated 22 June 2014 (and 15 March 2014); Service Charge Accounts YE2014; letters from PBC to Mr Begg dated 10th, 14th, 30th June and 7th July (both received from Mr Begg and replied to Mr Begg) and one email from me to Mrs Hillgarth dated 11 September.
As you and the Tribunal will appreciate, despite the fact that all the items supplied are in our opinion more help to our defence than to the applicant’s case, we can hardly expect the Tribunal to fully comprehend our extensive and comprehensive responses with hard copy references to Mr Begg since his letter of 23 March 2016 and Mrs Hillgarth since 2011 if those replies and hard copy references are not included in Mr Begg’s s22 Notice which they patently are not save for the five letters above.
As a further example. Mr Begg’s 23 March 2016 letter was fully replied to, paragraph by paragraph, with supporting hard copy evidence (as indeed were all his other lengthy letters) but none of those replies are included in his bundle save for our replies on his 21 June letter (reply dated 30 June). As such we are obliged, surely, to include those replies and the attendant hard copy references in our bundle which regrettably runs to 13 Folders of relevant evidence in support of our defence to the following accusations:
(i)_ Multiple requests from the Applicant and other Lessees for information from the year ended 2014 Accounts summary within six months of their publication which the Respondent refused to comply with?
(ia) These accusations were robustly denied for months and repeated for months including to third parties, RBK&C, our Freeholder and Macfarlanes, Scotts Group and other lessees, but subsequently in (para 73) of the Applicant’s own Witness Statement she admits: "...we failed to take advantage, within the prescribed period of six months from the date of the service charge accounts, of section 22 of the Landlord and Tenant Act 1985 to inspect the invoices supporting MHML's service charge accounts summary.”
(ii)_ Despite multiple denials with supporting bank statements, both the Applicant’s Witness Statement and Mr White’s two Witness Statements (the first was revised after initial comment) contained an accusation that MHML had not paid an electrical supplier and was refusing to pay another. Mr White’s initial Witness Statement also contained a reference to the Water Tank installation which was not true.
(iia) Mr White admitted in a series of emails dated 15 June 2016 that: "You are correct about the tank,
I only said to Michel that I thought it was in the first draft which I did not retain as it was void.(she
wrote the statement, I just signed) However I am back next week and will look into the statement and see what can be done. Possibly a further statement agreeing that the other works done by yourself and others was up to a good standard in my view.
(iii)_ The Applicant’s Witness Statement contains 92 paragraphs of various accusations spread over 20 pages, requiring each to be addressed yet again with supporting hard copy evidence, as indeed each and every one has previously been explained or denied with hard copy evidence in previous correspondence with Mrs Hillgarth direct or Mr Begg since 23 March 2016 but as you will note none were included in Mr Begg’s s22 bundle:
(iiia) Evidence supplied showing Mrs Hillgarth’s approval of attempting to manage Mitre House (iiib) Evidence supplied disproving unsubstantiated verbal conversation
(iiic) Evidence supplied disproving statement of “vital to his plan”
(iiid) Evidence supplied reminding Mrs Hillgarth of her Director’s responsibilities and company policy (iiie) Evidence supplied denying petty complaints (MHML from Flat 7)
(iiif) Evidence supplied denying petty complaints (Basement Office) (iiig) Evidence supplied denying petty complaints (the website) (iiih) Evidence supplied denying alleged majority (decor & finance) (iiii) Evidence supplied denying petty complaints (vote rigging) (iiij) Evidence supplied denying misuse (s20 Notices)
(iiik) Evidence supplied denying petty complaints (non availability on www) (iiil) Evidence supplied denying petty complaints (quotes incl. vat & fees) (iiim) Evidence supplied denying petty complaints (PBC workings)
(iiin) Evidence supplied denying petty complaints (PBC shoddy workings)