Page 385 - FINAL MASTER 616pp 20-6-19

Wade interior specs (all on hard copy in bundle)
(vi) Mrs Hillgarth’s insistence of having contractor’s original invoices as opposed to her percentage
share raised by MHML (all on hard copy in bundle)
(vj) Mrs Hillgarth’s and other lessees disregarding MHML’s advice to await year end accounts and
request sight of all documents (all on hard copy in bundle)
(vk) Mrs Hillgarth’s insistence that she and other lessees were denied sight of 2014 accounts
documentation (all on hard copy in bundle or para 73 in her Witness Statement)
(vl) Mrs Hillgarth’s ignorance in not having properly perused the 2014 accounts showing £16,201
carried forward in Reserves as opposed to the predicted £11,243 and made clear in the letter dated 8 June 2015 accompanying the accounts (all on hard copy in bundle)
(vi)_ And in Summary - outlined in previous correspondence a dozen times with supporting hard copy evidence:
(va)_Did Mrs Hillgarth source quotes from Wade & Hemi for “expensive additional internals works” in July 2012 and January 2013 - Yes or No?
(vb)_ Were those quotes posted on our website alongside other independent single contractor quotes (and still there!) - yes or No?
(vc)_ Did the Wade & Hemi quotes average approx £60,000 including vat and fee - Yes or No?
(vd)_ Did MHML make clear the £60,000 outlay could be halved if individual contractors be used as opposed to a main contractor using sub-ciontractors - Yes or No?
(ve)_ Did MHML suggest firstly a £25k budget followed by a £37k budget after adding some of the “expensive additional internals works” - Yes or No?
(vf)_ Did MHML post on the website these £25k and £37k specifications on the website alongside Wade’s quotes - Yes or No?
(vg)_ Did Mrs Hillgarth make an RTM application in June 2013 stating reason (as per her RTM Solicitor's letter 2 July 2013) to adopt Wade as contractor for Internals works - Yes or No?
(vh)_ Did that RTM fail due to the 25% ruling which Mrs Hillgarth had advised was the situation to all lessees in an email on 7 April 2011 (in bundles) yet still proceeded- YES or No?
(vi)_ Did Mrs Hillgarth pay her Solicitors for their due diligence in her RTM application seeing as they obviously were unaware of the 25% ruling and let her proceed - Yes or No?
(vj)_ Did Mrs Hillgarth’s RTM Solicitors demand MHML withdraw an s20 Notice which delayed the Internals for another year - Yes or No?
(vk)_ Did Mrs Hillgarth still insist on using Wade’s £60,000 quote but with no additional funding to be collected for interior budget for 2014 but to use existing Reserves which were adequate
(£85,000) and then do Externals in 2015 once Reserves were slightly replenished or to then demand additional funding - Yes or No?
(vl)_ Did MHML retain a Surveyor in 2013 to draw up a final Schedule of Works to an affordable budget as in Reserves (predicted to be £98,262 in late 2014) - Yes or No?
(vm)_ Was Mrs Hillgarth aware of a Surveyor drawing up a Schedule of Works and was she presented with a copy (five or six eventually) of his December 2013 Schedule of Works - Yes or No?
(vn)_ Did Mrs Hillgarth attend a board meeting of MHML Directors on 23 May 2014 to finalise the various quotes our Surveyor had arranged for choosing - Yes or No?
(vo)_ Did MHML post all the original Surveyor’s quotes AND his Schedule of Works AND all his correspondence on our website - Yes or No?
(vp)_ Did MHML request of Mrs Hillgarth in an email dated 22 May 2014 to attend the Board Meeting on 23 May with a confirmed list of those in agreement with her (ie the majority) - Yes or No?
(vq)_ Did Mrs Hillgarth NOT oblige - Yes or No?
(vs)_ Did Mrs Hillgarth attend the meeting and check that all quotes and schedules matched her Wade quote and was satisfied they were - In the Minutes Yes or No?
(vt)_ Did MHML make clear at the meeting that some works could be done by MHML cheaper and savings could be made - in the Minutes Yes or No?
(vu)_ Did Mrs Hillgarth wait two weeks and then inform MHML in an email dated 6 June that “ I would like it registered that the estimates provided are not “like for like” in my opinion, for example
Wade has included several things such as lighting etc which are not included in some of the other quotes including the quote from AR Lawrence - Yes or No?
(vv)_ Did Wade include additional items in their quote from our Schedule of Works - you check it as I sent Mr Begg a 44pp copy = don’t bother, there isn't - Yes or No?
(vw)_ Did 22 June 2014 s20 Notice state including vat and fees on all quotes incl. AR Lawrence and Reserves standing at £98,262 - Yes or No?
Did MHML advise all lessees that with AR Lawrence’s agreed budget £105,019 incl. vat and fees and with only £98,262 in Reserves, we were short by £6756 - Yes or No?
Did Mrs Hillgarth agree at the Board Meeting that to fund AR Lawrence £105,019 with only £98,262 in reserves it was necessary for contributions of £2000 per lessees - Yes or No?
Did MHML advise all lessees that a £2000 per lessee contribution was required if they did not want to accept MHML's cheaper Benitor quote - Yes or No?
Did MHML advise all lessees that after £2000 contributions approx £11,243 could be in Reserves at end of works if no unexpected problems -Yes or No
Did all lessees agree to the £2000 contributions - Yes or No?
Did Mrs Hillgarth then renege on her commitment to contribute and cite others to do same - Yes
Was Mrs Hillgarth the last lessees to pay her £2000 contribution or 6 October 2014 - Yes or No? Were lessees advised of 100% agreement to forego s20 Notices for both Water Tank and TV/Sky
or No?