Page 514 - FINAL MASTER 616pp 20-6-19

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WE WERE MORE THAN PERMITTED TO CHARGE FOR SERVICES RENDERED
WE WERE NOT CHARGING UNREASONABLE OR EVEN NEAR EQUIVALENT PROFESSIONAL CHARGES
WE DID PRODUCE COSTINGS, QUOTES AND BUDGETS
WE DID FOLLOW ALL STATUTORY REQUIREMENTS FOR S.20 NOTICES
WE DID NOT REDUCE WORKINGS PLEADING POVERTY
WE DID REDUCE WORKINGS ON THE ADVICE AND ASSURANCES OF OUR SURVEYOR
WE DID ALL AGREE TO MAKING SAVINGS INCLUDING MRS HILLGARTH
WE DID ALL AGREE THAT MHML (PAUL BROWN-CONSTABLE) WOULD PROGRESS SOME WORKINGS
WE DID RESPOND TO ALL LESSEE REQUESTS AND INSISTED THEY AWAIT PUBLICATION OF ACCOUNTS
WE DID MAKE CLEAR TO ALL LESSEES THAT 100% AGREEMENT WAS NEEDED FOR CERTAIN WORKINGS
WE DID MAKE CLEAR TO ALL LESSEES THAT ONE SINGLE DISAGREEMENT WOULD ABORT THE PROCESS
WE DID NOT DENY OR IGNORE ANY LESSEE’S REQUEST TO VIEW ACCOUNTS WEDIDNOTINTENTIONALLYORUNINTENTIONALLYMAKEMISLEADINGSTATEMENTSINOURACCOUNTS
WE DID NOT DISREGARD ANY MAJORITY DECISIONS (BENITOR AS EXAMPLE)
WE DID NOT RECOGNISE ANY MAJORITY FOR DECOR PREFERENCES AS THERE WAS NO MAJORITY WE(PAULBROWN-CONSTABLE)WERENOTUSINGANYCONTRACTORONFLAT7DURING2014
WE WERE UNDER NO OBLIGATION TO ADVISE LESSEES OF REDUCING THE WORKS SPECIFICATIONS
WE WERE UNDER NO OBLIGATION TO DECORATE THE COMMUNAL AREAS TO THE PREFERENCE OF LESSEES WE MADE CLEAR THAT VARIOUS ARTIFACTS, ARTWORKS & TOPIARIES WERE FOR CONSIDERATION
WE DID NOT PROGRESS ANY SHODDY OR UNPROFESSIONAL WORKINGS
WE (PAUL BROWN-CONSTABLE) ADMITS TO MAKING UNGENTLEMANLY REMARKS BUT FOR GOOD REASON WE (PAUL BROWN-CONSTABLE) ADMITS TO PLAGIARISING T&CS MUCH LIKE SEABORNE FREIGHT?
WE (PAUL BROWN-CONSTABLE) DID NOT STEAL £29 LET ALONE £29,000 AND IF ANYTHING, IN CREDIT WE (PAUL BROWN-CONSTABLE) CONFIRMS THAT NEITHER HIS CO-DIRECTORS NOR OUR ACCOUNTANTS NOR INDEED ANYBODY ELSE BEAR ANY RESPONSIBILITY NOR CULPABILITY OF OR IN ANY OF THE VARIOUS ACCUSATIONS LEVELLED AT MHML BY MRS HILLGARTH TO DATE AS IT CANNOT BE DENIED THAT SHE HAS
A DISLIKE AND DISTRUST OF PAUL BROWN-CONSTABLE, THE RESULT OF WHICH ARE THE MANY VARIED AND SCURRILOUS ALLEGATIONS BORDERING ON THE MANIC AND EVIDENCE OF WHAT CAN ONLY BE DESCRIBED AS A VENDETTA DUE IN PART TO MHML’S INSISTENCE THAT SHE COMPLIES WITH HER LEASE COVENANTS MOST ESPECIALLY WHILST A DIRECTOR OF MHML FOR OBVIOUS REASONS AND DESISTS FROM SIGNING OFF TEN- ANCY AGREEMENTS WHEN SUBLETTING HER PROPERTY MAINTAINING THAT ALL CONSENTS HAVE BEEN GRANTED - THEY HAD NOT BEEN AS NO CONSENTS HAD EVER BEEN REQUESTED.
THAT IS WHY MRS HILLGARTH HAS PURSUED BOTH MHML AND PAUL BROWN-CONSTABLE. HAD ANYBODY ELSE, OTHER THAN PAUL BROWN-CONSTABLE, PROGRESSED WORKINGS INITIALLY CONSIDERED UNAFFORDABLE FROM SAVINGS MADE FROM WORKINGS OUR SURVEYOR AGREED WERE NOT CRITICAL OR INDEED REQUIRED OR NECESSARY, PLUS FURTHER SAVINGS FROM NON USE OF SUBSTANTIAL CONTINGEN- CIES, AND THOSE SAVINGS WERE USED TO PROGRESS THOSE WORKINGS INITIALLY CONSIDERED UNAFFORD- ABLE WITH NO ADDITIONAL CALL ON LESSEES FOR FUNDING.
FAR MORE WORKINGS WERE ACHIEVED THAN THE VERY FEW REDUCED AND ALL WITHIN THE AGREED BUDGET FOR THE INTERIOR & EXTERIOR WORKS FOR THE BENEFIT OF LESSEES ALL OF WHOM INCLUDING MRS HILLGARTH WERE FULLY AWARE OF WHAT THE UNAFFORDABLES CONSISTED OF AND WERE ALL WELL ADVISED BY MHML THAT SAVINGS WERE BEING MADE AND SPENT ON AS MANY UNAFFORDABLE ITEMS AS POSSIBLE - WITH THE COMMENT FROM MRS HILLGARTH THAT THE NOTIFICATION WAS ONLY MADE AS MHML (PAUL BROWN-CONSTABLE) HAD BEEN “CAUGHT OUT” DOING SOME WORKS?
EVIDENCE HAS BEEN SUPPLIED THAT THOROUGHLY AND COMPREHENSIVELY DISPUTES ALL ALLEGATIONS, ACCUSATIONS AND INNUENDOS OUTLINED IN THE 23 MARCH 2016 LETTER (COPY ATTACHED) AND TO DATE AND IS AGAIN SUPPLIED AND REPEATED IN THIS COVERING LETTER AND THE VARIOUS ATTACHMENTS WHICH INCLUDE A THIRD OR FOURTH PARTICULARS OF CLAIM (WEST LONDON COUNTY COURT) AND A SECOND [SUPPLEMENTARY] REPORT TO CITY OF LONDON POLICE. ALL DENIALS ARE IDENTICAL TO ORIGINALS.
Please refer to attached “ADDENDUM/FURTHER REFERENCES” in suPPort of argument