Page 16 - The Big Begg_1
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Mrs Hillgarth or are figments of your imagination or a combination of both.
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“HOW DID YOU THINK MHML WERE FUNDING THE NEW LIGHTING?”
This reply letter has three purposes, namely:
I) to deny yet again all and any of your allegations, accusations and innuendos since your letter
of 23 March 2016 to date save for that admitted “plagiarism?” alongside Seaborne Freight. Ii) to inform you of various misunderstandings on your part which have either originated from
III) to prove conclusively and incontrovertibly your client’s perceived dishonesty, ignorance and contrariness including undeniable examples of such behaviour both past and present.
As has been established without doubt since your 23 March 2016 letter relaying information given to you by your client, Mrs Hillgarth, and then interpreted by you in legalise to accuse both myself and my MHML co-directors (and for the sake of simplicity I am referencing below various ongoing concerns as outlined yet again in your Supplementary Report To City Of London Police and to The Insolvency Service included with your letter dated 1 March 2019) that you still allege:
a) We (MHML but notably and only Paul Brown-Constable) allegedly provided dishonest and incompetent management, whilst charging above average fees we were not anyway permitted to charge etc etc - previously denied and here again.
b) We (MHML but notably and only Paul Brown-Constable) allegedly covertly and fraudulently reduced the 2014 works’ programme of items not considered required or could be done more economically to make savings to be spent (not refunded) on items initially considered unafford- able 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 requests 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 requiring explanation which allegedly indicate a possible theft of £29,000 from leaseholders - previously 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 position” 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 appears 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
PLEaSE rEFEr to attaCHED “ADDENDA/FURTHER REFERENCES” in SuPPort oF arguMEnt