Page 428 - FINAL MASTER 616pp 20-6-19 SOUND

Mrs Hillgarth and other leaseholders decided to accept that the settlement agreement had been repudiated, and to establish a new company called Mitre House Management Company (2017) Limited. By a Transfer dated 19 March 2018 the head lease of Mitre House was transferred from MHML to this new company, which is currently owned by all nine leaseholders at Mitre House, including Messrs Raja, Karupiah and Brown-Constable. Previous criminal activity of MHML and its directors. As stated above, we have grave suspicions about the manner in which MHML’s assets have been depleted prior to dissolution. In order to demonstrate to you why our suspicions about those recent activities are likely to be well-founded, we should highlight some of the other criminal activities of MHML’s directors of which we do have well-substantiated evidence, any of which can be provided to you on request. These activities may be summarized as follows: 1. MHML purported to have qualifications and experience relevant to the management of property by making fraudulent claims and representations on its website which were not true (these claims and representations having been plagiarized in their totality from the website of a reputable property management company). Reply: A very petty observation which our apology to Canonbury was gentlemanly accepted as correspondence well evidences. 2. Directors of MHML converted for their own use money belonging to Mrs Hillgarth for time incurred by MHML and its directors in dealing with a “Right to Manage” application supported by Mrs Hillgarth (the purpose of which had been to displace MHML as manager of the Property). Reply: Discharging a long overdue debt due from Mrs Hillgarth to MHML by way of discounting an amount due to her along with all other directors. 3. In connection with a substantial refurbishment carried out at Mitre House in 2014 the leaseholders made available monies to pay a contractor who had been engaged by MHML to carry out the refurbishment work. The work itself, as well as the contractor engaged to carry out the work, had been formally agreed and approved by the leaseholders pursuant to statutory consultation procedures under Section 20 of the Landlord and Tenant Act 1985. However (without disclosing this to the leaseholders) MHML and/or its directors cancelled some of the work which was to have been undertaken by the contractor and fraudulently remunerated themselves out of monies which ought to have been paid to him. For so long as MHML was responsible for the operational management of Mitre House it was for all practical purposes the creature and alter ego of Paul Brown-Constable, since (prior to the intervention of Jamil Raja as referred to above) the other directors of MHML had effectively abdicated all operational responsibility for the provision of management services by Paul Brown- Constable.