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in total contradiction to what had been actually discussed and agreed. I was also fearful that more serious accusations could be fabricated against me personally and with no witness present my defence would be contestable. 7. There are reasonable grounds for suspicion that Mr Brown-Constable arranged for his own flat to be redecorated at the expense of other tenants at Mitre House. Reply: This is yet another totally fabricated mischievous innuendo and not true as has been denied and proved a total fabrication on numerous occasions previously. Even a simple referral to whom Mr Brown-Constable was allegedly in receipt of workings from would allay any reasonable grounds for such an outrageous accusation. This is a perfect example of Mrs Hillgarth’s personal vendetta against both Mr. Brown-Constable, MHML and its directors. I have explained and developed each of these complaints in further detail in the relevant numbered paragraphs below, with reference to relevant supporting documents. In the First Schedule I have identified the relevant legislation and the applicable breaches of the criminal law. In the Second Schedule I have set out the relevant evidence and key supporting documents. The most important of these are Witness Statements from Mrs Michele Hillgarth (the leaseholder of Flat 5 at Mitre House), Mr Christopher Leigh Pemberton (the leaseholder of Flat 8 at Mitre House) and Mr Tony White, the Managing Director of AR Lawrence and Sons Ltd (the building firm which was engaged to carry out the 2014 refurbishment project at Mitre House). Where relevant admissions have been made in correspondence the relevant letters are numbered appropriately and listed in the Second Schedule below. 1. Fraudulent Misrepresentation of Qualifications and the MHML website The imposition of MHML’s management charges lay at the root of all the problems that subsequently arose at Mitre House. The leaseholders generally resented the fact that Mr Brown-Constable, who had no relevant qualifications to manage a property, called himself a managing agent and was doing (or purporting/attempting to do) the work that a proper managing agent would do, and charging the leaseholders as though he were one. While it is true that specific qualifications are not required to serve as a managing agent, it is not true, as asserted in an e-mail from Mr Brown-Constable to Mr Diego Fortunati (Flat 9) of 18 December 2015, that a “monkey can be an Agent these days”. The role implies appropriate training and qualifications, relevant expertise, a relevant regulatory authority (such as the RICS or the Association of Residential Managing Agents), a code of conduct, professional indemnity insurance, complaints procedures and so on. Mr Brown-Constable, to whom all the management activity was delegated by his co-directors, is a graphic designer by profession. The lessees found it difficult to see why they should pay for his (unqualified) services the same sort of charge as they would have to pay for a properly qualified agent. MHML had no office costs to cover, no personnel costs, no professional indemnity or fidelity insurance, and no relevant expertise. Reply: In an email from Mrs Hillgarth to Mr Brown-Constable dated 27 April 2011 @ 22.52, she states: ....that if some monkeys buy the place \[ref the auction of the Head Lease\]....