Page 585 - FINAL MASTER 616pp 20-6-19 SOUND

-8- in THe WesT London CoUnTY CoUrT - Case No: \[ \] Mrs MiCHeLe HiLLGArTH - Claimant versus MiTre HoUse MAnAGeMenT LiMiTed - First Defendant and pAUL BroWn-ConsTABLe - Second Defendant and seGAr KArUpiAH - Third Defendant and JAMiL rAJA - Fourth Defendant __________________________________________________________________________________ pArTiCULArs oF CLAiM __________________________________________________________________________________ ConseqUenTLY THe ConTrACTor, WHoever THeY MiGHT HAve Been, Were never GoinG To reCeive THe FULL sTATed CosT WHiCH inCLUded vAT And Fees To pAY oTHer proFessionALs or personneL, CdM, MHML, sUrveYor eTC 27. however before work had started on the project, and without the knowledge or approval of the leaseholders, the Second Defendant arranged for the cancellation of a substantial amount of the work to be carried out by ar lawrence and Sons limited, and covertly arranged for much of the cancelled work to be carried out by himself and/or through third parties. A Considered response: oUr sUrveYor Advised CerTAin exTerior CosTs CoULd Be redUCed As BeinG CosMeTiC And noT sTrUCTUrAL none oF WHiCH CoULd Be ConsTrUed As BeinG “A sUBsTAnTiAL AMoUnT” And FAr More WorKinGs Were per- ForMed For THe AvAiLABLe BUdGeT THAn redUCed. As Advised To ALL Lessees And Mrs HiLLGArTH, THe sTATUTorY s.20 noTiCe dATed 22 JUne 2014 (As indeed on ALL previoUsLY issUed s.20 noTiCes) sTATed UnAMBiGUoUsLY THAT ALL CosTs “in- CLUded vAT And Fees” ConseqUenTLY THe ConTrACTor, WHoever THeY MiGHT HAve Been, Were never GoinG To reCeive THe FULL sTATed CosT WHiCH inCLUded vAT And Fees To pAY oTHer proFessionALs or personneL, CdM, MHML, sUrveYor eTC Mrs HiLLGArTH WAs AsKed TWo qUesTions on oATH, BoTH oF WHiCH sHe denied, nAMeLY HAd sHe soUrCed TWo qUoTes FroM WAde (Yes sHe HAd) BUT denied sHe HAd, And seCondLY, HAd sHe AGreed in A MHML BoArd MeeTinG on 23 MAY 2014 in THe presenCe oF Her TWo Co_direCTors, Mr seGAr KArUpiAH And Mr pAUL BroWn-ConsTABLe THAT sHe exCLAiMed “WeLL THen everYBodY WiLL Be HAppY” WHen iT WAs expLAined To Her THAT sAvinGs CoULd Be MAde FroM THe WorKs’ Tender CosT To spend on iTeMs noT sCHedULed To Be done As THeY Were iniTiALLY Considered UnAFFordABLe As Her WAde qUoTes MAde ABUndAnTLY CLeAr? 28. Neither the First Defendant nor the Second Defendant, nor any of the third parties who car- ried out the said work, were approved contractors for the 2014 project. Nor had they (or any of them) submitted tenders to carry out work on the 2014 project. A Considered response: MHML did prodUCe BUdGeTs, CosTinGs And sCHedULes For BoTH A £25,000 And A £35,000 sCHedULe oF WorKs. Mrs HiLLGArTH WAs AsKed TWo qUesTions on oATH, BoTH oF WHiCH sHe denied, nAMeLY HAd sHe soUrCed TWo qUoTes FroM WAde (Yes sHe HAd) BUT denied sHe HAd, And PleaSe reFer To aTTaCheD “AddendA/FUrTHer reFerenCes” iN SuPPorT oF argumeNT