Page 2 - 39_PBC to Begg_17-6-16 (2pp)
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As it has already been established by me but not yet admitted by your client, she was in receipt of not less that 4 copies of the Schedule of Works, one of which she had to have given to her preferred contractor, Wade Designs, to tender from. Which they did. Was the Water Tank in Wade’s schedule of costed works? Was it in any contractors schedule of costed works? It certainly was not in Tony White’s AR Lawrence’s schedule of costed works?
So who wrote the offending lie in the Witness Statement? I somewhat doubt Mr. White would even have the faintest idea about a Water Tank as he did not cost the tender for AR Lawrence - his surveyor, Richard Cue did, and that costing, like all others, was made some 4 months after the Schedule of Works was drawn up in December 2013.
We have nothing to hide, we never had anything to hide (exactly what could we be hiding given the replies we’ve supplied to date to all queries and accusations?) or else we would hardly have offered to comply on 1st April. Exactly what do you suppose would have happened if we had received a reply by return of, “yes thank you, send tomorrow?” And we didn’t? It’s totally inconceivable that you ignored our offer for the ridiculous reasons stated.
Even if we had presented the invoices requested, Mrs Hillgarth would still have found something to argue, accuse, disagree etc. She can’t help it, it’s her modus operandi as is surely evidenced in previous correspondence with previous agencies as indeed you have been supplied with, as well as our/my 1800 odd emails to same effect..
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If anything proves without a shadow of doubt that your client, Mrs Hillgarth, despite having requested and been supplied with multiple copies of the Schedule of Works, had never read one let alone 4 or 5... and despite multiple replies from me (see voluminous correspondence file) to her various multiple requests for copies, information, statistics, analyses, correspondence etc etc, and me stating unequivocally to look on our website, she obviously either could not fathom it, comprehend the information posted there or the instructions to satisfactorily compute the information posted there or same for that which she requested I email and sent to her in attachments in hundreds of emails - all as evidenced in the voluminous correspondence file, no doubt.
Basically, the same goes for various other items in this perjured Witness Statement as briefly described and explained on your 14 June letter sent hand delivered back to you to meet your “fraud squad” threat on Wednesday 15 June 2016 I always thought “Action Fraud” was for Credit Card misappropriation as opposed to our alleged crimewave.
As far as I’m concerned, Mr Begg, this affair has reached its low point conclusion. What with offers being made and nefariously ignored (pneumonia and trips to the Sahara), UK law statutes being stubbornly ignored as to Landlord & Tenant Act s22 etc, totally erroneous Witness Statements fabricated to suit the purpose, non disclosure to me of same for obviously nefarious reasons, mammoth reams of correspondence being totally ignored for weeks prior to one line acknowledgements:” I acknowledge receipt of your letters dated 18,25, 27 and 28 May, and your latest letter dated 10 June.”, referrals to RBK&C with totally false and erroneous paperwork attempting to establish your client’s assertion that other lessees had requested documents from the year ended 2014 Accounts’ summary dated 30 May 2015 which was not only very quickly disproved but which then proved that your client’s request of 17 December 2015 was not only the only request ever received in 5 years, but was received 17 days outside of the permitted 6 months as laid down in your client’s lease, and as stated on the reverse of all her Quarterly Demands, and as stated in the Landlord & Tenant Act 1985 Section 22. Have you even bothered to look at the documents posted on our maligned website?
I daren’t even mention your client’s stubborn refusal to attend to the breaches of her stated and well documented lease covenants. She will soon, though, unless our Solicitor is as cavalier in law as you appear to have been to date.
Your client has libeled myself and MHML with the well documented slurs, innuendos and accusations, all of which since well disproven. Thankfully she has also informed other parties which adds further proof of libel. Even the Witness Statement in the parts that are true were available on the website and explained in correspondence ad nauseum.
You have threatened us to date with every conceivable fate save for remaining in the EU just so you can get your own way as opposed to admitting to items that are simply untrue, uncalled for and unacceptable for us not to have insisted be confirmed as such. I doubt there is a management company in the country that would have put up with your client’s constant bickering, complaining, querying ad nauseum and certainly no management company in the country would have been so thorough, so well informed, so accommodating with facts, figures, dates, times, situations etc in fully and comprehensively answering each and every one of your clients, slurs, innuendos and accusations in such a timely, almost by return, manner. I just hope we both get paid or it’ll simply just start all over again. You wait and see?
You started this with a 13pp diatribe on 23 March 2016 as opposed to a 3 line request for documents? We offered to comply but pneumonia and wandering about the Sahara was deemed more important. C’est la vie.....
No more please, Mr Begg. We’ll go the court route if you insist but for God’s sake, don’t rely on that poor excuse of a Witness Statement or you’ll be laughed out of the Law Society. I would like you to sign my/your book, though.
Its a treasured classic, like I imagine you must be! Me, too, if the truth be told. Yours sincerely,
Paul Brown-Constable
cc S. Karupiah Esq, Dima International Ltd


































































































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