Page 23 - 67_PBC to Begg Addendum_31-10-16 (24pp)
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That’ll be the day as Mrs Hillgarth, as is evidenced from all emails and correspondence, is a congenital complainer and come rain or shine, she never relents! Mind you, we are questioning her memory or paucity. That to all intents and purposes covers the most obvious errors and recollections in Mrs Hillgarth’s Witness Statement, which when read alongside comments actually attached to the original is relatively comprehensive - but I must stress that I can comment on and disagree with almost every paragraph and statement made save for those paragraphs which simply confirm what has been expressed to date - as she thankfully has confirmed in detail.
(i) Your Preliminary Notice is simply a repeat of your 23 March letter, your Draft Crime Report dated 12 July and most if not all your correspondence to date, with one or two new additions one of which was the “By way of explana- tion to the leaseholders Mr Brown-Constable has asserted in correspondence that the leaseholders, and in partic- ular Mrs Hillgarth, were insisting that certain items within the Schedule of Works should be excluded in order that other improvements outside of the Schedule of Works could be included.” - obviously denied and despite requests for proof, none has been forthcoming.
More relevant and significant queries are as follows?
Consequently I am relying on the facts in this letter as my final reply following the sending back of Mrs Hillgarth’s Witness Statement, with only brief comments, on 27 October.
(Mrs Hillgarth’s Witness Statement, although allegedly helped to draw up by you, is again a repeat of your 23 March letter, your Draft Crime Report dated 12 July and most if not all your correspondence to date, with one or two new additions one of which was the “By way of explanation to the leaseholders Mr Brown-Constable has asserted in correspondence that the leaseholders, and in particular Mrs Hillgarth, were insisting that certain items within the Schedule of Works should be excluded in order that other improvements outside of the Schedule of Works could be included.” - obviously denied and despite requests for proof, none has been forthcoming.
Her Statement contains too many fantasies to list and so much of what she states simply confirms what we have been explaining ad nauseam since 23 March reply most especially once you reverse her observation from fantasy to fact. Example above being a prime example.
Her latest repeated request to RBK&C will be as unsuccessful as her first. Rarely have I come across a more obtuse demand than maintaining that a request to view documents from a previous set of accounts because they are referenced (as all accounts are) in the subsequent accounts is a sane valid intelligent request?
It’s patently obvious that had Mrs Hillgarth simply wished to understand, peruse and possibly query the expenditure of the 2014 works she could have done so within days or weeks of the published accounts. She makes a comment in her Witness Statement (and made and answered ad finitum) that In his e-mail to me dated 23 March 2015 they weren’t. Of course they were as we stated they would be; once the accounts were published all documents would be available to peruse etc. “They weren’t” is simply stupid. If they weren’t, no accounts could have been published and how on earth she can say they weren’t if she didn’t request to view... in time!
It’s also patently obvious that her tardy request to view documentation was with the intention of maligning MHML as opposed to a healthy interest in the actual funding of works. Her request in December 2015 (a year after the works were finished) as to whether or not we had received permission to install scaffolding on a Sunday does somewhat evidence her mischievous contrariness. We had received permission by the way.
Your letter of 23 March 2016 also evidences a spiteful, malicious and thoroughly uncalled for onslaught on MHML and myself for no other reason than a continuance of her dislike of me personally (or maybe not?) and certainly her abject dislike of authority no matter the agency, be that MHML or any of our Agents to date.
Had it been a simple request or even a kid-gloved demand to view our documentation as opposed to a 13pp dia- tribe
listing every conceivable misfeasance, malfeasance, mismanagement, incompetence, fraud, misappropriation of funds, ignoring statutory requirements, verbal abuse and intimidation, blackmail, plagiarism, indecent exposure etc etc (appreciate some came recently), we would have been quite content to overlook the unacknowledgment of our offer to fully comply on 1st April 2016 in quick response to your letter and make good our offer.
The mere fact your client was making these slurs and accusations indicated without a shadow of doubt she was not in the least bit interested in the funding aspects but more in having MHML (me) removed and replaced by someone she could control, influence, order about, spend money willy-nilly but not the benefit of neighbouring lessees but her own selfish agenda in sub-letting her flat for a high or higher still market rent.
Comments above in this addendum when added to all those comments made to date in correspondence (of which there has been a ridiculous amount) evidence yet again misinformation, misunderstanding and sheer ignorance and the example given as regards the Brooks alleged (and incorrect) non payment is a perfect example of what we could expect from your client once she views the funding of the disputed additional works, no matter to whom it was paid. We would be arguing over expenses, costs, professional workings, etc for years simply to satisfy your client’s voracious appetite for revenge. She would find fault everywhere especially if we had said we’d paid Brooks £2400 in


































































































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