Page 4 - STATEMENT OF CASE re-OCR s22_1

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9 MHML (on the admission of one of its directors, Mr Brown-Constable) falsified records of voting inten- tions in connection with statutory consultation procedures.
(comment/reply) We note you insist on refusing to accept correspondence which disproves.
Further information outlined on the Third Schedule (Item 9)
10 MHML has refused to comply with reasonable requests for information relating to expenses (allegedly) incurred in connection with a recent refurbishment of the Property.
(comment/reply) No requests were received within the statutory 6 month period as is confirmed by Mrs M. Hillgarth (applicant) in her Witness Statement (Para 73).
Further information outlined on the Third Schedule (Item 10)
11Mr Brown-Constable (one of the directors of MHML) blackmailed and intimidated, or attempted to black- mail and intimidate, one of the leaseholders at Mitre House
(comment/reply) Correspondence of the period will disprove these allegations.
Further information outlined on the Third Schedule (Item 11)
12 The said refurbishment of the Property has demonstrated the gross incompetence and negligence of MHML and its directors, and their unsuitability/inability to manage this Property or any other property.
(comment/reply) Correspondence of the period will disprove these allegations. Further information outlined on the Third Schedule (Item 12)
13 MHML (through one of its directors Mr Brown-Constable) has been grossly and persistently rude and abusive to individual tenants and leaseholders.
(comment/reply) Fully apologised for but made clear that there were extenuating circumstances all as explained in correspondence of the period and certainly disproving “persistently” as there exists perhaps 4 or 5 examples over a 3 year period of 1800 emails and all within a 4 week period in 2014.
Further information outlined on the Third Schedule (Item 13)
14 The leaseholders/tenants have reasonable grounds for suspicion that in the course of the said refurbish- ment Mr Brown-Constable (one of the directors of MHML) enjoyed a private benefit at the expense of other leaseholders/tenants.
(comment/reply) Correspondence of the period will disprove these allegations. Further information outlined on the Third Schedule (Item 14)
15 One of the directors of MHML (Mr Brown-Constable) has used certain common parts of the Property as his personal office and for running a business contrary to the terms of his own lease and the head lease.
(comment/reply) Another example of (applicant) Mrs M. Hillgarth’s mischiefmaking Further information outlined on the Third Schedule (Item 15)