(NOTE: This section is c. 30 pages in length)
Cawdery Kaye Fireman & Taylor (CKFT), 25/26
Hampstead High Street , London NW3 1QA and British
Virgin Islands (which 'appears' to be
a recent addition).
(NB: CKFT is covered in my 3 June 2008 (74 pg) Witness Statement; (4 pg) Main Points)
At September 2005, the property section on the
firm's website (ckft.com) reads
"The property team at CKFT has a wealth
of experience in all aspects of commercial
and residential conveyancing. They provide
practical and pragmatic advice with the focus
on results - which means getting the deal done
quickly and building in all necessary protections
for the client"
At September 2005, CKFT's website stated for:
Mr Lanny Silverstone: "Partner Head of Employment Department Litigation and Family Law. Areas of Practice: commercial and property related litigation; contentious landlord and tenant work."
Ms Ayesha Salim : "Assistant Solicitor Litigation Department"
Their 21 August 2003 "Statement of costs" (they expected to be awarded against me at the 26 August 2003 hearing ( not granted )) states, under "Description of fee earners" :
Robin Lanning Silverstone [grade A] which is described later on as "Solicitors with over eight years post qualification experience including at least eight years litigation experience"
Ayesha Salim [grade C] , described as "Other solicitors and legal executives and fee earners of equivalent experience"
I view Mr Lanny Silverstone and Ms Ayesha Salim as evil, corrupt, morally depraved individuals... but, as demonstrated in this section : they have the blessings of their 'professional' assocation, the Law Society, to act as they do. (= same as Mr Richard Twyman and Ms Lisa McLean, Piper Smith Watton, as well asMr Jeremy Hershkorn and Mr Daniel Broughton, then at Portner / Portner and Jaskel LLP - and no doubt this would also apply to Mr Ahmet Jaffer, Portner and Jaskel)...and the Law Society has the blessings of the Legal Services Ombudsman.
I first became aware of CKFT as a result of conducting desk research on Mr Andrew Ladsky in 2000 which led me to identify that CKFT had instructed counsel in the TSB Bank v. Arthur Ladsky 1996 Court of Appeal case.
My first exposure to CKFT's method of operating came from being copied by two leaseholders on an identical letter they had received from Ms Ayesha Salim, dated 11 October 2001 - letter to Leaseholder A (see Elderly Resident), letter to Leaseholder B. (It 'seems' to me that this letter amounts to harassment and intimidation of witnesses - which is a very serious offence)
It is abundantly clear that Mr Andrew
Ladsky and Steel Services are one and
the same client of Cawdery Kaye Fireman & Taylor
In her identical letter of 11 October
2001 to Leaseholder
A and Leaseholder
B , Ms Ayesha Salim wrote "We are
solicitors instructed by Mr Andrew Ladsky" (Elderly Resident ; Other Residents)
By sending his 28 November 2002 letter to my employer, and one to me of the same date, following my 24 October 2002 fax to K&C Housing and 24 October 2002 fax to the LVT (detail in My Diary 15 May 2008), Mr Lanny Silverstone confirmed the connection between Mr Ladsky and Steel Services
It can also be seen, for example,
in the 7
October 2002 letter sent to me by Mr Lanny
Silverstone in which he - illegally - threatened
to forfeit my lease. This letter has the reference 'LAD';
the 1
July 2004 Consent Order has, likewise
the reference 'LAD'.
CKFT acted for Mr Arthur Ladsky,
instructing counsel, in the TSB
Bank v. Arthur Ladsky 1996 Court of Appeal
case. Messrs Andrew
Ladsky and Arthur
Ladsky were both directors of Combined
Mercantile Securities.
(See Directorships for related information)
(I do not know whether CKFT acted for Mr Andrew
Ladsky in the case reported in the article in
the Sunday
Times (printscreen of site) , referring to a relationship he
had with a model that "culminated in a
court battle over a floor-length sheepskin
coat and two paintings" )
CKFT acts for Steel Services -
as evidenced in numerous documents, including
the Particulars
of claim for the 29
November 2002 - false - claim (ref:WL
203537) filed in West
London County Court
In the context of the several transactions
probably best described as further 'carving out'
and 'reshuffling' in the named owners of Jefferson
House which took place late 2005 and early 2006
(see Freehold
ownership , Headlessors , Owners
identity ), Cawdery Kaye Fireman & Taylor became the nominated solicitors
for 'Steel Services' on the Land Registry (Title NGL
373 333 ) - in the process taking over from Laytons, solicitors, London EC4Y 0LS
See also Headlessor for transactions driven by 'Steel Services'
CKFT acted for Steel Services prior
to 2002, as can be seen in the 15
October 2001 letter from Ms Hathaway,
MRICS,
Martin
Russell Jones, 'managing' agents for
the block, in reply to Nucleus,
(local Citizens Advice Bureau) who gave
CKFT's address as contact.
At the 29 October 2002 LVT pre-trial hearing when Mr Andrew Ladsky was asked by the Chair what his interest was in the proceedings, he replied: "I am just a tenant" . (His name is stated on the 29 October 2002 directions issued by the tribunal).
However, throughout the four-day Leasehold Valuation Tribunal hearings, Mr Ladsky was a member of Steel Services party, holding frequent discussions with: Mr Warwick, Steel Services' counsel (My Diary 13 March 2003 ; LVT # 8.2 ) ; Mr Brian Gale, MRICS, 'Steel Services' surveyor who, during the hearings, confirmed that Mr Ladsky was a prior client ; Ms Joan Hathaway, MRICS, Martin Russell Jones , 'managing' agents for the block.
(In spite of seeing this, the tribunal continued
to use Mr Ladsky's initial answer - as can be
seen in its 17
June 2003 report under point 4
"attended
by.Mr A Ladsky, the owner of flats 34 and
35 ",
as well as under point 50 "It is noted
that apparently the majority of the tenants
wish all the works to be carried out. A letter
from Mr Ladsky, the lessee of flats 34 and
35 dated 28 April 2003 stated: "31 or 32 of
the 35 tenants have paid their contribution." )
Please note that in the "summary
of contributions to the major works" attached
with the ICAEW's letter of 29
August 2006, Mr Ladsky who is the registered
owner of flats 34 and 35 since
the year 2000, has not
paid any contribution towards the major
works.
Furthermore, in its 10 February 2006 so-called "notice", Portner and Jaskel, solicitors, said to be acting "as agents for Steel Services" (see Notices by landlord - 10 February 2006). Eight months later, in its 3 October 2006 letter to my then ISP, it identified its client as being Mr Andrew Ladsky (My Diary 3 October 2006)
Also, in 2002, I approached the Tenancy Relations Officer at Kensington & Chelsea Housing to obtain, as per my statutory rights (under Sections 1 and 2 of the Landlord & Tenant Act 1985 ), the identity of the landlord, as well as the name and address of every director and secretary of the landlord. In his 5 November 2002 email, the Tenancy Relations Officer informed me that he had
"...received a telephone call from Mr Ladsky. He has asked for copies of all correspondence that you have sent me"
(The next day, 6 November 2002, the Tenancy Relations Officer sent me an email saying: "...we will not be releasing any documents to Mr Ladsky. The councils legal department believes you are entitled to a degree of confidentiality when you have sought assistance from us and this is why we have taken this decision")
Sections
- (1) The evidence suggests that, at least
for a while, Mr Silverstone claimed
to be acting on behalf of a company that
did not exist. This included threatening to
forfeit my lease
- (2) CKFT knowingly committed an abuse of
process of court by filing a claim against
me (and 10 other leaseholders)
- (3) Very clearly, the objective of the action
was to bully and coerce me (and other leaseholders)
into paying an amount not due and payable -
failing that, through 'striking a deal'
- (4) Triggers to filing the complaint against
CKFT with the Law Society
- (5) Mr Lanny Silverstone and Ms Ayesha Salim
have a high propensity to threaten proceedings
- always "with costs"
- (6) My complaint to the Law Society and its
replies
- (6.1) CKFT committed an abuse of the court
process
- (6.2) CKFT made inappropriate use of forfeiture
legislation in an attempt to force me to pay
monies that were not due and payable
- (6.3) CKFT demanded monies not due and payable
- (6.4) CKFT actively supported the breach
of covenants in my lease
- (6.5) CKFT persistently ignored the evidence
against its client's claim
- (6.6) CKFT knowingly made false statements
against me to the court - including under a
Statement of Truth
- First false statement made by Ms Ayesha Salim
- under of a Statement of Truth
- In fact, Ms Salim made another false statement
in this application
- Ms Salim also made a third false claim to
the court
- (6.7) CKFT accompanied the claim to West
London County Court with a lease falsely claiming
that it was representative of my lease
- (6.8) CKFT acted in tandem with Piper Smith
Basham with the objective of forcing me to
strike a deal with its client
- (6.9) The evidence suggests that, for a while,
CKFT was demanding monies and threatening me
with proceedings on behalf of a company that
did not exist
- (6.10) CKFT failed to observe proper standards
of work
- (7) Overall, in relation to numerous points
in my complaint, the Law Society said to be
unable to consider them citing one of the following
three reasons:
- (8) I filed a complaint with the Legal Services
Ombudsman against the Law Society
- (9) And finally, at the end of the day, what
is the ROOT CAUSE OF ALL OF THE ABOVE?
(1) The evidence suggests that, at least for
a while, Mr Silverstone claimed to be acting
on behalf of a company that did not exist.
This included threatening to forfeit my
lease
In 2002, my first contact with CKFT was of an
indirect nature. As related above, in January
2002 , I had approached Kensington & Chelsea
Housing department to help me obtain - as per
my statutory rights - the name of the directors
for Jefferson House. (See Owners
identity for
additional information)
In a letter dated 1
August 2002 to the Housing department,
CKFT wrote
"All we can say is Steel Services
Limited is an existing entity, and we have
provided you with all of the information we
have so far been instructed to supply"
At this point I contacted the British
Virgin Islands Authorities because:
(1) a claim filed by Portner and Jaskel against
the Elderly
Resident in Central London County
Court on 26
February 2002 gives the claimant as Steel
Services "Freehold owner" , with
an address in the British Virgin Islands (see Freehold Ownership, Headlessors, Owners identity, British Virgin Islands Registration, Notices
by landlord - 10
February 2006 , as well as Portner
/ Portner and Jaskel LLP for its other 'activities' )
(2) in her 25
January 2002 letter to the Housing department,
Ms Hathaway, MRICS, Martin Russell Jones, wrote "The Directors and secretary
of Steel Services are F.M.C.
Ltd" and
gave an address in the British Virgin Islands (Owners identity)
The 8
August 2002 reply from the BVI stated
that Steel Services had been
"Struck-off
the register for non-payment of licence
fee"
To this should be added that, by August 2002,
the outcome of the various searches undertaken
by myself and Kensington & Chelsea Council
housing department (and previously Nucleus,
our local Citizens Advice Bureau) had led
to a 'nil'
return: there was no record of the company
in the UK.
Among others, this includes the 10
October 2001 reply from the Land Registry
to Nucleus:
"Steel Services Limited
is in fact an overseas company and
therefore does not have a companies registration
number"
(See Owners
identity, BVI
registration, Headlessors and Jersey
address ).
Detail of events is captured in my 20
December 2004 complaint against Cawdery Kaye Fireman & Taylor,
under points 12 - 22.
The outcome is that I believe it to
be fair comment for me to say that the
evidence suggests that Cawdery Kaye Fireman & Taylor (Martin
Russell Jones, and the accountants, Pridie Brewster) were, at least for a while, claiming
to be acting on behalf of a company that did
not exist.
(See Freehold
ownership, Headlessors , Owners
identity )
This includes, among others, Mr Lanny
Silverstone threatening me with forfeiture and prosecution "on behalf of Steel Services" in
his 7
October 2002 letter.
This 7 October 2002 letter amounted to 'my turn'
to being at the receiving end of what I view as
a highly unscrupulous, evil and immoral
method of operating.
In this letter
(received on 10 October), Mr Silverstone
threatens to forfeit my lease (see 'Abbreviations
and Definitions for an explanation of forfeiture)
unless I paid the £14,400 (US$25,400) demanded
by 10 a.m. on 14 October 2002.
Needless to say that this illegal tactic (illegal
because it was, among others, in breach
of my statutory rights) had the intended effect
of causing me extreme alarm and distress -
to the point of actually being physically
sick. (I was at work when I read it). (See My Diary 10 October 2002 )
At the time, I had near non-existent knowledge
of landlord-tenant legislation - which,
of course, is what Mr Lanny Silverstone
was relying on in sending me this letter.
Based on information
I received from LEASE, as well as managed
to gather from other sources, I held firm with
CKFT and replied to its letter on 17
October 2002 in which I repeated what
I had already stated on two previous
occasions to Ms Hathaway:
"I require additional information
before I can agree to the demand" .
By the time I wrote this letter, I had received
notification from the Leasehold
Valuation Tribunal (dated 8
October 2002 ) that Steel Services had
made an application
"to determine the reasonableness
of the global sum demanded"
Subsequent note: In -my non-lawyer opinion - I hold the view that Cawdery Kaye Fireman & Taylor -"under instructions from its client" Mr Ladsky - has, in addition to breaching my lease, committed offences against me under the Malicious Communications Act 1988, the Protection from Harassment Act 1997, the Theft Act 1968 s.21 Blackmail and the Landlord and Tenant Act 1985 s.19(2)
Back to list
(2) CKFT knowingly committed an abuse of process
of court by filing a claim against me (and
10 other leaseholders)
Consequently,
in my 17 October 2002 letter to CKFT,
I asked whether it was aware that its
client had taken this step. In his 21
October 2002 reply, Mr Lanny
Silverstone states
"We are aware that Steel Services
has applied to the Leasehold Valuation
Tribunal"
Two weeks later, at the 29
October 2002 pre-trial LVT hearing which,
as can be seen from the tribunal's
directions , was attended
by, among others, CKFT's
client Mr Andrew Ladsky, Ms
Joan Hathaway, MRICS and Mr
Barrie Martin, FRICS of Martin
Russell Jones , and Mr
Brian Gale, we (leaseholders)
were asked by the Chair whether we
had paid the 15
July 2002 service charge demand.
We
all replied that we had not because
we had not been supplied with a
breakdown of the costs.
At this point, the Chair told us that
if we paid, the tribunal would not be able
to help us.
To emphasise the point, we were handed a booklet 'Applying
to a Leasehold Valuation Tribunal - service charges,
insurance, management' which, on page
5 states:
". a recent Court of Appeal case ruling
(Daejan Properties Limited v London Leasehold
Valuation Tribunal) determined that LVTs only
have the jurisdiction to decide the reasonableness
of disputed service charges that are
still unpaid except under certain
circumstances" (NB: bold type
face as per the leaflet)
In spite of the fact that leaseholders had,
in effect, specifically been told by the
tribunal to NOT PAY (the Chair, pressed
the Daejan Properties case upon us), CKFT
nonetheless proceeded - one month later
- to draw-up a claim (WL 203537) against 11
leaseholders, including myself ,
who represented 14 flats, stating:
"The Defendants have failed
to pay the service charges, details
of which are set out in Schedule 1and
there is now due and owing from the
Defendants to the claimant the sums
set-out in Schedule 1 payable by way
of payment..."
This claim was filed
by Ms
Joan Hathaway, MRICS, Martin Russell
Jones - under a Statement of Truth (1.1MB) - in West
London County Court on 29 November
2002 i.e. precisely one month after we had been told by the tribunal to NOT pay the 15 July 2002 service charge demand
See also events in 2007 - My Diary 9 March 2007 re. the very serious breach of Civil Procedure Rules as the Statement of Truth signed in 2002 by Ms Hathaway, a 'managing agent' ; and see West London County Court point # 23 for Her Majesty Court Service's reply to my highlighting this very serious breach
Subsequent note: In -my non-lawyer opinion - I hold the view that Cawdery Kaye Fireman & Taylor -"under instructions from its client" Mr Ladsky - has, in addition to breaching my lease, committed offences against me under the Malicious Communications Act 1988, the Protection from Harassment Act 1997, the Theft Act 1968 s.21 Blackmail, the Defamation Act 1996, the Court and Legal Services Act 1990 - Chapter 41 - s.17 and CPR 1 1.3
Back
to list
(3) Very clearly, the objective of the action
was to bully and coerce me (and other leaseholders)
into paying an amount not due and payable
- failing that, through 'striking a deal'
Typically,
this widely-used tactic by abusive landlords
and their equally abusive aides works.
Indeed, as leaseholders incur ever-increasing
costs fighting the abusive landlord they
end-up, either of their own volition, or
under increasing pressure from 'their
advisers' making a 'commercial decision' i.e.
pay the landlord - thereby preventing
progression to trial. (See Business
model)
The expectation of being
able to 'strike a deal' - resorting
to, in the process - bullying,
coercion and extortion tactics in order to
achieve the objective, is evidenced in the next
few paragraphs below.
It is also found in the correspondences I exchanged
with Ms McLean, Piper
Smith Basham. (NB: At
the time, I had just appointed Piper Smith & Basham) (Now Piper Smith Watton)
In my 21
August 2003 letter to Ms McLean following
a conversation with her, I wrote:
"About CKFT's offer "to discuss" with
them i.e. try to strike a deal. I am
not prepared to do this.
This would be a very unwise move as it would
allow them to get away with the need to redraw
the specification, thereby leaving me exposed
to further demands at a later stage which,
I can guarantee, would be made (letters from
MRJ of 26
March 2002 and 15
July 2002 ).
By forcing them to do this, it will put
a line under the costs i.e. they will not have
any comeback and, if they do come back, I will
be in a much better position to challenge them.
Last but not least, I am also hoping that
by doing this they will give up on the block
as I am taking away their opportunity to illegally
charge works to the residents "
In this letter, I also referred to my 9
August 2003 letter to the court (on which
I copied CKFT; I also gave a copy to Ms McLean),
in which I wrote, among others:
"The LVT has made a determination on the
reasonableness of the service charge for the
block -as a whole - not just for myself.
There are no side deals to be made with
the Claimant: the nature of the works and their
associated costs must be totally clear and
transparent - to ALL lessees.
Nowhere does the lease state that the share
of the service charges payable by individual
lessees is dependent on their amount of 'backbone'
and courage to challenge a demand for money
they do not owe.
Their resistance to prolonged harassment
and intimidation.
What each lessee is required to pay is clearly
defined by means of a fixed percentage (see
the attached list of percentage for each of
the 35 flats supplied by SSL-MRJ in their 7
August 2002 application to the LVT)"
But, as can be seen in Ms McLean's letter of 4
September 2003 , she and CKFT were not
giving up on the idea:
"Incidentally (NB !!!) ,
I took a call from CKFT today and, in view
of the costs being incurred by both sides they
asked whether we would be amenable to any deals (NB
!!!)
I said that I had noted that you had previously
refused to deal with them but in the event
that they wished to make an offer (NB
!!!) I was, as they well know,
obliged to put it to you (NB !!!)
They intimated that they will make a Part
36 offer (NB !!!)
The relevance of this is that if they make
an offer which is rejected and, following trial
the judge makes a determination that is no
better than the offer that they had made then
you will have to pay their costs from the time
the part 36 offer had been made up until the
trial" (NB Please note
the threat)
I replied as follows on 9
September 2003
"I maintain what I said: the situation is
the result of Steel Services/Mr Ladsky and
MRJ's doing - not mine (nor indeed that of
the other residents).my position has remained
unchanged: 'No' as this does not achieve
my objectives "
From liaising with Piper Smith Basham, CKFT
and its client realised that I was prepared to
go to trial over this action: I had written a Witness
Statement and was appointing a barrister.
It
is my belief that this triggered the 21
October 2003 'offer' which, in 'typical
style' included a demand for £143 (US$250)
of interest. (See Piper
Smith Basham and Mr
Gallagher for detail of events)
I was not prepared to 'shut up' and pay monies
I did not owe.
I wanted to enforce
the terms of my lease, as well as exert
my statutory rights.
I wanted to comply
with the instructions that had been given
to me by a tribunal.
And I wanted
to abide by my moral principles, my
integrity: I wanted to pay my just and fair
share of the costs for the major works.
My wanting this undermined, what I now view
as the highly lucrative Business
model for which
the foundation is that once everybody has become
quite fat one way or another at the expense of
the leaseholder, the pressure starts mounting
on the leaseholder to 'make a commercial decision':
"Com'on, look at what you have spent so
far. It's nearly as much as what our client
is asking. Make a commercial decision. Let's
strike a deal. Accept the 'offer".
(NB: When, at the 24
June 2003 West London County Court hearing,
I told Mr Lanny Silverstone (in front of a
witness) that I found it absolutely outrageous
that West London
County Court had been instrumental
in making
seven residents pay BEFORE the
LVT had issued its determination (ref: LVT/SC/007/120/02) (printscreeen of site) ,
he replied: "They made a commercial decision" )
The leaseholder not playing the game sends the
lawyers and their clients on a chase 'to snare
the prey'. They keep threatening court proceedings - and,
of course, 'costs'! (the major weapon) - but have
no intention of going that far.

|
Why?
In my view, because a trial
results in an official record
of evidence available in the
public domain - unlike
when the leaseholder accepts
/ is made to accept 'an offer'
which allows the rogue
landlord and his equally rogue
aides to come out 'smelling of
roses' (and with their coffers
substantially fuller than they
should be).
(This consideration
is even more important in the
case of a defendant like me who
has an overwhelming body of evidence
against the landlord and his
aides). |
So, more of the 'artillery comes out': the salvo
of threatening letters goes into full swing (as
can be seen in the next few paragraphs), as well
as applications to the courts for 'case management
hearings' (that are granted with much haste by
the courts) - all aimed at bullying and coercing the leaseholder into striking a deal.
It works,
as the rapidly mounting fees leads to
more leaseholders to 'cave in' e.g. Mr Silverstone's 23
May 2003 correspondence.
All the follow-up actions from Mr Lanny Silverstone
and Ms Ayesha Salim - which (so far!) have led
to the last contact being in June 2004 - were
in a similar vein to the 7
October 2002 letter.
For detail, see below,
Law Society section which covers my
complaint against CKFT, as well as West
London County Court and Wandsworth County Court
Back
to list
(4) Triggers to filing the complaint against
Cawdery Kaye Fireman & Taylor with the Law Society
(Subsequent note: For update, see Portner and Jaskel and West London County Court - Post 2004, and my 3 June 2008 (74pg) Witness Statement; (4pg) Main Points)
What prompted me to file the complaint
against CKFT were the possibility that
it might file proceedings against me for alleged
breach of agreement, as well as the fact
that I received another demand from Martin
Russell Jones,
dated 21
October 2004 , stating a 'Brought
forward balance" , of £14,452 (US$25,600). Yes, the same "amount as the original sum demanded in July 2002
There was no explanation whatsoever as to what
the sum refers to i.e. there was no
supporting documentation. I do
NOT owe this sum -as:
(1) in
my 19
December 2003 letter to Cawdery Kaye Fireman & Taylor, I accepted
its client's
' offer '
of £6,350 (US$11,200) in settlement
of my share of the major works (i.e.
the original demand of £14,400 (US$25,400) (For reasons see e.g. My Diary December 2003 ; Mr Gallagher # 3.e.1 , # 3.e. 2 , # 3.f.2 , # 9 ; Home page # 3 , # 4.13 , # 4.14 )
(2 ) Wandsworth County
Court endorsed the document sealing
the agreement on 1
July 2004
(3) It was preceded
by Ms
Ayesha Salim, stating in her 28
May 2004 letter to me acceptance
of the Consent Order, while
in her 15
June 2004 letter, she stated having
sent it to the court for approval
and sent me a copy with her correspondence
of 14
July 2004.
Three weeks after the 21
October 2004 invoice, another
invoice followed from Martin Russell
Jones, dated 16
November 2004 , this time, stating "Brought
forward balance" of £15,447 (US$27,300)
- likewise, with no explanation whatsoever.
This
invoice was sent with a covering letter,
dated 5
October 2004 . (Yes, this letter dated
six weeks previously, was the covering
letter with the invoice).
I knew that these invoices were bogus, an act of revenge - and hence did NOT pay
them.
They were followed by an invoice
dated 9
January 2006 ( i.e. 14 months
later) (*), this time stating a "Brought
forward balance" of £5,625 (US$9,900).
Yet again, no explanation provided.
(*) I attribute the gap to the fact that I filed a complaint with the Law Society against Cawdery Kaye Fireman & Taylor on 20 December 2004, which I escalated (in vain!) to the Legal Services Ombudsman # 2 , as well as filed a complaint with the Royal Institution of Chartered Surveyors against Martin Russell Jones on 2 February 2005 (1.1MB)
Some other
points of note about this invoice
(which further demonstrate the fraudulent method of operating of Mr Ladsky et.
al and their aides) are:
It includes a "half yearly
service charge in advance - to 23 June 2006" of £815 (US$1,435)
With the invoice, Martin Russell
Jones enclosed a document headed "Steel
Services estimated expenditure for
the year ended 2006 " from which
I conclude that it was 'somehow' used to
arrive at the sum of £815 (US$1,435)
(I do not understand how this sum
was arrived at
This document claims that the £76,167
(US$134,300) of expenditure is attributable
to "All
flats" .
This is FRAUDULENT given
that Steel Services no longer had control
of the last floor of Jefferson House (See
Headlessors, Owners
identity and
Pridie
Brewster )
It was followed in June 2006 by an invoice
stating a "Brought forward balance" of £8,621 (US$15,200). As
with the prior invoices: no explanation as to
the composition of the sum.
The 30
June 2006 invoice represents an increase £2,995
(US$5,300) over the 9
January 2006 invoice, which states a
half-yearly service charge in advance of £815
(US$1,435).
As can be seen from the 30
June pack , my half-yearly service
charge BEFORE the addition of four
new flats, including a penthouse
flat that spans the whole length
and width of the top floor, and BEFORE
the complete overhaul of Jefferson
House was £680
(US$1,200).
Outcome: what is the amount currently
'deemed' by Mr Ladsky et. al. and their
aides to be hanging over my head? £14,500 (US$25,600)(?), £15,500 (US$27,300)(?), £5,625 (US$9,900)(?), £8,621 (US$15,200)(?)
or all four combined making a total of £44,246
(US$78,000)?
Who knows, considering the fraudulent
method of operating of Mr Ladsky et. al. and
their retinue of thugs - as can be seen from
some of the evidence compiled in this
pack (2.4MB) (Subsequent note: see Portner and Jaskel for update: another claim was filed against me in February 2007 and, after a 16-month battle, was dropped in June 2006)
Fair minded, reasonable visitor to
the site, you would think that somebody
with two brain cells, facing somebody
like me - who had nonetheless paid the sum of £6,350
(US$11,200) that was NOT
due and payable - would have backed-off.
Such is the profile
of Mr Ladsky et. al. and their aides -
and the extent of their arrogance
and greed... as well as their 'justified'
belief in the supporting infrastructure
of lawyers, courts, tribunal, accountants,
local councils, etc.
In addition to viewing this as an act
of vengeance by Mr Ladsky et. al.
for my challenging the LVT
application , I read in this an abundantly
clear message of an intention to ruin
me by hoping that it will again force
me to pay for legal advice. And, if
I am declared 'bankrupt',
they will be able to get my flat for
next to nothing. (To some people, these
actions by Mr Ladsky et. al. and
their aides 'might' conjure up sociopathic traits) (Subsequent note: they do fit the profile of sociopaths - My Diary 15 May 2008).
I believe it is fair comment for me to say:
given that the courts have 'worked for Mr Ladsky'
last time, he is bound to, yet again, file a
false claim against me. Indeed, to borrow a leaseholder's
comment about his own landlord,
Mr Ladsky et. al. "...seem to have
turned intimidatory litigation into
an industry"
(Judging from the article in
the Sunday
Times, even girlfriends can end-up being
subjected to this treatment)
Mr Ladsky et. al. and their aides know that
(as demonstrated by events in West
London County Court ) the courts will totally disregard any
evidence I provide against the claim.
(Subsequent note: I was proven right! see Portner / Portner and Jaskel LLP and West London County Court - Post 2004)
In addition to these fraudulent service charge
demands, Mr Ladsky will probably add other claims
as well depending on his fancy - as indicated,
for example, by the 28
February 2005 'dictate' "from" Ms Hathaway
(i.e. from Mr Andrew Ladsky) which threatens
to enforce - yet again through proceedings
- another breach of my lease .
(This is Clause
5 (5) (b) which makes it an obligation
for the landlord "to remove. from the flat
all domestic refuse and rubbish." . I
highlighted the breach of my lease in my 30
March 2005 reply to Ms Hathaway and
in my 21
March 2005 letter to the Royal
Institution of Chartered Surveyors ).
In fact, like the other parts of the 'triple
act' ( Martin
Russell Jones and Mr
Brian Gale ), Ms Joan Hathaway, MRICS and Mr Barrie Martin,
FRICS will do whatever Mr Ladsky dictates, regardless
of the glaringly obvious - and very damning -
evidence and facts.
Subsequent note: I was proven right - see Portner / Portner and Jaskel LLP
In the process, they demonstrate
an endless capacity for flaunting the
laws of the land, amoral conduct, matched by
an equally endless amount of gall.
NO, I
am not going to write 'allegedly' as
I believe that any fair minded, reasonable
person will agree that the body of evidence
in support of my assessment is overwhelming.
There are also numerous examples of
this under Martin
Russell Jones, as well as under Portner / Portner and Jaskel LLP.
One example that has to be seen to be believed
is the 2
May 2006 (2.3.MB) reply from Mr
Barrie Martin, FRICS to my
criticisms of his firm and of Mr Brian
Gale:
"Your allegation is false and we
require your written acceptance that you
were wrong to make it"
Consider this reply in the context of the evidence
contained in the above 2 May 2006 pack
- as well as in the context of this
pack (2.3MB) containing, among others,
a compilation of documents issued by
Mr Brian
Gale, MRICS, Martin
Russell Jones and
their client.
The reason they flaunt the laws of the land? Because they know that they have 'carte blanche' to do it.
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(5) Mr Lanny Silverstone and Ms Ayesha Salim
have a high propensity to threaten proceedings
- always "with costs"
(NB: Events covered in my 3 June 2008 (74pg) Witness Statement; (4pg) Main Points)
Of course, in CKFT, in particular Mr
Lanny Silverstone and Ms Ayesha Salim,
Mr Ladsky has the 'ideal' firm of solicitors
to assist him in his dishonest objectives - as they very clearly don't give a damn about committing criminal offences - in this instance under: Malicious Communications Act 1988 ; Protection from Harassment Act 1997 ; Theft Act 1968 s.21 Blackmail (= same attitude as Mr Ladsky's other puppets: Portner and Jaskel # 3 ; Martin Russell Jones # 25 ; # 26 )
Indeed, the threat of
proceedings - of course, always "with
costs" - is
their favoured approach, as exemplified
by the following which amounts to, bullying, blackmail, extortion and intimidation to make me pay a sum not due and payable
and force me into making a deal with
their client:
Mr Lanny Silverstone's 7
October 2002 letter to me:
"In the
event that payment is not received
by Martin Russell Jones by 10 am on Monday
14 October, we have instructions immediately
to commence proceedings for recovery of the
debt"
Mr Lanny Silverstone's 21
October 2002 letter to me:
"Your consistent
failure to pay such sums is a matter
that could be taken into account by the court
in considering the weight to be given to your
complaints now"
Mr Lanny Silverstone's 4
February 2003 letter to me:
"...will
take injunctive steps prior to
other proceedings."
Mr Lanny Silverstone's 25
June 2003 letter to me
"...the costly
LVT process has now resulted in
a percentage uplift in the contract
figure and a significant delay in the
project"
Mr Lanny Silverstone's 24
July 2003 letter to me:
"Clearly substantial
costs will be incurred if the court has to
deal with the determination of this issue..we
reserve the right to refer to this
and previous correspondence in relation to
any subsequent issue as to costs"
Mr Lanny Silverstone's 7
August 2003 letter to my solicitors (of
a few hours):
"She has declined
to accept those offers. We shall contend that
this is a relevant matter in relation to the
question of costs "
Ms Ayesha Salim's 21
August 2003 letter to me in which she
expected me to pay £708 (US$1,250) for
her "clients costs" (Not granted
by West London County Court )
Ms Ayesha Salim, through the intermediary
of Ms Lisa McLean, Piper
Smith & Basham,
who recorded in her 24
September 2003 correspondence to me:
"...receiving
a voicemail from Ayesha of CKFT...she
said that she had been instructed that
there was now an issue with the Section
20C LVT application. If that was the
case, she was then instructed to commence
proceedings within the next 48 or 72
hours "
(See Piper Smith Basham # 7.18.5 for
further detail)
Ms Ayesha Salim's 21
October 2003 'offer' faxed to Piper Smith
Basham:
"If the offer is rejected and your
client is held liable at the trial."
Ms Ayesha Salim's 28
May 2004 letter to me:
"...we will be
seeking an order for our client's
costs."
The effect of this was that over a
period of 20 months I suffered unbelievable
harassment, alarm, distress and torment
with serious consequences on my physical
and emotional health, great financial
loss and a highly detrimental impact
on my quality of life...
...and continued
to suffer long afterwards due to the
judge in West
London County Court: # 14 deciding
to offer Ms Salim the 'freebie' of having
the action against me "stayed" (See
also
Lord Falconer
of Thoroton # 4 )
Visitor to the site, I give as evidence the
fact that I have numerous witnesses
to the state I was reduced to - including
medical evidence. (See My Diary Year 2003 11 November , 12 November , 13 November , latter part 13 November , 14 November , November 2003 , Latter part of November 2003 , December 2003 , Christmas 2003 )
Given CKFT's method of operating, added to the
fact that there appears to be nothing to stop
Mr Ladsky from filing a false claim against me
in court every day of the week, I concluded that
my only solution for stopping him - at least
for a while - was to file a complaint against
CKFT.
Subsequent note: In -my non-lawyer opinion - I hold the view that Cawdery Kaye Fireman & Taylor -"under instructions from its client" Mr Ladsky - has, in addition to breaching my lease - committed offences against me under the Malicious Communications Act 1988, the Protection from Harassment Act 1997 and the Theft Act 1968 s.21 Blackmail
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(6) My complaint to the Law Society and its
replies
The complaint I filed with the Law Society
against CKFT comprises of:
a summary dated
20 December 2004, supported by
detailed background
information , dated 20 December 2004, as
well as
a pack of 132 enclosures ,
also dated 20 December 2004
With these I enclosed:
a covering
letter , dated 20 December 2004, and
a completed
form , dated 20 December 2004
Given my experience with the Law Society in
relation to my complaint against Piper
Smith & Basham,
I decided that, in filing my complaint
against CKFT, I had to gain as much knowledge
as possible in order to 'pin down'
the Law Society .
Over several weeks, I spent evenings and weekends
researching the solicitors code of conduct, numerous
Acts, the Civil Procedure Rules, etc.
Indications are that I succeeded in doing this
as the 8
February 2005 reply did
not leave the door open for further communication.
(Unlike the case of my complaint against Piper
Smith Basham where it was clear that the Law
Society wanted to keep me running 'like a hamster
on a wheel' until I accepted its ludicrous
assessment)
As can be seen from, among others, the summary of
my complaint, it is my
- non-lawyer - opinion that...
...CKFT has breached many of the rules
in the handling of the case, rules comprised
under the solicitors code of conduct
and Civil Procedure Rules. Also,
that it has committed criminal offences.
Well, CKFT's trade association, the Law
Society, does NOT share my views about breaches
of the solicitors code of conduct and Civil
Procedure Rules - as evidenced
by its reply of 8
February 2005 which concludes with:
"...I am not in a position to
take any of your concerns any further"
I responded to this letter on 19
February 2005 .
To this letter, the Law Society replied on 17
March 2005
"...read through your letter and do
not believe that I can add anything
further over and above what is cited
in my letter of 8 February 2005."
I also highlight that in her 11
July 2005 reply, the Legal
Services Ombudsman has endorsed the Law Society's response. The
sentence in the penultimate paragraph reads:
"In the circumstances... I take
the view that the Law Society's response
was satisfactory and that their decision
to close their file was justified."
In light of this reply, on 1
August 2005 , I just sent an acknowledgement
capturing the above sentence. I felt that my
precious little spare time would be more usefully
spent developing the site, instead of wasting
it writing a letter drawing attention to points
and evidence I had already supplied.
As
they were not acknowledged the first
time round, nor would they be the second time
round.
Although not a lawyer, I strongly believe
that I have a valid complaint against CKFT
The following are examples of some of the key
points in my 20
December 2004 complaint.
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(6.1) CKFT committed an abuse of the court
process
(NB: Events covered in my 3 June 2008 (74pg) Witness Statement; (4pg) Main Points)
Under point 1.1.4 in the summary of
my complaint, headed 'Principle (f) (duty
to the court)' of the solicitors code of
practice, I stated: "CKFT breached
its duty to the Court by pursuing proceedings
which amounted to an abuse of process of Court" (i.e. the 29
November 2002 claim , ref: WL 203537) - giving
as reasons:
The fact that leaseholders had
been told at the 29
October 2002 LVT pre-trial hearing to NOT
PAY the
service charge until the Tribunal has
issued its determination - and
it had been implemented
The fact that CKFT was fully cognisant
of this action as, in reply to my 17
October 2002 to CKFT in which I asked
"Are you aware that Steel Services has
applied to the Leasehold Valuation
Tribunal for determination of the reasonableness
of the charge for major works?"
Mr
Lanny Silverstone's reply of 21
October 2002 states:
"We are aware that Steel Services has applied
to the Leasehold Valuation Tribunal"
(A copy of these letters was included in the
supporting enclosures to my complaint to
the Law Society. In the main
body of my complaint, I refer to the 17
October 2002 letter under points 72, 73 and
75. While I refer to the 21 October 2002 letter
under points 75, 178 and 179)
I also supplied the Law Society with a copy of the 29 November 2002 court claim ref. WL 203537, drawn-up by CKFT , including the Particulars of Claim (1.1MB) and, in my complaint, under point 82 , I reproduced the content of the Particulars of Claim which states , among others :
"The Claimant believes that the facts stated in this Claim Form are true"
I followed this, under point 82, by stating "This claim, written by CKFT, is false on several counts".
In first place, I wrote : "
1. As previously explained, payment is not due as the LVT told residents to not pay until it had issued its determination and therefore until it had been implemented"
One of the responses from the Law
Society's 8
February 2005 reply to this part of my
complaint includes
"...CKFT on a client's instructions
were at liberty to issue proceedings" (ABSOLUTELY UNBELIEVABLE!)
I draw your attention to the fact that
some of the Law Society's own members
do NOT share its view - (thereby vindicating
my 'non-lawyer'
position) e.g.
The 12
December 2002 letter from one of the leaseholder's
solicitor to CKFT:
"We are surprised
that proceedings have been issued at West London
County Court whilst consideration of your client's
claim is currently before the Leasehold Valuation
Tribunal.
We have written to you concerning
this.our letter dated 28 October 2002.
We will
refer to this correspondence
to the court. Please
confirm that you will arrange
for the proceedings issued at West London
County Court to be suspended pending resolution
of the issues before the LVT."
The 9
April 2003 letter from Ms McLean, Piper
Smith Basham, to my then solicitors:
"We
shall be contending that the county court
proceedings should be stayed pending
the outcome of the Leasehold Valuation Tribunal.
It
could be said in our view that having
issued an application to the LVT. to thereafter commence
proceedings in the county court seeking
the recovery of those same charges could
be an abuse of the process of court".
I
included this letter as part of the supporting enclosures
to my complaint for the purpose of
substantiating point 136 in the main
body of my complaint - under which I captured extracts from the above letter.
See my reply of 19
February 2005 to the Law Society in which,
among others, I refer to parts of the solicitors
code of conduct.
Another of the responses from the Law
Society to this part of my complaint
includes:
"..the information which you have provided
does not demonstrate that CKFT acted
as alleged above as they were at liberty
to issue a claim at court for the Court
to consider"
Please note that:
Under point 78 in
the main body of my 20
December 2004 complaint, I quote from
the booklet that
we, leaseholders, were handed at the 29
October 2002 pre-trial hearing. As can
be seen, I captured the exact text which
states that
"...a recent Court of Appeal case ruling
(Daejan Properties Limited v London
Leasehold Valuation Tribunal) determined
that LVTs only have the jurisdiction
to decide the reasonableness of disputed
service charges that
are still unpaid. "
I copied the first 5 pages of the
booklet, including the front cover, which I included
as part of the enclosures with
my complaint to the Law Society
I covered this issue /
referred to it among others, under
points 75, 81, 82, 83, 92, 97, 131, 139, 143, 150,
157, 179, 181 in the main
body of my complaint. In other words: at
least 12 times .
Under point 114 in the main
body of my complaint, I highlighted part
of point 64 (page 15) of the 17 June 2003 LVT/SC/007/120/02 determination (ref. #992 on the LVT database)
"...the Respondent and other tenants could
not be forced to contribute in the
case of improvements and / or works
not determined as reasonable by the Tribunal"
And the Law Society is of the view that
"...the information [I] provided
does not demonstrate that CKFT acted
as alleged." (ABSOLUTELY UNBELIEVABLE!)
See also my reply of 19
February 2005 to the Law Society
Fair minded, reasonable visitor to the
site: do you see why I stated in the introduction
to the site that there is 'no avenue open to
me for justice and redress on this island'?
Subsequent note - In my non-lawyer opinion - I hold the view that Cawdery Kaye Fireman & Taylor -"under instructions from its client" Mr Ladsky - has, in addition to breaching my lease, committed offences under the Malicious Communications Act 1988, the Protection from Harassment Act 1997, the Defamation Act 1996, the Theft Act 1968 s.21 Blackmail and s.16 Obtaining pecuniary advantage by deception ( 9 out of 14 flats on the 29 November 2002 West London County Court claim ended-up paying the full amount demanded in the claim + a further 16 flats also paid the full amount (Pridie Brewster # 18 ) the Landlord and Tenant Act 1985 s.19(2), the Court and Legal Services Act 1990 Ch. 41 s.17 and CPR 1 1.3
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(6.2) CKFT made inappropriate use of forfeiture
legislation in an attempt to force me to
pay monies that were not due and payable
(NB: Events covered in my 3 June 2008 (74pg) Witness Statement; (4pg) Main Points)
The second example is recorded under point 1.2.2.1
in the summary of
my complaint that "CKFT inappropriately
used Forfeiture legislation, as well as threatened
to contact my mortgage lender as a means of obtaining
from me monies not due and payable" .
This refers to the 7
October 2002 letter from Mr Lanny Silverstone in which he demanded that I immediatedly pay the sum of £14,400.19 (US$25,400)
"Our client requires payment of the above
sum within seven days of the date of this letter.
Our client reserves the right to
take action to forfeit your lease for
breach of covenant and to communicate with
your mortgagee (if any) if such action becomes
necessary"
(As evidenced by Mr Lanny Silverstone 's
reply of 21
October 2002 ) CKFT knew that its
client had applied to the LVT "to
determine the reasonableness of the service
charge demanded" )
I read this letter at work. It caused me so much distress that I ended-up being physically sick (My Diary - 10 October 2002 )
In the main body of my 20
December 2004 complaint, this is covered,
among others, under points 67, 68, 69, 70,
75, 178 and 179.
Under point 70, I also highlighted Mr
Lanny Silverstone's very
different style in the treatment ( 12
days later ) of a leaseholder represented
by a solicitor, as evidenced by his 21
October 2002 letter to the leaseholder's
solicitors:
"We note that you have made no proposal
on behalf of your client to pay all or part
of the interim service charge.
We would
be grateful if you would clarify whether
your client does in fact have any objection
to the cost of the major works."
I also included a copy of this letter as part
of the enclosures .
In my complaint (under point 1.2 in the summary and
under points 68 and 69 in the main
body ), I recorded Mr Silverstone's 7
October 2002 letter to me as amounting
to an offence under Section 21 of
the Theft Act 1968: "Blackmail" (Subsequent note: to which I could have also added criminal offences \under: the Malicious Communications Act 1988, the Protection from Harassment Act 1997, and an offence under the Landlord and Tenant Act 1985 s.19(2))
To this, the Law Society replied
"You claim that CKFT improperly demanded
money from you that was not due.
This, in itself, is a legal issue which this
office cannot consider."
My 19
February 2005 response was:
"Your assessment is incorrect: "Rule 17.05 of the Solicitors Code of Conduct - Letters
before action - When writing a letter of claim
a solicitor must not demand anything other
than that recoverable under the due process
of law" .
I also added: "I refer you again to the
Administration of Justice Act 1970, Section
40" (Subsequent note: I have changed my mind about this - see my note under the extracts )
Fair minded, reasonable visitor to the
site: do you see why I stated in the introduction
to the site that there is 'no avenue open to
me for justice and redress on this island'?
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(6.3) CKFT demanded monies not due and payable
(NB: Events covered in my 3 June 2008 (74pg) Witness Statement; (4pg) Main Points)
The third example refers to my complaint to the Law Society that
CKFT had:
"obtained orders before
the LVT issued its report" ; " ...demanded
monies that were not due and payable - as
ruled by the 17
June 2003 determination
by the Leasehold Valuation Tribunal,
and under the terms of my lease" ;
" consequently that
it led to residents being charged
differentially for the works. CKFT's client
cannot charge differentially "
This is captured in the summary of
my complaint under points 1.1.2.2., 1.1.3.2,
1.1.3.5 and 1.1.3.6.
Under point 148 in the main
body of my complaint I highlighted the
fact that, in its 23
May 2003 Case Management Conference
application to West London County Court,
CKFT states:
"The Claimant has
obtained judgment or settled proceedings
against all Defendants, except the following:
1st., 2nd., 5th. and 7th. Defendants" .
One example can be seen from the consent order faxed by CKFT to West London County Court on 2 April 2003. It reads:
"Judgment against the Seventh Defendant dated 28 January 2003..."
Please note the date. This is ABSOLUTELY APPALLING (see (see Lord Falconer # 1 , WLCC # 5 )
Please
note that the LVT signed its determination, LVT/SC/007/120/02 nearly one month AFTER Mr Silverstone's 23 May 2003 application,
as it is dated 17 June 2003 (ref #992 on the LVT database)
In my complaint to the Law Society, I provided
comprehensive detail of the LVT determination
under section 5 "Determination
by the LVT - 17 June 2003" (points
103 - 123),
supported by documents, including
a copy of the LVT report and the reports
from my surveyor.
This included my surveyor's assessment of 31
July 2003 that the LVT determination had NOT been
reflected in the document produced subsequent
to the 24
June 2003 hearing
(My
surveyor, Mr Brock, is
a Chartered Surveyor,
member of the RICS. To which I will
add: a highly professional surveyor,
with the utmost level of integrity)
Based on my surveyor's
assessment (as the Leasehold
Valuation Tribunal - 'conveniently'
for Steel Services - failed to provide
a global assessment
of the sum demanded - thereby failing
to perform its remit : Leasehold Valuation Tribunal # 4 , # 6 , # 7 , # 10.7 ),
the outcome of the LVT determination,
in relation to the original global sum
demanded of £736,206
(US$1.3 million) (£564,467 (US$995,400)
excl. VAT and 11% management fees) was:
Amount disallowed by the
LVT because improvements: £169,498
(US$299,000) (£129,958 (US$229,200)
excl. VAT and fees) = 23% of
the global sum demanded (point 48, 29
August 2004 )
Amount for which the LVT
could not make a determination due to
lack of specification = £188,784
(US$333,000) (£144,745 (US$255,300)
excl. VAT and fees) = 25.6% of
the global sum demanded (point 48, 29
August 2004 )
A view supported by the
LVT (*) , considering
the terms of the lease, as well as RICS
best practice, that the reserve fund
should be used as contribution: £141,977
(US$250,000) - or 19.3% of
the global sum demanded (point 48, 29
August 2004 )
Leaving an amount that can be charged of £235,947
(US$416,000) - or 32% of the original sum demanded .
In other words, £500,000
(US$882,000) of the original sum demanded of £736,206 (US$1.3 million) was not
considered as reasonable . (point
48, 29
August 2004 )
(*) In the £500,000 (US$882,000)
I have included £141,977 (US$250,400) of
contingency fund. My then Counsel raised it as
an issue during the hearing as Steel Services
/ Martin Russell Jones had not used it as contribution
towards the costs - and were refusing to do so,
in spite of, among others, having stated this
in the 7
June 2001 letter. (This is captured under
point 34 of the LVT/SC/007/120/02 determination, ref #992 on the LVT database).
However, it subsequently did in my case, as
can be seen in the 21
October 2003 'offer' drawn-up by Ms
Ayesha Salim. I believe this to be because,
among others, I had the 7 June 2001 letter
from Ms Hathaway.
(As detailed towards
the end of the section on Pridie
Brewster,
it is clear that this was not taken
into consideration for - at least
- some of the other leaseholders. Which
is clearly WRONG) (See also Martin
Russell Jones point
# 20)
Although the LVT said to not have the jurisdiction
to force Steel Services to use the contingency
fund, considering Clause
2 (2)(e) of the lease (captured under point
59 of the LVT report), under points 62 the
LVT quotes from the RICS Code.
Under point 114 in the main
body of my complaint, I highlighted part
of point 64 (page 15) of the 17
June 2003 LVT determination
"...the Respondent and other tenants (NB!!!) could
not be forced to contribute in
the case of improvements and /
or works not determined as reasonable
by the Tribunal"
Under point 150 in the main
body of my complaint, I highlighted that:
(1) " As consistently provided and
confirmed by Martin Russell Jones, the amount
of service charge for each flat is a fixed
percentage.
(2) The global sum to which these
fixed percentages are applied must be the same
for all the 35 flats in the block.
I
also stressed that:
(3) these percentages were supplied
by CKFT-Steel Services-MRJ to West London County
Court at the 24
June 2003 and 26
August 2003 hearings, and the full
list of percentages was attached to Steel
Services-MRJ's 7
August 2002 application to the LVT.
(4) As to the global sum for the
works, it has to be the same for all lessees.
Hence, Steel Services cannot charge differentially,
other than on the basis of individual lessee's
fixed percentage share of the service charge"
I repeated this under for example,
point 164 in the main
body of my complaint by highlighting the
contents of the 9
August 2003 letter I had sent to the
court - and on which I had copied CKFT.
Under point 159 of my complaint,
I highlighted Mr Lanny Silverstone's 17
July 2003 letter to the LVT, in which
he wrote:
"Our client's Council has advised us that
the LVT was asked to make a determination of
the specific amount of the service charge payable
the tenant of flat 3, Ms Dit-Rawé." .
Under the same point, I captured
the LVT's reply of 21
July 2003 :
"It is not the duty of the Tribunal to
assess the particular contribution payable
by any specific tenant but only to
determine the reasonableness , or
otherwise of the service charges as
a whole to go on the service charge account from
which no doubt you can assess the proportion
for that particular tenant"
To this I added my note:
"Thereby
confirming again that the determination
of the LVT is for the global sum demanded and
therefore: the decision applies to every resident
in the block"
In his 21
July 2003 reply to the LVT's letter of
the same date, Mr Silverstone wrote:
"We are mindful of the fact that the LVT
was, in fact, in a position to make a determination
of the sums that it considered to be reasonable
based on the evidence that it received at various
hearings"
Equally, CKFT's client, Mr
Andrew Ladsky, had full knowledge
that the LVT determination applies to the whole
block, as evidenced by his letter to the tribunal,
captured under point 50 of the LVT
report :
"Whilst I accept that the Tribunal
is to rule on the reasonableness of
the proposed works."
As did his 'other puppet', Ms Joan
Hathaway, Martin
Russell Jones, as can
be seen in 'her' 16
December 2002 letter to me (I believe
this letter was written by Mr Andrew
Ladsky ):
"...the Chairman of the tribunal's instructions
where he indicated that the tribunal
was concerned with the reasonableness
of service charges as set out
in Section 19 of the Landlord & Tenant
Act 1985"
(This is addition to the fact that Ms Hathaway
filed the 7
August 2002 application to the Leasehold
Valuation Tribunal "to determine the reasonableness
of the works" )
(NB: Please note that (after a battle) Mr Stan Gallagher eventually admitted (point 4(1) of his 11 October 2004 reply:
"I accept that the outcome was a significant reduction in the amount due from the tenants" (point 8) (Mr Gallagher # 3.a.3 )
"I accept that it is possible that, given the level of the sums disallowed by the LVT and the criticisms that could be made about the landlord's conduct, a Court may have been persuaded to make no order for costs" (point 6) (Mr Gallagher # 3.a.3 ) )
As with everything else, I included a copy
of these documents in the enclosures to
the Law Society (but not Mr Gallagher's 11 October 2004 reply)
To these, the Law Society 's
replies in its 8
February 2005 letter were:
"CKFT were at liberty to enter
into negotiations with the parties to the litigation
in spite of the pending action in the County
Court"
"...it would be for those individuals
to have taken appropriate legal advice
in order to protect their position."
"This is not a matter for this
office and should have been raised before the
Court for it to determine the jurisdiction
of the Leasehold Valuation Tribunal over the
Court's jurisdiction in respect of CKFT's client's
claim"
My 19
February 2005 reply to these included
"It
is a matter for your Office as there
has been breach of the Solicitors Code of Conduct"
The outcome : 9 out of 14 flats on the 29 November 2002 West London County Court claim ended-up paying the full amount demanded in the claim + a further 16 flats also paid the full amount (Pridie Brewster # 18 )
Subsequent note: In my non-lawyer opinion - I hold the view that Cawdery Kaye Fireman & Taylor -"under instructions from its client" Mr Ladsky - has, in addition to breaching my lease, committed breaches under the Malicious Communications Act 1988, the Protection from Harassment Act 1997, the Landlord and Tenant Act 1985 s.19(2), the Theft Act 1968 s. 21 Blackmail, s.16 Obtaining pecuniary advantage by deception, the Money Laundering Regulations / Proceeds of Crime Act 2002, the Courts and Legal Services Act 1990 Ch. 41 s.17 and CPR 1 1.3
Fair minded, reasonable visitor to the
site: do you see why I stated in the introduction
to the site that there is 'no avenue open to
me for justice and redress on this island'?
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(6.4) CKFT actively supported the breach of
covenants in my lease
Under point 1.1.3.2 in the summary of
my complaint I wrote "CKFT has repeatedly
refuted my defence that the demand was in breach
of the terms of my lease opting instead to align
itself with its client in spite of the evidence"
In the main body of my complaint, under point
98, I wrote
"'Even if' lawyers want to argue that the
sum demanded is an "interim payment" (although
I simply cannot see how this could be demonstrated
in view of the facts), I would like to draw
the attention to Clause
(2)(2)(j) of my lease (attached) :
". nothing shall disable the Lessor from
maintaining an action against the Lessee in
respect of non-payment of any such interim
payment as aforesaid notwithstanding that the
Accountant's Certificate had not been furnished
to the Tenant at the time such action was commenced subject
nevertheless to the Lessor establishing in
such action that the interim payment demanded
and unpaid was of a fair and reasonable amount
having regard to the amount of the Service
Charge ultimately payable by the Lessee"
In the main
body of my complaint, under points 103 - 115,
I provided comprehensive detail on the LVT
determination, and wrote in my introduction
"I will now demonstrate that the £14,400.19 (US$25,400) demand
I received was very far from being "fair and
reasonable" as the impact of the LVT determination
meant that it should be reduced by nearly 70%
to £4,615" (US$8,200)
I also added
"It will also demonstrate that Steel Services
is in breach of Clause
(2)(2)(b) of my lease which states: "The
lessor will use its best endeavours to maintain
the annual service charge at the lowest reasonable
figure consistent with due performance and
observations herein". I will demonstrate
in the following that this has most definitely
not been the case."
The Law Society's 8
February 2005 reply was
"CKFT owed a duty to their client to act
in their clients best interests and put forward
their arguments.
Therefore, the rebuttal of your defence
would be the normal course of the litigation
process.
This aspect cannot be taken any further
as in refuting your defence CKFT would have
been relying upon their client's instructions and utilising their professional judgement
on the evidence before them and their interpretation
of the law"
I
replied
"You are endorsing the position that it
is proper conduct for an officer of the court
to assist its client in breaching statutory
requirements and contractual obligations..."
"Your conclusion suggests that, if for example, Mr Ladsky instructs Mr Silverstone and/or Ms Salim to shoot you because he is unhappy with the reply you have provided to my complaint against CKFT, they would be under a duty to do so. This, to me, is the logical extension of your position"
Hence, in filing the claim under
a ' Statement
of Truth ' Ms Hathaway, MRICS, Martin
Russell Jones, and Cawdery Kaye Fireman & Taylor who produced
the claim - breached Clause (2)(2)(j)
of my
lease... in addition to committing a very serious breach of CPR - see My Diary 9 March 2007
Subsequent note: In my non-lawyer opinion - I hold the view that Cawdery Kaye Fireman & Taylor -"under instructions from its client" Mr Ladsky - has, in addition to breaching my lease, committed breaches under the Malicious Communications Act 1988, the Protection from Harassment Act 1997, the Defamation Act 1996, the Landlord and Tenant Act 1985 s.19(2), the Theft Act 1968 s. 21 Blackmail