[DPS:4I:51DR001/001:E] RE: L10CL472 - URGENT Please put before judge

Dear Sirs

PLEASE PLACE BEFORE A JUDGE ON RECEIPT - URGENT- RE HEARING ON 15 AUGUST 2025

We do not wish to litigate in correspondence, so keep this reply from the Claimant brief.

We consider all the points in the Defendant’s email below are dealt with in our witness statements. This matter has been ongoing for a long time and had all the relevant documents were served long ago, and by it’s own admission seen/received since April 2025. We are still not aware of any sound basis on which the Defendant wishes to contest the application.

This is a straightforward vesting order application, made upon the refusal of the Defendant to sign a Transfer Deed after an enfranchisement. There is no valid application for permission to appeal (much less an actual Appeal) ongoing, and there are a multitude of urgent issues with the Property that need to be resolved. They cannot be resolved until the Transfer Deed is executed/ Vesting Order made.

Kind regards

Jason Kallis

F: +44 (0) 207 937 9202

M: +44 (0) 7969 691025

Vicarage House

58-60 Kensington Church Street

London W8 4DB

www.meralibeedle.com

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From: Davy Thielens <51DP@davylondon.net>
Sent: Friday, August 8, 2025 7:20 AM
To: Central London County, Enquiries <enquiries.centrallondon.countycourt@justice.gov.uk>; Morris, Diane <diane.morris@justice.gov.uk>
Cc: Jason Kallis <JKallis@meralibeedle.com>
Subject: L10CL472 - URGENT Please put before judge - re: hearing on 15 August 2025

Dear Sirs,

PLEASE PLACE BEFORE A JUDGE ON RECEIPT - URGENT- RE HEARING ON 15 AUGUST 2025

We write further to Mr Kallis’s notes to the Court of 6 August and his third witness statement, served this morning, 7 August. He now states that he concedes the order of 12 February should be set aside, and asks the Court to extend the 15 August hearing to 1.5 hours and use it to dispose of the Claimants’ application for a vesting order

At the same time, four of the five pages of his witness statement argue that the conditions under CPR 39.3(5) are not met. The Claimants cannot have it both ways: argue the application is without merit, then “concede” it to avoid the financial consequences of having resisted it for three months. The 15 August hearing is listed to determine our set-aside application, and that is what we have prepared for, and will continue to prepare for, unless and until the Court sets the order aside.

We wrote to the Claimants repeatedly during set-aside preparations, asking for their position on our central point: that the vesting order is premature due to multiple unresolved terms of acquisition not agreed nor determined by the Tribunal. Mr Kallis’s latest statement typifies their response — a stream of allegations, unevidenced and irrelevant to the proceedings, designed to obscure the lack of substance. Not even an acknowledgement was offered. We still do not know their legal or factual position. Preparing for a substantive hearing under these conditions is near impossible.

This has been their approach throughout. Rather than engage with the substance or seek to resolve matters on the merits, the Claimants again resort to false and unsubstantiated claims — not to inform the Court, but to prejudice it, cast us in a bad light, and drive the case down a procedural route that suits them. Just take the increasingly outlandish, but very serious, claims concerning alleged drug offences, offered without any evidence — because none exists. We set out our full objections in an email to the Court on 18 June 2025 (see attached). They remain equally valid now.

We questioned the validity of Mr. Kallis first two submissions as evidence. Since then Mr Kallis has confirmed that the police never shared any information about their visits to the property or any aspect of any investigation. This admission renders the 14 references to police actions, opinions, or conclusions about alleged drug activity nothing more than speculation and conjecture, all misleadingly phrased to give the impression of corroborated fact, when none exists. Still, Mr Kallis stands by every line and offers no correction.

In reality, the entire narrative rests on two isolated events: a 2022 raid when the flat was empty and forced entry was required, and a second police visit in April 2023, allegedly to arrest the tenant, but again, no proof or supporting evidence has ever been provided. Nothing has happened since April 2023: no incidents, no complaints, no reports of antisocial behaviour, making any renewed claim of urgency now wholly untenable.

The Claimants rely solely on their witness statements to support both urgency and substance. We reject these statements as evidence. We have shown how Speculation is routinely framed as confirmed fact. A quick read further reveals that the statements are not based on any first-hand knowledge by Mr Kallis, but on vague hearsay (“we are told”, “they have said”), often attributed to unnamed “clients” without a single specific source. Assertions are inaccurate, selective, or misleading; yet presented as fact under a statement of truth, relying entirely on the credibility of Mr Kallis as an officer of the Court. However embellished, they remain hearsay originating almost exclusively from one of his clients, who has a documented, personal campaign against the tenant of Flat 2. These statements have shed all credibility. They are advocacy, not evidence — and should be treated as such.

We repeat this point deliberately: the aim of these tactics is not to prove a case, but to provoke prejudice and press the Court into premature action. We have not yet had any opportunity to respond to these allegations, plead a defence, or file evidence for a substantive hearing. To treat the matter as suitable for summary disposal under Part 8 would entrench that procedural unfairness. There are clear and unresolved disputes of fact. The matter belongs on the Part 7 track.

As to costs, the Claimants’ position is unsustainable. The prematurity of the vesting order has long been raised, with reference to binding case law. We identified unresolved terms, sought engagement, and were ignored. Their solicitor knew the February hearing was procedurally flawed and that a set-aside was inevitable; a point we raised as soon as we saw the Order in April. Yet they waited until days before the hearing to concede, wasting time and resources. Objections based on tone or our unrepresented status are irrelevant. The application was necessary and well-founded. The costs fall to them.

We will file a further witness statement later today addressing our position on the Application to Set Aside the Order made following the 12 February hearing, the Claimants’ allegations and evidentiary gaps.

Yours faithfully,

Davy Thielens

on behalf of Tarquin Management Ltd

On 7 Aug 2025, at 11:12, Jason Kallis <JKallis@meralibeedle.com> wrote:

Dear Sirs

PLEASE PLACE BEFORE A JUDGE ON RECEIPT - URGENT- RE HEARING ON 15 AUGUST 2025

Please find a witness statement in support of the urgency of this matter, and the need for it to be heard on 15 August, and the costs issues relating to the Defendant’s application. Please place this before the Judge today or tomorrow, along with our email below.

This is filed on behalf of the Claimant.

Yours faithfully

Merali Beedle

From: Jason Kallis <JKallis@meralibeedle.com>
Sent: Wednesday, August 6, 2025 1:08 PM
To: 'Tarquin Management Ltd' <51DP@davylondon.net>; 'Central London County, Enquiries' <enquiries.centrallondon.countycourt@justice.gov.uk>; 'Morris, Diane' <diane.morris@justice.gov.uk>
Subject: Re: [DPS:4I:51DR001/001:E] RE: L10CL472 - URGENT Please put before judge - re: order of 6th June

Dear Sirs

PLEASE PLACE BEFORE A JUDGE ON RECEIPT - URGENT- RE HEARING ON 15 AUGUST 2025

Further to the email below, we have consulted with our counsel and make the follow submission in respect of this matter being heard on 15 August:

1 This matter is urgent due to the issues referred to in previous correspondence and submissions made. It ought to be heard as soon as possible.

2 It is estimated that the vesting order hearing will not take more than 1.5 hours to be heard but ought to be capable of being disposed of more quickly.

3 If the court needs to relist the hearing as a result of the above hearing estimate being in excess of the listed time of 30 minutes, or for any other reason, the Claimant asks that the costs order be no order as to costs or that costs matters relating to this application are reserved to the final hearing of the matter. A short witness statement will be filed and served shortly on this issue, in any event.

Would the court please indicate whether the hearing will remain in the list to dispose of the matter more generally and not just the remaining issues within the Defendant's application.

It is submitted that the claim for a vesting order can be disposed of using the Trial Bundle that was filed and served before the hearing on 12 February 2025.

Yours faithfully

Merali Beedle

Sent from Outlook for iOS

From: Jason Kallis <JKallis@meralibeedle.com>
Sent: Wednesday, August 6, 2025 10:54 am
To: 'Tarquin Management Ltd' <51DP@davylondon.net>; 'Central London County, Enquiries' <enquiries.centrallondon.countycourt@justice.gov.uk>; 'Morris, Diane' <diane.morris@justice.gov.uk>
Subject: RE: [DPS:4I:51DR001/001:E] RE: L10CL472 - URGENT Please put before judge - re: order of 6th June

Dear Sirs

URGENT - PLEASE PLACE BEFORE A JUDGE ON RECEIPT

We act for the Claimant and Respondent in this matter, and write in respect of the hearing dated 15 August 2025, the hearing of the Defendant’s application to set aside the order made on 12 February 2025.

The grounds for this application are not well set out in the application, nor evidenced.

Nonetheless, the notice sent out by the court for the hearing on 12 February 2025 was very short. On this basis alone the Defendant’s concede that the order dated 12 February should be set aside. However, they do not agree to pay costs of that setting aside (the Applicant has not instructed lawyers and in any event there are a number of other issues that relate to costs that would weigh in the Respondent’s favour in this case).

Further, the Claimants are very clear that the address for service used in the claim form and in respect of the service of the Order made on 12 February but dated 2 April was correct – the address has been used by the landlord Respondent since issue, and indeed since 12 February in relation to formal matters and correspondence regarding this matter. Indeed, it is the address most connected with this dispute in any event.

The matter also concerns issues relating to a property being at the centre of a long standing police investigation into drug dealing which the current landlord will not take action in respect of (despite being the long leaseholder of the flat also at the centre of the investigation). The freeholder (as was) has made it his stated intention to cause as much delay and cost for the Claimants and has no real Defence to the Claim either. The property is in disrepair, with the roof needing major works for the last 8 to 10 years, and that lead to a ceiling collapsing dangerously in the last 6 – 9 months. The matter is very urgent as a result, and only relates to a vesting order.

The Claimant’s therefore respectfully request that the court leaves the hearing date of 15 August in as an appointment to make the Vesting Order and deal with costs generally as a result.

Please acknowledge receipt.

Yours faithfully

Merali beedle

From: Jason Kallis <jkallis@meralibeedle.com>
Sent: Monday, June 23, 2025 10:15 AM
To: Tarquin Management Ltd <51DP@davylondon.net>; Central London County, Enquiries <enquiries.centrallondon.countycourt@justice.gov.uk>; Morris, Diane <diane.morris@justice.gov.uk>
Subject: RE: [DPS:4I:51DR001/001:E] RE: L10CL472 - URGENT Please put before judge - re: order of 6th June

Dear Sirs

We act for the Claimant/Respondent.

We agree that the 15 August can remain the hearing date, but we have not agreed any extension of time for the hearing. We would only agree the same if the date remains the same.

Yours faithfully

Merali Beedle

From: Tarquin Management Ltd <51DP@davylondon.net>
Sent: Monday, June 23, 2025 2:04 AM
To: Central London County, Enquiries <enquiries.centrallondon.countycourt@justice.gov.uk>; Morris, Diane <diane.morris@justice.gov.uk>
Cc: Jason Kallis <jkallis@meralibeedle.com>
Subject: Re: [DPS:4I:51DR001/001:E] RE: L10CL472 - URGENT Please put before judge - re: order of 6th June

Dear Mrs. Morris, Court,

Further to the Court’s order of 6 June 2025 — issued in response to the Claimant’s request for urgency — which directed that the set aside hearing originally listed for 15 August be relisted for the first available date after 12 June, we confirm that both parties are now content for the hearing to proceed on 15 August 2025. A copy of Mr Kallis’s confirmation is attached.

In light of this agreement, we respectfully request that the hearing be relisted for 15 August 2025, with the allocated 60 minutes.

Yours faithfully,
Davy Thielens
For Tarquin Management Ltd

On 18/06/2025 10:44, Jason Kallis wrote:

Dear Sirs

In response to the email below, the Claimant/Respondent should make the following clear to the Court staff.

Could we make sure that any decisions made about the listing of this matter are dealt with by the Judge presiding over the application hearing. The Court record should show that this matter results from failures (repeated) by Tarquin to attend to previous court deadlines in this court and in the LVT, and they have stated on record (in writing) that they will make it their job to delay matters, and increase costs. That is, we consider, the purpose of the email below.

The hearing of the Defendant’s application has now of course been listed as per the attached for 15 August. We hereby serve it on Tarquin.

We do not intend to respond to the points made below, here, but can if the Judge wishes us to do so.

Yours faithfully

Merali Beedle

From: Tarquin Management Ltd <51dp@davylondon.net>
Sent: Wednesday, June 18, 2025 9:22 AM
To: Central London County, Enquiries <enquiries.centrallondon.countycourt@justice.gov.uk>
Cc: Jason Kallis <jkallis@meralibeedle.com>
Subject: L10CL472 - URGENT Please put before judge - re: order of 6th June

Dear Judge,

On Monday 16 June 2025, we received at our registered office a notification of an order made on 6 June, directing that a hearing be listed at the first available date, seven days from the date of the order – i.e., from 12 June. The envelope in which the order was sent bears a postmark of 10 June (photo attached), and we only received it on 16 June.

We are not currently represented, and if we understand the order correctly, it means the hearing could now be listed on any day without further notice.

This appears to be in response to an email by Mr Kallis, solicitor for the Claimants, dated 2 June 2025, which grossly misrepresents the current situation and portrays a picture of urgency that is entirely divorced from reality. It is alarmist and unprofessional in the extreme.

Prejudice Arising from Timing and Service

The vesting order was granted at a hearing of which the Defendants received no adequate notice, and on the basis of serious misrepresentations by Mr Kallis – a position he has not resiled from. On the contrary, he doubled down in his second statement and now again in his request for urgency.

We had been in the process of responding to that email and preparing to rebut the unfounded allegations against us as freeholders when we received notice setting a hearing for 15 August. In light of that earlier notice, we felt it unnecessary to correct Mr Kallis’s misleading account or file evidence at that stage.

Now, having received this new notice – very late – of a listing potentially from last week onward, we are faced with an impending hearing at virtually no notice, with both directors out of the country until 25 June.

On the basis of further misleading allegations, unsupported by any evidence from Mr Kallis, we now risk our application to set aside an order made in our absence – and based on untrue statements of fact – being decided again without adequate notice, and again in our absence if listed before 25 June. That would compound the unfairness of the original hearing with further unfairness in the handling of our set-aside application.

We respectfully invite the Court not to list the hearing prior to 25 June and to provide us with adequate notice. We have repeatedly indicated our willingness to accept service by email at 51DP@davylondon.net, but this does not appear to have been updated on the Court file. As a result, the Claimants are served by email the day orders are made, while we receive them only by post, sometimes over a week later – as here, 11 days after the order, and well after the expiry of the supposed 7-day notice.

The Manufactured Sense of Urgency

We strongly invite the Court to reconsider whether this case warrants being prioritised over genuinely urgent matters. The urgency is entirely manufactured, and distracts from the key issue in this dispute: a number of the acquisition terms remain unresolved, have not been agreed, and were never determined by the Tribunal – making the vesting order inapplicable regardless of any claimed urgency.

Mr Kallis makes dramatic assertions – “children evacuated,” an untrustworthy landlord – but provides no supporting evidence. He purports to conclude, “on the balance of probability,” that drug dealing is taking place, yet gives no indication of the evidential basis for that conclusion, or why such an exercise is even necessary if, as he claims, criminal proceedings are ongoing.

These same allegations have been repeated since 2022, never supported with evidence, and already dismissed by the Tribunal both in its substantive decision and its later ruling on costs. No new material has been offered. No incident has been reported to us that would justify evacuations or render the property unusable.

The tenant alleged to be involved in criminal activity has lived at the property since December 2019. There has never been a single report of anti-social behaviour, noise, confrontation, or safety issue. Still less has there been any suggestion that children, including those in Flat 5 – the source of most complaints – were at risk.

There is absolutely no supporting evidence. Not only is there no conviction, as Mr Kallis admits, but no evidence has been offered at all. Just a few anonymous reports of a smell on the common stairs, which could not be verified later. No evidence of a seizure, arrest, denial of bail, custody, or charges. Nothing but the ongoing campaign of Mr Galani in Flat 5, who has labelled the tenant in Flat 2 a “bad apple.”

The Roof Narrative – Facts Omitted

The Claimants now cite a ceiling collapse to reinforce their narrative. Again, facts are missing.

Since January 2021, leaseholders behind the enfranchisement – including Mr Galani – have refused access to our structural engineers to inspect the roof. They have not paid service charges since 2019, rejected all pre-funding and loan proposals, and insisted works wait until the freehold transfers. This position has been confirmed by their solicitor.

We proposed multiple alternatives, including full delegation of the roof works. All were ignored. Our latest email of 29 May 2025 (enclosed) offered four clear options. The reply? “We do not consider it necessary to answer the other points you make on an open basis.”

It is disingenuous for Mr Kallis to now present a crisis. His clients blocked every effort to remedy it. The portrayal of a negligent landlord is false. We have repeatedly tried to find a reasonable solution; every attempt has been rejected or ignored.

The Real Question Before the Court

The true issue before the Court is narrow: the vesting application was premature, and material acquisition terms remain unresolved. None of Mr Kallis’s evidence addresses these defects. Neither of his witness statements engages with the real issue.

This narrative of urgency appears designed to manipulate listing priorities and apply pressure on litigants in person. We consider it a discreditable use of the process.

We respectfully submit that this hearing has been accelerated not on the basis of evidence or law, but on inflammatory rhetoric: a stream of allegations, unsupported and often previously dismissed. We ask the Court to consider whether this matter truly warrants such prioritisation, and whether a return to the original timetable – allowing for proper attendance and preparation – would better serve justice.

Yours faithfully,

Davy Thielens

on behalf of Tarquin Management Ltd

<3rd witness statement of Jason Kallis fv.pdf><Jk3_07082025103250.PDF>