Would you like to meet (and/or Davy) and try and hash out our differences?

Sincerely,

John A Galani

On 21 May 2025, at 16:42, Tarquin Management Ltd <51DP@davylondon.net> wrote:

John,

I see you adopt he usual accusatory tone and victim role and that the benefits of a more pragmatic approach totally escape you.

1. Can you please be specific on what you regard as "wrong on the below", i.e. my account of the facts and the offer made back in 2022? Generic assertions like this one are meaningless without some details and supporting evidence. Happy to refer you to contemporaneous communications and documents to support any factual assertion in my previous email you may dispute.

2. The email address was never said or meant to be for Davy alone. I never said anything about this email at all.  Yesterday's email was the first time I wrote anything since March 2024. You are inventing pointless accusations again, just for the sake of it. This email was always meant as a shared address to be used by both of us for the business of the building at 51 Draycott Place and these proceedings. Full stop. And what difference does it make to anything either way?

3. "Our suspicions that the email changes were purely cosmetic": what supposed deceit are you looking for this time and how is this of any relevance? What are you so desperate to show? You have sought to portray everything I do or say as dishonest or hiding some ulterior motive but have yet to identify and prove even a single incident of such supposed dishonesty towards you or other leaseholders.

4. You say nothing about the offer outstanding since 2022 to restore your ceiling. Do I gather you prefer to continue with the fiction of the helpless victim against the evil Dickensian landlord than actually get your bedroom ceiling fixed and stop complaining about it? Are you worried you will be left with nothing to complain about?

5. No, I am not circling around the court order at all. We were just dealing with your ceiling following your latest videos. It seems that as you got a reasonable answer and an offer you cannot refuse, you immediately find something else to complain about. You know already that we are challenging the vesting order because it was wrongly obtained by your solicitor misleading the Court, in other words lying to the Court. That order was premature and should never have been granted as it was and your solicitor should be sanctioned for misleading the Court as he did.  A barrister presenting the case as he did would be likely to be suspended or even disbarred. I am not sure of what happens with solicitors. You cannot get away from the fact that most of the factual allegations in his witness statement were untrue and he knew them to be untrue.  

6. We have not delayed anything, you have made it impossible to move forward with anything and still prevent any progress being made now. This has been explained in correspondence enough times, but you do not want to listen. No point repeating those explanations. Please set out how you say we should have progressed works in the circumstances.

Does that answer your accusations sufficiently? Too detailed an answer and we should just dismiss your comments without explaining and without offering any way forward like you do?

Regards

Mario

On Monday, May 19, 2025 at 6:02:18 pm +01:00, John Galani <john@galani.com> wrote:

Mario,

Your email of 19 May 2025 does not alter our position: you are factually wrong on the below and you circle around the court's decision obliging you to sign the TR1, refusing to do so with no explanation, having already delayed by years said roof works amongst many other works essential to this building.  

You are even using the email address that you yourself stated was for Davy as you were stepping out, confirming our suspicions that the email changes were purely cosmetic.

Sincerely,

I

On Mon, May 19, 2025 at 20:24:39, Tarquin Management Ltd <51dp@davylondon.net> wrote:

Dear John,

I intended to leave Davy to continue dealing with this, as he’s done since April 2024—and since last month with my input where needed—but I have to step in to correct what can only be described as several gross inaccuracies (to use your own words) in your version of events. I’ll keep it short and simple.

The Roof — Again

Your latest complaint about delays on the roof is even more misguided than before.

We’ve been over the original causes: your refusal to allow an inspection by our structural engineer, and your refusal to fund the work—while also blocking the alternative of funding it through borrowing. That’s all on the record, and Davy has already explained it.

But more to the point: you and your solicitor made it clear, for nearly two years now, that you wanted the roof left alone until you’d taken over the freehold. Not just suggested—it was your fixed position. You were absolutely insistent that we shouldn’t start anything.

Just to refresh your memory:

9 September 2022 –

“We are taking over the ownership of the freehold... There is no point you instructing that engineer now…”

19 October 2022 –

“The coming roof works must be done by the new owners of the freehold so even going through that process now would be in my view otiose, as we will need to go through it again once the other tenants own the freehold... We do not see that it is reasonable for you to place or organise contracts of any nature…We want to fix the leaks, but not under your guidance now. The new freeholder can do that.”

You were given multiple chances to agree to an inspection. You dodged dates, moved goalposts, and we finally accepted your position that you wanted to deal with it later. You can’t now turn around and say the delay is our fault because it no longer suits you.

I also remind you that, as far back as 2021, we had also offered for you to be in charge of the whole roof refurbishment, from contractor selection to completion, as you were not satisfied of how we went about the process and wanted more control over it. That was not good enough either and you rejected that offer as well.

The Ceiling — More Fiction

You claim there was an offer to just repaint the ceiling. That’s completely made up. It never happened.

I never said it. Davy never said it. There’s no message, email or WhatsApp that could even be twisted into meaning that. It’s a fantasy—one more example of this victim vs villain story you keep spinning.

Let’s not waste words. I refer you to the email dated 27 September 2022, which we’ve attached again. We invite you to re-read it in full as it could have been written today almost word for word. It’s all there, plain and clear:

“Everything, but absolutely everything, is on standstill as you create a ridiculous overblown conflict because of your bedroom ceiling [...] To take this factor our of the equation and out of pure exasperation .....we can arrange the ceiling in your bedroom to be completely replaced and repainted, in accordance with the recommendations of your expert report, this coming week or the next or whenever it suits you.”

“...without accepting any liability but purely as a compromise to move forward…”

This was a full replacement, not a coat of paint. It was offered to remove your ceiling complaints from blocking everything else: the roof, the entryphone, the front elevation, the common parts. It was never withdrawn.

You did not take up the offer then or when it was repeated since and chose instead to continue complaining about your ceiling and now you want to rewrite history to suit your narrative.

Conclusions 

You’ve said no to inspections, no to external funding, no to major repairs. And now you want to pin the blame on us for your own decisions.

I���ve set the record straight by reference to contemporaneous correspondence, not invented memories. For one last time the ceiling offer stands—exactly as before—if you want it done and stop moaning about it. Otherwise, let’s stop going in circles and inventing excuses for a conflict you created and keep perpetrating which, so far, has only caused disproportionate costs and resentment all round. 

This whole circus you are determined to continue with will not result in any benefit for anyone involved on either side. There will never be "winners" The only winners in all this will be the lawyers, whatever the final outcome.

Regards,

Mario

On Monday, May 12, 2025 at 8:11:05 pm +01:00, John A Galani <john@galani.com> wrote:

Dear Mario and Davy,

Thank you for your email of 12 May 2025. Unfortunately it contains several gross inaccuracies.

1. Ceiling works

Your past offer was limited to repainting -not repairing- the bedroom ceiling. This is wholly inadequate and structurally very dangerous: both your insurer and our engineer confirmed that the ceiling is severely sagging and must be fully replaced, not repainted.  

The insurer also required for disbursement of the claim that the roof be repaired first to prevent further water ingress damaging the repaired ceiling.  

Please therefore confirm—by 19 May 2025—that you will replace the entire bedroom ceiling;

2. Liability

In your email you deny liability yet simultaneously acknowledge that the ceiling “requires replacement” and offer to carry this out. These positions are contradictory and have been from the very beginning since you have already acknowledged in writing that the roof’s water ingress is the lead cause of damage. We reserve all rights to recover our costs should you refuse to act.

Please confirm—again by 19 May 2025—how you intend to proceed. If we do not receive a satisfactory response, we will instruct the works ourselves and seek reimbursement.

Yours sincerely,

John A. Galani

On 12 May 2025, at 18:12, Tarquin Management Ltd <51DP@davylondon.net> wrote:

Dear John,

Thank you for your message and the accompanying videos.

We do not dispute that both the ceiling and the roof require replacement. That has long been accepted. What we do not accept is the claim that the prolonged state of ceiling disrepair is the result of landlord inaction, rather than the result of your actions in relation to the roof, which have blocked even preparatory steps, and still prevent us from carrying out the roof works you want done. This narrative is not new. For clarity, we reiterate our position below.

Starting with your ceiling, we have offered, since 2020, to replace your bedroom ceiling at our own cost, using our contractor, at a time of your choosing. That offer has never been withdrawn. While we deny any liability, whether as alleged or otherwise, we made this offer in good faith to resolve the matter practically. It was not conditional on the roof being completed first, and we confirmed that any further remedial work would also be carried out if required. You never acknowledged that offer, despite it being repeated multiple times. It appears resolution came second to sustaining the narrative.

The same offer remains open today, entirely without prejudice. If you would like to accept it now, we can arrange the work without delay.

Should you instead choose to proceed independently, that remains your decision. However, the cost would be borne solely by you. We do not accept liability, and no agreement to reimburse has been made.

Coming to the roof, we agree it requires replacement and have been seeking to commence works since 2018. The facts do not bear out the suggestion that landlord inaction is to blame. Every practical route has been explored. The real obstacle has not been landlord inertia, but consistent obstruction by some leaseholders. Given that proposals have been rejected, inspections blocked, and funding withheld, your attempt to reassign responsibility seems both false and calculated.

For the roof replacement to proceed, three criteria must be met, as stated throughout:

1.     A valid Section 20 process, including specifications for consultation;

2.     An inspection by our appointed surveyor to prepare those specifications.

3.     Full advance funding for the contract, contingency, and associated costs.

None of these conditions has been fulfilled. Your objections and refusals have impeded each:

     1. Consultation

• Disputed the Section 20 process because specifications were insufficiently detailed.
  

     2. Surveyor inspection

• Objected to the appointment of our surveyor, claiming the appointment itself required consultation;
  
• Repeatedly refused access for inspection, despite formal notice;
  
• Adopted the position, via your solicitor, that inspection can be deferred until after enfranchisement.
  

   3. Funding

• Refused to make any advance contribution to the works, or to ongoing upkeep, since part-settling the 2018–19 demand;
  
• Successfully applied to stay the Tribunal application that sought to clarify leaseholder responsibility for funding planned works;
  
• Rejected the alternative of the company borrowing against future contributions.
  

You have rendered it practically and financially impossible for the freeholder to carry out the roof repairs, yet now cite that very inaction as the cause of further damage. That contradiction does not stand.

Unless your position changes on the points set out above, there is no practical route forward. The landlord is not blocking progress; however, the absence of leaseholder funding, the refusal to consider a loan facility as an alternative to advance payment, and your continued denial of access to our structural engineer are hindering progress. Without funds in place, no contract can be awarded. This is not a matter of principle, but of commercial and legal necessity. Only the leaseholders can unlock the works by fulfilling their obligations under the lease.

 Yours sincerely,

Davy

of and on behalf of Tarquin Management

On 11/05/2025 15:19, John A Galani wrote:

Dear Davy,

I have returned from a trip to find the historical damage to our 3rd floor bedroom ceiling from the roof leaks starting end 2016 into 2019 has now substantially worsened with the entire ceiling sagging.

We will urgently undertake remedial work which now cannot wait and will bill Tarquin for this; it was always accepted by both parties that the water damages were a direct consequence of said leaks, but with Tarquin failing to actually undertake the required repairs to the roof, let alone ceiling and wardrobe, as we all well know.
 
Sincerely,

John A Galani