Subject:
Re: [DPS:4I:51DR001/001:E] L10CL472 - Request for Skeleton Argument hearing held 12 Feb 2025
From:
Davy Thielens <51DP@davylondon.net>
Date:
16/06/2025, 15:15
To:
Jason Kallis <JKallis@meralibeedle.com>

Dear Jason,

This is becoming absurd. You do not need counsel’s opinion on whether to disclose a skeleton argument, particularly one you now seek to rely on. 

Since 5 March, I have asked repeatedly for a copy of the skeleton argument you filed with the Court on 12 February 2025 for the vesting order hearing. We have never received it.

In your latest witness statement, you rely on that document and assert it was served at the time. That is simply untrue.

When we spoke on 4 April, you said you would send it that same day. You did not. Since then, you have either ignored follow-up requests or offered excuses.

You are relying on a document that has not been disclosed. This is not tenable.

Please send the skeleton argument without further delay.

Regards,

Davy


for and on behalf of Tarquin Management Ltd

On 13 Jun 2025, at 14:43, Jason Kallis <JKallis@meralibeedle.com> wrote:

Dear Both
 
I will take instructions, which are likely to refer me to counsel. With that in mind it maybe a few weeks before we respond substantively.
 
Yours faithfully
Merali Beedle
 
From: Tarquin Management Ltd <51DP@davylondon.net>
Sent: Friday, June 13, 2025 12:46 PM
To: O'Rourke, Angela <angela.orourke@justice.gov.uk>
Cc: Jason Kallis <jkallis@meralibeedle.com>
Subject: Re: L10CL472 - Request for Skeleton Argument hearing held 12 Feb 2025
 

Dear Ms O'Rourke,

Thank you for your response and for checking with the usher, your efforts are much appreciated. 

For ease of reference, please find attached a printout of the original email from the Claimants' solicitor, sent at 1:49 AM on 12 February 2025 to the standard court enquiries address. It included the skeleton argument as an attachment, though it was not copied to us at the time. If this information helps in tracing the document in the Court's system, we would be grateful. 

I have copied in the original author, as it would certainly ease matters if he were to reissue the document and save you from having to spend more time tracing it manually.

Separately, could you advise how to ensure the Court records our preference to accept service by email at51DP@davylondon.net? We notified the Court previously, but documents still arrive by post -- often days after they reach the Claimants by email. If there is a specific form or department we should contact to update this, we would be grateful for your guidance.

With thanks again for your help.


Kind regards,

Davy Thielens

for and on behalf of Tarquin Management Ltd

On 05/06/2025 15:34, O'Rourke, Angela wrote:
Dear Sirs
Unfortunately the usher has got back to me and stated that she also does not have any electronic copy
Of this skeleton in her emails
 
Kind regards
Ms A O'Rourke
Correspondence section
CLCC
 
-----Original Message-----
From: O'Rourke, Angela On Behalf Of Central London County, Enquiries
Sent: Thursday, June 5, 2025 3:21 PM
To: 'Tarquin Management Ltd' <51DP@davylondon.net>
Cc: 'jkallis@meralibeedle.com' <jkallis@meralibeedle.com>
Subject: RE: L10CL472 - Request for Skeleton Argument hearing held 12 Feb 2025
 
Dear Sirs
Thank you for your email to the court of 9.5.2025 I have searched the courts computer emails and am unable to locate a copy of the requested skeleton I have asked the court usher by email today whether she may hold a copy on her emails.
If located I will Revert back to yourselves with a copy
 
Kind regards
Ms A O'Rourke
Correspondence Section
CLCC
 
-----Original Message-----
From: Tarquin Management Ltd <51DP@davylondon.net>
Sent: Friday, May 9, 2025 5:16 PM
To: Central London County, Enquiries <enquiries.centrallondon.countycourt@justice.gov.uk>
Cc: Jason Kallis <jkallis@meralibeedle.com>
Subject: L10CL472 - Request for Skeleton Argument hearing held 12 Feb 2025
 
Dear Court Manager,
 
Please find attached a formal letter from Tarquin Management Ltd requesting a copy of the skeleton argument submitted by the Claimant in connection with the hearing held on 12 February 2025.
 
We understand the document was filed with the Court but not served on us. We have contacted the Claimant's solicitor, but the document remains outstanding. As the document formed part of the record before the Court, we ask that a copy be provided.
 
Yours faithfully,
 
Davy Thielens
of and on behalf of Tarquin Management Ltd
 
 
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