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 That offer has never been withdrawn.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