Dear John, all,

We did not say no to a meeting; just to switching it to a video call.
  
You asked for our availability, and we gave it. You chose a time not offered, which did not work. Instead of picking another date, you changed it to a video call. We explained why that was not practical and suggested rescheduling.

Your response feels like you're looking to cancel -- as long as you can blame us for it. But alas, we are still keen to meet.

Regards,

Davy 
Davy
For and on behalf of Tarquin Management Ltd

On 10/07/2025 11:19, John A Galani wrote:

Dear Tarquin,

No apologies needed, we have been around Tarquin long enough, we never expected you to actually go forward with any meeting.

There is no need for an agenda when there is no meeting.

Sincerely,

John A Galani

On 10 Jul 2025, at 14:10, Tarquin Management Ltd <51DP@davylondon.net> wrote:

Dear John,

Apologies for the delay in responding to your email regarding the meeting arrangements.

We note your suggestion to hold the meeting online via Teams at 6pm instead of in person. However, we must respectfully decline. The entire purpose of a face-to-face meeting — especially as this would be the first — is to allow for a proper and direct discussion, with all parties in the same room. That is simply not achievable in a virtual setting, particularly when dealing with longstanding issues and contested matters.

A further key reason for an in-person meeting is ability to search, share and inspect the relevant records and files as and when needed, which is essential to resolving points of disagreement efficiently. That effectiveness would be lost in an online format.

We trust you will understand, and probably agree, that these are not discussions best held over video call. In which case, we suggest finding the next suitable alternative date and time for the meeting. 

In the meantime, i can confirm that you will receive later today our comments on the proposed agenda, together with our written positions on the outstanding issues.

Kind regards,

Davy
For and on behalf of Tarquin Management Ltd

On 09/07/2025 13:34, John A Galani wrote:

Dear Tarquin,

Please confirm your virtual attendance tomorrow at 18:00 UK time as per your choice of date and time for our meeting by confirming the MS Teams invitation.

Sincerely,

John A Galani

On 8 Jul 2025, at 17:27, John A Galani <john@galani.com> wrote:

Dear Tarquin,

In this case we will have to do the meeting remotely at your chosen time.  I am sending out a Teams invite.

Sincerely,

John A Galani

On 8 Jul 2025, at 15:46, Tarquin Management Ltd - Draycott Place <51dp@davylondon.net> wrote:

Dear John,

We offered a range of defined dates and times at which both Mario and I would be available to meet.

10 July at 11 am was not one of them so, no that meeting was never a possibility from the outset. 

We will provide our comments on your agenda and unfeasibility of your proposed venue later today. The agenda can then be adopted, subject to our clarifications. The venue not so.

Regards

for and on behalf of Tarquin Management Ltd

On Tuesday, July 8, 2025 at 11:00:55 am +01:00, John Galani <john@galani.com> wrote:

Dear Tarquin,

Please confirm the meeting on Thursday at 11:00.

Sincerely,

John A Galani

On 1 Jul 2025, at 21:46, John A Galani <john@galani.com> wrote:

Dear Tarquin,

Jason Kallis and Dominic Galvin will be representing leaseholders at the meeting.  

They are free on the 10th July at 11:00 but do not feel comfortable meeting you at your premises, and are therefore proposing the offices of Mr Jason Kallis on High Street Kensington, address 58-60, Vicarage House, Kensington Church St, London W8 4DB.

Please confirm said meeting and who will be attending your side.

Sincerely,

John A Galani

On 30 Jun 2025, at 16:37, John Galani <john@galani.com> wrote:

Dear Tarquin,

Thank you for proposing dates for the meeting.

Meeting Composition and Representation

Your request for all leaseholders to attend any meeting is not practical. Coordinating international travel on short notice, given past experiences with meeting attendance, is unreasonably burdensome.  We will proceed with the meeting using our chosen representatives (which may not necessarily be me personally). 

Meeting Agenda and Outstanding Issues

We have consistently requested a meeting and provided outlines of the issues to be resolved. It appears you are attempting to negotiate these matters through correspondence instead of the face-to-face meeting we have been urging.  For clarity, the agenda for the proposed meeting can be divided into two categories – Legal/Financial Matters and Operational/Property Matters – as detailed below. These are the points that require resolution:

Legal and Financial Matters

1. Transfer of Freehold Title / Premium Payment / Costs: Finalise the transfer of the freehold title as ordered, including payment of the determined premium and any payable costs. (The necessity of completing the transfer is not up for debate – it is a legal requirement following the Tribunal’s decision.)
   
2. Lease Compliance – Flat 2: Address Flat 2’s failure to abide by leasehold requirements. This includes the issue of possession and occupancy (e.g., the situation regarding Russell) and ensuring all lease terms are being honored by the flat’s owner and any occupants. Any breaches of the lease must be remedied promptly.
   
3. Service Charges (2019–2020 and Other Periods): Determine who owes what service charges and when those payments should be made. We point you to numerous correspondence on the subject including the list of questions included therein. As an example, clarification is required on any “professional charges” listed in the service charge accounts – we requested details of those charges, including who levied them, for what services, and copies of the invoices.  The same goes for verification of accounts as is legally required.  We refer Tarquin to its legal obligations on SCs and urge you to comply with them in full. 
   
4. Service Charge Contributions by Flats 2 and 4: We require proof of payment for the service charges that Flats 2 and 4 were billed for and paid over the past years. It is critical to ensure that all leaseholders have been billed the same service charges, and full transparency on payments is necessary, given past concerns, to move forward in good faith.  You state in your email to state that the SC you wish to levy on past periods are now substantially different. 
   

Operational and Property Matters

5. Major Works – Roof Replacement: Confirm the need for a full roof replacement and agree on how this major work will be handled after the freehold transfer. Our position has been consistent in that this substantial work should be overseen by the new freeholder(s) once the transfer is complete (as they will have the long-term interest in the building).
   
6. Ceiling + Wardrobe Damage payment through insurance claim or by Tarquin: Resolve the outstanding insurance claim for the damages to the master bedroom and collapsed ceiling in Flat 5 (the bedroom ceiling that fell in). We need to rectify the insurance claim issue and determine consequences for the failure to allow that claim to proceed properly. Because the claim was accepted but not processed, I have had to pay for repairs out-of-pocket. I will be issuing an invoice for the ceiling repairs and damages in Flat 5, expecting reimbursement. Furthermore, I put you on notice that the handling of this insurance matter may constitute a breach of fiduciary duty by the directors of Tarquin Management Ltd.  If the claim is not reinstated and honored (or our costs not reimbursed), we reserve the right to pursue all remedies, including holding the responsible director(s) personally accountable for failing to carry out their duties in good faith.
   

7. Flat 1 Leak – Access to Flat 2: There is an ongoing leak affecting Flat 1 that requires inspection and likely repairs involving Flat 2. Access to Flat 2 must be granted so that the source of the leak can be identified and fixed. Any continued refusal to provide access will inevitably result in further damage, for which Tarquin Management Ltd and its directors will be held responsible.
   

Conclusion

These agenda items cover the core issues that need resolution for us to move forward should Tarquin wish to settle amicably the outstanding disputes. We expect to address each of these points substantively in the meeting. We will not engage in protracted email negotiations on these matters; the proper forum is the meeting itself.   This includes not be responding to legal arguments or assertions via email, or reviewing accounts "on the side" so to speak, the mechanism to audit SCs can be agreed upon during the meeting. 

Our focus for the meeting is on practical resolution of the above issues and ensuring the tribunal’s decisions and legal requirements are carried out without further unnecessary delay.

Our aim is for either of the 10 or 11 July, but this is still uncertain at this stage, we will revert within the next few days.

Sincerely,

JAG

On Fri, Jun 27, 2025 at 09:31:55, Tarquin Management Ltd <51DP@davylondon.net> wrote:

Dear John,

 

Thank you for your message.

 

We are indeed open to meeting, but the composition of that meeting matters. The request for all leaseholders to attend is not a question of representation. It reflects a simple reality: any serious discussion must include those with ownership stakes and decision-making authority. Conversations limited to the usual intermediaries — however qualified — have repeatedly failed to lead anywhere. Unless we widen the circle, there is little reason to expect anything different now. If there is a genuine intent to resolve matters, all parties with a stake in the outcome must be present in the room. That remains our position.

 

If you recognise the potential that brings, and the Erdems are willing to attend, please let us know their following visit dates to London, with a minimum of two weeks’ notice. We will then propose meeting windows during their stay.

 

Nevertheless, if you are determined to win the optics of the meeting rather than resolve its substance, and to proceed as before, with a meeting limited to you and Jason, by all means proceed. Mario and I will attend. I will be away from 28 June to 4 July, and Mario will be away from 4 July to 9 July. We are both available on 10 or 11 July after 5.30 pm at our registered office, where the records will be on hand. Failing that, we can offer most afternoons from 24 to 29 July after 4 pm, or from 5 August onwards most days after 1 pm, up to the August Bank Holiday.

 

Regarding your reference to the 25 April email, it outlines a list of demands and conditions but does not qualify as an agreed-upon agenda, nor does it address most of the points we have raised, nor does it state your positions and rationale (e.g. what parts of the service charges you challenge and what you accept). That is precisely the issue. Progress will only occur when there is engagement on substance, not just assertions of position.

 

Again, if you choose to proceed on that basis rather than pursue a more cooperative approach, that is your decision. But you will forgive the lack of enthusiasm: that non-reciprocal mindset has delivered little more than stalemate so far, and there is little reason to expect different outcomes now.

 

It does not help that the current framing reads more as a pretext rather than progress, but I may be wrong, and am willing to be proven so. Meanwhile, to preserve our position, we will shortly issue a formal letter of claim for the 2019–20 service charge: in your case, £2,279.58 for incurred expenses and £9,544.71 for recurring costs under the lease, plus four years’ interest. You are, of course, free to respond as you see fit. Naturally, if the meeting proves productive and we can resolve the issue regarding service charges, the claim will likely be dealt with and progress no further.

 

Concerning the TR1, your repeated insistence — echoed by Jason — that the Tribunal’s decision is the “final word” on all matters overlooks clear authority to the contrary. The Court of Appeal explain any terms not determined by the Tribunal remain pending till the Tribunal issues an additional decision in this respect: see Goldeagle Properties Ltd v Thornbury Court Ltd [2008] EWCA Civ 864 (see especially paragraphs 17–28) for a clear explanation of how section 24 of the Leasehold Reform Act 1993,  is to be interpreted and applied. In short, any remaining terms must still be agreed upon or determined before the transfer can proceed. That remains the legal position.

 

We remain willing to move forward. We would like to do so with clarity, substance, and full participation, but that's up to you.

 

Yours sincerely,

 

Davy Thielens

for and on behalf of Tarquin Management Ltd

On 25/06/2025 10:06, John A Galani wrote:

Dear Davy,

We have legal representation and Mario is a barrister, it is not for you to dictate the meeting representatives.  We are willing to meet and keep on asking for dates.

You also refer to outline, it has already been discussed, I refer you to the 25/04/25 email.

Please give us windows for said meeting.

Sincerely,

John A Galani

On 25 Jun 2025, at 02:23, Davy Thielens <tarquin.management@gmail.com> wrote:

Dear John,

Let me begin with the obvious: Mario and I are both willing to meet — as we always have. As I said in my last message: “Our offer to talk remains open, as it always has, if approached in good faith, with a clear agenda and a genuine intent to resolve matters.” And yet, despite this, no meeting has ever taken place.

What continues instead is a pattern of deflection. Each time we try to move discussion toward specifics — timelines, funding models, repair logistics, legal points requiring resolution — the response returns to well-worn themes: alleged preconditions, ghostwritten emails, absenteeism, imagined demands to pre-agree commercial terms. These accusations are not just incorrect and irrelevant — they are a distraction. And increasingly, they serve a single purpose: to avoid engaging with the issues that actually require resolution.

This refusal to deal with content — whether by performance, suspicion, or revisionism — has real consequences. It delays the enfranchisement, drives up legal costs, and obstructs necessary works. It shifts attention away from the concrete decisions that need to be made and turns every communication into a rerun of the same complaints, retold with minor variations. That serves theatrically, but it leads nowhere.

There is a simple truth here: the transfer of the freehold cannot proceed until the remaining issues are either agreed or determined. That is not our opinion; it is a legal requirement under section 24 of the Leasehold Reform Act. It is also why the current vesting order is premature and why, in due course, the Court is likely to say so.

Sooner or later, the focus will have to shift from narrative to substance. If not, and you continue to decline engagement on the actual terms of transfer, the courts will be required to address every point — slowly, formally, and at considerable cost. That is the road we are currently on. If, like us, you prefer a different course, the choice is yours to make. If not, do not expect us to carry the blame for delay or expense.

Should you choose to engage with genuine intent to resolve matters, we are ready to meet up. To get to shared outcomes, that meeting must be structured, prepared, and inclusive. That means setting a clear agenda, sharing short outlines of each party’s position and any known obstacles in advance, and ensuring the discussion is documented. These are not ‘preconditions.’ They are safeguards — or what legal and business professionals would simply call good practice.

Most of all, the meeting requires the attendance of all leaseholders, not just the usual representatives. A limited conversation between you, Jason, Mario and me would only revisit old exchanges. If genuine progress is the aim, then those with a stake in the outcome need to be in the room. If that means that we need to arrange it around the Erdem’s next visit to London, that is what we will do. Provided we have sufficient notice, such as at least a week or two, we will find availability during their stay. I trust you (or Karolina) and Dominic will likewise find availability when they will visit.

As for the bill for ceiling repairs — you can save the stamp. The damage is a direct and foretold consequence of your repeated refusals and deflections — all of which were documented clearly and in advance. Facts do not yield to narrative. There is no question about where that liability lies. The bill is yours to keep.

 

Yours sincerely,

Davy Thielens

for and on behalf of Tarquin Management Ltd

 

On 20/06/2025 15:18, John A Galani wrote:

Dear Davy and Mario (I always have my strong suspicions who write these),

There is very little chance Davy you can write all this -what has transpired over the past 7 years prior to you joining- hence our strong suspicions.  

At the risk of sounding like a totally broken record again and again and again, I keep on asking to meet you without preconditions, you are an absentee landlord refusing to even visit the premises and leaseholders, it would be comical if it was not so tragic.  

Bill coming for the re-plastering and damages to our bedroom.

John A Galani

On 20 Jun 2025, at 18:01, Davy Thielens <tarquin.management@gmail.com> wrote:

 Dear John,

Jason's reply to my recent note only confirms what has long been evident: your side has no intention of cooperating to move the roof replacement forward. As set out in Mario's attached email of 9 January 2023, that stance is not without consequence -- not only for the state of the building, but for your liability, individually and collectively, for any damage that results from further delay. Yet you continue to insist that no work should begin until after the freehold transfer, while simultaneously refusing to fund the repairs or permit access for inspection. 

The court has accepted your fabricated urgency claim and accelerated the hearing of our set-aside application. If, against expectation, you succeed in preserving the vesting order, there will still be an appeal. At best, the freehold will not transfer before the autumn; more likely, spring 2026. The roof will remain unrepaired for yet another winter. And yet, even now, with that outcome in plain sight, your side continues to block every serious effort to proceed in parallel and prevent further damage. It is a continuation of your strategy of delay, dressed as grievance, at the expense of the building you claim to protect.

You cannot have it both ways: refusing to discuss alternatives, refusing access for our surveyors, rejecting all funding models, blocking loans, and then blaming us for the delay. You are the leaseholders of a building with a leaking roof. You have chosen inaction, and you will carry the responsibility for the consequences.

Besides conveying your non-choice, Jason's email exposes two other points. First, your supposed willingness to "settle amicably" is a fiction. Whenever a constructive proposal is made, it is met with silence or disdain. Second, it reveals the true cause of spiralling costs. We estimate your legal bill will exceed £100,000 by the end of the set-aside hearing -- already four times the premium awarded by the Tribunal. And that's without us having engaged counsel yet.

Despite repeated claims that Mario is driving up expenses, the facts point elsewhere. Jason has never once sought to explore settlement, never asked Mario what price might be acceptable to avoid proceedings, never tried to narrow the issues. Instead, he insists that everything be litigated. Even now, faced with continued uncertainty and avoidable harm, he refuses to engage in any form of resolution. That is not negotiation -- it is a crusade.

This single-minded fixation on reducing the premium ignores the broader picture: court fees, legal costs, wasted time. It discounts the real value of closure, speed, and finality. That is not cost control, it is a false economy; one that only benefits those paid to litigate.

Meanwhile the true cost of enfranchisement (the premium and legal expense combined) keeps growing -- not because of obstruction by Mario, but because your side has treated negotiation as optional, and engagement as weakness. I urge you to consider the full cost, not just the headline premium -- which is already the smaller part of the bill.

If you want to contain costs, stop sending everything to Court. Dialogue is cheaper than directions. Litigation has its place, but it should not be used as a substitute for basic communication. Since your notice was served, no attempt at negotiation has been made. Repeated invitations to "just meet and talk" -- without proposals, structure, or acknowledgement of the issues in dispute -- do not constitute meaningful negotiations, particularly in the context of ongoing litigation and serious allegations.

Our offer to talk remains open, as it always has, if approached in good faith, with a clear agenda and a genuine intent to resolve matters. But if silence is your strategy, do not be surprised if the eventual bill reflects it -- and do not expect us to carry the blame.

Yours sincerely,

Davy Thielens

for and on behalf of Tarquin Management Ltd

On 02/06/2025 15:19, Jason Kallis wrote:

Dear Sir

We are instructed to write to you about the email below. 

Our clients and we consider a “fair premium” as you put it has already been assessed, and considered at a one day hearing. Our client will not pay anything more unless it is ordered to do so, and we see no chance of there being a further order as you are out of time to appeal in our view. 

Obviously we are challenging you right to set aside the order made in February 2025, and that may end up having yet further costs consequences, but ultimately those proceedings do not affect the premium payable, they concern a vesting order and that is all. 

We do not consider it necessary to answer the other points you make on an open basis below. 

Yours faithfully

Merali Beedle

From: Davy Thielens <51DP@davylondon.net>

Date: Thursday, 29 May 2025 at 21:46

To: John A Galani <john@galani.com>, Kallis Jason <jkallis@meralibeedle.com>, Galani GB Karolina <karolina@galani.com>, Galvin Dominic <dgalvin@c-sr.com>, "sibelerdem@erdemhukuk.com >> Sibel Erdem" <sibelerdem@erdemhukuk.com>, Erdem Bahadır <bahadirerdem@erdemhukuk.com>, Erdem Pınar <pinarerdem@erdemhukuk.com>

Cc: Tarquin Management Ltd <51dp@davylondon.net>

Subject: Replacing the Roof – A Way Forward

 

Dear all,

The bedroom ceiling in John’s flat collapsed last Friday. Fortunately, nobody was injured, yet it is a wake-up call that legal arguments, objections, and pointing fingers will not fix the roof.

Holding back action until the enfranchisement concludes will be detrimental to the roof and progressively risks further damage to the building itself, to personal property, and unnecessary distress for those affected.

What we need is a practical and agreed-upon way forward, now, to avoid further damage and disruption. I have set out the options, briefly and constructively, as I see them (alternatives are welcome):

1. Tarquin manages the roof replacement

You allow us to go ahead with our preferred structural engineers. They would tender the contract in accordance with statutory consultation procedures. Leaseholders contribute their share of the cost in advance, or agree for the company to borrow the funds, in which case you would pay the interest on your share of the loan. Our structural engineers would supervise the execution. This is only workable with your full and honest cooperation and could potentially be completed by the end of the summer, although that timeline is tight and subject to factors beyond our control.

2. Leaseholders manage the process

If you are not happy with us handling of this, we can delegate the entire process to you, including appointing engineers, selecting contractors (in accordance with consultation requirements), and managing the contract. As we would still be the freeholder, we would enter into the works contract, so we would still require funds in advance or an agreement to borrow them.

3. Leaseholders act independently

Similar to option 2, but you enter into the works contract directly, even though the freehold has not yet transferred. How this is funded is entirely your decision. If you wish Mario (as leaseholder of Flat 2) to contribute, a detailed agreement would be needed with him and with us regarding liability, timing, and costs. We are open to any concrete and sufficiently detailed proposal.

4. Do nothing until the enfranchisement is complete

The default option in case of not choosing, which is continuing to block roof replacement until the freehold has transferred, by means of you refusing inspections and financial contributions. We would discourage this option for the reasons given earlier: delaying further exposes the building and individual flats to ongoing risk and compounding costs. The ceiling collapse has made this risk immediate, not hypothetical. Yet, if you prefer to wait for the freehold to transfer before doing anything, that remains a choice.

When considering these options, I would ask you to be realistic about the implications and timescales of each. The process may well take months to resolve, whether through continued litigation or by agreement.

On the freehold premium and settlement

Lastly, when weighing options, consider the benefits of negotiating a price instead of continuing to litigation. For a fair premium, the freehold can be transferred immediately. A fair price does not mean £24,000. Nor does it have to be the upper end of our valuation. We are prepared to consider the cost savings and practical benefits of resolving this matter swiftly and with minimal or no further court involvement.

The offer has been on the table from the outset. Still, until now, your solicitor has refused to engage on price or even acknowledge the details we have repeatedly set out to explain our position, removing negotiations as a viable and cost-effective option.

If there is now a willingness to negotiate in good faith, based on proper engagement rather than posturing, we are ready to do the same.

Best regards,

Davy

for and on behalf of Tarquin Management Ltd

 

-- 
for and on behalf of Tarquin Management Ltd

<9 Jan 2023 - List on inspection requests etc.pdf>

-- 
for and on behalf of Tarquin Management Ltd