Case Summary & Legal Analysis

Strategic Overview for Incoming Solicitor

URGENT: Immediate Actions Required

CRITICAL DEADLINE: Wright Hassall letter dated 9 January 2026 threatens court proceedings within 14 days. Previous solicitor (Benchmark) terminated retainer on 16 January 2026 after receiving £2,142 in fees.
  1. Respond URGENTLY to Wright Hassall LLP - Three letters received (3 Oct 2025, 14 Nov 2025, 9 Jan 2026). Latest threatens immediate court proceedings.
  2. Review the June 14, 2023 Stan Harris letter - WH is using this letter against Katerina. Critical to understand its contents and context.
  3. Provide insurance documentation - WH demanding copies of building insurance policies (2025-2026 policies available)
  4. Address Section 30A notice - WH claims Katerina failed to respond to tenant's notice under Landlord and Tenant Act 1985
  5. Prepare defence strategy - Address all claims while considering strong counter-claims

Case Overview

Client: KG Project Ltd (Director: Mrs Katerina Perepech)
Opposing Party: Mr Albert (Al) Sarpong - Leaseholder, Flat 14
Opposing Solicitor: HCR Wright Hassall LLP (from October 2025)
Property: 14-16 Carroun Road, Vauxhall, London SW8 1JT
Lease Date: 8 November 2013 (TGL388326)
First Contact: November 2016 (insurance policy communication)
Dispute Origin: March 2021 (first roof leak mention) / February 2022 (roof repairs)
Amount in Dispute: £3,500 (roof repairs) + ongoing maintenance costs + ground rent arrears
Total Emails Analyzed: 170+ emails across 9 years (2016-2025)
Previous Solicitor 1: Stan Harris - Buckles Law (to end 2022), then SA Law Solicitors
Previous Solicitor 2: Ross Paterson - Benchmark Solicitors LLP (Oct 2025 - Jan 2026) - Retainer terminated; £2,142 paid

Key Parties & Their Positions

KG Project Ltd (Freeholder)

Director: Mrs Katerina Perepech

Position:

  • Roof is freeholder responsibility (accepts "Retained Parts" argument)
  • BUT Al should not have acted unilaterally without consultation
  • Questions legitimacy of contractor and payment
  • £3,500 is excessive - offered £978.75 maximum
  • Al obligated to pay 50% of repairs under lease
  • Ground rent arrears owed

Mr Al Sarpong (Leaseholder)

Property: Flat 14 (2nd & 3rd floors)

Position:

  • Emergency repairs were necessary - freeholder unresponsive
  • Lease "Retained Parts" clause makes roof freeholder's responsibility
  • Entitled to full £3,500 reimbursement (or at least 50%)
  • Disputes 50% contribution clause interpretation
  • Claims lease is "out of date" - references defunct Management Company
  • Now represented by Wright Hassall LLP

Factual Background

Early Relationship (2016-2021)

CRITICAL EVIDENCE DISCOVERY - March 2021 Emails

Wright Hassall claims (paragraph 16, Nov 2025) that Katerina "was notified of roof issues in March 2021" to suggest 11 months of neglect before the 2022 repairs. The actual emails prove this is misleading:

  • The leak Al mentioned was from October 2020 - 5 months before the email
  • Al explicitly stated the leak "has not happened since then" - it had stopped
  • Al was asking a question about lease responsibility, not demanding repairs
  • Al himself said renovation works should wait until "next year"
  • The March 2022 repairs were for a NEW, DIFFERENT leak

View Full Email Evidence →

The Roof Repair (February 2022)

The Dispute Develops (2022-2023)

Settlement Attempts (June-September 2023)

Escalation (2025-2026)

Why Katerina Needs New Legal Representation

Benchmark Solicitors (Ross Paterson) terminated the retainer on 16 January 2026 after a strategy disagreement. Key issues:

Benchmark's Approach (Rejected by Katerina)

  • Wanted to focus only on responding to WH claims
  • Advised against raising counter-claims initially
  • Recommended "proportionate" response
  • Did not want to pursue "trespass" argument strongly
  • Concerned about tribunal costs exceeding disputed amount

Katerina's Position

  • Wants strong counter-claims raised immediately
  • Believes Al acted unlawfully by performing unauthorised works
  • Wants to pursue payment irregularities (JS Whitbread)
  • Feels previous solicitors too passive
  • Wants aggressive defence of freeholder rights
Fees Paid to Benchmark: £2,142 (Oct 2025 - Jan 2026) with no substantive response sent to Wright Hassall

Key Legal Issues

1. Roof Repair - "Retained Parts" Clause

Lease Terms: Schedule 1 states property does not include "Retained Parts" which include "the main structure of the Building including the roof and roof structures, the foundations, the external walls..."

Analysis: The roof appears to be the freeholder's responsibility. HOWEVER, the lease likely requires consultation before works and may require contribution from leaseholder.

Defence Points:

  • Al acted unilaterally without prior consultation
  • No competitive quotes obtained
  • Payment irregularity (to individual, not company)
  • Contractor solvency concerns

2. Contractor Legitimacy - Solution Roofing Ltd

Facts:

  • Sole director: Matthew Dean Eastwood
  • Payment requested to be made to "JS Whitbread" - not a director or shareholder
  • Company subject to strike-off proceedings at Companies House
  • Company now dissolved

Significance: Raises questions about legitimacy of the work and whether the £3,500 represents fair value. Also affects ability to pursue 10-year warranty.

3. 50% Contribution Clause

KG Project's Position: Lease requires leaseholder to contribute 50% of repair costs.

Al's Position: The relevant clause refers to "rates, taxes and impositions" - not repairs explicitly.

Analysis Required: Detailed review of lease clauses regarding service charges, repair contributions, and sinking fund provisions.

4. Ground Rent Arrears

Facts:

  • Ground rent: £250 per annum
  • Multiple years unpaid
  • Lease states ground rent payable whether demanded or not

Note: Ground Rent Act 2022 reforms may affect enforcement - legal advice needed on current position.

5. Insurance

Al's Claim: He was never informed about building insurance and had to purchase his own.

KG Project's Position: Building insurance is in place (documentation available for 2025-2026).

Action: Wright Hassall has requested insurance documentation - this needs to be provided.

6. Management Company

Issue: Lease references a Management Company that was never established.

Al's Argument: This makes the lease terms "out of date" and unenforceable.

Stan Harris's Response: The lease transfers with the property - you don't get a new lease when purchasing a leasehold.

Potential Defence Strategy

Strong Points for KG Project

  1. NEW - March 2021 "Notification" Rebuttal: WH claims Katerina was "notified of roof issues in March 2021" - but Al's own email shows the leak had already stopped ("It has not happened since then") and he was asking an informational question, not demanding repairs. The 2022 works were for a DIFFERENT, NEW leak. This destroys WH's narrative of landlord neglect.
  2. 10-Year Warranty: The roof repairs came with a guarantee - any issues should be pursued against contractor first (though company now dissolved)
  3. Unauthorised Works: Al performed works without prior consultation or freeholder approval - potential breach of lease
  4. Payment Irregularities: Payment to individual (JS Whitbread) rather than contractor company raises legitimacy concerns
  5. No Competitive Quotes: Al admitted obtaining no documented quotes despite £3,500 expenditure
  6. Ground Rent Arrears: Counter-claim for unpaid ground rent over multiple years
  7. Insurance Contribution: Potential counter-claim for insurance premium contributions
  8. 50% Contribution: If lease requires it, Al should contribute to costs of retained parts maintenance

Weak Points / Risks

Potential Outcomes & Recommendations

Option 1: Settlement

Pros:

  • Avoid tribunal costs
  • Preserve ongoing relationship
  • Certainty of outcome

Suggested Approach:

  • Negotiate from previous £978.75 offer
  • Set off against ground rent arrears
  • Establish formal communication protocol
  • Agree contribution basis going forward

Option 2: Tribunal

Potential Claims:

  • First-tier Tribunal (Property Chamber)
  • Determination of lease terms interpretation
  • Service charge disputes
  • Administration charges

Risks:

  • Cost - limited cost recovery in FTT
  • Time - significant preparation needed
  • Uncertain outcome on key issues

Priority Documents & Timelines for Review

Critical Documents

  1. Wright Hassall Letters Timeline - All 3 letters with full analysis (URGENT)
  2. Original Lease (2013) - Key clauses on repairs, contributions, retained parts
  3. Insurance Documentation - Required by Wright Hassall (2025-2026 policies available)
  4. Tribunal Prep Documents - Previous legal analysis and evidence bundles

Comprehensive Email Timelines

  1. Katerina-Al Timeline - 71 emails (Nov 2016 - Jul 2025) - Complete freeholder-leaseholder history
  2. Katerina-Stan Timeline - 50+ emails - SA Law correspondence including key June 2023 letter
  3. Katerina-Ross Timeline - Benchmark Solicitors relationship breakdown (Oct 2025 - Jan 2026)
  4. WhatsApp Messages - Informal communications and real-time exchanges

Key Contact Information

Client

KG Project Ltd

Director: Mrs Katerina Perepech

Office: 07816082115

Direct: 07496449673

Email: katerina@kgplondon.com

Opposing Solicitor

HCR Wright Hassall LLP

Acting for: Mr Albert Sarpong

(Contact details per their letterhead)

Previous Solicitor 1 (SA Law)

Stan Harris - Consultant

SA Law Solicitors (formerly Buckles Law)

Mobile: +44 (0) 7879 816050

DDI: +44 (0) 1727 798000

Email: stan.harris@salaw.com

Note: June 2023 letter now used by WH

Previous Solicitor 2 (Benchmark)

Ross Paterson - Partner

Benchmark Solicitors LLP

Email: ross.paterson@benchmarksolicitors.co.uk

Retainer terminated 16 Jan 2026

£2,142 fees paid

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