URGENT: Immediate Actions Required
- Respond URGENTLY to Wright Hassall LLP - Three letters received (3 Oct 2025, 14 Nov 2025, 9 Jan 2026). Latest threatens immediate court proceedings.
- Review the June 14, 2023 Stan Harris letter - WH is using this letter against Katerina. Critical to understand its contents and context.
- ✓ Insurance documentation PROVIDED - Ross sent insurance policy/schedule to WH on 10 Dec 2025. WH Jan 9 letter confirms receipt and now asks if storm/water claim has been explored with insurer.
- ✓ Section 30A notice ADDRESSED - Ross's Dec 10, 2025 letter provided the insurance documents, fulfilling the statutory obligation. No summary offence risk.
- 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- Claims lease is "out of date" - references defunct Management Company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)
- November 2016: First contact - Katerina sends insurance policy to Al
- October 2018: Building insurance expired Oct 2017, not renewed. Al disappointed he wasn't notified
- 2018-2019: Ground rent payments made (£250/year), generally cooperative relationship
- February 2021: Al proposes double-glazed windows; Katerina abroad due to COVID
- 31 March 2021: KEY EMAIL - Al mentions PAST roof leak: "there was a leak during a heavy bout of rain back in October [2020]. It has not happened since then." Al was asking an informational question, not demanding urgent repairs.
- 1 April 2021: Katerina responds: "In regards of roof renovation issue I have to look into Lease Agreement and get back to you shortly." - Reasonable acknowledgment of an informational query about a leak that had already stopped.
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
The Roof Repair (February 2022)
- Roof had been leaking since Al moved in (2016) - worsened over time
- Al hired Solution Roofing Limited to perform emergency repairs
- Cost: £3,500 for newly laid slating material
- Payment made to "JS Whitbread" (not to the company - director is Matthew Dean Eastwood)
- Al notified Katerina on 2 March 2022 and sought reimbursement
- Katerina responded that KG Project had "no funds" for maintenance works
The Dispute Develops (2022-2023)
- 6 September 2022: Al cites lease "Retained Parts" clause - roof is freeholder's responsibility
- 26 September 2022: Property inspection conducted
- Stan Harris (Buckles Law) consulted; changes firms to SA Law end of 2022
- January 2023: Al's first ultimatum - threatens legal action
- May 2023: Solicitor questions about contractor (Solution Roofing vs "Solar Roofing")
- 21 May 2023: Fallen pipes issue at back of building - Al cites "Retained Parts" again
- June 2023: Al's second ultimatum - deadline of 15th June
Settlement Attempts (June-September 2023)
- 14 June 2023: Stan Harris sends formal advice letter to Al - NOW USED BY WRIGHT HASSALL AGAINST KATERINA
- 22 June 2023: WITHOUT PREJUDICE offer of £500 (roof £437.50 + pipes £62.50)
- 25 June 2023: Al rejects as "derisory"
- 5 July 2023: Revised offer of £978.75 total (includes ground rent waiver)
- 4 September 2023: Al claims lease is "out of date", wants independent review
- Matter goes quiet through 2024
Escalation (2025-2026)
- July 2025: New pipe/guttering leak reported - Al complains of no response
- 3 October 2025: First Wright Hassall letter received
- October 2025: Katerina instructs Benchmark Solicitors LLP (Ross Paterson)
- 14 November 2025: Second WH letter with additional demands
- December 2025: Strategy disagreements emerge between Katerina and Ross Paterson
- 9 January 2026: Third WH letter - threatens court proceedings in 14 days
- 16 January 2026: Benchmark terminates retainer (£2,142 paid)
- Current: Katerina without legal representation, facing court proceedings deadline
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
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
- 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.
- 10-Year Warranty: The roof repairs came with a guarantee - any issues should be pursued against contractor first (though company now dissolved)
- Unauthorised Works: Al performed works without prior consultation or freeholder approval - potential breach of lease
- Payment Irregularities: Payment to individual (JS Whitbread) rather than contractor company raises legitimacy concerns
- No Competitive Quotes: Al admitted obtaining no documented quotes despite £3,500 expenditure
- Ground Rent Arrears: Counter-claim for unpaid ground rent over multiple years
- Insurance Contribution: Potential counter-claim for insurance premium contributions
- 50% Contribution: If lease requires it, Al should contribute to costs of retained parts maintenance
Al Sarpong's Written Refusals (Critical Evidence)
Al rejected ALL offers from Stan Harris (KG Project's solicitor) and refused to contribute 50% to retained parts repairs:
WhatsApp Messages
29 June 2023 - Al disputes 50% clause:
"I will be getting the clause in the lease you refer to checked regarding the 50/50 split - it refers to 'rates, taxes and impositions'. It does not mention repairs explicitly but I'll be checking this out."
"I have already gone back to Mr Harris and queried the 50% clause."View WhatsApp Timeline
9 December 2024 - Al explicitly refuses to pay:
"I still question strongly that I should be paying 50% for something that is a freehold responsibility... I don't see why I should pay for pipe work anyway, and I have no intention of picking up any costs"View WhatsApp Timeline
Email Correspondence
14 June 2023 - Al to Stan Harris - Refuses acceptance:
"You mention in your letter Clause 2 being namely for me 'to pay 50% of the expenses incurred as a result of costs relating to the Retained Parts'. On reading this again... I think that statement is open to some interpretation."
"I would want that point to be further explored before making any kind of acceptance."View Original Email
21 June 2023 - Stan Harris's £500 Settlement Offer REJECTED:
Stan Harris offered: "our Client is prepared to accept that £1000 might have been justified to undertake the necessary repairs, and our Clients are prepared to pay half this sum, namely £500 in full and final settlement."
Al REJECTED this offer and continued demanding full £1,750 reimbursement.
View Original Email18 July 2023 - Stan Harris describes Al as "obstinate":
"Your neighbour at number 16 is proving to be a very obstinate man and as you know he is threatening to go to a solicitor himself !!"View Original Email
CONCLUSION: This written evidence directly contradicts WH's narrative that KG Project was unresponsive or unwilling to engage. Al was offered reasonable settlements, refused them all, disputed his 50% lease obligation in writing, and explicitly stated he has "no intention of picking up any costs."
Potential Outcomes & Recommendations
Option 1: Settlement (Ross Paterson's Approach)
⚠ REJECTED - Passive strategy that ignores freeholder rights
Ross's Recommendations:
- "This case is fundamentally about a water leak in a roof, which needs to be fixed" - ignores trespass and breach of covenant
- Negotiate 50/50 settlement - despite tenant's breaches
- Avoid "aggression" and tribunal proceedings
- Claims £9,500 trespass damages "on the high side"
- Warns of "18 months of legal hassle"
What Ross Ignored:
- Trespass claim: Al accessed retained parts without consent
- Breach of covenant: Unauthorised alterations to roof
- Al's refusals: Al rejected ALL settlement offers
- Full Indemnity Clause: Schedule 4, Para 7 of Lease (see below)
- Surveyor costs: 100% payable by tenant, NOT 50/50
Result: Ross terminated the retainer after receiving £2,142 in fees, leaving client without representation.
Option 2: Assertive Enforcement
✓ Proactive strategy enforcing freeholder rights under the Lease
Legal Claims to Pursue:
- Trespass to Retained Parts: Al accessed roof without freeholder consent
- Breach of Covenant: Unauthorised £3,500 alterations (not "repairs")
- Ground Rent Arrears: Multiple years unpaid (£250/year)
- Insurance Contributions: Outstanding payments owed
- Service Charge Demand: For maintenance and insurance costs
Key Lease Provisions Ross Ignored:
Schedule 4, Paragraph 7 - FULL INDEMNITY COSTS:
"To pay on demand the costs and expenses of the Landlord (including any solicitors', surveyors' or other professionals' fees) assessed on a full indemnity basis incurred by the Landlord in connection with... (a) the enforcement of any of the Tenant Covenants..."
This means surveyor and legal costs are 100% recoverable from Al, NOT 50/50 as Ross claimed.
Advantages:
- Enforces clear lease obligations
- Full cost recovery under indemnity clause
- Al's written refusals prove bad faith
- Strong evidence of trespass and breach
- County Court / FTT proceedings available
Priority Documents & Timelines for Review
Critical Documents
- Wright Hassall Letters Timeline - All 3 letters with full analysis (URGENT)
- Original Lease (2013) - Key clauses on repairs, contributions, retained parts
- Insurance Documentation - Required by Wright Hassall (2025-2026 policies available)
- Tribunal Prep Documents - Previous legal analysis and evidence bundles
Comprehensive Email Timelines
- Katerina-Al Timeline - 71 emails (Nov 2016 - Jul 2025) - Complete freeholder-leaseholder history
- Katerina-Stan Timeline - 50+ emails - SA Law correspondence including key June 2023 letter
- Al-Stan Timeline - Direct correspondence between Al Sarpong and Stan Harris
- Katerina-Ross Timeline - Benchmark Solicitors relationship breakdown (Oct 2025 - Jan 2026)
- Wright Hassall Timeline - All WH letters and correspondence (Oct 2025 - Jan 2026)
- 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