Solicitor Correspondence Overview
This timeline documents communications between Katerina Perepech (KG Project Ltd) and Stan Harris (Consultant, SA Law Solicitors) who represented KG Project in the Carroun Road leasehold dispute.
Initial Consultation Request
Katerina reaches out regarding the 14 Carroun Road dispute, seeking legal guidance on the lease interpretation and Al Sarpong's reimbursement demands for roof repairs.
Lease Review Confirmation
Stan Harris confirms receipt and indicates he will review the lease documents to provide advice on the dispute.
Meeting Scheduling
Katerina follows up to schedule a meeting to discuss the lease obligations and responsibilities.
Preliminary Advice
Stan provides initial thoughts on the lease interpretation and the "Retained Parts" clause cited by Al Sarpong.
Original Lease Located
Stan confirms the original lease for Carroun Road has been found and is being reviewed in detail.
Stan Harris Moves to SA Law
Stan Harris notifies Katerina that he has moved from Buckles Law to SA Law Solicitors.
SA Law Solicitors
Mobile: +44 (0) 7879 816050
DDI: +44 (0) 1727 798000
Email: stan.harris@salaw.com
Instructions Confirmed
Katerina confirms she wishes to continue instructions with Stan Harris at SA Law.
Case File Transfer
Multiple exchanges regarding transfer of case files and documentation from Buckles Law to SA Law.
Terms and Conditions + £200 on Account
Stan Harris sends formal engagement terms:
- Attached terms and conditions setting out fees and estimate of costs
- Requested £200 on account of fees and disbursements (as new client)
- Attached SA Law client account details
- Requested: relevant emails, dates, details of work the adjoining owner undertook without agreement
Stan's Detailed Legal Analysis
"Apologies for the delay but please have a read of this email and then we can either have a call or a Teams meeting."
Stan provides comprehensive legal analysis with colleague Emily Cross:
- Retained Parts = Landlord's Responsibility: Roof, foundations, external walls, main structural walls are "Retained Parts" per lease definitions (page 8)
- Leaseholder Overstepped: "Whilst it is possibly correct that the tenant has overstepped his obligations in taking this job on without requiring you to do it..."
- 2016 Claim Suspicious: If roof was in poor condition when Al bought in 2016, why no communication then? Would have held up sale.
- No Prior Notice: Never contacted before February 2022 when Solar Roofing already contracted
- Were other quotations obtained for roof repairs?
- Who is JS Whitbread and what is his connection?
- No proof of payment to Solar Roofing Ltd itself
- "Your legal position is quite difficult" - amount being fought over vs costs don't justify legal battle
- "Somehow need to settle this quickly and reasonably"
- Explains Section 20 Consultation Notice process that SHOULD have been followed
- 50% contribution: Would have clearly been payable by leaseholder under proper process
Note: Stan warns "Please don't pass on my email to your leaseholder until we have spoken."
View Original EmailKaterina Requests Teams Meeting
"Could we schedule a Team meeting for Thursday? Please let me know what time works best for you."
Asks if she can give Al Stan's email address and inform him solicitor is actively pursuing the matter.
Stan Proposes Meeting Times
Stan prefers morning meeting - may have to go into town tomorrow afternoon.
"Could you do 9-30-10-00 or if it assists a bit later. On Friday I can do the same time and also in the afternoon between 2-00 and 4-00pm."
Meeting Confirmed + Draft Email to Al
"Let me confirm 10 AM tomorrow, this time is perfect for me."
Katerina drafts email to Al with Stan's questions:
- Was "Solar Roofing" the only contractor with whom you communicated about the roof?
- Who is JS Whitbread?
- Why the payment has been done to JS Whitbread account?
Katerina Updates Al on Solicitor Progress
Katerina informs Al that KG Project is working with solicitor to understand lease obligations and will be in touch soon.
Stan Sends Draft Letters to Al
Stan sends draft letters for review:
- Attached: LET-MR SARPONG-2023-05-12 draft.DOCX
- Sent subject to comments - Emily Cross will also review
- Requests feedback on both content and tone
- Asks Katerina to consider what amount she might offer Al
- Notes firm's charges will need updating - "near or a little over the original estimate"
- Was Solution Roofing the only quote obtained?
- Who is JS Whitbread?
- Why was payment highlighted?
Katerina Provides Detailed Feedback on Draft
"That is exactly what I required."
- Paragraph 3 addition: "the freehold transferred to management company in case KG Project sells both apartments, but this never took place..."
- Compensation query: What amount to offer?
- Ground rent offset: Suggests offsetting combined £500 (2 years unpaid ground rent) against roof repair compensation
- Retained Parts clarification: Asks if lease means obligation to restore only when "clear need" rather than regular basis
Note: Katerina observed that Stan couldn't find direct obligation in Lease for Management Company or Freeholder to maintain Retained Parts.
View Original EmailStan Acknowledges - Will Review
"Thanks Katerina. I will be in touch shortly. If not tomorrow then Monday."
View Original EmailKaterina Thanks Stan
"Thank you very much. Looking forward to hearing from you."
View Original EmailAl Follows Up - Asks for News
"Given that over a week has passed away since your last note, do you have any further news from your company's solicitor please?"
View Original EmailAmended Draft + Fee Note + WP Strategy
"I have amended the long draft advice letter as you have requested."
- Fee Note: "Our charges to the end of April" enclosed
- Time Estimate: "Please allow for another 3-4 hours of my time to get this matter concluded"
- Press on Payment Issue: "Press Mr Sarpong on why payment was made to the third party" (JS Whitbread instead of Solution Roofing Ltd)
- Suggested Offer: £500 settlement + £500 ground rent offset (2 years at £250/year)
- WP Strategy: Settlement discussions to be conducted on "Without Prejudice" basis
"You can try me after 5:30 today if you want to have a quick chat about the amount you should offer."
View Original EmailAl Threatens Legal Action by 15 June
Al expresses frustration and sets deadline:
- "Once again you are ignoring my notes (and previously my phone calls) on the subject of the roof"
- "Unless I get positive feedback by the 15th June with regards the necessary repairs that were done back in the late winter of 2022, I will then without delay be taking the appropriate action legally to get my money"
- Notes contrast with "correct and prompt action" taken with pipes issue
- "For the sake of our cordial relationship, I would rather we did not go down this road"
Call Scheduling
Stan asks to schedule call to discuss the letter before sending.
View Original Email3:30 PM Call Confirmed
Katerina confirms availability for 3:30 PM call.
View Original EmailAmended Advice Letter Sent - NOW USED AGAINST CLIENT
Stan Harris sends formal advice letter to Al Sarpong on behalf of KG Project, explaining:
- Lease interpretation and obligations
- Position on roof repair reimbursement
- Recommendation for independent dispute resolution
- 50% contribution requirement under lease
⚠ CRITICAL: This Letter is Now Being Used Against Katerina
Wright Hassall (Al's solicitors) cite this letter in their 2025 correspondence. Ross Paterson (Benchmark Solicitors) confirmed in November 2025 that this was an "OPEN LETTER" - NOT marked "Without Prejudice" - meaning it CAN be used in court/tribunal.
⚠ DRAFTING PROBLEMS:
- Unnecessary Concession: States "the freeholder accepts that the obligations to keep in good repair and to maintain those parts of the building defined as Retained Parts are the freeholder's responsibilities" - then ADMITS there's no express covenant in the lease for this!
- Fails to Assert TRESPASS: Does NOT mention that Al performed works on Retained Parts WITHOUT authorization - a clear trespass claim that was never preserved
- Implicitly Validates Al's Works: Focuses only on future procedures, implying the past roof works were legitimate
- Not Marked "Without Prejudice": Can be shown to a Tribunal as evidence of landlord's position
✔ What the Letter Did RIGHT:
- Asserted tenant's 50% contribution obligation (Schedule 4, Clause 2)
- Questioned why defects appeared 5 years after Al moved in (2016)
- Set up proper consultation procedure for FUTURE works
- Stated no obligation to "enhance or improve" the building
⚖ VERDICT:
The letter creates a documented admission that Wright Hassall now cites. The damage is not fatal - the 50% obligation and consultation procedure (which Al violated) are also established. However, a better-drafted letter would have reserved trespass claims and been more defensive.
Al's Detailed Response to Stan's Letter
"Thanks very much for your letter. The first thing to say is that I would have preferred that I had received your letter or better still, one from the Directors around about a year ago."
- Management Company: "This is the first time I have been formally advised of this" - surprised he wasn't told
- Appreciates Retained Parts acceptance: "I appreciate that your client accepts the obligations with regards Retained Parts, and this really was the purpose of my claim"
- Questions 50% Clause: "Can vital emergency work to mend an area of the building owned by the freeholder that requires repair be classed as an imposition (it is neither a rate or a tax charge)? I would want that point to be further explored"
- Supports surveyor: "I am happy for a surveyor to be appointed as you have suggested"
- Minor leaks over 7 years - "nothing on the scale of what occurred in February 2022 where rain poured through the ceiling heavily"
- Roof area NOT inspected when purchased in 2016 - "would not have been safe for me to go up and fully inspect"
- "Only when Solution Roofing showed me the pictures prior to repair last year, that I realised how poor the state of the roof had been"
- No leaks since repair: "Since the roof was repaired, there has been no leaks of any kind at all"
Note: Stan forwarded this to Katerina on 20 June 12:49 with comment: "No mention of competing quotes. No mention of paying a third party."
View Original EmailKaterina Follows Up with Al
"I hope this letter finds you well. I would like to extend apologies once again for the delay and inconvenience caused."
- Notes KG Project was awaiting guidance from solicitor
- Confirms Mr. Stan Harris sent email on 14th June
- Asks if Al received the email and is aware of contents
- States ready to engage in discussion
- Will contact Al early next week regarding roof works
Thank You for Letter
Katerina thanks Stan for sending the formal letter to Al.
View Original EmailWithout Prejudice Settlement Letter Drafting
Multiple exchanges between Stan and Katerina regarding the WP settlement letter:
- 12:49 - Stan forwards Al's email response to Katerina
- 13:44 - Stan drafts WP letter with settlement proposal
- 20:33 - Katerina suggests modifications to letter
Final Letter Amendments
Stan confirms he has amended the last paragraph as per Katerina's suggestions.
View Original EmailAl Responds - Generally Supportive
"To confirm that I did receive Mr Harris' email and letter."
- "There was a lot in there that I thought made good sense and understood the situation"
- Supports independent person to decide disputes - "a good idea, and in principle I support it"
- "We are now where we are which at least is a much better place for resolution"
- Took issue with "a couple of points" in Stan's letter
- "Concerned about the manner in which the freehold is being managed"
- "This particular issue should have been resolved at least year ago"
- "Did not really appreciate having my initial phone calls and emails ignored"
Katerina Forwards Al's Letter to Stan
"Dear Stan, I also received a letter from Al Sarpong. Please see it attached below."
View Original EmailStan's Assessment
"Thanks Katerina. It will be interesting to see his reaction to my email."
View Original EmailKaterina's Response
"Thanks, Stan. Yes, I am intrigued as well. I suppose your email will ground a bit his ambitious expectations."
"Please let me know when you send your email. Thank you for your constant help."
View Original EmailWITHOUT PREJUDICE - £500 Settlement Offer
- Does not accept Al's answers - "no adequate reason given for the random payment to Mr. Whitbread"
- Company (Solution Roofing) was going to be struck off at Companies House
- Mr. Whitbread is neither shareholder nor director
- £3,500 invoice "wholly unreasonable"
- Absence of competitive quotes
Offer: £500 in full and final settlement, plus ground rent (£250/year x 2 years = £500) to offset claim.
View Original EmailAl Rejects £500 as "Derisory"
Al responds expressing disappointment that his honesty is being questioned.
Points out the strike-off action was initiated AFTER the work was done in February 2022.
Notes Matthew Dean Eastwood (sole director) was "Matthew" - the senior roofer on site who requested payment to JS Whitbread.
Revised Offer: £978.75
Stan Harris presents improved offer structure:
£500 (waived ground rent) + £278.75 (50% pipework repairs) + £200 (additional) = £978.75 total
Conditions for releasing the £200:
- Mr. Whitbread returns money to Company's bank account with evidence, OR
- Al demonstrates Solution Roofing is solvent and Matthew explains payment arrangement
Al Reports New Water Stain, Questions 50% Share
Al draws attention to sudden water stain on hallway wall after pipework. Requests pipework be revisited.
Questions the 50% repair payment requirement - says it assumes he owns a freehold share, which is not certified anywhere.
Wants lease checked legally regarding 50% clause.
Corrects name: payee was "J S Whitbread" not "Mr Wiltshire".
View Original EmailStan Discusses Fees - Case Taking Longer
Stan discusses the ongoing case costs:
- Notes firm has "spent many more hours than quoted"
- Case taking longer due to Al's responses
- "Your neighbour is proving to be a very obstinate man"
Note: This reflects the ongoing complexity of negotiating with Al, who continued to reject settlement offers.
View Original EmailAl Claims Lease "Out of Date"
Al consulted his own solicitor who advised:
- Lease obtained from Land Registry dates to 8th November 2013
- Over 2 years before Al moved in - doesn't include his details
- References Management Company which freehold decided not to set up
Recommends independent mediation rather than expensive legal proceedings.
View Original EmailStan's Response on Lease
"The lease you bought from the previous owner was the 2013 lease. You don't get a new lease when you buy a leasehold property unless it is a rental lease or you bought from developers - neither of which applied here."
Advises Al to go back to the solicitor who acted for him when he purchased, or have his solicitor contact Stan directly.
View Original EmailURGENT: Al Now Represented by Wright Hassall LLP
Mr Al Sarpong has escalated the matter by instructing professional legal representation - Wright Hassall LLP.
Wright Hassall letters dated 3 October 2025 and 14 November 2025 require response.
21-day deadline applied.
See Wright Hassall Letters for full correspondence.