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Domus & Sons

44 Montague Road
N15 4BD

By Post
By email

Our Ref: JP/3497


12 June 2014

Dear Sirs,

Our Clients: Mr Richmond and Mr Redding Quashie

Preliminary Notice - Professional Negligence Claim

We have been instructed to represent Mr Richmond and Mr Redding Quashie in relation to the
defective works carried out by Domus & Sons Limited. Please ensure that all correspondence relating
to this matter is directed to us.
This is a Preliminary Notice written in accordance the Professional Negligence Pre-Action Protocol
(copy enclosed), which governs how the Courts expect parties to conduct themselves prior to
engaging in litigation, in the hope that the matter can be resolved without recourse to the courts.
We are required by that Practice Direction to raise certain matters with you, as it has become clear
that there is high chance that our clients will bring a Professional Negligence Claim against you.
Notification to Your Professional Indemnity Insurer
First and foremost, we are required by the Pre-Action Protocol to ask you to immediately notify your
professional indemnity insurer of your receipt of this Preliminary Notice. Not only may this be
important from the prospective of the obligations that you owe to your insurer, but it may well help
with the work that will need to be done to resolve this matter.

A Brief Outline of Our Clients Grievance

Pursuant to a contract, dated 12 January 2014 (the Contract) you were engaged by our clients to
carry out works on two properties (28 Hafton Road, London, SE6 1LP and 1 Helvetica Street, Catford,
London, SE6 4EX; together referred to as the Properties). You indisputably owed our clients a duty
of care and you were obligated to provide your services with reasonable care and skill, yet the works
carried out were of extremely poor quality, as evidenced by the survey conducted by B Wolfenden
Surveying Ltd (the Survey). In addition to this, our clients have paid to you a total of 17,834 (over
3/5 of the Contract sum) yet you have carried out less than 1/5 of the work required under the
Contract. The services you provided to our clients were seriously deficient and have directly caused
our clients to suffer extensive financial losses. All documents referred to above enclosed herewith.
Based on the Survey, our clients current conservative estimation of the losses directly flowing from
your breach of duty, contract, and statutory and common law duty of care is: 16,788. Our clients
losses will be particularised further in the formal Letter of Claim you will receive in due course.
Furthermore, you have withheld our clients keys for almost 4 months, despite our clients numerous
telephone calls and text messages requesting that you rightly return them. Our clients clearly have a
claim under the tort of conversion, not to mention that such an act may also qualify as a criminal
offence under the Theft Act 1968.
Next Steps
Under the terms of the Practice Direction, you are under no obligation to do anything other than
acknowledge receipt of this letter within 21 days of receiving it, however, if you dont pay in full the
sum of 16,788 to our clients within 7 days we are instructed to take the next step and issue the
Letter of Claim. Furthermore, we would like to open dialogue with you/your professional indemnity
insurers as soon as possible about how to proceed with this matter, so that costs are not
unnecessarily incurred investigating and particularising matters unnecessarily. We would also
encourage you/your professional indemnity insurer to review your files on this matter as soon as
We appreciate that no professional firm wishes to receive a letter such as this, but we hope to work
with you in a constructive manner to resolve the matter as quickly and cost effectively as possible. If
there is any documentation that you consider would be helpful for us to see, then you are welcome
to provide it at this stage, bearing in mind that all relevant documents will have to be produced
eventually in any event. Please take all necessary steps to ensure that all relevant documents (which
include all electronically stored information on computers, back-up systems and so on) are
preserved and not, for example, destroyed/deleted as part of your archiving policy.
We look forward to hearing from you.
Yours faithfully,

Calvert Solicitors LLP