To: – Defendant
Dear Sirs
Re: Claimant’s Andreas Investments Ltd
Claimant’s full address Registered Address for correspondence 6 Colwick Rd NG2 4BU Nottingham

Your Claim Reference number 202309019087

This letter is due to the claims made in connection with the collapse of the rear of 68 A Harold Street DN32 7NQ both  in September 2023 and October 2023. The cause of both collapses are due to the explosion that pushed outward the reinforced side wall parallel to Castle Street in September 2023.

We write this letter as part of the standard procedure of pre court proceedings. This is stated on the following website

You can review it yourself, and we will  be compliant all throughout  the process up to court proceedings should it be necessary. We hope we can resolve this claim without resorting to court proceedings we will make our outmost effort to avoid court proceedings.
We therefore invite you to comply with these statutory rules, which we are sure you are fully aware o and find an amicable resolution.

The claim is for the collapse of part of the building insured with you. The building was under insurance cover during the event that led to the collapse in September 2023. Additionally, this collapse led to a further partial slow collapse which started in October 2023.
You have also been notified of this secondary collapse, as you had been notified as how this was clearly caused by the first collapse (due to explosion).

We are open to settling the claim without court proceedings, This is our preferred outcome, however compensation has to be matching the rebuild value of the damaged property.

It is our understanding that your company base the denial of liability solely on the report your company paid for made by Burgoyenes LLP. This is an LLP that  your company engaged and paid for. The appointment of this company was made without any consultation with ourselves. Therefore, it is  clearly a company with conflict of interests clearly in our view they are trying help you evade the liability of the incident described in this letter.

Understand each other’s position;

Do you understand that our position is that according to the policy we purchased, the liability for insurance cover stands? This is because the clear cause of the collapse was an explosion.  Do you understand that we would expect the full reinstatement t costs for both incident sin September 2023 and Late October 2023? Do you understand that it seems clear that the incident of October 2-023 is a direct consequence of the incident in September 2023?

IF our position is not clear please get in touch with us within 10 days and we will be explaining further.


b) make decisions about how to proceed;

We would rather come to an amicable settlement without court proceedings.

(c) try to settle the issues without proceedings;

Our preferred outcome is to save the costs of court proceedings and settle the claim amicably without recourse to court proceedings.

(d) consider a form of Alternative Dispute Resolution (ADR) to assist with settlement;

We are open to arbitration.

(e) support the efficient management of those proceedings; and

(f) reduce the costs of resolving the dispute.

It is our understanding that based on the report made by Burgoyenes LLP  your  company denies all liability for these two incidents.

We kindly ask you

Do you have any other basis for denying liability other thatn using the report from thgBurgeynes LLP? If you have any other basis to deny  liability so state all other basis for denying liability.

1 how many incidents does this self claimed “scientists forensics” carried out in year 2023, year 2022 year 2021.

2 The basis of the report produced by them as “forensics”, what forensics analysis have been carried out? What equipment to collect samples from the site was used?

Please provide the names and qualifications of the people that produced the report you sent us

Was the biased reporting company aware of the insurance policy liability wording prior to making preparing the report?

Was the reporting company in contact with the insurance company during or before the drafting og the report?

How much was the reporting copany paid for the report in particulal

how may reports does the company produces for the insurance company and how mush for eash in the years of 2023, 2022, 2021

It is clear that the cause was an explosion. This is clearly covered by the policy.

We will be open to informal discussions to settle this claim amicably over the phone or in person. Therefore, should you consider an amicable resolution we welcome it and please do not hesitate to contact us.

Given the nature of the claim we deem the maximmum repsonse time as applicable tby law to be 3 months from this letter date.

We may have further questions in connection with this case and we will ask them as they arise, you would be expected to reply promptly to those too.