# PROPERTY DISPUTE MEDIATION REQUEST
Date: 6 October 2031
Parties: Lila Morgan and Northgate Freeholds Ltd
## 1. Purpose and parties
Lila Morgan is the leaseholder of Flat 12, Northgate House, 31 Harbour View Apartments, Cardiff, CF10 4NZ. Northgate Freeholds Ltd is the freeholder and issued service-charge demand NG/SC/2031/44 for £7,000 on 1 August 2031. Lila invites Northgate to a voluntary mediation before either party starts proceedings about the charge for roof replacement works.
## 2. Facts, scope and terms
The disputed works cost £56,000 across the building and Northgate allocated £7,000 to each of the eight flats. Lila's lease permits recovery of a reasonable proportion of costs, but she says no section 20 consultation notice was served on her, no emergency reason was explained, and the demand did not include the contractor's priced scope. She therefore relies on the possible £250 statutory limit under section 20 of the Landlord and Tenant Act 1985 unless a tribunal dispenses with the consultation requirement.
## 3. Process and responsibilities
Lila paid £250 on 18 August 2031 expressly to protect her position, marked the balance disputed, and requested the notice, estimates, invoices, contractor appointment, insurance claim history and accounts. Northgate supplied two invoices on 2 September but has not supplied a consultation notice, a roof survey or a breakdown showing why Flat 12's share is £7,000. Lila's proposed outcome is withdrawal of the balance and a credit of £6,750, or an agreed independent review followed by a commercially reasonable settlement.
## 4. Evidence, records and safeguards
The mediation should be a confidential half-day meeting on 20 October 2031, remotely by secure video unless the parties agree to meet at Cardiff Mediation Rooms. Lila proposes Harriet Cole, a CMC-registered mediator with property experience, subject to Northgate's confirmation that there is no conflict. Each party will provide a short position statement, the lease, the demand, the payment proof, photographs of the roof and the relevant correspondence by 13 October 2031.
## 5. Review, escalation and outcome
Lila will attend personally with her adviser Daniel Price, and Northgate should send a director with authority to settle and its managing agent's representative. The mediator may hold private sessions, but no statement made in the mediation may be used as an admission in later proceedings unless recorded in a signed settlement. The parties will share the mediator's fee equally, pay their own advisers and keep personal data limited to resolving this dispute.
## 6. Reservations and practical protections
This invitation is made on a without-prejudice basis save as to costs and is not an admission that the statutory cap applies or that the roof works were unreasonable. Lila will consider Northgate's evidence in good faith, continue to pay undisputed future charges and take reasonable steps to prevent further loss. If mediation is refused or fails, she may apply to the First-tier Tribunal (Property Chamber) under section 27A of the Landlord and Tenant Act 1985 and will preserve her limitation and costs arguments.
## 7. England and Wales law and completion
This completed fictional request is dated 6 October 2031 and is governed by England and Wales law. Northgate is asked to accept or decline by 10 October 2031, identify its representative, and propose any adjustment to the mediator or format. Participation is voluntary, does not suspend an urgent application or statutory deadline, and does not prevent settlement before the meeting. Both parties will retain the demand, lease, accounts, evidence of service and any signed outcome.