A Request For All Emails and Julien Luke

Julien Luke TLT

Summary

This is a request for a complete record of all emails sent to TLT by November 3rd to be sent to info@propertycorruption.com.

Detail

In UK repossession cases, defendants have the right to request key documents from the claimant, such as the mortgage or tenancy agreement, arrears breakdowns, and formal notices. This falls under disclosure (similar to US Discovery), which ensures the claimant followed proper legal steps, including pre-action protocols that require fair warning and attempts to resolve the issue before going to court.

Correspondence between both parties — including demand letters, warnings, and repayment offers — is crucial. It helps the court assess whether the claimant acted fairly. If important communication is missing or shows the claimant ignored reasonable efforts, the court may delay or refuse the possession order.

The defendant’s own emails or letters to the claimant are also important. They can show attempts to settle or ask for help. If those efforts were ignored, it can support a strong defence. Courts favour parties who engage reasonably and may be critical of those who don’t.

Julien Luke of TLT Solicitors is recognised as an expert in assisting clients in obtaining full disclosure to support their legal case (see our open letter addressed to him). In that same spirit, and in the interest of transparency and fair process, we now treat this article as a formal disclosure request to TLT Solicitors.

We request a complete record of all emails sent to the following TLT email addresses:

mortgage.dispute@tlt.com

customer.contactteam@tlt.com

kam.o’neill@tlt.com

For each email sent, we ask for a clear status update, specifically:

  • Whether the email received a reply, and
  • If so, the date and content of the reply.

All emails from 15 July 2025 until 28 September 2025.

This information is essential for verifying whether proper procedural conduct was followed in line with pre-action expectations and professional obligations.

Under the Civil Procedure Rules (CPR) and principles of fair legal conduct, a solicitor who acts on behalf of a mortgage lender:

  • Is responsible for correspondence on the lender’s behalf
  • Must comply with disclosure obligations if requested by the court or the opposing party
  • Can be held accountable for how they manage communication and pre-action compliance

This means you are fully within your rights to request disclosure of emails and responses from the solicitor acting for the lender, especially if those communications relate to:

  • Offers to resolve the matter
  • Requests for information
  • Repayment proposals
  • Any ignored or unanswered attempts to communicate

Now, of course, we understand that Mr. Luke — who, notably, is not the allocated solicitor on our case (a detail TLT has declined to clarify) — acts in the interests of TLT’s clients when pushing for disclosure. It is entirely expected that his focus is on securing information that benefits his clients, not on what disclosure the defendant may or may not receive.

However, Mr. Luke and TLT is fully aware that they are expected to:

  1. Comply with rules of disclosure
  2. Act ethically and not mislead the court
  3. Follow the pre-action protocols

Below is one example of an email that has not received any reply after more than a month:

To illustrate the point, here is an email we published along with its subsequent updates:

From: info@propertycorruption.com
Subject: Compliance with the Pre-Action Protocol for Possession Claims
Date: Aug 20 2025, at 8:21 pm
To: Mortgage.Dispute@TLT.com <mortgage.dispute@tlt.com>
Cc: mark.routley@tlt.comjohn.wood@tlt.com

Subject: Compliance with the Pre-Action Protocol for Possession Claims

Dear TLT,

In light of your reference to the Pre-Action Protocol for Possession Claims based on Mortgage or Home Purchase Plan Arrears in Respect of Residential Property (Civil Procedure Rules, Justice UK), please confirm whether NatWest and TLT are in compliance with the following requirements:

  1. Consideration of Alternatives to Possession (Para 5.1 – 5.5)
    • This should also include your refusal to confirm court option to allow validation of the situation through discovery etc
  2. Engagement with Borrower’s Proposals (Para 6.1 – 6.3)
    • Has NatWest given proper written consideration to my proposals for dealing with the arrears (including my suggestion for neutral person to assist)?
    • If not, please explain why this was not done in accordance with the Protocol.
    • Clarify why you ignored almost all my 17 questions to help me understand your position?
    • Why ignore my court venue change proposal?
  3. Compliance Statement (Para 7.1 – 7.3)
    • Will NatWest/TLT confirm that all steps required by the Protocol have been followed in substance and in spirit, and provide evidence of this?
  4. Consideration of Unique Circumstances (Para 2.2 and 5.5)
    • Please confirm that NatWest/TLT have properly taken into account the unique circumstances of my situation, including security concerns and risks that go beyond ordinary property management.
    • If you claim not to understand these concerns, please explain why no reasonable enquiries have been made, and why dismissing them outright does not amount to negligence in the context of the Protocol.
    • Reducing a highly complex situation — involving 18+ entities, systemic misconduct, and documented security risks — to a mere “property management issue” while asking zero questions is not a position of neutrality. It is negligence. The Protocol requires matters to be treated fairly and in context. To dismiss serious, multi-party risks without inquiry is to ignore the very duty of risk assessment and reasonable engagement that the Protocol and the court expect.

Even just focusing on my questions (which there are many more):

Key Failures of Compliance and Guideline Adherence

  1. Ignoring Evidence Review
    • Repeated requests for TLT to confirm they had read the linked evidence and summaries in the Editor’s Story were ignored.
    • This shows a refusal to engage with material facts despite being placed directly in front of them.
  2. Refusal to Address Venue Fairness
    • Direct Yes/No questions about transferring proceedings to a neutral, non-local court (to ensure fairness) were completely ignored.
    • This undermines their duty to engage fairly and transparently under CPR and the Protocol.
  3. Liability Evasion
    • They were asked whether TLT accepts liability for harm caused by its correspondence or if it considers itself a mere messenger.
    • This binary question was deliberately sidestepped, avoiding accountability.
  4. Narrowing Scope Improperly
    • When asked whether NatWest had informed them of other developments beyond the mortgage, TLT ignored the question and confined the scope of correspondence strictly to arrears.
    • This contradicts the Protocol’s duty to act reasonably and consider wider context.
  5. Dismissal of Security and Market Risk Issues
    • Clear questions about the 18-month freeze on sales at Old College House and the risks linked to Oakley Property management were ignored or deemed irrelevant.
    • This avoidance of obvious red flags is inconsistent with risk assessment obligations and professional standards.
  6. Addendum and Litigation Summary Ignored
    • The Addendum to the Pre-Action Notice (31 July) and the linked Litigation Summary were not acknowledged or addressed, despite explicit requests.
    • Failure to review or explain why not breaches the requirement to consider all relevant material before issuing proceedings.
  7. Failure to Clarify Settlement Position
    • Contradictory statements about whether arrears must be paid in full or whether alternatives could be considered were never clarified.
    • This left the borrower without certainty, contrary to Protocol requirements to explore resolution options.
  8. Non-Disclosure of Information Provided by NatWest
    • Requests to confirm what information NatWest supplied to TLT, including whether linked evidence was included, were ignored.
    • This obstructs transparency and prevents verification of the factual basis for their case.
  9. Refusal to Engage on Discovery Scope
    • Direct questions about early discussion of discovery scope and the intended claim filing date were ignored.
    • This keeps the borrower in the dark, preventing efficient preparation and contradicting the Protocol’s spirit.
  10. Opaque Chain of Command
  • Repeated requests to identify who at NatWest made decisions, who authorised instructions to TLT, and who is accountable for the case remain unanswered.
  • This deliberate opacity is inconsistent with fair treatment and denies the borrower clear accountability.
  1. Errors Left Uncorrected
  • Noted errors in TLT’s formal correspondence (“TLT LPP” instead of LLP, “Oakely” instead of Oakley) were flagged and ignored.
  • While minor, failure to correct them shows disregard for accuracy and formality.
  1. Deadlines Without Decisions
  • TLT imposed arbitrary deadlines (7-day and 22 August) but refused to confirm when or if proceedings would actually be filed.
  • This creates pressure on the borrower while withholding clarity, contrary to transparent pre-action conduct.

📌 Summary:
Across every category — evidence review, venue fairness, liability, disclosure, settlement clarity, discovery, and accountability — NatWest and TLT have ignored direct questions. This is not neutral conduct but a pattern of selective engagement that breaches both the letter and spirit of the Pre-Action Protocol.

There are many other breaches of the Protocol that have been noted. If you would like me to set them out in full, please ask. If you don’t wish to know – why not? Please reply by end of August 21st 2025.

Update: 26/9/2025 – TLT never replied to this email and went ahead with court proceedings.

Update 2: 26/2025 – TLT sent this email yesterday but still hadn’t replied to the above email which was sent 36 days ago. So they will receive but never reply or explain why they didn’t reply.

From: Mortgage Dispute <Mortgage.Dispute@TLT.com>
Subject: RE: Pre Action Notice Follow Up [TLT-TLT.FID10942167]
Date: Sep 25 2025, at 5:20 pm
To: info@propertycorruption.com

Dear Mr

With reference to your email of 19 September 2025, please note that any correspondence in relation to this matter (including the pre litigation letter referred to in your email below) is sent to TLT LLP who remain instructed by the Bank. We confirm that we are happy to accept receipt of letters by email to this email address.

Many thanks.

Regards,

TLT LLP