Today I sent them another reply...
Hi,
I have a number of questions. You can choose to answer these or not however, you should probably think about how this will look to a judge in a county court and how the answering of these questions will be able to allow a Judge to differentiate between a company that scams customers vs one that is open and actually wishes to be able to pay its debtors.
1) Serving Winding Up Documents
I know that documents can be posted, emailed, or left at your office (which is a virtual one). It does not have to be to Mubasher Akram personally. I would be grateful if you can provide me with a home address for Mubasher Akram or a personal email so that I can ensure that he has been served winding up documents. Can you confirm if Mubasher Akram has a personal email? If so, can you provide it? I am wanting to make every effort to ensure that he at least has sight of the documents heading his way. Please be assured that court documents will be left at your office address and emailed to your company email in electronic format. How can a company director of a company that has zero sales and produces zero goods be overseas on business trips and be busy in meetings? It beggars belief. It's more likely he is trying to avoide being served. If not, please supply me with his details, even a telephone number would suffice so i can at least call.
2) Payment of Money You Owe Me
Can you at least make some effort to try to pay me the money that you owe me? At the moment your company simply stays quiet and does not reply to any of my demands for money nor does it propose any solutions.
3) Documentary Evidences
Can you provide documentary evidence to support any of the reasons why you say you cannot pay your debts? Example - you state that no winding up petition has worked against you. Can you provide County Court Judgements to back up what you are saying? If cases have been dismissed, you get Judgements saying so. Just send me a copy. It might sacre me away. Example - you say you have money in Paypal. Can you give documentary evidence of such claim? Example - you say there is money for HMRC (tax). Can you provide Bank statements? Tax depends on profit - Where is the profit in your company? It hasn't had a single sale in ages. Sales are zero. VAT is done quarterly and we are more than 3 years down the line so lets not use that excuse.
4) Company Outgoings
What are your company outgoings and can you provide documentary evidence? Why can you pay staff wages and hire legal representitives but not be able to repay your creditors?
5) Won't see another penny...
On September 8th 2016, I had an email from your company stating that it cannot pay me and that I would never see another penny. Is this still the position of your company? If not, what is the new position and what are you willing to do? How many people have you settled out of court with before?
6) Bankruptcy and Winding-Up
When a company owes £750 and cannot pay it then quite simply its bankrupt. Can you give reasons as to why you think your company cannot be wound up or should not be wound up? Please note your company has zero sales and not profitable and definitely not "positive" cash flow. As I am in a position to be able to wind up your company, you should be more open and frank with me. Simply putting head in sand and wishing people go away attracts further legal recourse.
Now that you are reading this bit, I would like to inform you that I will be sending this email in with my application to wind up your company if you do not repay me the money owed. A Judge will most likely read this email (and my questions) and wonder if the company replied to me on any of my questions. I will be raising with a Judge why your company is giving information or arguments in court that it could have raised with me (a creditor) earlier after getting this email. Bringing items to court on the day will invite a question, why could you not have given this earlier on in proceedings? This tactic is called "ambush" and looked down upon but I doubt you can use it now that I have brought it up and sent you this email WAY in advance of any court appearance.
I would like you to pay all monies due to me immediately.
Regards,
Khan