Please note that text in red denotes my comments

Main features of submissions on behalf of Mrs Vera Douglas and Mr W J Andrews to be made to the Court on Friday 24th February 1984.

1. 62-65 Smithfield Square, Belfast and 1-11 Francis Street, Belfast. (Paragraph 13 in the Report of Official Solicitor).

As it has been established that these premises are still in the ownership of the patient we respectfully submit that they should be retained in his ownership and the capital sum of 35,000 paid to the credit or for the benefit of the patient be applied towards rent of the premises.

2. 14 Castlehill Road, Belfast. Paragraph 9 in the Report of the Official Solicitor.

We submit that the valuation of Messrs Macrory and Jefferson is a truer valuation than that of Messrs Alex Murdoch & Deane in that it is based on better comparables while the comparables of Messrs Murdoch & Deane are not proper comparables.
We would respectfully suggest that in order to resolve the conflict between the two valuations the matter be referred to the District Valuer. If this valuation confirms the valuation of Messrs Macrory and Jefferson or shows that the price realised was below the market value we would respectfully suggest that the question of the recovery of damages in respect of the undervalue should be considered.

3. 3-5 Little King Street, Belfast and 5-21 Winetavern street, Belfast. (Paragraph 6 and 11 in the Report of the Official Solicitor).

We respectfully submit that these sales were not in the best interests of the patient because both premises had been purchased by the patient's father because of their development potential and capital appreciation and ought to have been retained with that object for the benefit of the patient. The fact that they had development potential is evidenced by the current development proposals for the Smithfield area which have appeared in the Press this present month.
As solicitors for the late Mr Frederick Andrews, Senior, the patient's father it is with our personal knowledge that these properties were purchased with that end in view and not for rental income.

4. Mrs Minetta Andrews (Paragraph 13 in the Report of the Official Solicitor).

Following on the conclusion of the enquiries of the Official Solicitor as to the financial affairs of Mrs Andrews and what sums should be recouped from her, we would respectfully suggest, that apart from the recovery of such current household expenditure as may be decided upon, the actual payment of capital sums should be postponed during her lifetime provided that some means could be devised to prevent her assets being dissipated and repayment thereby prevented.

5. We would respectfully submit that the professional fees of Mr John G Drennan as Committee and of Mr Peter Rankin as Acting Committee be taxed.

6. We respectfully submit that the costs of our clients be a charge on the patient's estate with a view to recovery from the party or parties whose actions brought about the necessity for these enquiries and this review.

Sated this 17th day of February 1984

James Boston & Sullivan
40 Victoria Square