 Re: Dispute with Freeholder to block of flats
You have not given enough information. For instance, you have not said what the provisions of your lease are in relation to insurance, nor whether the damage falls within those provisions.
You should consult a solicitor for advice as to what the legal effect is of the lease's provisions, in the particular circumstances of your case; and as to what the landlord's legal obligations are in consequence.
Also, you need to decide whether you are claiming £7,000 or only £4,500. If your claim exceeds £5,000 then your case falls outside the Small Claims track, and legal costs can be awarded against you if you lose the case, so in that event you should consider engaging a solicitor to handle the case for you.
Although some leeway will be afforded you by the Court as a litigant in person if you have a claim that genuinely falls within the Small Claims track (i.e. under £5,000), you may forfeit that leeway if the claim does not in fact fall within the Small Claims track.
A request under Part 18 is an unusual step to take in a Small Claims case. If you are proceeding on the Small Claim track, the Court might not allow the Defendant to serve such a request on you.
If your case is not on the Small Claims track, then the Court might require you to answer such a request. It will depend what details you included in your Particulars of Claim: the Court might decide that you gave too little information in them.
If you are unsure, the prudent course of action might be to answer the Request, by giving the details requested and any documents requested that you have. If so, simply answer the questions truthfully: i.e. if you have no documents of the type requested then say so.
It would be prudent to consult a solicitor before replying to the Request, because the Defendant may be fishing for a reply that will enable him to have your claim struck out, without his having to go to trial. That is the usual purpose of making such a request.
You may have made a tactical error in starting a civil action. You should first ask: has a criminal offence been committed?
There are criminal offences under the Theft Act 1968 that the freeholder might have committed, given the facts you mention. Have you laid a complaint with the police? They would be able to investigate, and decide what charges, if any, could be brought. If he is convicted, the Court could in some circumstances make a compensation order, requiring him to repay you the amount he received.
Whether a criminal offence has been committed is also something which a solicitor could tell you.
Advice & opinions on this forum are offered informally, without any assumption of liability. Use your own judgment. Seek advice of a qualified and insured professional if you have any doubts. | 
