2400. LORD YOUNG OF NORWOOD GREEN: Page?

  2401. MR SAUNDERSON: It is page 12, if you would like to just refer to it. It starts on page 14, I beg your pardon.[10] "Development appraisal", and it is a surveyor's calculation of value with rents and square footages and costs of construction and so on, providing a basis for their view of the value of the site. We had provided the first valuation back in April to Crossrail and talked about the figures. There is some discussion over figures, rents and construction costs and so on.

  2402. LORD YOUNG OF NORWOOD GREEN: You will pardon this next question. It is probably in ignorance of the process, but you are basing this on, I presume, current market rents and things like that or the appropriate values of that? Do you also take into account any current decision of the Lands Tribunal?

  2403. MR SAUNDERSON: It is provided by Jones Lang LaSalle so I do not know exactly what they do. They take in evidence from whatever source—presumably the Lands Tribunal might well provide evidence if there has been evidence—but they take in evidence from other surveyors who have done lettings and construction costs. They have various sources of information that they look to provide the material for the evidence.

  2404. CHAIRMAN: Most surveyors and valuers have knowledge of the market, have they not?

  2405. MR SAUNDERSON: Absolutely yes, they have extensive research departments compiling such evidence and such material. This would be common for either a developer or a valuer or anybody really in the property world to work with such a valuation type of basis.

  2406. LORD YOUNG OF NORWOOD GREEN: There is a slight discrepancy between this valuation and clearly a Crossrail valuation?

  2407. MR SAUNDERSON: Absolutely, that is right. We consider their offer to be discourteous in the extreme and especially including the surveyors' fees when explicitly surveyors' fees, for example, were to be paid on top.

  2408. LORD BROOKE OF ALVERTHORPE: Are Kinney Green lawyers or surveyors?

  2409. MR SAUNDERSON: They are surveyors. It is a small firm of surveyors. If I may just take you on just further through the Petition it is only just over the page and then it will be finished with the Petition. My submission is that no practical offer has been provided when they undertook that they would deal with the matter with the purchase now or within six months. Almost 12 months later no offer has been forthcoming and there have been unsatisfactory discussions with a firm of surveyors called Kinney Green, acting for Crossrail.

  2410. The barrister clearly indicated that the purchase would be:

  2411. (a) Now or within six months, that is by 18 August 2007 and

  2412. (b) At full market value taking into account the development potential of the site which had received planning permission for a six-storey office building

  2413. (c) The Petitioner's costs of surveyors and lawyers would be paid by Crossrail.

  2414. This has not been adhered to by Crossrail and I humbly request that you:

  2415. (a) Order Crossrail to purchase by 31 March 2008 or within 30 days of this hearing, if later, at the value advised to Crossrail by Jones Lang LaSalle as at either

  2416. (i) the date of the Safeguarding Order in 1990 or

  2417. (ii) the date of acceptance of the blight notice, 19 February 2007, or

  2418. (iii) six months after that date, namely 18 August 2007.

  2419. (b) Order Crossrail to pay interest at the statutory rate from the date appointed in (a) above to the date of payment to Your Petitioner.