Dear Sir or Madam,

> The company is ready to continue discussing the matter in a professional and constructive manner.

That being the case, please consider the arguments and evidence that follows. However, please keep in mind my demands are still in force.

> We would like to inform you that the elevators and common-use areas within the building are part of the building’s shared infrastructure, and the rules for their use are determined by the rules applicable within the building and by safety requirements.

Under Georgian Law, this is not a matter of building rules. The Law of Georgia on Homeowners' Associations, Article 5(4)(დ), lists lifts (ლიფტები) expressly among the common property of the apartment owners. Article 5(3) fixes each owner's share by the ratio of his individually owned area to the total apartment area of the building. Article 7(2) provides that an owner may use the common property. And Article 6(5) permits the use of certain listed objects of common property — including, at subparagraph (ბ), lifts and lift shafts — to be transferred to another only on the basis of a decision taken unanimously by all owners. I did not consent.

> The building’s access control system is implemented for security purposes, in order to limit the uncontrolled movement of unauthorized persons within the building. This rule applies to all apartment owners.

That is factually incorrect. In 30 September 2025, in the official owner's chat, Next wrote:

"Additionally, please note that many residents currently have significant unpaid debts for maintenance services.

To avoid the implementation of a chip-access system in the elevators and to maintain the comfort of our building, we kindly ask you to settle any outstanding debts in a timely manner."

Your company clearly stated that the purpose of the access-control system is the self-enforcement of alleged debts. It is not and has never been about security, because you asked owners to avoid the implementation of the system, conditioned on alleged debt settlement, implying the building would be perfectly safe without it, as long as the alleged debts were settled. You furthermore explicitly conditioned the comfort of residents on the settlement of the alleged debts.

Moreover, that the rules apply to all apartment owners has nothing to do with what I wrote in my previous message. I am a co-owner of the common areas, including the elevators, and your company does not have the right to interfere with the functionality without my consent, even if all other co-owners consented, which I doubt is the case.

> Access chips have been and continue to be provided to apartment owners free of charge.

If I send a representative of mine to the reception, with the name and passport number I provide you, your staff will provide that representative with four copies of the chips, free of charge, and will not demand a signature on a waiver of claims, correct?

Note that the Act of Handover you demanded me to sign to receive the chips contained the following clause, which would waive my claims against Next Hospitality LLC.

"By signing this Act, the Parties confirm that it contains no ambiguous provisions and they have no claims against each other."

> Regarding the specific incident described in your letter, if you consider that the Front office employee did not provide an appropriate level of service, please provide us with the date, time, and other relevant details so that the matter can be investigated

It happened on the 4th of July, towards the end of the afternoon.

I had to converse with them in Russian, but I could not speak well, so I wrote on a piece of paper that I was sick, and that I needed the elevator. The front staff asked for a number, I wrote "16". The clerk angrily asked for the apartment number, so I added "-11". He claimed there were debts on the apartment (which is false). I had to write, in broken Russian, that "Next wants me to sign a contract, I don't want to." He still did not relent. I was lucky the other young man had more common sense.

> Regarding the statements concerning Mr. Saba Tsiskaradze, we would like to clarify that the request for a signature was related to confirming the receipt of the access chip/chips.

This is false. His request was for the signature of two documents, titled:

• "Residential building management Agreement"; and
• "Conditions of common areas’ service".

The first agreement is the one with a date prior to the issue of the passport number it contains, and the second one was also dated incorrectly, almost six months earlier.

They were not related to the access-control chips. Instead, Next wanted rights over my units, without any substantive compensation. Namely:

• 40% of my rental income with zero tax obligations;
• Unilateral power to set service conditions, fees and sanctions;
• The right to manage the units, including renting them out in our absence;
• The ability to prevent me from occupying the units if I would fail to warn them in advance;
• The need for me to demand any future buyer to carry on these legal obligations;
• Disproportionate penalties, including 3,000 US dollars payable by the owner merely for giving notice of termination, against 10 Lari per day payable by Next.

Obviously, I did not sign such a one-sided pair of agreements.

> Neither the company nor I confirm that any coercion took place. The company does not agree with the legal assessments referred to in your letter.

Then let me elucidate my conversation with Saba. Saba stated:

"Hello Luis. It's Saba, the manager of Next White.
I need to prepare a management and service contract, which you will need to sign.
I will need your passport, email, and contact number, so please send them to me."

I replied:
"However, I don't need to sign anything. A contract you "need to sign" is coercion.
Let's make sure the terms are fair and agreeable, and I will have no problem compensating Next for their services, despite Next never having extended any offer of compensation for the massive disruption they caused us during our renovation and after our move here, nor anytime our utilities were interrupted, even without warning."

Saba still insisted:
"Luis, no, we are not forcing you. These two agreements - the residential building service agreement and the management agreement - are concluded with every apartment owner.

Since you purchased the apartment from a private individual, these two agreements had already been prepared and signed with the previous owner. Now, as the new owner, the same two agreements must be prepared in your name and signed by you.

This is not coercion - it is simply compliance with the existing regulations."

Saba has never been able to produce a reference to the cited regulations. He also made a request:
"We will prepare these agreements and send them to you. After your confirmation, we will meet at the reception, where you can sign them."

I replied:
"It would have been necessary then, that these agreements be presented to me at the time of the purchase of the apartment. Next has failed to inform me of their existence, and so I have consented to nothing. I can't have consented to something I didn't read or didn't even know existed.

[...]

Despite all of this, and despite me not having consented to any agreement, I am not a parasite and wish to pay for the services. But I would like the service terms to be fair, and am stressing that Next does not have the right to compel me to agree to arbitrary terms of service, so I reserve the right not to sign any contract, if I do not deem it to be fair."

Saba forwarded me the documents, and I refused to sign them. Then Saba said:
"Luis, I explained to you that this is a matter of regulatory compliance. If you suspect that the company is managing your apartment without your consent, a contract terminating the management arrangement can be prepared.
As for the service agreement, this fee has been charged to you since August, $1 per square meter, which currently amounts to $608. Information that the service fee would start being charged from August was posted in the owners’ chat, and notifications were also sent via email.
The management company complies with all existing clauses related to service fee obligations."

Here Saba admits that he charged me a debt, even though the contracts establishing that debt were precisely the contracts Saba was pressuring me to sign.

Further, Saba adds:
"Luis, I am trying to explain to you that this is a contract requested from residents of apart-hotel buildings due to existing regulations in the country."

I stated:
"The problem is that you are abusing this as a pretext to put my property under your management and control.
It's not only about the compensation and you know it."

The rest of the conversation confirms the contracts were not signed.
Yet you are still enforcing them against me, both by alleging the debt and by regulating elevator access.

> Any legal dispute shall be addressed in accordance with the procedure established by law before the relevant authorities.

Then it shall.

Before closing, please note that you chose to remain silent regarding the following claims, which I made in the previous email:

• The previous owner does not recollect signing any such agreements with Next;
• My units are legally unencumbered and I have not signed any agreement that grants Next entitlement to debts or permission to modify the elevator;
• Next sent me a document with a date prior to the passport number it contains;
• Next sent me another document dated more than six months prior.

I also maintain my view that Next's conduct violates the Criminal Code of Georgia:

• Article 360 (arbitrariness): Next admitted to using the elevator access-control system to self-enforce alleged debts;
• Article 150 (coercion): pressuring me to sign both contracts, as well as the Act of Handover that contains a waiver of claims;
• Article 362 (making or use of a forged document): drafting a backdated agreement, sending an agreement with a date almost six months prior and using them, without my signature, to claim a debt and enforce elevator access control.

I am keeping you to your word that you are ready to continue discussing this matter in a constructive manner, and observe that I have maintained a factual, professional and respectful tone, despite Next currently obstructing access to my property.

Please respond timely to this message,
Luís

[Quoted previous correspondence omitted]