Thank you for your question
My name is Clare
I shall do my best to help you if you still want assistance.
What funds are YOU currently holding?
In that case simply write to the solicitor along these lines
"Thank you for your letter.
I note your point regarding the Limitation Act - but would remind you that there is also a general requirement that there is no unreasonable delay.
You appear to have misunderstood the position - which is surprising given that I have forwarded the paperwork you requested.
You are currently holding the remaining funds in the estate.
Any injunction you may contemplate therefore will bite on those funds alone.
If your client's wish to take further action they are indeed free to do so but I require your undertaking to hold the funds sent to you to my order pending
I hope that this is of assistance - please ask if you need further details