ravenscroft v cart claimant witness statement

7/23/2019 Ravenscroft v CaRT Claimant Witness Statement

http://slidepdf.com/reader/full/ravenscroft-v-cart-claimant-witness-statement 1/17

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CLAIM NO: HC/2015/001906IN THE HIGH COURT OF JUSTICECHANCERY DIVISION

BETWEEN:

LEIGH RAVENSCROFT

Claimant

and

CANAL and RIVER TRUSTDefendant

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WITNESS STATEMENT OF CLAIMANT

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This witness statement is made by the Claimant in response to the submissions

both of Ms Barry and Mr Stoner for the Defendant, in the matter of their:

a) opposition to allow Mr Moore right of audience, &b) application to strike out my Statement of Case, alternatively,

c) application to strike out part of my Statement of Case.

Opposition to Right of Audience

1. Paragraph 16 of Ms Barry’s statement claims that Mr Moore’s

involvement has changed the issues I was seeking to resolve into moregeneral issues of claimed “only tangential relevance ” to me. The

statement appears to postulate that the only problem I asked him to help

with, was getting my boat back [paragraph 17].

2. Insofar as this is a correct analysis of her position, it is false. I will refer

the Court to the videos of the boat’s seizure at Newark Marina. I told the

police officer in the hearing of CaRT’s Enforcement Officer Mr Garner,

and their unidentified Debt Collector, that I would take this matter to the

Queen’s Bench as a matter of theft facilitated by him.



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3. The police officer had refused to query CaRT’s authority to take my boat

and told me to take it up in law as a civil matter – which he [the police

officer] was not going to involve himself with.

4. As I had told Mr Garner, I was going to sue them for theft, criminal

damage and acting without due process, by which I meant that they

were seizing my boat for an alleged debt of 4 years’ licence fees without

obtaining a court warrant to do so, and having absolutely no paperwork

to establish either their claims or their rights to take the action they did. I

explained this to the police officer, and as I said at the time, I was “never

going to let this one drop ”.

5. I told CaRT and the police officer also, from the beginning, that I needed

no licence where I was moored on the private property of my moorings

provider. My father was prepared to pay the alleged debt for this

regardless, to prevent them taking the boat away, but was told by Mr

Garner that the full sum of more than £8,000 would need to be paid for

that to happen, inclusive not only of the 4 years alleged licence arrears

but also the estimated cost of removal and transportation – even thoughthe boat had not at that stage left the marina

6. I note at this point that Ms Barry’s paragraph 8 relating to “the Trust’s

stance that . . . a licence was required ” for my boat and that I had

previously held a licence for it, is knowingly false. CaRT are very clear

[as Shoosmiths’ Ms Barry must be] that no licence is required for boats

on the Trent, and that at most a registration certificate needs to bemaintained [I had previously had a Pleasure Boat Certificate, not a

Licence as claimed by Ms Barry].

7. This is not a mere matter of careless drafting; it has potential to mislead

the Court over the central core of my case. CaRT’s understanding is set

out in their response to an FoI request, dated 2 August 2013 –

https://www.whatdotheyknow.com/request/river_licence_a_percentage_ of_fu#comment-40388

https://www.whatdotheyknow.com/request/river_licence_a_percentage_



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“There is no technical difference between a 'Boat licence' and the'Registration Certificate'. The canal licence (which includes use of rivers)is distinctly a licence – this is because we own the canals and thedevice for granting permission to use is via a licence . Rivers aredifferent. There is a statutory right of navigation and we don’t own them,so all that people have to do is to ‘register’ to use them (subject to a fee

which the statutes allow for subject to the percentage condition wecovered in the last query). So technically, it is not a ‘river only licence’but a ‘river registration’ .” [my bold]

8. This is a very muddled and technically inaccurate answer; the ownership

of the canals and lack of ownership of rivers has nothing to do with the

right to grant permission – it is the effect of the 1968 Transport Act that

abolished conferred rights of navigation on the canals, combined with

the 1976 Byelaws, that makes pleasure boat licences on the canalscompulsory, not the ownership of the canals.

9. Nor are the navigation rights on rivers conferred by statute as suggested

here, and the first sentence contradicts the last - however, the

difference between canals and rivers re: the right of navigation is

pertinent, and the answer correctly identifies that no licence is

required to keep boats on the rivers; it is simply that there is a

statute-imposed requirement to maintain a paid up certificate of

registration for so long as a boat is kept or used within the main

navigable channel of the listed rivers.

10. The distinction is not merely technical; it is vitally important in the

present context, wherein reliance is placed on the absence of a “lawful

authority” to keep the boat on the river. The river registration certificate

is a superimposed statutory obligation on those exercising the right to be

on the river, breach of which is subject to specific [and criminal]

penalties; it does not form any “lawful authority” as in “permission” for

the boat to be left or moored, even within the “river waterway” as

defined. The section 8 powers are therefore inapplicable.

11. It is pertinent to quote from the Witness Statement of Stuart Garner

[paragraph 17] which Ms Barry has attached:



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“On 3 September 2014 I served a Patrol Notice to “Grandma

Molly/Three Wise Monkeys” advising the Boat was on CRT waterways

without permission and failing to display a current licence .” [my bold]

12. As CaRT were quoted in paragraph 7: “the device for granting

permission to use is via a licence. Rivers are different .” Not needing a

licence there is no device for granting permission respecting the rivers.

While CaRT’s enforcement officers have been known to be abysmally

ignorant &/or casual in their use of the law, and to lie in evidence under

oath, still, the enforcement management; legal department, and CEO,

have all approved of Mr Garner’s actions and this Statement.

13. It is quite understandable for the authority to loosely use the term

“licence” in the general context of public references for convenience; it is

not so understandable for them to use this inapplicable term in a

misleading way within the context of these legal submissions. If my boat

had been kept within the main navigable channel, then I would have

been guilty – not of being there without permission, but - of failing to

abide by a statutory requirement while exercising the permission we all

have under common law.

14. After videos were posted on YouTube, Ms Tracy Thomas came along to

help me start off with court proceedings to prevent CaRT from selling or

disposing of my boat, which we had been led to believe they could do if

not paid the outlandish sum of more than £8,000 inclusive of the 4 years

alleged licence arrears. She spent many hours before and after,

attempting to get specific sums identified and justified.

15. Following internet publicity, Ms Thomas was put in touch with Mr Moore

who had been posting details of the legislation controlling CaRT’s rights

of removing boats. Mr Moore advised on the content of emails and

letters sent by her, and also advised writing to the legal department to

suggest that I could drop the Injunction hearing as unnecessary, if they

only agreed in writing that they would not dispose of my boat while we

were attempting to sort matters out to retrieve the boat.



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16. [They refused to do this, despite their last minute admission that they

had no right to do what my injunction sought to forbid.]

17. I believe that there could never have been any doubt that CaRT were

aware that I was going to take matters into the High Court. Mr Moore

only advised on the specific legal reasons why my already stated

intention to do so was justified; the right to demand tolls for use of the

river being – contrary to Ms Barry’s suggestion – a matter that County

Courts lack jurisdiction to determine.

18. I would note that it was I who introduced Mr Moore to the applicability of

the Statute of Marlborough, which forbids seizure of goods without Court

Warrant; seizing goods in the highway, and removing them from the

County.

19. Ms Barry suggests [as I understand] in her paragraphs 20 & 21 that the

email of 24 April 2015, despite my reference to preparing for these

proceedings, indicates no desire to do so, because I had said I wanted

nothing more to do with keeping the boat. In making that claim she is

confusing what I wanted to do with the boat with what I wanted to doabout their unlawful seizure of the boat.

20. My intention had always been to sell the boat as soon as it was finished

– as I had told them in the videos: I had already advertised it on ebay,

and I had in fact agreed a sale immediately prior to the seizure. The

intent had been to make a bit of income from the renovation project.

21. Being refused return of the boat unless it stayed off ‘their’ water [despite

being made to pay for it to be there], it has since been in a farmer’s field

costing me the same as if I was paying for moorings, and yet being

unable to sell easily from there. At this stage, even if I sell it for what I

wanted, I will end up out of pocket.

22. Paragraph 22 itself illustrates that I was fully engaged in preparing for

this current action, even while negotiating for the return of the boat

through payment under protest of the illegal demands.



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23. In light of their recognition of this, the contradictory nature of the

preceding claims is incomprehensible.

24. The reliefs that I am seeking from the court can never be described as

academic – as the videos amply demonstrate, I want not only

compensation for all the monies illegally extracted from me, I want

satisfaction that only the Courts can provide, in declarations affirming

that everything [well mostly] of what I said to CaRT and police at the

time, was fully justified.

25. Besides which, I need to establish that my claims over the criminality of

their actions are justified, in order to justify repayment and

compensation for all the money they have both charged and cost me.

26. For all the above reasons, I maintain that contrary to the claims of Ms

Barry, my stated intention had always been to both retrieve my boat and

to sue them in the High Court on the grounds outlined in my Statement

of Case. All that Mr Moore has contributed is the specific waterways

legislation that confirmed the correctness of my allegations; he has alsoprovided the history of such of the Defendant’s past activities that have

demonstrated that they are as criminal in enacting their own unlawful

policies as I repeatedly accused them of at the time.

27. I submit that objecting to Mr Moore’s involvement and assistance in

preparing my case, most especially in view of my unfamiliarity with the

waterways specific legislation; my inability to communicate effectively inwriting; my verbal dyslexia, and my lack of any knowledge of court

procedures, is entirely unwarranted. They had no objection to Ms

Thomas assisting in exactly the same way.

28. I am unclear as to what constitutes “conducting litigation ”. I note that the

“Practice Guidance: McKenzie Friends” exhibited to Ms Barry’s

Statement refers to: “the provision of reasonable assistance in court or

out of court by, for instance, carrying out clerical or mechanical

activities, such as photocopying documents, preparing bundles,



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delivering documents to opposing parties or the court, or the provision of

legal advice in connection with court proceedings .” This is no more than

what both Ms Thomas and Mr Moore have provided for me.

29. I cannot speak to the claims made about Mr Moore’s conduct over his

own litigation, which I will have to leave to him. What I, as anybody can

say, is that in the principal case that addresses much of the same issues

I have, over the use of s.8 Notices, he succeeded. That they wasted a

quarter million pounds in fruitlessly arguing the issues and ended up

ordered to pay 75% of his costs besides, is only testimony to the lengths

they will go to pursue boaters even when it is they who are in the wrong.

30. For the judge whose judgment was overturned to class resolute defence

of an eventually justified claim as indicative of being “stubborn ” and

“relentless and obstinate ” [as quoted by Ms Barry] is singularly

inappropriate. From the outset I put CaRT on notice that I will be equally

as resolute in seeking redress in the cause of justice for the criminal

actions they took against me.

31. Ms Barry’s paragraph 30 protests that I am following the same ‘strategy’as Mr Moore in pursuing my case at CaRT’s expense. As with Mr

Moore’s situation, I cannot see why impecuniosity should debar anyone

from fighting for their rights in the Courts in circumstances where grave

injustice has been perpetrated against them by the Defendant.

32. There is no unnecessary multiplication of issues by reason of my

straightened circumstances; there are, as CaRT have readily identified,only 3 major issues, any and all of which involve the authority in criminal

offences which they have an established history of perpetrating.

33. As to the objection to CaRT having to engage in this litigation at their

own expense, there are several good answers.

34. In the first place, and most importantly, they need never have decided to

engage in litigation with me at all.



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35. They summarily dismissed my letters before action, and it was entirely

their decision to reject my repeated offers to withdraw from litigation if

they refunded my money and acknowledged the wrongs done.

36. In the second place, the employment of external professionals to

prepare elaborate defences at disproportionate cost is a tactic of their

choice when they have their own more knowledgeable in-house legal

officers with full right of audience.

37. In the third place, in an example of extravagant expenditure in the

Defence that they prepared to object to my application for an injunction,

the £4,500 spent was not aimed at the injunction to neither sell nor

destroy my boat, but instead involved a detailed defence of their right to

seize the boat in the first place. The preparation of that Defence, with

the accompanying witness statement and exhibits, involved the matters

that are raised in this action rather than that of the injunction

application, such that the work required for preparation of a defence in

the instant case has already been largely [and pointlessly] undertaken

anyway.

38. The Defendant’s argument on this score boils down to a claim that I

should accept going into debt to pay their unlawful extortion of money

from me to retrieve my possessions, and that my lack of funds should

preclude my being able to seek justice for that.

39. What the point is of Ms Barry’s paragraphs 33 & 34 I do not know. Iattended at Nottingham County Court in company with Mr Moore

because I was interested in the case, and to support yet another CaRT

victim.

40. Having discussed that case with him beforehand, I knew that Mr Moore

had written an amended Defence for them that the solicitors were

postponing looking at in the belief that the hearing would be only for

directions. He did not submit that to the Court, but to the solicitor only.



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41. It was Mr Moore’s belief [correct as it turned out] that the hearing would

be dispositive, and so he helped Mr Wingfield file a short witness

statement instead of the unused Defence.

42. Neither of us were permitted to sit in on the hearing, but the transcripts

reveal that Mr Wingfield’s solicitors had failed to file an

Acknowledgement of Service with the Court objecting to the Part 8

procedure, and handed up a draft Defence only at the hearing. The

judge accorded great latitude in allowing Mr Wingfield’s barrister to

address the Court at all in the circumstances, and paid no attention to

any legal argument in the Statement, addressing only the disputed facts

according to Mr Wingfield - which his barrister acknowledged as correct.

43. It is hard to see why objection should be taken to Mr Moore’s assistance

in that instance when the judge himself allowed it in opposition to Mr

Wingfield’s own barrister’s request that it be dismissed.

44. The only Defence filed with that Statement was an exhibited copy of a

relevant Defence that Mr Moore has also helped draft [together with acouple of other boaters] for yet another boater who faced s.8

proceedings from CaRT earlier. In that prior instance they had

discontinued the case after reading the Defence, and having sight of it at

the Wingfield hearing, CaRT offered to restore the licence on a 3 month

probationary basis if he returned to his home mooring. It was only the

failure of Mr Wingfield’s representatives to take up that offer that led to

the hearing going ahead.

45. I have talked at length with these and other boaters who have faced

similar issues and been assisted voluntarily by Mr Moore. I do not see

why I should be denied the same assistance just because he has been

effective in helping others.

46. Neither I nor Mr Moore have any objection to any of the correspondence

being revealed concerning the attempt to resolve matters out of court;

there need be no legal argument about it. I have made no secret of my



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inability to prepare the case on my own, and it was at Mr Moore’s

insistence that I agreed to try resolving matters outwith litigation. If any

one item of the correspondence is to be exhibited, however, the whole

of it should be, so that the Court is able to form a balanced view.

47. I asked CaRT to allow Mr Moore to conduct negotiations, and he

persuaded me to be content with far less than I had wanted. The

principal reason for failure in this was not, I believe, due to the sums

suggested but to my insistence on transparency, and on an

acknowledgement that errors in conduct had been made on at least one

of the grounds that I had initially insisted on before this started.

48. Insofar as any point will be sought to be made from this correspondence

relating to the fact that buying my silence could not buy his, that would

be redundant, as the arguments involved had already been publicised

by Mr Moore beforehand in public forums – which was how I came to be

put in touch in the first place. He has only remarked on the obvious.

49. In summary, in the premises above, I submit that there is no substance

to the assertion that Mr Moore’s involvement has meant that myStatement of Case includes issues that are merely peripheral to my

claim. His involvement has meant only that my claims, based as they

were on the general principles of law that I understood, were placed

within the specific context of the waterways legislation, with examples

from the authority’s history to back my claims of criminality in their

approach.

50. I feel that it is important for the court to recognise that Mr Moore’s advice

to me, as indicated by the email he suggested over resolving the

application for an injunction, was to always seek resolution outside of

the Courts if possible, and the emails CaRT wish to exhibit demonstrate

that he repeatedly – though fruitlessly - asked for personal discussion

with the Defendant in lieu of correspondence with their solicitors.

51. It is unfortunate that they were unwilling to follow that route. Their

complaints over the expense of defending litigation rings hollow in the



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light of that approach. Even the judge in the County Court appeal

queried why they were unwilling to resolve our differences that way;

their stance being then that I should drop all claims entirely with no

unbending or concession on their part, even though admitting at the last

that they could not do as the injunction sought to forbid them anyway.

52. For the reasons given in my Request, I firmly believe that I will be

severely prejudiced should I have to orally present my case myself.

Application to Strike out my Claim

53. I submit that it would be a terrible miscarriage of justice to allow this

application to succeed. I gave reasons in my Reply to Defence.

54. The points raised by reference to the absence of the required

‘Statement of Truth’ in the relevant documents have, I assume, been

addressed by the replacement ones now filed, sent in compliance with

the Chief Master’s directions.

55. The principal argument of Ms Barry as backed by Mr Stoner at thehearing, is that the Statement of Case is too “prolix and

disproportionate ”, which I take to mean that the Statement of Case is not

concise as the CPR demands.

56. I start by noting that the latest ‘White Book’ commentary on CPR s.16 as

helpfully supplied by Mr Stoner begins by saying that “Part 16 and the

Practice Direction supplementing it offers little guidance on draftingstatements of case . . .”

57. CPR 16.4(1) however, provides: “Particulars of claim must include (a)

a concise statement of the facts on which the claimant relies .” [my bold]

58. I submit that the Particulars of Claim as attached to the Claim Form are

a concise outline of the relevant facts and the reliefs sought, comprising

a mere 5 pages of double-spaced 12 pt font with generous margins.



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59. The White Book commentary states: “The primary function of the

particulars of claim is to state concisely the facts on which the claimant

relies ” and “The claimant should state all the facts necessary for the

purpose of formulating a completed cause of action . A claimant may

also: (1) refer in their particulars of claim to any point of law on which

their claim is based .” [my bold]

60. I submit that my Particulars of Claim meets the relevant rule perfectly,

having referred not only to the bare facts far more concisely than the

filed Defence, but including a bare mention of the relevant Acts, the

points of law within which are, on my argument, violated by the

Defendant and so giving rise to valid causes of action.

61. With respect to the “Statement of Case” that I filed in addition to and in

elaboration of the concise Particulars, I acknowledge the applicability of

the Practice Direction 16.1.4, which provides: “If exceptionally a

statement of case exceeds 25 pages (excluding schedules) an

appropriate short summary must also be filed and served .” [my bold]

62. My Statement of Case begins with just such a summary, being lessthan a single page that sets out the three essential grounds, which the

Statement elaborates upon for the sake of complete understanding of all

parties as to how and why those grounds arise and are justified.

63. Furthermore, the Statement concludes with a summary of just over 2

pages, summing up as succinctly as possible the foregoing material of

the statement.

64. I refer to my comments respecting this in my Reply to Defence.

65. I further note that the length of the additional “Statement” was

considered important in order to lay out as completely as possible for

the benefit of both Defendant and the Court, such material as is

illuminating of the issues and arguments, bearing in mind the potential

inadequacy of a litigant in person [including Mr Moore if permitted] to

present the case orally at trial.



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66. As noted in the Reply to Defence, the Defendant has demonstrated in

their Defence that the essential core issues have been readily

appreciated. There can therefore be no legitimate claim of obfuscation

or difficulty of understanding. I submit that the detailing within the

Statement has been of considerable assistance to all parties rather than

otherwise, and so providing essential tools for just disposal of the

proceedings.

Application to strike out the ‘Presumption of Probity’ section

67. I note that the single most oft repeated accusation that I made to CaRT

at the time of seizure and thereafter, was that they were acting in a

criminal fashion contrary to law. This is very evident from the videos.

68. Each of the three primary issues that I have raised embraces the

inevitable accusation of criminal action, each of them involving a

violation of either common law and/or Statute by the Defendant, which I

have claimed is a characteristic of CaRT’s enforcement policy.

69. As the White Book comments: “Paragraph 8.2 of the Practice Direction

supplementing Pt 16 requires the claimant to specifically set out the

following matters in their particulars of claim where they wish to rely on

them in support of their claim: (1) any allegation of fraud; (2) the fact of

any illegality; (3) details of any misrepresentation; (4) details of all

breaches of trust; (5) notice or knowledge of a fact; (6) details of

unsoundness of mind or undue influence; (7) details of wilful default, and(8) any facts relating to mitigation of loss or damage .”

70. It is submitted that there is therefore a two-fold requirement

necessitating inclusion of this section: rebuttal in this instance, of the

natural and officially stated presumption that authorities in the position of

exercising rights over the public should be considered to act at all times

lawfully and for the strict purposes of their administration, plus the CPR

requirement that any accusation that this is not the case, be backed by

factual example and any prior case history.



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71. The past actions of the Defendant as a corporation administering

enforcement against members of the public in ways contrary to the law,

involving criminal behaviour, are therefore not merely directly pertinent

to my claims [establishing that the grounds for them are not fanciful

despite being against common and legal presumption], but the citing of

examples both of general policy and of identical/similar actions as obtain

in my own case, is in fact mandatory.

72. My claim that the Defendant has acted in a criminal fashion in denying

and obstructing the public right of navigation – a right which they

acknowledge exists in this case – is verified by the precedent of every

one of the past court actions to remove boats which involve Injunctions

against the boats being used on public navigable rivers, and is

specifically exampled in the cited case of Moore v British Waterways .

73. It is all the more relevant that in that latter case, there had been a history

of many years of violating the rights of boats to use a public navigable

river, in demanding illegal tolls and evicting and threatening to evict

boats therefrom.

74. Worse, the cited example of the Defendant still forcing boats from that

river using s.8 powers, even post the relevant judgment and

acknowledgement of its effect – supported by the same regional

manager as publicly acknowledged that effect – demonstrates that such

criminal actions are continued in the face of knowledge, with the

sanction of upper management.

75. This is essentially pertinent as grounds to support my claims that the

nature of the actions I accuse them of is institutional in character and not

the “inadvertent ” [CaRT’s argument] behaviour of a single rogue

employee.

76. The other examples cited in the section likewise demonstrate that the

general attitude is reflective of the attitude of the highest office holders,

as well as that of the enforcement and legal departments.



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77. There is no need, as I have stated in my Reply to Defence, for the

Defendant to respond to this section; the facts are matters of public

knowledge and publication, and of relevant Court judgments and orders.

78. It is all the more inappropriate for the Defendant to demand their costs in

applying to have this section struck out, seeing that they have not in fact

addressed the details of the section at all. Indeed, they cannot deny the

facts; they can only hope to suppress them via this application.

79. I submit that it is vital to my case that the general presumption of probity

is challenged, with unassailable examples demonstrating that I have

good and sufficient grounds of action that underlie the accusations I

have made.

80. The effect of the presumption is nowhere more obvious than in the video

evidence of the police officer at the scene of the seizure.

81. When it was forcefully put to him that the seizure was an act of criminal

nature which he ought to prevent, his response was: “From myuntrained perspective in the rule of the river, or the laws of the river, it’s

no different to if someone’s left their car on a highway, and it’s been

abandoned . . .” “You guys are saying they need paperwork, where’s

your proof that this chap doesn’t own the [boat?] ” . . . “These guys, the

Canal and River Trust, know what they’re entitled to do . . .”

82. While there can be no disagreement with that last statement, theobvious thinking of the officer in making the statement was to assert the

correctness of their actions – that knowing what they were and were not

entitled to do, the fact that they did something was proof enough - for

him - of their entitlement to do it.

83. When weighing up the conflicting claims of CaRT employees and a

member of the public, officialdom automatically [and understandably]

assumes that CaRT are in the right.



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84. As the same officer also said: “I’m not bothered about paperwork. I’m

quite happy that the Canal and River Trust are acting lawfully .”

This, without any knowledge, as quoted in the preceding paragraph, of

what the “laws of the river ” actually were.

85. When that understandable presumption exists, it is necessary to

demonstrate that CaRT and their predecessor [same legal personnel]

have done exactly opposite to what they knew themselves to be entitled

to - historically and to the present.

86. The 29 examples of illegal s.8 actions against boats entitled under the

common law right of navigation to be on the Brent, as detailed in the

section objected to, speak directly to the readiness of the Defendant to

commit these crimes, as they have done in the other examples listed,

and with me.

87. The example given of the CEO’s dismissive attitude to crimes committed

by his senior staff serves to justify my accusations that the criminal

actions of the corporation are a result of carried-over corporate policy.

88. The other itemised historical facts are similarly indicative of the abusive

approach of which I have accused them both verbally and in pleadings.

They serve to establish the validity of my claims as perfectly justified, so

providing reasonable grounds for bringing the claims that I have.

89. What the Defendant is seeking to ask the Court to do in this strike-outapplication, is to deny me the right to present the existing relevant

evidence to the Court of the validity of my claims; this being contrary to

the requirements of Practice Direction 16 paragraph 8.

90. I refer also to paragraph 356 of my Statement of Case respecting the

need to justify ‘opening the gate’ to look behind for the reasons for

CaRT’s actions against me, in respect of the Human Rights aspect to

the offences claimed.



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91. In the premises I submit that the application to strike out this section

should be dismissed as wholly improper and inappropriate, and contrary

to “the over-riding objective of ‘dealing with the case justly’ . . .”

Statement of Truth

I believe that the facts stated in this witness statement are true.

. . . . . . . . . . . . . . . . . . . . . . . . . . . 2 January 2016

Leigh Ravenscroft

c/- The Croft

Moor Lane

Newark

NG23 5QD

Email: [email protected]

ravenscroft v cart claimant witness statement

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