Defendants/Respondents
___________________________________________________
SECOND WITNESS STATEMENT OF JULIAN DIAZ-RAINEY
___________________________________________________
I, JULIAN DIAZ-RAINEY, of Pinsent Masons LLP, 30 Crown Pl, Earl St, London EC2A 4ES,
WILL SAY as follows:
1.
I am a solicitor of the Senior Court in England and Wales and a Partner (or, more
precisely, a Member) in the firm of Pinsent Masons LLP (" PM "), solicitors for the
Applicant / Claimant.
2.
Save where stated to the contrary, the facts and matters contained in this witness
statement are within my own knowledge (gained whilst acting as a solicitor for the
Applicant) and are true. Where facts and matters are outside my knowledge, the source
is stated and I believe those facts to be true.
3.
During the course of this statement, I will refer to certain documents, copies of which
are exhibited in a paginated bundle marked 'JDR2' which accompanies this statement.
Save where stated otherwise, references below to page numbers are to the pages of
exhibit ‘JDR2’.
Duty of Full and Frank Disclosure
4.
As recently re-affirmed by the case of Wolverhampton City Council v London Gypsies
and Travellers [2023] UKSC 47, the Claimant is under an ongoing duty to provide full
and frank disclosure to the Court, which requires reasonable research and diligence as
to the circumstances around this case.
5.
I t has come to the Claimant’s attention that there has been a change of circumstances
that affects the content of the Second Witness Statement of Nevin Truesdale, Chief Executive Officer of the Claimant. 1 The purpose of this statement is to provide an update
to the Court so that it is aware of the change in circumstances and current position.
Animal Rising - Website
1 Pages 2 to 10 of JDR2
2
4
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