53. Service must necessarily be effected on unknown respondents by alternative means, given that their identities are not known. There is good reason for service by alternative means, therefore, and the Applicant has taken all reasonable steps to bring the Claim Documents to the attention of Rs 2 to 8, following the steps referenced in paragraph 50 above [Diaz-Rainey (DB/227) §§11-15].12 Moreover, AR issued a response to the Application on its website at approximately 6.30pm on 22 May 2023 [Diaz-Rainey (DB/227) §8] [DB/234]. 54. The Applicant considers that the same steps can reasonably be expected to bring the Order to the attention of Rs 2 to 8 if an injunction is granted, and invites the court to grant permission for alternative service of the Order to be effected on Rs 2 to 8 by the means set out at paragraph 3 of the draft Order. 55. It was not possible personally to serve the Claim Documents on R1 as the Applicant intended; however, personal service is not required by the CPR rules. Insofar as it is necessary to do so, the Applicant invites the court to direct that the steps taken - leaving copies in R1's letterbox, and emailing him digital copies - amount to good service [Diaz-Rainey (DB/227) §§5-7] [DB/231-232]. The Applicant received a notification that R1 had downloaded the documents at 5.24pm on 22 May 2023, and the AR's response on its website was almost entirely a quote attributed to R1 [Diaz- Rainey (DB/227) §§7-8]. leaving copies in R1’s letterbox, and emailing him digital copies - amount to good service [Diaz-Rainey (DB/227) §§5-7] [DB/231-232] . The Applicant received a the AR’s response on its website was almost entirely a quote attributed to R1 [Diaz- Rainey (DB/227) §§7-8] . referenced in paragraph 50 above [Diaz-Rainey (DB/227) §§11-15] . 12 Moreover, AR May 2023 [Diaz-Rainey (DB/227) §8] [DB/234] .
F. CONCLUSION
56. In all the circumstances, the Applicant respectfully invites the court to: (i) grant the injunction in the terms set out in the draft Order; (ii) direct that good service of the Claim Documents has been effected on each of the Respondents; and (iii) order that
12 The Claim Documents are those defined in the draft Order, namely, the Claim Form, the sealed Application Notice and draft Order, the Witness Statements of Mr Truesdale, Ms Starkey, Mr White and Mr Knapp, and the exhibits thereto.
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