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WITNESS STATEMENT OF JULIAN DIAZ-RAINEY
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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. 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 Applicants) and are true. Where facts and matters are outside my knowledge, the source is stated and I believe those facts to be true.
2.
3.
During the course of this statement I will refer to certain documents, copies of which are exhibited in a paginated bundle marked 'JDR1' which accompanies this statement.
4.
I make this witness statement in suppor injunction against the Respondents in the terms of the draft order attached to the application notice.
Service of the claim documents on the First Respondent
5.
I enclose at pages 1 - 2 of JDR1 the witness statement of Stephen Williams a process server at Conflicts International Limited. Per that statement, I understand that the Unsealed Application Notice, Sealed Claim Form, Response Pack and witness statements of Nevin Truesdale, Amy Starkey, Simon Knapp and Dickon White (the Witness Statements were left at the First Respondent 15:40 on 22 May 2023 after a woman at the address confirmed that the First Respondent lived there.
6.
Further, I understand that the Sealed Application Notice was left at the First Respondent
7.
In addition to the above I enclose at page 3 of JDR1 an email sent to the First Respondent from PM enclosing the Sealed Application Notice, Sealed Claim Form, Response Pack and the Witness Statements at 15:50 on 22 May 2023. Enclosed is
140242150.1\645003
2
JDR2 / 422
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