Appendix 3: Examples of a witness statement and supporting Skeleton Argument

Examples of a witness statement and supporting Skeleton Argument in a case where the Claimants (Contrary Ltd), the former employers of the Defendant, Andrea Blank, obtained an interim injunction without notice preventing her from starting employment with another employer (Obliging Ltd).

QUEEN’S BENCH DIVISION
INTERIM APPLICATIONS COURT
TO BE COMPLETED BEFORE ANY WITHOUT NOTICE APPLICATION IS HEARD BY THE JUDGE
DATE: 03/05/2016
NAME OF CASE: CONVETION TRAVEL DOCUMENT & BIOMETRIC CARD
NUMBER OF CASE (IF ASSIGNED): N/A
NAME OF COUNSEL/SOLICITOR/LITIGANT IN PERSON PRESENTING THE APPLICATION:N/A
SOLICITORS’ CONTACT DETAILS IF INSTRUCTED: N/A
NATURE OF APPLICATION AND ESTIMATED LENGTH OF HEARING:
Denial of Biometric card and Travel Document (CTD), Its about 25 minutes
HAS INFORMAL/SHORT NOTICE HAS BEEN GIVEN TO THE PARTY AGAINST WHOM THE ORDER IS SOUGHT? No
REASON FOR NOT GIVING NOTICE: Thought of High Court decision to inform
WHERE IS THE REASON FOR NOT GIVING NOTICE DEALT WITH IN THE EVIDENCE SUPPORTING THE APPLICATION? HOME OFFICE SAYS THAT I CAME TO BRITAIN WITH A UGANDAN PASSPRT. SO, NTL REFUSED IN 2014 AND 2016 THAT TRANSFER OF CONDITIONS FORM NOT ALLOWED. NO TIME LIMIT INSTEAD. EVIDENCE OF 2014 DIRTY AND BINNED.
WHAT ARE THE CONTACT DETAILS (E-MAIL, TELEPHONE, ADDRESS, etc.) OF THE PARTY (AND/OR HIS/ITS REPRESENTATIVE) AGAINST WHOM THE ORDER IS SOUGHT? UK Visas and Immigration, Po Box 3468, Sheffield, S3 8WA, Telephone 03001232241

____________________________________
Signature of Counsel/solicitor/litigant in person confirming the above information.
Appendix 3: Examples of a witness statement and supporting Skeleton Argument
Examples of a witness statement and supporting Skeleton Argument in a case where the Claimants (Contrary Ltd), the former employers of the Defendant, Andrea Blank, obtained an interim injunction without notice preventing her from starting employment with another employer (Obliging Ltd).
The Judge had granted the order for seven days until a “return date” at which the court would consider whether to continue the order. Andrea Blank has prepared a witness statement and a Skeleton Argument in support of her argument that the order should not be extended and indeed should be set aside.
WITNESS STATEMENT
Buteera Disan v Home Office, UK Visas and Immigration
Witness Statement
I, Buteera Disan , of 21 Churchside Gardens, Room 4, Nottingham NG7 5GW, state as follows:
1. I am hoping the first application I have submitted regarding Student Finance is progressing. Back to the matter.
2. I contacted the Department for Immigaration which is UK Visas and Immigration via Home Office, Travel Documents BRP, Po Box 588, Durham, DH99 1AA which was returned by the Liverpool Office. Unfortunately, the No time Limit application was refused saying that since I came with a passport is the only… dates back in 2014/5.
3. I became surprised seeing maladministration taking a move with the Home Office which I believe was a sort of biasness, inaptitude, laziness, incompetence and being Professional uncivilised. As a Law abiding Citizen; Ugandan – hoping to get the British Citizenship or perhaps Rwandan Citizenship, the latter my ancestrial and Traditional Homeland. The Home Office is exercising such kinds of arrogances and somewhat lacking common sense.
4. Recently, the Home Office having refused the NO Time Limit application I had personally written and submitted, I thought of some legal advice. As a result, I contacted Panacea Solicitors, New Brook House, 385 Alfreton Road, Nottingham, NG7 5LR of Telephone Number 01158719456 and discussed the situation and circumstances by which I was falling in being the holder of an Indefinate Leave to remain in the United Kingdom of Great Britain and Northern Ireland.
5. The Solicitor who can not be named here for legal reasons, assessed and did the rest on my behalf. Consequently, a Transfer of Conditions application was filled. I am wondering since as a result, the Home Office dramatically with the firm refused the Transfer of Coditions form saying (Refer to Home Office letter dated 12/02/2016). Remember, I had explained earlier that in the Home Office file there is already a No Time Limit application which was refused for entering Britain with a passport. Am I an angel?
6. During the 2014/5 application the return feedback, the envelope was dirty and unpleasing with lot of dust inside. I used DHL while posting to the Home Office. The results were dirty and unpleasing.
7. Upon Panacea’s call that a No Time Limit application AGAIN reguires to be completed, I refused that and as a result, I left their Office.
8. Today, I have been invited by Nottingham Refugee Forum at Sycomore Community Centre , St Anns for the issue and completion of the Biometric application and perhaps travel document. Something which is also undermining from the rational point of view following what has been happening. The arrangement is on 05/ 05/2016 from 1pm before an Immigration expert.
9. Thank you, Buteera Disan
10. In conclusion, I do persuade you to intervene and the Home Office do process my request for a Travel document and a Biometric Card WITHOUT completing another No Timit Limit application. Thank you, Buteera Disan, 07951167275.
I believe that the facts stated in this witness statement are true.
Signed …Buteera Disan, 07951167275………………………….
BUTEERA DISAN
Date 03/05/2015
SKELETON ARGUMENT
Buteera Disan v Home Office, UK Visas and Immigration
Defendant’s Skeleton Argument

1. My arguments are –
(i) The Home Office does not act properly in a civilised Professional manner. What was then their engagement with Panacea Solicitors. What was discussed??? In my absencia basing on what was on ground such as the completion of the first NTL Form in 2014/5.
Find attached
1.Note from Home Office about TOC via Panacea Solicitors
2.Deed of change of Name
3.Immigration Document – Home Office
4.Post Office Biometric Exercise    5. Current Address

02/11/2017, Recent response from the Home Office UKVI: scan0001, scan0002,

and feedback N Jennion (2018) Residency continuity,  Liverpool Managed Migration available (online) at https://twitter.com/BUTEERADisan/status/977180722460053504 and Finally, The Biometric Stencil has finally come available at https://www.facebook.com/disan.buteera/posts/2132114787023574.

Regards,

Disan Buteera, 1st Deputy Information Minister Emeritus (2001/2) though!

URL Director & Projec Manager, http://www.buteeradisan.wordpress.com

Interests

Interests

£200.25