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    Notice of Hearing In the High Court of Justice Chancery Division Birmingham District Registry Claim Number _]A30BM539 Date 9 December 2014 THE UNIVERSITY OF WARWICK t Claimgane ] Ref JEFAICC/WA7572377| HATTIE CRAIG iL" Defendant IRef CAXKUM CANT a Defendant ef PERSONS UNKNOWN (INCLUDING STUDENTS OF THE UNIVERSITY OF B™“Defendant WARWICK) IRef ‘TAKE NOTICE that the Possession and Injunction Hearing will take place on Friday 12 December 2014 at 2:00 PM before His Honour Judge Cooke at Birmingham District Registry, Civil Justice Centre, The Priory Courts, 33 Bull Street, Birmingham, B4 6DS ‘When you should attend 1.5 Hours has been allowed for the Hearing Please Note: This case may be released to another Judge, possibly at a different Court The cour office u Birmingham Distt Regist, Civil ustioe Cente, Te Priory Coors, 33 Ball Set imingham, B8 6DS is open by epomtment Monday t Fide ‘When corresponding withthe cout, please adress foro eters othe Cout Manage an quot the claim number Tel: 0121 681 $41, Produced by Rowe N24 Nonce of PTR/AdjndRestredir/Management Conference ‘CoROa = Persons Unknown (Including Students Of The University | OFwarwick) General Form of Judgment or Order In the High Court of Justice Chancery Division Birmingham District Registry Claim Number | A30BM539 ‘Date 9 December 20 | THE UNIVERSITY OF WARWICK Claimant IRef JEF/DCC/WA7572377 HATTIE CRAIG 1" Defendant Ref CAKKUM CANT b™ Defendant IRer PERSONS UNKNOWN (INCLUDING STUDENTS OF THE UNIVERSITY OF B™ Defendant WARWICK) _ Ref Before His Honour Judge Cooke sitting at Birmingham District Registry, Civil Justice Centre, The Priory Courts, 33 Bull Street, Birmingham, B4 6DS as a Judge of the High Court, UPON hearing Counsel for the Claimant AND UPON reading 1. The documents on the court file being (a) The Claim Form with Particulars of Claim; (b) The Application Notice for the Order dated 9 December 2014; (c) The witness statement (with exhibits) of Kenneth Sloan dated 9 December 2014, 2. The Certificate of Reasons for bringing the Possession Claim in the High Court IT IS ORDERED THAT 1. The Claimant shall as soon as reasonably practicable serve copies of the Claim Form and the following documents: (@) this Order; (b) the Particulars of Claim; (©) the Application Notice for the Order dated 9 December 2014 and draft Order; (@ the witness statement dated 9 December 2014 of Kenneth Sloan (with exhibits); (©) the Certificate of Reasons for bringing the Possession Claim in the High Court; and (f) a Notice of hearing for 12 December 2014 The court ofice a Bizmingham District Registry, Civil Juste Cee, The Prion Cours, 33 Bll Suee, Birmingham, Bé 6DS is open by appolnaent Monday to Frid. When coresponding wit the cour, plese address forms or ltrs oth Court Manager and quote the claim number. Tl, 121 6814441 Produced by:L Rowe [N24 General Form of Judgment or Order Caos b (i) affixing copies thereof to the two fixed doors and the fire exit to the Top Floor of The Rootes Social Building, ‘The University of Warwick, Coventry CV4 8UW i) taking reasonable steps to bring the said documents to the attention of the occupants of The Rootes Social Building aforesaid (iii) placing further copies thereof a) on the reception desks of the Senate House and of University House; b) on the reception of the box office at Warwick Arts Centre; and ) in a prominent area inside the Students! Union (iv) sending notice of these proceedings to the Facebook accounts of the first and second Defendants stating that copies of the documents referred to in paragraphs (a) to (f) above are available from the Claimant's solicitors and elsewhere as set out herein. 2. Such steps (a) shall be good service of all the documents referred to provided that copies are affixed within the Rootes Social Building as required by para 1 above by 7 pm on 9 December 2014; (b) shall constitute service deemed to have taken place one hour after the posting of the documents on the doors and fire exit of The Rootes Social Building aforesaid; (6) shall be verified by a witness statement explaining the steps taken, to be filed at the next hearing, 3. Provided such steps are taken, the Court hereby abridges the time for service otherwise required by Civil Procedure Rule 55.5(2) for the hearing of the possession claim so that such hearing may take place at 2pm on Friday 12 December 2014. All parties or their legal representatives should attend on that occasion. Dated 9 December 2014 1 Inthe High Court Of Justice @ Claim form for Chancery Division possession of property | *ixinchan District Registry Claim no. A SOB Me : Fee Account no. ‘You may be able tots ste your claim online and it may save you time and money. Go to www.possessionclaim.gov.uk to find out more. Claimant (name(s) and address(es) The University of Warwick Coventry cv4 Bun Defendant(s) (name(s) and address(es)) (1) Hattie Craig (2) Callum Cant and (3) Persons Unknown (including Students of The University of Warwick) entering or remaining upon the land and buildings of the campus of the University of Warwick, Coventry for the purpose of protest action without the consent of The University of Warwick The claimant is claiming possession of: the land and buildings of’ the campus of The University of Warwick, as shown edged red, but excluding those land and buildings edged and hatched green, on Plan A annexed to the Particulars of Claim ("the Campus") which (includes) O9XHXKIRNGR residential property. Full particulars of the claim are attached. This claim will be heard on: at amipm at At the hearing + The court will consider whether or not you must leave the property and, if so, when. + Itwill take into account information the claimant provides and any you provide. peices (1) Hattie Craig 485.00 ‘bddress for (2) Callum Cant and ; sevice (3) Persons Unknown 's costs a Total amount 685.00] The Rootes Social Building The University of Warwick Coventry pos tet im cv4 Bow Issue date 16 Gisim form for possession of property (05.14) ©Ceomn copyright 2014 Laserform ternatonal 8/14 422221 What you should do + Get help and advice immediately from a solicitor or an advice agency. + Help yourself and the court by filling in the defence form and coming to the hearing to make sure the court knows all the facts. Grounds for possession Anti-social behaviour The claim for possession is made on the following The claimantis alleging - ground(s): [_] rent arrears (online issue available) actual or threatened anti-social behaviour [_] other breach of tenancy (J actual or threatened use of the property for % _ unlawful purposes [forfeiture of the lease Li (| mortgage arrears (online issue available) (J other breach of the mortgage X] trespass [_] other (please specify) Is the claimant claiming demotion of tenancy? [yes [x] No Is the claimant claiming an order suspending the right to buy? Ll yYes [x] No See full details in the attached particulars of claim 422221 Claim No. Does, oF will, the claim inciude any issues under the Human Rights Act 1998? Yes [X]No Statement of Truth XX80689@)( The claimant believes) that the facts stated in this claim form are true. “1am duly authorised by the claimant to sign this statement. ge Stoned date 9 December 2014 . | “(Claimant , be | “delete as appropriate Full name James Edward Roger Fownes Name of claimant's legal representative's firm SGH Martineau LLP Position or office heldSenior Associate (Gf signing on behalf of fim or company) it epplicable TEE /MIE/WAIS72377 (cam: 422222) No. 1 Colmore Square Birmingham 0800 763 2002 [721090 Bizmingham 43 w/a ..o800 763 1000 42222: Parti lars of claim for nossession (tre passers) Chanoanfigniogtartog A20BME2Y | Birmingham District Registry aL THE UNIVERSITY OF WARWICK ‘Inthe High Court of Justice Telain No. Claimant HATTIE CRAIG (2) CALLUM CANT (3) PERSONS UNKNOWN Persons Unknown (including Students of The University of Warwick) entering or remaining upon the land and buildings of the campus of The University of Warwick, Coventry for the purpose of protest action without the consent of The University of Warwick ! . Defendants), 1. ‘The claimant has a right to possession of: the land and buildings of the campus of The University 9 edged red, but excluding those land and buildings edg; gen on Plan A annexed hereto ("the Campus") claimant's consent or licence. ‘The defendant(s) (QQ (have) never been a tenant or sub-tenant of the and. 3. The land mentioned at paragraph 1 does (4) include residential property. 4. The claimant’ interest in the land RXXOOOXXIKKRIKIOOOODONIOORIOODOODOOONIO is Give details. ‘The Claimant is the registered proprietor of all these land and buildings edged in red, but excluding those land and buildings edged and hatched green, comprised within Plan A. A schedule of the title numbers for all that land shown edged in red on Plan A is annexed hereto. 5. The circumstances in which the land has been occupied are Give details. On 2 December 2014, the Defendants began protest action on the Campus. The Defendants’ protest action was mobilised and they attempted to enter/occupy the Rootes Social Building and Senate House on the Campus. Disturbances continued on 3 December 2014. The occupational sit in at the Rootes Social Building started on 4 December 2014 and is continuing. [NI21 Particulars of eam for possession (trespassers (10.01) Lasers neatins 1001 42222 ‘The Defendants also threaten to commit ongoing acts of trespass upon the Claimant's land (as well as other buildings comprised within the Campus as shown shaded red on Plan A) unless restrained by the Court. ails of the circumstances upon which the Campus is being occupied are as set the attached witness statement of Kenneth Sloan dated 9 December 2014 Foll d out in 6. The claimant does not know the name(s) of (all) the defendant(s). ‘The ciaimant asks the court to order that the defendant(s): {a) give the claimant possession of the land; ODIO OMI DIIK, Statement of Truth OORIDOORIDGOUOHAORIOOOK that the facts stated in these particulars of claim are true. *1 am duly authorised by the claimant to sign this statement. signed s We date 9 December 2014 ROBDDRIOOTRIOTRONDOONIRAOURDOOIANDOROKDONAAN (Claimant's solicitor) ‘delete as appropriate Full name James Edward Roger Fownes Name of claimant's solicitor’s firm SSH Martineau LLP position or office held Senior Associate (if signing on behaif of firm or company) 422228 Index of Registered tle: Title Land Freehold/Leasehold Number 4. | WK27444 | The University of Warwick, Gibbet Hill | Freehold | Road, Coventry, CV4 7EQ | 2. | WK33876 | Cryfield Old Farmhouse, Gibbet Hill Freehold | Road, Coventry. CV4 7A) WK377703 | Land lying to the west of Gibbet Hill Freehold . Road, Warwick { : Wk411819 | The Lakeside Residencies, University Freehold | of Warwick, Gibbet Hill Road, Coventry t = 7 5. | wk323864 | Block 1, 2 and 3, Cryfield Cottages, Freehold | on the west side of Gibbet Hill Road, Stoneleigh 6. | wo246619 | The Cottage, Gibbet Hill Road, Cva Leasehold 7A) | wmo47743 | The New Varsity, Gibbet Hill Road, Freehold Coventry, CV4 7A) I 8. | WM563073 | National Grid House, Kirby Corner Leasehold Road, Coventry, CV4 8Y} wM68222 | Land lying to the east of Gibbet Hill Freehold Road 40, | WM731713 | The Medical School, The University of Freehold Warwick, CV4 7AL 11. | wK390478 | Warwick Business School, The Freehold University of Warwick, Scarman Road, Warwick 12, | wK402833 | Land and buildings at Warwick Freehold | Business School. Phase IL, Warwick l | com - 422223 - 1 Appi cation notice Inthe High Court of Justice Chancery Division Birmingham District Regisry Fp in completing tis form please read the + notes for guidance form N244Notes, | Stabe ne. KR 2OBAS3 Fee Account no ‘Warrant no. | (if applicable) I Claimant's name |The University of Warwick {including ref) TEE /MIE/WN7572377 Defendant's name| (1) Hattie Craig (2) Callum {including ret) Cant (3) Persons Unknown (including Students of The University of Warwick) entering or remaining upon the land and buildings of the campus of The University of Warwick) Coventry for the purpose ‘of protest action without the consent of The University of Warwick Date 8 Decemby 1. Whats your name or, if you are a legal representative, the name of your fir? SGH Hartineau LLP 2 Aeyoue — [] Claimant [oetendant (7) Legal Rb Other (please specify) If you are a legal representative whom do you represent? The Claimant 3. What order are you asking the court to make and why’? The Claimant is seeking, the form of the attached Order, that 1. Pursuant to Civil Procedure Rule 6.1(b) and/or 6.15 that service of the Claim form shall be deemed served at the time copies of this Order are affixed to (a) affixing copies to the doors and entrance of The Rootes Social Building, The University of Warwick, Coventry CV4 8UW; and (b) prominent places on the Claimant's property at The University of Warwick, Coventry, Warwick Pursuant to Civil Procedure Rule 6.1(b) and/or 6.97 that service of (a) this order; (b) the Particulars of Claim; The Application Notice for the Order dated 9 December 2014 and draft order; (d) The witness statement dated 9 December 2014 of Kenneth Sloan; 'N244 Aoplcaion notice (05.14) 1 ‘© Crown copyright 2014 Laserform International 8/14 az222t le) The Certificate of Reasons for bringing the Possession Claim in the High Court; and fA hearing for 12 December 2014 shall be deemed served at the time copies of this Order are affixed to:- (1) affixing copies to the doors and ent nce of The Rootes Social Building, The University of Warwick, Coventry CV4 8UW 11) promi nt places on the Claimant's property at The University of Warwick, Coventry CV BUW and such step shall be good service provided that: December 2014; and (i) that it iS verified by the completion of a certificate of service 3 the Court abridges the time for service otherwise required by Civil Procedure | (4) there is service in the manner or manners set out above by 7 pm on 9 | | Rule 55.5(2) for the hearing of the possession claim. 4, Have you attached a draft of the order you are applying for? v] Yes No 5. How do you want to have this application dealt with? Y| ata hearing ‘without a hearing at a telephone hearing 6. How long do you think the hearing will last? Hours 30 | Minutes Is this time estimate agreed by all parties? Yes ¥)No 7. Give details of any fixed trial date or period 8. What level of Judge does your hearing need? High Court Judge or Section 9 9. Who should be served with this application? Defendants 9a. Please give the service address, (other than details of the claimant or defendant) of any party named in question 9. 10. What information will you be relying on, in support of your application? 7] the attached witness statement the statement of case the evidence set out in the box below 422228 | | | | | | Statement of Truth ‘The applicant believes that the facts stated in this section (and any continuation sheets) are true. Signed Applicant's Solicitor Full name Dated Name of applicant's legal representative's firm Position or office held [i signing on behalf of fr or company) 11. Signature and address details Sones Os "AO Dated 9 December 2014 Applicant's Solicitor Position or office held Senior Associate (if signing on behalf of firm or company) (for and_on beha: of SGH Martineau LLP) Applicant's address to which documents about this application should be sent SCH Martineau LLP No. 1 Colmore Square Birmingham Posteode [B[@] [e]a[A applicable Phone no. [0870 763 1000 Fax no. - 0870 763 1001 DX no. 721030 Birmingham 43 Retro, | JEF/Use/WA7572977 (COM 422225) Eales [sn 42222 IN THE HIGH COURT OF JUSTICE CLAIM NO CHANCERY DIVISION BIRMINGHAM DISTRICT REGISTRY ‘THE UNIVERSITY OF WARWICK Claimant vand- (1) HATTIE CRAIG (2) CALLUM CANT (3) PERSONS UNKNOWN (INCLUDING STUDENTS OF THE UNIVERSITY OF WARWICK) ENTERING OR REMAINING UPON THE LAND AND BUILDINGS OF THE CAMPUS OF THE UNIVERSITY OF WARWICK, COVENTRY FOR THE PURPOSE OF PROTEST ACTION WITHOUT THE CONSENT OF THE UNIVERSITY OF WARWICK Defendants ORDER BEFORE HIS HONOUR JUDGE COOKE sitting in Birmingham on 9 December 2014 as a Judge of the High Court UPON HEARING Counsel for the Claimant AND UPON READING ‘The documents on the court file being () ‘The Claim Form with Particulars of Claim; () ‘The Application Notice for the Order dated 9 December 2014; © ‘The witness statement of Kenneth Sloan dated 9 December 2014. 2 The Certificate of Reasons for bringing the Possession Claim in the High Court IT IS ORDERED that: ‘The Claimant is seeking, In the form of the attached Order, that 1. Pursuant to Civil Procedure Rule 6.1(b) and/or 6.15 that service of the Claim form shall be deemed served at the time copies of this Order are affixed to (2) affixing copies to the doors and entrance of The Rootes Social Building, The University of Warwick, Coventry Cv4 8UW; and (©) prominent places on the Claimant's property at The University of Warwick, Coventry, Warwick COM -422228-1 Coventry, Warwick 2. Pursuant to Civil Procedure Rule 6.4(b) and/or 6.27 that service of (2) this Order; (b) the Particulars of Claim; (©The Application Notice for the Order dated 9 December 2014 and draft order; (d) The witness statement dated 9 December 2014 of Kenneth Sloan; (e) The Certificate of Reasons for bringing the Possession Claim in the High Court; and (f) A Nlotice of hearing for 12 December 2014 shall be deemed served at the time copies of this Order are affixed te (2) __ affixing copies to the doors and entrance of The Rootes Social Building, The University of Warwick, Coventry CV4 8UW (11) prominent places on the Claimant's property at The University of Warwick, Coventry CV4 BUW and such step shat! be good service provided that: ()__ there is service in the manner or manners set out above by 7 pm on 9 December 2014; and (il) that itis verified by the completion of a certificate of service. 3. thie Court abridges the time for service otherwise required by Civil Procedure Rule 55.5(2) for the hearing of the possession claim. Dated 9 December 2014 COM - 422228-1 App’ :ation notice inthe High Court of Justice Chancery Division Birmingham District Regisry Fc pin completing this form please read the - notes for guidance form N244Notes. Giaimn no. R200 S37 Fee Account no. Warrant ne. ( appeable) Claimant's name |The University of Warwick (ating ret) bE 656 /WK7572377 Defendant's name| (i; Hattie Craig (2) Callum (indving tet) [Cant (3) Persons Unknown (including Students of The University of Warwick) Jentering and remaining upon the land and buildings of the campus of The University of Warwick) Coventry for the purpose ‘of protest action without the consent of The University of Warwick Date 9 Decent What is your name or, if you are a legal representative, the name of your firm? SGH Martineau LLP Areyoua —— [_] Claimant (2) Defendant Other (please specity) If you are a legal representative whom do you represent? 3. What order are you asking the court to make and why? The Claimant is seeking an injunction order in the form of the attached Order because the Defendant is already trespassing on the Claimant's University campus land (as set out in the Order) as part of a protest and there is a substential risk that further protestors (some of whose identities are currently unknown) will trespass upon the Claimant's campus land (as set out in the Order) in order to participate in such a protest 4, Have you attached a draft ofthe order you are applying for? Y] Yes No 5, How do you want to have this application dealt wth? Z] at a hearing without a hearing [_]ata telephone hearing 6. How long do you think the hearing will ast? 1 | Hours 30 | Minutes Is this time estimate agreed by al parties? Yes ZNo 7. Give details of any fixed trial date or petiod ae Alcon rac (6514) 7 © Grom capran 2076 Laseror atonal 4 42223: 9a 10, What level of Judge does your hearing need? High Court Judge © should be served with this application? Defendants Please give the service address, (other than details of the claimant or defendant) of any party named in question 9. What information will you be relying on, in support of your application? [7 the attached witness statement [Li tne statement of case [[] the evidence set out in the box below Ifnecessary, please continue on a separate sheet, Statement of Truth | The applicant believes that the facts siated in this section (and any continuation sheets) are true. | Sioned Dated Applicant's Solicitor Fullname __ Name of applicant's legal representative's firm Position or office held (if signing on behalf of firm or company) " Signature and address details signed SJ > hen, —— . Dated 9 Decenber 2014 Applicant's Solicitor Postion or offee held Senior Associate Solicitor (for and on behalf of SGH Mareineau LLP) (ifsigning on behalf of frm or company) 42223: Applicant's address to which documents about this application should be sent H Martineau LLP applicable he eae Phone no. | 0870 763 1000 : : Faxno. [0870 763 1001, DXno, [721090 Birmingham 43 Posteode [B [4] [S]ala Refno. | JEF/msE/uN4002620 (CDM 408103) 422235 IN THE HIGH COURT OF JUSTICE CLAIM NO CHANCERY DIVISION BIRMINGHAM DISTRICT REGISTRY BEFORE HIS HONOUR JUDGE COOKE sitting In Birmingham on 12 December 2014 as the designated Chancery Judge of the High Court under section 9 Senior Courts Act 1981 ‘THE UNIVERSITY OF WARWICK Claimant -and- (2) HATTIE CRAIG (2) CALLUM CANT (3) PERSONS UNKNOWN (INCLUDING STUDENTS OF THE UNIVERSITY OF WARWICK) ENTERING OR REMAINING UPON THE LAND AND BUILDINGS OF THE CAMPUS OF THE UNIVERSITY OF WARWICK, COVENTRY CV4 SUW FOR THE PURPOSE OF PROTEST ACTION WITHOUT THE CONSENT OF THE UNIVERSITY OF WARWICK Defendants ORDER IMPORTANT:- PENAL NOTICE (2) This Order prohibits you from doing and obliges you to do the acts set out in this Order. You should read it all carefully. You are advised to consult a Solicitor as soon as possible. You have a right to ask the Court to vary or discharge this Order. (2) If you disobey this Order you may be found guilty of Contempt of Court and any of you may be sent to prison or fined. AND UPON HEARING Counsel for the Claimant: DM - 422234 -1 AND UPON HEARING Counsel for the Claimant AND UPON READING 1 The documents on the court file being @ The Claim Form with Particulars of Claim; () ‘The Application Notice dated 9 December 2014 and Order dated 9 December 2014 for abridgement of time for service; © The Application Notice dated 9 December 2014 with draft Order for an Injunction; (4) The witness statement and exhibits dated 9 December 2014 of Kenneth Sloan 2 ‘The Certificate of Reasons for bringing the Possession Claim in the High Court IT IS ORDERED that: POSSESSION 1. The Defendants do forthwith give possession of the land and buildings of the campus of The University of Warwick, Coventry CV4 8UW as shown edged red, but excluding those land and bulldings edged and hatched green. INJUNCTION 2. The Defendants shall not, without the prior written consent of the Claimant enter or remain upon land comprising the Claimant's campus and bulldings at The University of Warwick as shown edged in red, but excluding those land and buildings edged and hatched green, on Plan A annexed hereto for the purpose of any occupational protest action. SERVICE 3. Pursuant to Rule 6.27, service of this Order shall be effected by i. affixing copies to a post outside the Rootes Social Building, University of Warwick; |i. affixing copies to the doors of and gates to the Rootes Building, University ‘of Warwick; iii, posting further copies through the letterbox (if appropriate) com = 4222341 4, The said documents shall be deemed to be served on the date of such affixation at the Land, such date to be verified by the completion of a certificate of service. 5. The costs be the Claimant's costs to be summarily assessed (alternatively by detailed assessment) to be payable by the first three Defendants INTERPRETATION OF THIS ORDER In this Order the words *he” “him” or “his” include “she” or “her” and “it” or “ts”. 8 Where there are two or more Defendants then (uniess the contrary appears) (2) References to “the Defendant” mean both or all of them; (b) An Order requiring “the Defendant” to do or not to do anything requires each Defendant to do or not to do it; ‘THE EFFECT OF THIS ORDER A Defendant who is an Individual who is ordered not to do something must not do it himself or in any other way. He must not do It through others acting on his behalf or (on his Instructions or with his encouragement. 11. It Is a contempt of court for any person notified of this order knowingly to assist in or permit a breach of this order. Any person doing so may be imprisoned fined or have their assets seized. COMMUNICATIONS WITH THE COURT 12. All communications to the Court about this Order should be sent to Birmingham Civil Justice Centre, Priory Courts, 33 Bull Street, Birmingham B4 6DS quoting the case number. The office 1s open between 10 am and 4.30 pm Monday to Friday. The telephone number is 0121 681 4441 Dated 12 December 2014 cpm - 4222341 Defence form lim the BIGH COURT OF gusTICE Fe CHANCERY DIVISION BIRMINGHAM DISTRICT REGISTRY ai Hl ‘The University of warwick \ Claimant k 7 (1) Hattie Craig (2) Callum cant (3) / Persons Unknown (including students of The University of Warwick) entering or remaining upon the land and buildings of the campus of the University of Warwick, Coventry for the purpose of protest action without the consent of the University of Warwick Defendant(s); 1 dispute the claimant's claim because: | Statement of Truth *({ believe)(The defendant(s) believe(s)) that the facts stated in this defence form (and any continuation sheets) are true, Lam duly authorised by the defendant(s) to sign this reply form. signed : date *(Defendant(s))(Litigation friend (where the defendant is a child or a protected party))(Defendant's solicitor) | “delete as appropriate Defendant's date of birth [es as eae] Full name Name of defendant's solicitor's firm position or office held (if signing on behalf of frm or company) Defendant's or applicable defendant's solicitor's rr address to which et 0. documents should fax no. he sent. : — DX no. e-mail Pesteode Tel. no. NII Defence orm (1207) ‘ros copia 2007 Last ners 107 42224 CLAIM NO IN THE HIGH COURT OF JUSTICE CHANCERY DIVISION BIRMINGHAM DISTRICT REGISTRY ‘THE UNIVERSITY OF WARWICK Claimant -and- (2) HATTIE cRATG (2) CALLUM CANT (3) PERSONS UNKNOWN (INCLUDING STUDENTS OF THE UNIVERSITY OF WARWICK) ENTERING OR REMAINING UPON THE LAND AND BUILDINGS OF THE CAMPUS OF THE UNIVERSITY OF WARWICK, COVENTRY FOR THE PURPOSE OF PROTEST ACTION WITHOUT THE CONSENT OF THE UNIVERSITY OF WARWICK Defendants CERTIFICATE OF REASONS FOR BRINGING A POSSESSION CLAIM IN THE HIGH COURT 4 [am James Fownes, Senior Associate Solicitor of SGH Martineau LLP of No.1 Colmore ‘Square, Birmingham B4 6AA. I make this certificate in accordance with Part 55.3(2) of the Civil Procedure Rules to certify the Claimant’s reasons for starting this claim in the High Court, 2. ‘The Claimant is applying to the High Court for an injunction to restrain acts of trespass by the Defendants on the campus of the Claimant. 3 The application is urgent for the reasons stated in the Witness Statement of Kenneth Sloan dated 9 December 2014. In summary, there Is disruption to the proper functioning of the University and various staff and contractors have been injured as a result of the occupational ‘sit-in’ which constitutes a trespasses upon the land and buildings of the campus. It is important to the University to deal with this urgently iven the risks to property and the need to take enforcement action without delay (Le. instruct High Court enforcement). 4, It Is appropriate to Issue the possession claim in the same Court as the injunction application in order to avoid the duplication of costs and unnecessary use of resources in two different courts. ‘ep - 4202381 4, It is appropriate to Issue the possession claim in the same Court as the injunction application in order to avold the duplication of costs and unnecessary use of resources in two different courts. I believe the facts stated in this Statement are true. eel Senin Akec Eel Dated! 9 December 2014 Signed: cm 422235-1 1, Claimant 2. Ken fark Sloan aR ae 5. ood IN THE HIGH COURT OF sUSTICE cuaIM No: 208 a BIRMINGHAM DISTRICT REGISTRY FR 0M S31 CHANCERY DIVISION THE UNIVERSITY OF WARWICK Claimant and- (2) HATTIE CRAIG (2) CALLUM CANT. (3) PERSONS UNKNOWN (INCLUDING STUDENTS oF THE UNpERsT OE ENTERING OR REMAINING UPON THE BUILDING KNOWN a & BUILDING AT THE UNIVERSITY OF WARWICK FOR THE F PROTEST. ACTION (WITHOUT THE CONSENT OF THE UNIVE! oe eh SB Sion a WITNESS STATEMENT OF KEN MARK SLOAN, 1, Ken Mark Sloan of the University of Warwick, Coventry, CV4 8UW will state as follows: 1 1 am the Registrar and Chief Operating Officer of the University of Warwick ("the University”) and am authorised to make this Witness Statement on behalf of the University in support of the University’s application for an order for an injunction and Order for possession as set out in the Ciaim Form, Particulars of Claim and Application Notice herein dated 9 December 2014. (com - 422213 -1 2 Insofar as the facts and matters referred to herein are within my own knowledge, they are true and in so far as they not within my own direct knowledge they are true to the best of my information and belief, acquired in the course of acting in my capacity as the Registrar and Chief Operating Officer of the University. 3 1 exhibit hereto a bundle of copy documentation to which t shall refer in the course of the Witness Statement, marked "KS2”. ‘The University 4 ‘The University is a leading centre for teaching and research across a diverse range of subjects. The University has almost 24,000 students, with approximately 40% of whom are on postgraduate or research programmes. The University employs circa 5,000 staf 5. ‘The University is @ substantial orgonisetion and has an annual turnover of circa £460 milion, The Campus 6. ‘The University’s campus Is an extensive development in Coventry and ‘Warwickshire. T shall refer to this main campus throughout this Witness Statement as "the Campus” 7. ‘The University Is the registered proprietor of the Campus under Title Numbers WM27414 and WK33876, WK377703, WK411819, WK323864, WM246619, we947743, WM563073, WM68222, WM731713, WK390478, WK402033. A copy of the relevant titte plan, marked ‘Plan A’ is at page 1 of exhibit *KS1". The Campus comprises the land edged in red (save for the areas edged and hatched green). A true Official Copy of the University’s registered titles are exhibited to this Witness Statement marked pages 2 to 53 of exhibit *KS1", 8 ‘The Rootes Sociat Building is wholly owned by the University and no other person or organisation has any Interest In these premises. On the ground floor of the building, Costa Coffee has a lease for a coffee shop and this remains open, Further, the Campus property (including the Rootes Social Building) Is private land. ‘As such, only persons with the (express or implied) licence or consent of the University may enter or remain on the Campus. The Rootes Social Building is edged and hatched in blue on Plan A. However, this is a University-wide issue with forced entry occurring both at Senate House end the Rootes Social Building together with protests outside. com 42213 4 10. 44, 12, 23. 14, ‘The Rootes Social Bullding Is 2 multi-use/occupancy building which houses a dedicated learning space for students (which Includes a major technology sulte calied Learning Grid Rootes), a bar and restaurant for members of the University community and visitors along with the University's largest flat floor meeting and ‘exhibition factty which is the subject of the current occupation. ‘The Students at the Campus ‘The University places a high value on providing its students with e fulfiling ‘education In their chosen discipline. There are a wide range of activities on the Campus end the Campus environment is the focal point for the lives of students attending the University. The University therefore seeks to ensure that its students hhave the right environment on the Campus to enable them to settle in and study effectively in a safe environment. This Is reflected in the University’s Values. A copy of the University’s Values is at page 54 of exhibit “KS1". One of the University’s Values Is "Community" as follows: “Ours is a lively university community that encourages and challenges ideas, promotes dignity, respect, health and well being and makes Warwick welcoming’ The University’s Values generally, and this Value In particular, are being contravened by recent unacceptable events on Campus as set out below. ‘The Occupation and Events Leading Up to the Occupation ‘Tuesday 2 December 2014 On Tuesday 2 December, it was reported by University staff at the Rootes Social Building that there was a successful attempt by a group of protestors to access the top floor of the building where the main flat floor meeting spaces are located Two members of University staff, who were clearing away from an event that hed recently concluded (in Chancellor's 2), were confronted by the sight of 20-25 individuals in the adjacent room (Chancellor's 1). The individuals were dressed in ark clothing, had thelr faces hidden by hats and scarves and were in the process of barricading exits. They had with them 0 focks, ropes and chains and were in the process of moving furniture. This activity was being undertaken in @ darkened room and it wes not apparent to staff what their purpose was. Staff inital thought that @ rabbery was in progress before realising that the Individual were students seeking to occupy the venue. Staff has reported being terrified upon (com = 922213 3 15, 16, 7, 18, 19, encountering this situation. Upon the arrival of members of the security team, itis Understood that the group vacated the building shortly thereafter, ‘The University’s 50" Anniversary dinner, attended by over 200 people, was concurrently taking place in the Arts Centre, It was initially thought that the attempt to occupy was intended to disrupt that event and that the wrong venue had been attempted. The University stepped up its security of the dinner but no

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