BUSINESS AND PROPERTY LIST
BETWEEN:
MR CHRISTOPHER TURNER
(Executor of the Estate of the late
MR KENNETH JAMES BRADSHAW)
Claimant
and
MRS JOAN YVONNE WATSON
Defendant
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SKELETON ARGUMENT ON BEHALF OF THE CLAIMANT
________________________________________________________
Introduction:
1. This is an application by the Claimant (‘C’) under CPR 24.2, for summary
judgment against the Defendant (‘D’) for delivery up of the three rings and
judgment for cash amounting to £805.73. Alternatively, C requests for an
interim order for delivery up of the three rings. A bundle has been lodged with
the Court for the hearing. Estimated reading time: 30 minutes.
Evidence:
2. In support of the application reference will be made to C’s witness statement
(‘WS/CT’) dated 15.02.23, together with the following exhibits:
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, (a) Particulars of Claim dated 03.02.23 (‘POC’, pg. 5).
(b) Defence dated 10.02.23 (pg. 9).
(c) Exhibit CT1: Patient Property Form dated 04.11.22 (pg. 22).
(d) Exhibit CT2 Page 1: Letter C to D dated 02.12.22 (‘CT2/1’, pg. 24).
(e) Exhibit CT2 Page 2 and 3: Letter D to C dated 08.12.22 (‘CT2/2’, pg. 25).
(f) Exhibit CT2 Page 4: Letter from C to D dated 09.12.22 (‘CT2/4’, pg. 27).
(g) D’s witness statement dated 24.02.23 (‘WS/JYW’, pg. 28).
The Relevant Facts:
3. C is the executor of Kenneth James Bradshaw's estate. Mr Bradshaw left
most of his estate to the Marie Curie Cancer Care Trust in his final will. In
2016, Bradshaw became romantically involved with D.
4. When Bradshaw passed away, D assumed she was entitled to the house and
contents. C informed her that Mr Bradshaw's will left most of his property to
the Cancer Trust. D was angry and claimed she was entitled to something in
return for tolerating Mr Bradshaw's behaviour.
5. C discovered that Bradshaw's personal belongings, including three rings and
£805.73 in cash, were missing from the hospital. A Patient Property Form
confirmed that D had retrieved the items and cash by lying to the hospital staff
and claiming to be Bradshaw's cousin.
6. C confronted D, who confirmed having the items and cash but refused to
return them. Later, a jeweller in Hatton Gardens reported that a woman
matching D's description had come in with the three rings and asked for them
to be valued for sale.
7. C has permission to give the two men's rings to their intended recipients, as
money would not be an equivalent memento.
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