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MR EDMUND RIPON
MR FICTITIOUS PERSON
PARTICULARS OF CLAIM
1. The Claimant claims damages for personal injury and associated losses incurred in an accident at Monte Cristo House, 98 Manchester Drive, Lanchester XX44 2PI (“the Fictitious Property”), on 3 May 2012.
2. The Defendant owns the Property, which is divided into four flats. The Defendant rents out the flats at the Property to various parties.
3. At all material times, the Claimant rented and occupied one of the flats (No. 3) at the Property from the Defendant under the terms of a lease.
4. On 3 May 2012, the Claimant was descending the central staircase at the Property when he slipped and fell down the stairs. The staircase lacked any handrail or other safeguard to either prevent users from falling or to enable them to arrest a fall before sustaining injury. The Defendant had removed the original handrail to allow easier access for furniture being installed or removed into the upstairs flats. The Claimant had previously requested that the Defendant replace the handrail, or in the alternative, that he install a removable handrail, but this had not happened.
5. The accident was caused by the negligence and or/breach of statutory duty of the Defendant.
PARTICULARS OF NEGLIGENCE
6. The Defendant was negligent in that he:
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