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Witness Statement of Stuart Sherbrooke Wortley Dated April 2021 Urbex Activity Since 21 September 2020
Party: Claimant Witness: SS Wortley Statement: First Exhibits: “SSW1” - “SSW7” Date: 27.04.21 Claim Number: IN THE HIGH COURT OF JUSTICE QUEEN’S BENCH DIVISION B E T W E E N (1) MULTIPLEX CONSTRUCTION EUROPE LIMITED (2) 30 GS NOMINEE 1 LIMITED (3) 30 GS NOMINEE 2 LIMITED Claimants and PERSONS UNKNOWN ENTERING IN OR REMAINING AT THE 30 GROSVENOR SQUARE CONSTRUCTION SITE WITHOUT THE CLAIMANTS’ PERMISSION Defendants ______________________________________ WITNESS STATEMENT OF STUART SHERBROOKE WORTLEY ________________________________________ I, STUART SHERBROOKE WORTLEY of One Wood Street, London, EC2V 7WS WILL SAY as follows:- 1. I am a partner of Eversheds Sutherland LLP, solicitors for the Claimants. 2. I make this witness statement in support of the Claimants’ application for an injunction to prevent the Defendants from trespassing on the 30 Grosvenor Square Construction Site (as defined in the Particulars of Claim). cam_1b\7357799\3 1 3. Where the facts referred to in this witness statement are within my own knowledge they are true; where the facts are not within my own knowledge, I believe them to be true and I have provided the source of my information. 4. I have read a copy of the witness statement of Martin Philip Wilshire. 5. In this witness statement, I provide the following evidence:- 5.1 in paragraphs 8-21, some recent videos and photographs of incidents of trespass uploaded to social media by urban explorers at construction sites in London; 5.2 in paragraphs 22-27, information concerning injunctions which my team has obtained -
Worthington Steel
Worthington Steel (Division of Worthington Industries) Historical Load Volume March - May, 2002 Carrier Weekly Estimated Truck ORIGIN DESTINATION DST Historical Load Volume Capacity BALTIMORE DECATUR AL 8 BALTIMORE BRISTOL CT 2 BALTIMORE FARMINGTON CT 1 BALTIMORE PLANTSVILLE CT 2 BALTIMORE SOUTHINGTON CT 7 BALTIMORE THOMASTON CT 5 BALTIMORE WATERBURY CT 6 BALTIMORE WATERTOWN CT 3 BALTIMORE WEST HAVEN CT 2 BALTIMORE WINSTED CT 2 BALTIMORE DOVER DE 1 BALTIMORE CARTERSVILLE GA 2 BALTIMORE COLUMBUS GA 1 BALTIMORE LAWRENCEVILL GA 1 BALTIMORE ROME GA 4 BALTIMORE ROYSTON GA 2 BALTIMORE ELK GROVE IL 3 BALTIMORE FRANKLIN IL 2 BALTIMORE FORT WAYNE IN 2 BALTIMORE GREENFIELD IN 0 BALTIMORE PORTER IN 1 BALTIMORE LOUISVILLE KY 2 BALTIMORE ATTLEBORO MA 3 BALTIMORE EAST MA 16 BALTIMORE FITCHBURG MA 1 BALTIMORE GARDNER MA 3 BALTIMORE S. ATTLEBORO MA 4 BALTIMORE SOUTH MA 4 BALTIMORE SOUTHWICK MA 2 BALTIMORE WORCESTER MA 26 BALTIMORE BALTIMORE MD 58 BALTIMORE COCKEYSVILLE MD 1 BALTIMORE CUMBERLAND MD 2 BALTIMORE HAMSTEAD MD 15 BALTIMORE JESSUP MD 29 BALTIMORE SEVERN MD 1 BALTIMORE SPARROWS MD 173 BALTIMORE TANEYTOWN MD 18 BALTIMORE WEST MD 35 BALTIMORE WESTMINISTER MD 6 BALTIMORE WESTMINSTER MD 56 BALTIMORE JACKSON MI 2 BALTIMORE KENTWOOD MI 5 BALTIMORE MONROE MI 3 BALTIMORE DENTON NC 2 Worthington Steel (Division of Worthington Industries) Historical Load Volume March - May, 2002 Carrier Weekly Estimated Truck ORIGIN DESTINATION DST Historical Load Volume Capacity BALTIMORE GASTONIA NC 23 BALTIMORE HAMILTON NC 4 BALTIMORE HIGH POINT NC 12 BALTIMORE NEWTON -
LEATHAMS, 227-255 ILDERTON ROAD South Bermondsey, London SE15 1NS
LEATHAMS, 227-255 ILDERTON ROAD South Bermondsey, London SE15 1NS Landmark Consented Mixed Use Development Opportunity View of consented scheme from Sharratt Street (Source: Maccreanor Lavington) Leathams, 227-255 Ilderton Road Southwark, London SE15 1NS 2 OPPORTUNITY SUMMARY DESCRIPTION • Landmark mixed use development The site is broadly rectangular in shape and extends to approximately 0.39 hectares (0.96) acres. It is currently occupied by opportunity in South Bermondsey within a three storey industrial warehouse (use class B1 and B8) and used as an industrial food storage and distribution centre (B8) with ancillary office space (B1). The internal area extends to approximately 2,529 sqm (27,222 sq ft) GIA and the two external London Borough of Southwark. loading yards extend to approximately 874 sqm (9,408 sq ft). • 0.39 hectare (0.96) acre site. The table below sets out the existing area schedule: • Existing site comprises an industrial EXISTING INDUSTRIAL SPACE GIA (SQM) GIA (SQ FT) warehouse building with two loading yards Storage (B8) 2,005 21,582 extending to approximately 3,403 (sqm) Ancillary Offices (B1) 523 5,630 36,630 sq ft GIA occupied by Leathams Total Workspace 2,529 27,222 Food Distribution business. Covered loading yard 730 7,858 • Located 800 metres (0.5 miles) south External Plant 144 1,550 of South Bermondsey Overground Total Site Area 3,403 36,630 station, providing regular services to Source: Design & Access Statement Maccreanor Lavington London Bridge (5 minutes), and the wider Underground Network (Northern Line and Jubilee line). • New Bermondsey Overground station scheduled for completion in 2025 located 400 metres to the east of site. -
D3 Contract Reference: QC53403 the Date of Tender for This ITT Is
7. Service Specification Route: D3 Contract Reference: QC53403 This Service Specification forms section 7 of the ITT and should be read in conjunction with the ITT document, Version 1 dated 29 September 2011. You are formally invited to tender for the provision of the bus service detailed below and in accordance with this Service Specification. Tenderers must ensure that a Compliant Tender is submitted and this will only be considered for evaluation if all parts of the Tender documents, as set out in section 11, have been received by the Corporation by the Date of Tender. The Tender must be fully completed in the required format, in accordance with the Instructions to Tenderers. A Compliant Tender must comply fully with the requirements of the Framework Agreement; adhere to the requirements of the Service Specification; and reflect the price of operating the Services with new vehicles. Terminus Points Bethnal Green, London Chest Hospital and Leamouth, Saffron Avenue Contract Basis Incentivised Commencement Date 17th September 2016 Vehicle Type 55 capacity, dual door, single deck, minimum 10.2m long Current Maximum Approved 10.2 metres long and 2.44 metres wide Dimensions New Vehicles Mandatory Yes Hybrid Price Required Yes Sponsored Route No Advertising Rights Operator Minimum Performance Standard Average Excess Wait Time - No more than 1.10 minutes Extension Threshold Average Excess Wait Time Threshold – 1.00 minutes Minimum Operated Mileage No less than 98.00% Standard The Date of Tender for this ITT is: nd No later than 12 Noon on Monday 2 November 2015 Tenderers should refer to section 3 of Part A for the Service Specification Explanatory Notes and Appendix B of section 5 for the Example Service Specification of the ITT document. -
Buses from Manor Park
Buses from Manor Park N86 continues to Harold Hill Gallows Corner Leytonstone Walthamstow Leyton Whipps Cross Whipps Cross Green Man Romford Central Bakers Arms Roundabout Hospital Leytonstone Roundabout Wanstead Romford 86 101 WANSTEAD Market Chadwell Heath High Road Blake Hall Road Blake Hall Crescent Goodmayes South Grove LEYTONSTONE Tesco St. James Street Aldersbrook Road ROMFORD Queenswood Gardens Seven Kings WALTHAMSTOW Aldersbrook Road Ilford High Road Walthamstow New Road W19 Park Road Argall Avenue Industrial Area Ilford High Road Aldersbrook Road Aldborough Road South During late evenings, Route W19 Dover Road terminates at St. James Street Aldersbrook Road Ilford County Court (South Grove), and does not serve Empress Avenue Ilford High Road Argall Avenue Industrial Area. St. Peter and St. Paul Church Aldersbrook Road Merlin Road Aldersbrook Road Wanstead Park Avenue ILFORD 25 425 W19 N25 Forest Drive Ilford City of London Cemetery Hainault Street 104 Forest Drive Ilford Manor Park Capel Road Redbridge Central Library Gladding Road Chapel Road/Winston Way Clements Lane Ilford D ITTA ROA WH Romford Road 425 Manor Park [ North Circular Road Clapton Romford Road Kenninghall Road Little Ilford Lane Z CARLYLE ROAD S Romford Road T The yellow tinted area includes every A Seventh Avenue T I Clapton Pond bus stop up to about one-and-a-half O N Romford Road MANOR PA miles from Manor Park. Main stops are D A Rabbits Road O c R M R shown in the white area outside. RHA O DU A Romford Road D First Avenue Homerton Hospital ALBANY ROAD CARLTON -
London, a World-Class City an Introduction to the Berkeley Group
LONDON, A WORLD-CLASS CITY AN INTRODUCTION TO THE BERKELEY GROUP Our ambition on every site is to create a beautiful, successful place. TONY PIDGLEY, CBE CHAIRMAN, THE BERKELEY GROUP 2 LONDON, A WORLD-CLASS CITY London is an extraordinary city, a magnet for people I believe it’s the talent of our architects and the and a hub of creativity and enterprise. Its architecture clients who commission them that keeps London and public spaces play a huge part in this appeal. fresh. Together they continually create places that They define the ‘picture postcard’ view that makes flex to the changing needs of our workforce, our London such a big draw for visitors. education, and our lifestyles. Yet it is the city’s ability to refresh and renew itself, The best new development has a great sense of respect blending contemporary buildings and public realm for London’s neighbourhoods. Despite all the pressures with the historic fabric, that is so intrinsic to its that come with growth, it recognizes that we are drawn success. International headquarters sit alongside to beautiful, sociable spaces. Places that feel authentic Elizabethan pubs and modern homes. You find arts and truly designed for people. venues forged from heritage buildings to make Today, neighbourhoods throughout London are set space for our contemporary creative spirit. to change, driven by the urgency of providing more Above all, London remains a collection of villages. homes for everyone within a finite footprint. The quality Neighbourhood shops and restaurants, local parks and of architecture and new development always matters. attractions, all produce a global world city and yet still But perhaps now more than ever, it seems to me feel intimate, local and familiar at the same time. -
Cultural Infrastructure Around the Queen Elizabeth Olympic Park
URBAN Cultural infrastructure around the Queen Elizabeth Olympic Park: mapping survey and report 1 LAB Clare Melhuish and Ben Campkin UCL Urban Laboratory Published in November 2017 Dr Clare Melhuish is a Senior Research Associate in the UCL Urban Laboratory and ‘Curating the City’ cluster lead at the UCL-University of Gothenburg Centre for Critical Heritage Studies. [email protected] Dr Ben Campkin is Director of the UCL Urban Laboratory and Senior Lecturer in Architectural History and Theory at the Bartlett School of Architecture. [email protected] UCL Urban Laboratory Gordon House, 29 Gordon Square, London WC1H 0PP www.ucl.ac.uk/urbanlab @UCLurbanlab [email protected] Key to cover images (clockwise from top left): demolition and reconstruction under way in Hackney Wick; parents and children leave the Discover Story Centre; view towards the Olympic Park and the International Quarter from House Mill; bar/café area at Stratford Circus; advertising for Stratford High Street regeneration Y UMMAR S E V This report identifies and presents existing and new data on cultural infrastructure in the environs of UCL East. It is intended to inform the ECUTI continuing development of the UCL East vision and to provide a baseline EX for monitoring the future impact of UCL East on existing cultural resources around the Olympic Park. It is also in line with new Mayoral and GLA initiatives to map effectively and protect London’s cultural infrastructure, as one of the city’s most important assets. We hope that the findings will be useful to all the organisations involved in the Cultural and Education District being developed in the Olympic Park as part of the regeneration of the wider area. -
Opportunity and Intensification Areas – 2009 Compared with 2008 London Plan
Opportunity and Intensification Areas – 2009 compared with 2008 London Plan Opportunity Areas – Policy Comparison The policies for the Opportunity and Intensification Areas are broadly similar for both the 2008 and 2009 London Plans. The differences are as follows: In the 2008 plan the areas are structured and broken down into the relevant sub-regional areas and form part of sub-regional policy, whereas in the updated plan there is a single table provided which covers all of the areas. The 2009 London Plan omits references to, “deliver good design, including public realm, open space and where appropriate, tall buildings.” In the 2008 Plan authorities should “seek to exceed” minimum housing targets for relevant sites whereas the 2009 Plan refers to “optimizing density” and “contributing to meeting the minimum guidelines”. This change of approach may account for some of the alterations in housing projections for some of the sites, both upwards and downwards. Map of Opportunity and Intensification Areas – 2009 London Plan Map of Opportunity and Intensification Areas – 2008 London Plan Comparison of Targets for Employment and Housing in Intensification Areas, 2008 versus 2009 London Plan Area 2008 London Plan 2009 London Plan Change Housing Housing Minimum Minimum Homes 2001 - 2026 Canada Water/Surrey Quays 2000 2500 +500 Dalston N/A 1700 +1700 Farringdon/Smithfield 100 1000 +900 Haringey Heartlands/Wood Green 1700 1000 -700 Harrow and Wealdstone N/A 1500 +1500 Holborn 200 200 0 Kidbrooke 2400 4400 +2000 Mill Hill East 3500 2100 -1400 -
21,134 Sq Ft
21,134 SQ FT RARE URBAN WAREHOUSE UNIT UNDERGOING FULL REFURBISHMENT UNIT 4 AVAILABLE TO OCCUPY JUNE 2021 IN PRIME LONDON LOCATION SEGRO.com/ParkCanningTown WELL-PLACED FOR ACCESS TO PORTS CITY OF LONDON CANARY WHARF Unit 4 at SEGRO Park Canning Town provides 21,134 sq ft (1,963 sq m) of A12/A102 rare urban warehouse space in one of London’s most premium and well- connected city logistics parks. A406 NORTH CIRCULAR RD Here’s why a variety of businesses have already set up shop and called SEGRO Park Canning Town home: UNIT 4 A13 An enviable location in the heart Within walking distance of three Zone A406 NORTH CIRCULAR RD and bustle of East London 2/3 tube stations, making it an ideal location for workers on the estate A key location for London centric M25 J30 customers, SEGRO Park Canning With convenient links to London Town’s proximity to Canary Wharf Gateway and Tilbury Port, SEGRO Park and beyond makes it ideal for serving Canning Town provides direct access CANNING TOWN STATION a London market to the city’s large shipping network. STAR LANE STATION CLOSE PROXIMITY TO THE CITY IN THE HEART OF EAST LONDON BOREHAMWOOD ENFIELD WATFORD BARNET Unit 4 is undergoing a complete M1 A1 STAPLEFORD M11 ABBOTTS 4 refurbishment which will enhance A10 M25 2 NORTHWOOD EDGWARE employee wellbeing, exceed sustainability WOODFORD F U LLY standards and introduce new tech REFURBISHED 4 HARROW A12 innovations and solutions to create 1 A1 ROMFORD 1 a more holistic working environment. WEMBLEY HOLLOWAY STRATFORD A40 DAGENHAM A10 BARKING HAYES GREENFORD A13 -
Key to Maps for Details in Central London See Overleaf
S 1 N B C 712.724 M S 2 O 9 Maldon Manor Station, The Manor Drive, Worcester Park, Dorchester Road, North Cheam, London Road, Windsor Avenue, H A C 242.C1.C2 M H 310.311 W1† 614 S 298 308.312 610 66.103.175 D 9 757 to D NE R R 2 E Cuffley 381 3 R E R A A 8 N LEY 4 1 A 5 .39 FF H U . 364 5.248 . A L N 12 A CU IL D 1 T A E P C1.C3.C4 6 621 N 615 A 3 A 380.880 L 191 W8 W10 247.294.296 O 8 - * Luton Airport E Cranborne Road . L T H 8 Stayton Road, Sutton, Cedar Road, Langley Park Road, Lind Road, Westmead Road, Carshalton, Carshalton Beeches, D R 2 9 O 1 R Breach Barns A R D Colney D * L T N 2 84 N C1 K B81 Y . O 2 648.N15 4 N S3 R 6 TI 242 I 8 E . E 0 84.302 A 365.375.575 S . A 797 D *T C T 2 S S C1 W9 O O L M B 298 B Industrial 3 RD C 382 9 . E N 7 6 G Y R . 8 CH 880 G * S S 1 T I U Street E . R R 242 211.212† 6 4 8 602 A U O R C Belmont, Royal Marsden Hospital, Sutton Hospital (Mon-Sat except evenings). Quality Line M O O O 4 398 H R 169 R T H S Shenleybury B 0 E 242 F . -
Baltimore Tower
BALTIMORE TOWER CROSSHARBOUR LONDON E14 BALTIMORE TOWER An iconic new landmark for luxury living creating a new focus on Canary Wharf’s world famous skyline A JOINT DEVELOPMENT BY BALTIMORE TOWER Canary Wharf - a track record second to none BALTIMORE TOWER Canary Wharf is the hub of one of the most dynamic transport infrastructures in the world Residents at Baltimore Tower will connect within 2 minutes walk at Crossharbour connect from Crossharbour THE DLR JUBILEE LINE MAINLINE CROSSRAIL CABLE CAR THAMES RIVER BUS SOUTH QUAY HERON QUAYS CUTTY SARK CANARY WHARF This highly automated network London’s most advanced London Bridge handles over This new super highway across The new Emirates Airline links Canary Wharf south Canary Wharf central Greenwich and UNESCO Canary commerce, DLR, links the Capital’s financial tube line and service 54 million passengers a year the Capital will have an London’s largest entertainment and Plaza and shopping World Heritage Jubilee Line and Crossrail centres, Royal Greenwich and connects at Canary Wharf for with mainline and Thameslink interchange at Canary Wharf, venues - crossing the river in London City Airport in minutes. direct travel to Westminster services departing every 3 significantly cutting journey just 5 minutes with cars running and The West End. minutes. It is the fourth busiest times when operational from every 30 seconds. hub in the UK. 2017. Liverpool The Barbican Street Aldgate Canning Town Custom MINUTE MINUTES MINUTES MINUTES Limehouse 1 3 5 6 St Paul’s Cathedral House Fenchurch Tower Shadwell -
The Environmental Statement
The Environmental Statement The Environmental Statement and this Non-Technical Summary have been prepared by Environmental Resources Management (ERM), on behalf of DLRL. ERM is an independent environmental consultancy with extensive experience of undertaking Environmental Impact Assessments of transport infrastructure schemes. Copies of the Environmental Statement are available for inspection at the following locations: Docklands Light Railway Ltd Canning Town Library PO Box 154, Castor Lane, Poplar, Barking Road, Canning Town, London E14 0DX London E16 4HQ (Opening Hours: 9.00am-5.00pm Mondays to Fridays) (Opening Hours: Monday 9.30am-5.30pm, Tuesday 9.30am- 5.30pm, Wednesday Closed, Thursday 1.00-8.00pm, Friday London Borough of Newham 9.30am-5.30pm, Saturday 9.30am-5.30pm, Sunday Closed) Environmental Department, 25 Nelson Street, East Ham, London E6 2RP Custom House Library (Opening Hours: 9.00am-5.00pm Mondays to Fridays) Prince Regent Lane, Custom House, London E16 3JJ Bircham Dyson Bell (Opening Hours: Monday 9.30am-5.30pm, Tuesday 9.30am- Solicitors and Parliamentary Agents, 5.30pm, Wednesday Closed, Thursday 1.00-8.00pm, Friday 50 Broadway, Westminster, London SW1H 0BL Closed, Saturday 9.30am-5.30pm, Sunday Closed) (Opening Hours: 9.30am-5.30pm Mondays to Fridays) North Woolwich Library Hackney Central Library Storey School, Woodman Street¸ Technology and Learning Centre, North Woolwich, London E16 2LS 1 Reading Lane, London E8 1GQ (Opening Hours: Monday 9.30am-1.30pm and 2.30pm-5.30pm, (Opening Hours: Monday 9.00am-8.00pm, Tuesday