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Hello, this is Jim and welcome back to JustAnswer. The statement reads well and contains everything you need in my view - it needs to be in numbered paragraphs and there are typos at the top which need to be addressed. I would also change the title to "Witness Statement of the Claimant in support of application dated (date)". You may want to add in a draft order too - e.g.
1. unless the defendant complies with the Part 18 request by 4 pm on (14 days), the defence is struck out.
2. The Defendant do pay the claimant's application costs of £..... by 4 pm on (14 days).
If you see the attached - it has a draft order which you can use though the wording should be as I have set out earlier.
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