Hi, I really need help with understanding what I can include in a witness statement. Sorry this is a long read but I have attached the claimant's proof of evidence below. I need help with converting this proof of evidence into a witness statement but I am unsure on what parts to include in the witness statement as there are some things that I think would be irrelevant? Any help would be very much appreciated!

Proof of evidence:

Clive D Irwin of "The Cottage", Westwood Road, Christlethorpe, Guildshire GU89 3RW will say:

1. My wife, Maria, and I founded The Keyboard Partnership ("KP") ten years ago. During that time, we've always restored pianos but I'm proud that we've progressed from hand building small, basic upright pianos to baby grand pianos. We secured our first order for a concert size grand piano in 2017. We trade from the above address which is truly a cottage with roses around the front door.

2. In August 2018, Maria was approached by Mr and Mrs Tabalo of "The Old Rectory", Field Way, Castle Morpeth, Northumberland to build a concert grand piano. It was to be a birthday present for their son. He is a well-known concert pianist. I can't say that I have ever heard of him as I'm more into jazz than classical music, although I've been known to have Classic FM on the radio in the car on long journeys. We started work on the piano in September 2018 with delivery scheduled for May 2019.

3. The piano was completed and inspected by Mr and Mrs Tabalo at the end of April 2019. They were very pleased with it. They immediately paid the agreed fee of 124,976 for the piano. That only left transporting the piano to Mr and Mrs Tabalo's house and our agreement was that they would pay 10,000 for that on delivery.

4. The completed piano weighed 390 kilos. This was far heavier than any piano we had made before. We had agreed to deliver the piano in the week commencing 20 May 2019. So, I started looking for a suitable haulage company to make the three hundred or so miles trip. I contacted Road Haulage (Guildshire) Limited ("RH") and spoke to their Mr Patrick O'Connor, a Director, on 1 May 2019. He agreed to visit us and provide a quote.

5. On 4 May 2019, Mr O'Connor came to our premises. He asked me how we intended to pack the piano. I told him that we would be using a wooden container, similar to the type used for shipping heavy industrial machinery. The piano would be secured to the container by bolts. Mr O'Connor said that given the weight of the piano he would need to have a crane to lift it on and off the lorry. We agreed that KP would pack the piano in a container and that RH would transport it by lorry and crane to Mr and Mrs Tabalo's house on 25 May 2019. Mr O'Connor explained that it was vital that after the piano was loaded in the container the centre of gravity had to be identified so the load could be transported safely. He gave me a large red star shaped sticker for this. We agreed a fee of 7,980.

6. I purchased the container and set up a small team to pack the piano headed by our then general works manager, Andrew Bhogal. Neither Maria nor myself had anything to do with packing the piano. Andrew Bhogal left the firm in July 2019 to go travelling in Australia. I do not have any means of contacting him. Andrew Bhogal telephoned me on 23 May 2019 and said, "We've packed the piano in the crate and I've personally secured each of the four bolts into their washer securing mechanism. Our tests show that the piano will not move when in transit." I have printed off Andrew Bhogal's subsequent e-mail to me later that day confirming that the packing of the piano had been completed and this is Document B attached. When I saw Mr O'Connor on 21 May 2019 to review the final arrangements, I gave him a cheque for 7,980.

7. Mr O'Connor and his employees arrived at 6am on 25 May 2019. My staff had got the container out into the yard of our premises and a crane lifted it directly onto the back of a lorry. Mr O'Connor told me that another crane would be meeting us at Mr and Mrs Tabalo's house that evening. Mr O'Connor, his crane driver, Leonard Howarth, and I travelled in the lorry together.

8. We arrived at Mr and Mrs Tabalo's house at about 4.30pm. The crane was already there. As the driveway was too narrow for the lorry, the crane had to take the container up the driveway to the house. This meant manoeuvring round a sharp bend. Mr Howarth hooked the container up to the crane. He pulled away up the drive. Mr O'Connor took the footpath that led directly to the house but I followed the crane. It accelerated, and I saw the container start to swing. I was concerned. I had to run to try to catch up with the crane. By now it was starting to turn very quickly into the bend.

9. About half way round the bend the container toppled over and fell on its side. Fortunately, the connection between the container and the crane came free so that the crane righted itself. I immediately climbed up to the driver's cab. The driver, Leonard Howarth, looked shocked but unhurt. I got down and inspected the container and the piano. Both looked badly damaged. Mr O'Connor came over and after looking at the container he suggested that the piano was left for repair, but I insisted that it was taken back to our workshop for close inspection. The container was patched up, put back on the lorry and returned to us on 26 May 2019. My wife took a DVD recording and digital photographs of the container and the piano when they were returned to us so that we had a record of their condition. I did not want any argument with RH about that. I met our most senior piano restorer, Nigella Lake on 31 May 2019. She told me that she had come to the conclusion that the piano was beyond economic repair. When I told her that the crane driver had been Leonard Howarth she said, "Leonard's my stupid cousin. He always drives too fast.

10 I 'phoned Mr O'Connor on 31 May 2019. I told him that we had had to refund Mr and Mrs Tabalo in full and that we expected to be compensated by his company. I was shocked when he told me that the accident was my firm's fault. He claimed that his crane driver had been driving slowly and the container fell because it had been badly packed by us. I said that I wanted a full enquiry. He said he would co-operate insofar as his company's policies allowed. He confirmed this in a letter that he sent to me dated 4 June 2019, a copy is Document C attached. He did permit an expert that we instructed to inspect the crane, but when I telephoned Mr O'Connor on 20 July 2019 and told him what the expert had concluded, he refused to accept it. A copy of the expert's report is Document D attached.