I have updated my draft WS and Court Bundle which now includes a cover letter and an index to court bundle (as per the feedback in post #94), and also included the recent case on 3rd party rights which UPS won (as per the feedback in post #91). In the WS, i have explained that the ruling in the UPS case should not be applied to my case due to my points on the Defendant’s Insurance Requirement. The draft redacted WS and court bundle is attached below - please let me know if this is good