IN THE CENTRAL LONDON COUNTY COURT

Claim Number : 3YU14956

Between :-

MRS M SPEARMAN
Claimant
-v-

KYPROS KYPRIANOU
First Defndant
and

AXA INSURANCE UK PLC

Second Defendant

________________________________
WITNESS STATEMENT
OF MARINA ANASTASIA SPEARMAN
________________________________

I, Marina Anastasia Spearman will say :I was born on the 30th July 1985 in London and have lived in London and Hertfordshire all
my life. My present address is 45 Hawkshead Road, Potters Bar, Hertfordshire, EN6 1LF,
where I have lived for over three years.
I have held an Automatic UK driving licence since November 2010 and since that time I have
regularly owned and driven motor vehicles in and around the south east.
In 2012, I cannot remember exactly when, I was the driver of a C Class Mercedes in Potters
Bar, I cannot remember exactly where, when a car pulled out from the nearside street and
hit the front and nearside. The accident damaged my car and I was injured. I made a claim
for compensation and received 2,000.00, but I cannot remember the name of the insurance
company or the Solicitors who dealt with the claim.
I have been involved in another accident on the 24th March 2014 that is being dealt with by
Waring & Co., Solicitors. This claim is ongoing.
I make this statement about a road traffic accident I was involved in at about 12.30pm on
Saturday 13th April 2013 on Cattlegate Road, Crews Hill, Hertfordshire.

On that day I had driven from my home to my cousins home to collect them before visiting
the Crews Hill area where we were going to look at garden centres and pet shops. My
cousins liave at 30 Cuffley Hill, Geoffs Oak, Herts. I collected them and began to drive
towards Crews Hill. I was the driver, Zack Koulia was sitting in the front passenger seat and
Kristina Koulia was sitting in the rear nearside seat behind Zack. We were all wearing our
seat belts. It was on the way back from Crews Hill shopping trip that the accident happened
on Cattlegate Road at its junction with Coopers Lane on the left hand side.
I was driving my Audi Q5 four wheel drive vehicle registered number EN09 HLO which was
an automatic, petrol vehicle. I had owned it for about eight months. I was completely used
to the controls and instruments of the car and the car was in very good condition,
mechanically sound and fully taxed and tested and insured for use on the road.
On the day in question it was daylight, but cloudy, the visibility was good and the roads were
dry and in a good condition. The area is very rural with fields and open space on both sides
of the road. There are no footpaths on Cattlegate Road and it is governed by a 60mph
speed limit. I knew the route and the roads I drove on that day very well as I have driven
them before.
Cattlegate Road does have an up and down nature to it, sometimes it is difficult to see too
far into the distance and for that reason I was only driving at about 30mph.
I knew that Coopers Lane existed and that it was ahead of me, when the junction came into
view there was nothing there and I carried on as normal. As I drove almost level with the
mouth of the junction another car appeared out of the junction as it was turning right and
collided with my vehicle. Looking back it seems to me that the other car just pulled out at
speed without checking the traffic or giving way. I tried to brake and swerve to the right out
of the way, but could not avoid the collision between the front of the other car and the front
left hand wheel of my car.
On a scale of 1 to 10 where 1 is a minor and 10 is severe I would describe the impact as a 7.
I was thrown around inside the car and held in place by my seat belt.
The next thing that happened was that because I had forced into the wrong side of the road I
was then heading towards another vehicle which was travelling towards me from the
opposite direction. I then hit this second vehicle a glancing blow as we went past each other
and both cars received damage along their offsides. I would describe this second impact as
a 7 on the scale of 1 to 10.
After the second impact I was forced back onto my side of the road where I managed to stop
and see if everyone was ok.
After that I got out of my car to check with the other people. I saw that the vehicle that had
pulled out in front of me was a Peugeot 5008 registered number LR12 PLF. The driver was
alone in his vehicle and I would describe him as about mid thirties, unshaven, dark hair,
quite tall and I think he was possibly Greek because although I cannot speak the language I
thought I recognised some words he was saying. He could not speak English and all he
kept saying was sorry, sorry, sorry.
The other vehicle was a blue VW Golf and that was being driven by a small white lady who
spoke English with an Eastern European accent, she had a male passenger.
We all then swapped registration numbers, name and addresses as best we could and there
did not appear to be any reason to call the police.

My car was damaged and not driveable because one of the wheels was hanging off. I called
my husband who arrived within twenty minutes and he took over from me because I was in a
bit of a panic.
Eventually he took us all home and we left the Audi at the scene to be collected later.
My husband has dealt with the whole incident and reported the incident to an accident
claims company called Carriages Cross Hire at South Mimms and we have done everything
they asked us to do.
I understand the Audi was written off because it was beyond economical repair and I have
received 4,850.00 from Carriages Cross Hire which is the salvage value of my vehicle. I
have not received the balance of the write off value of my vehicle. I have since used that
money as a deposit for another car to replace the Audi.
After the accident I think that I ran on adrenaline for a while and although I felt pain at the
time it was not until the next day that I really started to suffer pain and discomfort in my neck,
back, write and knee. I started to take my own painkillers for a few days before seeing my
own GP on 18th April 2013, I think at High View Medical Centre, Southgate Road, Potters
Bar. The doctor prescribed me some more painkillers which I took for about a week.
During that time I suffered with pain and discomfort whenever I tried to lift or carry anything
and at the time I had a one year old daughter which made it very difficult for me. I had a
problem sleeping when it came to domestic chores and I found that cooking, cleaning,
hovering etc became very difficult for me.
In the May of 2013 my Solicitors arranged for a medical expert to visit me at home and
examine me. I have seen the report from that examination and agree with its contents. I
have not had any physiotherapy following the accident.
As far as I am concerned all of my injuries were caused by the accident and the accident
was the fault of the Peugeot driver.
I am willing to attend Court if required.
I have read the contents of this statement. I understand and agree with what is written and
believe that the facts in this statement are true.
Statement of Truth
I believe the facts stated in this witness statement are true.

Signed .

Dated ..
Ref : 573