"This statement relates to my involvement in five road traffic incidents which occurred during my employment with the Defendant/Part 20 Claimant, Tesco Stores Limited. The incidents occurred on:12 July 2019 . 3 August 201.5 October 2019 .6 December 2019 and2 January 2020 . I will give details about each of these crashes in this statement but at the outset I want to say each and every one of those incidents was staged by others and which I took part in. The collisions were set up so that compensation claims could be brought against Tesco Stores Limited and they were in no way genuine….. I cannot remember when I was originally approached and asked to take part in these incidents, but it must have been before July 2019. I was approached when I was driving out of the Greenford depot in one of the delivery vans one day. I was just about to start my delivery route for the day and as I was driving out of the depot I had to stop at the junction to wait for traffic to clear on the main road. I remember that there were temporary traffic lights on the main road so traffic was heavy, and I had to wait quite a long time to get out of the junction. Two men walked up to my van. From memory they were stood at the side of the road. I had never seen them before. They tapped on the van's window, which I then opened and they began speaking to me. I talked to them from the cab of my van. I believe one man was Eastern European, and the other was Asian. They were of a similar age, in their late 20s and dressed casually. I only know them as 'Nik' and 'Dee'. 'Nik' was the Eastern European man and 'Dee' was the Asian man. I remember that 'Dee' had a beard. I do not know their full names. They asked me if I wanted to make some money and explained that to do this, I would need to help them by crashing into other cars so they could bring claims. They told me that they would pay me£200 for each incident. I told them that I thought it was risky and that I was worried about getting caught. They told me that there were quite a few drivers that were doing it and there was limited risk. They said that they knew Tesco's procedures and that they would sort out the rest. I agreed to do it and gave them my telephone number so they could contact me. This conversation lasted around 5-10 minutes…. After this initial meeting, they would call me on my mobile and ask if I was working. If I was on shift, they would ask me to tell them, from my delivery sheet, where I would be at a certain time. It was usually towards the end of my shift, after my last delivery. I would tell them where I would be, and they would meet me at that location. 'Nik' and 'Dee' turned up at the scene, always in a black Mercedes. I don't know the registration number of this car. They would be accompanied by another vehicle which would be driven by somebody else. 'Nik' and 'Dee' would come over to the van to tell me how to crash into the other car and would then watch the 'incident' from the side of the road. After I hit the other car with the Tesco van I did not get out of the van. 'Nik' or 'Dee' would come to the window of the van and take one of the 'Collision report Forms' or 'Bump Cards' which the drivers are supposed to fill out in the event of an incident. They would walk over to the car that I hit and talk to the driver of that car through the window and take their details and write them on the Bump Card. I did not write any of the Bump Cards relating to any of the staged incidents. They were all written by 'Nik' and/or 'Dee' at the scene. 'Nik' and 'Dee' attended every staged incident that I was involved in. I would then report the crash to the Sopp and Sopp incident report line as normal and then return to the depot to report it to my manager and fill in an Incident Investigation Form."
"As I have said, this case is a paradigm one for the award of exemplary damages. As to the amount of such damages, as was stated by Arden LJ in Ramzan v Brookwide at [82], the sum must be principled and proportionate. As in that case, given the need to deter and punish the outrageous conduct and abusive behaviour in the present context, the principled basis is to make a punitive award. The respondents have chosen not to place before the court any evidence as to their means so that it is not appropriate to limit the amount of any award by reference to ability or inability to pay …. Given the seriousness of the conduct of the respondents and the need to deter them and others from engaging in this form of "cash for crash" fraud, which has become far too prevalent and which adversely affects all those in society who are policyholders who face increased insurance premiums, I consider that the appropriate award of exemplary damages is that each of the first, second and third respondents should be liable to pay£20,000 ."