Court - what to put in statement of witness-non protection of deposit

[Rangers0508]

The details are:

There were 5 conseqeutive agreements :


First AST 11.12.17 to 10.06.18 (6 months)

Second AST 11.06.18 to 10.09.18 (3 months)

Third AST 11.09.18 to 10.03.19 (6 months)

Fourth AST 11.03.19 to 10.07.19 (4 months)

Fifth AST 11.07.19 to 16.11.19 (4 months)

I returned deposit to tenant

I cannot prove I protected the deposit.

So have to aim at limiting the claim - no win no fee lowest offer to accept is 4 x deposit plus costs.

I believe first agreement is time barred and so does he with this latest offer.

I believe there is only 1 breach and not multiple especially when some agreements were just 3 months long and 4 months long.

I am thinking of offering 3 x deposit but belive i need a string witness staement which is due by 17/7/24

I believe the case Howard Davies v Scott Case is a relevant case for defending multiple agreement breaches.

Dj referred to section 214 of the Housing Act 2004 which refers to “a penalty, a tenancy and a deposit” in the singular, and noted that the opportunity to clarify the point in the Deregulation Act amendments to Housing Act 2004, after Superstrike, had not been taken.

Could someone advise how I would word this in my witness statement please.