- 6 - A A B 2 of the Substituted Service Order. Please take appropriate steps to rectify the situation and confirm your client’s position in these proceedings forthwith.” C D On 29 June 2023, OTC replied. 15. E It is an important letter by which Ms Chow’s position on her status was made clear : F B C D E F (1) G (2) H Ms Chow did not need to show locus as she was not seeking leave to apply for judicial review; G there was a distinction in the Service Order between H “Defendants” (Service Order, [1]) and “anyone who opposes I the [Injunction]” ([2]), and that “persons opposing the application for [Injunction] J are not necessarily the Defendants”; K (3) Ms Chow “gave notice pursuant to [Service Order, [2]] as a person with intention to oppose the application for L [Injunction]” without admission that she was a Defendant; and M (4) N J K L M “The reference to “the intended Defendant” in paragraph 1 of our letter dated 26 June 2023 was a reference to Ms Chow’s status as an additional party to these proceedings other than O I N O the existing defendants”. P Q P 16. On 4 July 2023, Ms Chow filed her Grounds of Opposition in which she was referred to as the “Opposing Party”. R document addressed the issue of locus as follows : Q Paras 32 to 35 of that R S S T T U U V V

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