2.2 The User Evidence Forms identified a wide range of purposes for which the path had been used. These included exercising, walking dogs, cycling, pushing babies in prams, taking children on healthy walks, visiting Reynolds Park and the walled garden, posting letters (in Woolton Park), visiting Churches and graves (St Peter's and St Mary's RC), visiting friends, relatives, doctors (Quarry Street and Woolton Street), supermarkets (Sainsbury's and Tesco), and other shops, pubs and restaurants (in Woolton Village), and walking to bus stops (in Acrefield Road and Church Road) and schools (St Francis Xavier's, Bishop Martin and Woolton Primary).
2.3 The User Evidence Forms confirmed that the path had been open, in one form or another, ever since the 1960s. Prior to 1984, people could walk freely through the grounds of Highfield Hospital/the Royal Liverpool Babies Hospital, which in the 1960s was demolished to make way for the Council flats in Glenacres and a Children's Admissions Unit on the site of the present Woolton Park Close. Between 1984 and 2000, people could walk freely through the grounds of Acrefield Bank (on the site of the present Byron Court) and Glenacres. After 2000 - when Byron Court was built - this use continued.
2.4 At no time, from 1984 onwards, was there any suggestion that pedestrians and cyclists were not allowed to use the route to move between Woolton Park and Acrefield Road. There were no gates, either at the Woolton Park entrance to Acrefield Bank/Byron Court or at the Acrefield Road entrance to Glenacres. Bollards were inserted along the boundary between Byron Court and Glenacres, to prevent vehicular access, but these were collapsible to allow fire engines and ambulances to reach Glenacres from Woolton Park (the entrance from Acrefield Road involving an awkward bend). The only notices were 'Private Road' and 'No Through Road' signs at the Acrefield Road entrance. The former indicated, we believe, that Glenacres was an unadopted highway - maintained at the expense of LCC's Housing Committee rather than Highways Committee. The latter indicated that vehicles could not use the road to reach Woolton Park. There were also various signs prohibiting parking by non-residents and indicating that the bin store at Byron Court and the gardens at Glenacres were private areas.
3 Additional Evidence
3.1 Mike Chitty's own Form E (May 2016) was accompanied by 10 Annexes, consisting of maps and Council documents, etc., relating to the path. These are listed ('Annexes 1-10') at the end of this Statement of Case. Annex 1 was an Explanatory Note elaborating on some of the points made in Form E, Annexes 2-6 were Ordnance Survey maps of the site (1904-1999), Annexes 7-9 were Liverpool City Council documents relating to various planning applications (for Woolton Park Close, Byron Court and Glenacres respectively), and Annex 10 was the exchange of emails with John Evans already mentioned.