IMPORTANT: Please make sure your posts do not contain any personally identifiable information (both your own and that of others). When uploading images, please take care that you have redacted all personal information including QR codes, number plates and reference numbers.
At Small Claims stage - PCM and Gladstones
Comments
-
Thank you Coupon-mad.
Yes I intend hand deliver a lever arch file with a contents page and WS and appendices all nicely numbered and hopefully easy to follow.
On my last pint of confusion - do I need to send a full copy of everything to Gladstones as well? From your answer on the postage, I assume I do?0 -
Yes you must. But not tons of attachments on a single email, and post it too (with free proof).PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
1st draft of the witness statement below (I need to do a bit more digging on the DYL rules). Would appreciate a review. I'll also draft a skeleton argument doc and include the evidence refs.
1. I, xxx, of xxx, am the Defendant in this matter, and will say as follows
2. I am unrepresented, with no experience of Court procedures. If I do not set out documents in the way that the Claimant may do, I trust the Court will excuse my inexperience.
3. In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.
4. Whilst I was the Registered Keeper of the vehicle concerned, there is no evidence of the driver and as this event has been resurrected from over 1 year ago, it is impossible to expect a keeper to recall who might have been driving.
5. The Defendant denies being the driver at the time of the supposed event, and therefore puts PARKING CONTROL MANAGEMENT (UK) LIMITED to strict proof that any contract can exist between the Claimant and themselves.
6. At the time in November 2016, the insurance covered more than one family member, who I have no obligation to name to a private parking firm. It remains the burden of the Claimant to prove their case.
7. There was no requirement upon me as keeper to respond to what appeared to be junk mail. No adverse inference can be drawn from my lawful decision to ignore the colourful letter, impersonating a parking ticket yet with no basis in law.
8. In May 2017 I received a Letter before Claim from the claimants solicitors for an inflated amount of £160. I have researched this and discovered that the claimants solicitors, Gladstones, have history of issuing robo-claims for 'parking charges' in their thousands.
9. The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160. I submit the added costs have not actually been incurred by the Claimant; these are figures plucked out of thin air and applied regardless of facts, as part of their robo-claim litigation model, in an attempt at double recovery, circumventing the Small Claims costs rules. Further, Gladstones appear to be in contravention of the Solicitors’ Regulation Authority Code of Conduct by knowingly demanding more monies than they know they can recover.
10. The Defendant also disputes that the Claimant has incurred £50 solicitor costs.
11. The Defendant has the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt.
12. Notwithstanding the Defendant's belief, the costs are in any case not recoverable.
13. The Claimant described the charge of £50.00 "legal representative’s costs" not "contractual costs". CPR 27.14 does not permit these to be recovered in the Small Claims Court.
14. I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress, such that I intend to report PARKING CONTROL MANAGEMENT (UK) LIMITED to the Information Commissioner for misuse of my data, obtained from the DVLA.
15. My DVLA data was supplied for the single strict purpose of enquiring who was driving, not for storing for a prolonged period then suing me as if I can now be held liable, in the hope I will not defend/will have lost the paperwork/will have moved house, or even better, that I will be so scared that I will pay over £244, for what was apparently an unproven £100 charge, allegedly incurred by another party, if incurred at all.
16. The claimant has failed to properly respond to my request made on 12/05/2017 & 09/06/2017 by royal mail postal service, requesting any documentation and relevant contracts with the land owners that allow the claimant to issue claims upon the landowner’s behalf. My request was not actioned appropriately (I received copies of two PCN’s, one of which states the time as 15:25 and the other as 15:58 and also 7 poor quality prints of photographs, one of which does not look like any siganage in the direct vicinity of where the car was located and of such low quality that the timestamp cannot read).
CLAIMANTS CORRESPONDENCE APPENDED AS EVIDENCE: E.XX
17. No windscreen ticked was attached to the vehicle at the time. The claimant took photographs but did not place a ticket on the car. Additionally, as far I am aware, there are no uniformed wardens patrolling the site – photographs are taken in a secretive manner. I believe this is because the claimant is deliberately targeting motorist for their financial gain.
18. I did not receive a copy of the contract with the landowner or an answer on whether the charges were based on damages for breach of contract or trespass, nor did I receive a full explanation on how the additional £60 on an £100 charge was calculated, only that it was incurred in facilitating the recovery. This appears to be an added cost with apparently no qualification and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.
19. Para. 4(5) Schedule 4 Protection of Freedoms Act 2012 which sets out that the maximum amount recoverable from the registered keeper, where the keeper liability provisions have been properly invoked (which is expressly denied in this case) is that amount specified in the Notice to Keeper (whether issued in accordance with paras 8(2)c; 8(2)d, 9(2)c or 9(2)d of the Act).
POFA APPENDED AS EVIDENCE: E.xx
20. The claimants photographs show the car is parked on a section with double yellow lines. However there are no upright signs or markings on the kerb on that side of the road indicating any restrictions. The car was not causing any obstructions and the driver would have only stopped there to pickup or drop off something from the school office on that side of the road. Additionally as this is not a public road, I do not believe double yellow lines have the same legal basis as they do on a public road.
LOCATION PHOTOGRAPHS APPENDED AS EVIDENCE: E.XX
21. I believe the signage on entrance to the site and in the surrounding area parking signage in this matter was, without prejudice to my defence, woefully inadequate and incapable of forming the basis of a contract.
SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: E.Xx
SIGNAGE VIDEO APPENDED AS EVIDENCE: E.Xx
22. The signage at the site entrance measures 450mm wide by 610mm high containing over 300 words in varying font size and at heights over two meters from the ground, some at first story height did not comply with the requirements of the Code of Practice of the Independent Parking Committee’s ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory.
SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: E.Xx
IPC CODE OF PRACTICE 2016 APPENDED AS EVIDENCE: E.XX
IPC CODE OF PRACTICE 2017 APPENDED AS EVIDENCE: E.XX
23. The signage opposite the area where the vehicle was photographed is on the opposite side of the road, approximately 4 meters above ground with very small writing, making it illegible and does not mention what restrictions apply to the section of the road with the double yellow markings
SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: E.Xx
24. The claimant has not supplied to me any part of the contract with the landholder or any other document that demonstrated that PARKING CONTROL MANAGEMENT (UK) LIMITED had their authority to make a claim.
25. I did not receive a fully completed directions questionnaire from the claimant, they only sent a blank form with additional paperwork that did not answer the questions set out in the DQ.
CLAIMANTS DQ APPENDED AS EVIDENCE: E.XX
26. I have yet to receive any documents that the claimant intends to rely upon at the hearing other than what I have already mentioned.
27. I believe that the facts stated in this Witness Statement are true.
Signed xxxxxxxxxxxxxxxx
Dated xxxxxxxxxxx0 -
2 isnt needed
4 and 5 arent great when read together; you say you cant recall who drov, then categorically state you were not hte driver. the last element of 5 is an ARGUMENT and not a statement of fact.
6) I would roll that into 4. not only was it more than 1 year ago, but the insurance covers more than one driver AND ADD IN that ANYONe with DOV cover could have driven your vehicle with your permission . State that you were not the driver as a lead in to 4
9) why is this in a WS? Its more argument. Just state the amount had bene inflated iwhtout any explanation as to the lawful basis for this incresae.
10) Is this the filing fee? If so the proper place for disputing that was in the defence. You could state to back up your defence disputing of their filing fee something like "this poorly worded partiuclar of cliam, that disclosed no cause of action and had ni significant detail, appears to be identical to the thousands of automatically generated particulars you have seen while researching your defence. It only used X of the 180 characters available, and could not had taken more than 5 miniutes to prepare. You require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced AND PAID.
12) and 13) the FILING costs ARE recoverable. Are you sure you have not picked this from a BW legal case, where they DO describe costs as "initial legal costs" and to the amount of £64, which is then easily distinguishable from the filing fee
14) Who cares what you INTEND to do?
15) you now say £244, not £160... I also dont think it belongs here unles syou are counterclaiming for DPA breach - their breach of KADOE isnt your concern as a defence.
16) If youre going to mention 2 PCNs - are they different numbers? You need t state exactly what the relevance i of two pcn, and of course, REFERENCE THEM AS EVIDENCE with your initials and a unique reference INLINE to your argument - so two pcn (ref INITIALS/001) and 7 photos (ref INITIALS/002) if you wish to include them. For example, if there are 2 pcn for the same reference but differnet times, state that both cannot be true. etc.
17) Your conclusion isnt really relevant?
18) POFA does not disallow double recovery. Thats the job of courts to not allow them to double recover.
19) What you need to say that, EVEN IF they had met the requirements of POFA to make the Keeper liable - and I notice youve not addressed the validity of the NTK in your WS at all yet, whether they were received in time etc - POFA does not allow them to recover more than the value of the NTK, with no additional charges. You need to deny POFA compliance here, you havent done so yet - obv only if POFA wasnt met!
POFA is NOT evidence I wouold suggest - its an Act. Take a copy on the day, dont supply them with copies now. See what others such as Jonersh think
20) there is no "belief" here. DYL on privtae land have NO inherent meaning, and in addition, even IF they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting (to use the TMA2004 verbage) is NOT parking, and IS allowed on public roads covered by DYL so again, IF the driver was boarding /alighting,there would still nbe no breach of any supposed contract, which is denied.
24) Does this not repeat what you said earlier?
26) You likely wont, as they will send them on the deadline.
Just my initials thoughts. See what others suggest.0 -
Thanks nosferatu1001. Responses below
Will remove2 isnt needed4 and 5 arent great when read together; you say you cant recall who drov, then categorically state you were not hte driver. the last element of 5 is an ARGUMENT and not a statement of fact.
I’ll amend and also remove last element of 5.
I was not the driver so will stick with that and amend to (rolling 4, 5 and 6 together):6) I would roll that into 4. not only was it more than 1 year ago, but the insurance covers more than one driver AND ADD IN that ANYONe with DOV cover could have driven your vehicle with your permission . State that you were not the driver as a lead in to 4
“Whilst I was the Registered Keeper of the vehicle concerned, there is no evidence of the driver. I deny being the driver at the time of the supposed event. At the time in November 2016, the insurance covered more than one driver, who I have no obligation to name to a private parking firm. Additionally, anyone with Driving other Vehicles cover could have driven the vehicle with my permission. It remains the burden of the Claimant to prove their case.”
Will amend to:
9) why is this in a WS? Its more argument. Just state the amount had bene inflated iwhtout any explanation as to the lawful basis for this incresae.
“The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160”
In the POC, it states:10) Is this the filing fee? If so the proper place for disputing that was in the defence. You could state to back up your defence disputing of their filing fee something like "this poorly worded partiuclar of cliam, that disclosed no cause of action and had ni significant detail, appears to be identical to the thousands of automatically generated particulars you have seen while researching your defence. It only used X of the 180 characters available, and could not had taken more than 5 miniutes to prepare. You require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced AND PAID.
£160 for the parking charges + interest = £169.76
£25 court fees
£50 “Legal representative’s costs”
Total £244.76
I did dispute this in my defence and will bring it up in the skeleton defence as well. There seems to be more than 180 characters so I’ll reword to:
“The Defendant also disputes that the Claimant has incurred £50 solicitor costs. The poorly worded particular of claim, that disclosed no cause of action and had no significant detail, appears to be identical to the thousands of automatically generated particulars I have seen while researching my defence. It only used 80 words, and could not had taken more than 5 minutes to prepare. I require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced and paid”
12) and 13) the FILING costs ARE recoverable. Are you sure you have not picked this from a BW legal case, where they DO describe costs as "initial legal costs" and to the amount of £64, which is then easily distinguishable from the filing fee
As listed above, the £50 looks to be on top of the hearing fee – is that the same as the filing fee? If so I will remove points 11, 12 and 13.14) Who cares what you INTEND to do?
Fair point, will reword to:
“I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress”
Amount breakdown listed earlier but will remove the point15) you now say £244, not £160... I also dont think it belongs here unles syou are counterclaiming for DPA breach - their breach of KADOE isnt your concern as a defence.
Sorry that should have said two NTK’s. Both with the same reference but have different times (same date).16) If youre going to mention 2 PCNs - are they different numbers? You need t state exactly what the relevance i of two pcn, and of course, REFERENCE THEM AS EVIDENCE with your initials and a unique reference INLINE to your argument - so two pcn (ref INITIALS/001) and 7 photos (ref INITIALS/002) if you wish to include them. For example, if there are 2 pcn for the same reference but differnet times, state that both cannot be true. etc.
“The claimant has failed to properly respond to my request made on 12/05/2017 & 09/06/2017 by royal mail postal service, requesting any documentation and relevant contracts with the land owners that allow the claimant to issue claims upon the landowner’s behalf. My request was not actioned appropriately. I received copies of two NTK’s (Ref xx/E.xx), one of which states the time as 15:25 and the other as 15:58. Both of the NTK’s cannot be true as they state different times. The claimant also included 7 poor quality prints of photographs (Ref xx/E.xx), one of which does not look like any signage in the direct vicinity of where the car was located and of such low quality that the timestamp cannot read.”
BTW, on the evidence itself, where should I write the unique reference? Along the top or bottom of the documents and as they are multiple pages, should I have a different ref per page?
I’ll remove the last sentence and leave as:17) Your conclusion isnt really relevant?
“No windscreen ticked was attached to the vehicle at the time. The claimant took photographs but did not place a ticket on the car. Additionally, as far I am aware, there are no uniformed wardens patrolling the site – photographs are taken in a secretive manner.”
I’ll remove part of the sentence and leave as:18) POFA does not disallow double recovery. Thats the job of courts to not allow them to double recover.
“I did not receive a copy of the contract with the landowner or an answer on whether the charges were based on damages for breach of contract or trespass, nor did I receive a full explanation on how the additional £60 on an £100 charge was calculated, only that it was incurred in facilitating the recovery. This appears to be an added cost with apparently no qualification and an attempt at double recovery”
I’ll add a para about POFA. In my defence I pointed out that the NTK does not meet all of the requirements – it does not state the duration the vehicle was parked. Other than that I didn’t spot anything else.19) What you need to say that, EVEN IF they had met the requirements of POFA to make the Keeper liable - and I notice youve not addressed the validity of the NTK in your WS at all yet, whether they were received in time etc - POFA does not allow them to recover more than the value of the NTK, with no additional charges. You need to deny POFA compliance here, you havent done so yet - obv only if POFA wasnt met!
POFA is NOT evidence I wouold suggest - its an Act. Take a copy on the day, dont supply them with copies now. See what others such as Jonersh think
I included POFA in the evidence as it was suggested that the judge may not have a copy of it at hand and it may be useful to include.
I’ll reword para to:
“It is denied that the Defendant was the driver of the vehicle and the Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. If the claimant is perusing me as keeper under POFA, then the NTK’s must be fully compliant with POFA schedule 4, which in this case it is expressly denied that both the NTKs are fully compliant as they do not state the duration the vehicle was parked. Additionally each NTK states a different time and both cant be true. Even if the NTK’s had met the requirements of POFA to make the keeper liable, POFA does not allow the claimant to recover more than the value of the NTK, no additional charges are allowed.
Last sentence amended to say:20) there is no "belief" here. DYL on privtae land have NO inherent meaning, and in addition, even IF they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting (to use the TMA2004 verbage) is NOT parking, and IS allowed on public roads covered by DYL so again, IF the driver was boarding /alighting,there would still nbe no breach of any supposed contract, which is denied.
“Additionally as this is not a public road, double yellow lines on private land have no inherent meaning and in addition, even if they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting is not parking, and is allowed on public roads covered by DYL therefore, if the driver was boarding /alighting, there would still be no breach of any supposed contract, which is denied.”
I’ll merge with 1824) Does this not repeat what you said earlier?
Amended to:26) You likely wont, as they will send them on the deadline.
“I have yet to receive any documents that the claimant intends to rely upon at the hearing other than what I have already mentioned. I am therefore unable to present a full and proper defence for the claim”0 -
Updated Witness Statement - new para added (#15, #6 and #23)
1. I, xxx, of xxx, am the Defendant in this matter, and will say as follows
2. In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.
3. Whilst I was the Registered Keeper of the vehicle concerned, there is no evidence of the driver. I deny being the driver at the time of the supposed event. At the time in November 2016, the insurance covered more than one driver, who I have no obligation to name to a private parking firm. Additionally, anyone with Driving other Vehicles cover could have driven the vehicle with my permission. It remains the burden of the Claimant to prove their case.
4. There was no requirement upon me as keeper to respond to what appeared to be junk mail. No adverse inference can be drawn from my lawful decision to ignore the colourful letter, impersonating a parking ticket yet with no basis in law.
5. In May 2017 I received a Letter before Claim from the claimant’s solicitors for an inflated amount of £160. I have researched this and discovered that the claimant’s solicitors, Gladstones, have history of issuing robo-claims for 'parking charges' in their thousands.
6. The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160.
7. The Defendant also disputes that the Claimant has incurred £50 solicitor costs. The poorly worded particular of claim, that disclosed no cause of action and had no significant detail, appears to be identical to the thousands of automatically generated particulars I have seen while researching my defence. It only used 80 words, and could not had taken more than 5 minutes to prepare. I require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced and paid.
8. The Defendant has the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt.
9. Notwithstanding the Defendant's belief, the costs are in any case not recoverable.
10. The Claimant described the charge of £50.00 "legal representative’s costs" not "contractual costs". CPR 27.14 does not permit these to be recovered in the Small Claims Court.
11. I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress.
12. The claimant has failed to properly respond to my request made on 12/05/2017 & 09/06/2017 by royal mail postal service, requesting any documentation and relevant contracts with the land owners that allow the claimant to issue claims upon the landowner’s behalf. My request was not actioned appropriately. I received copies of two NTK’s (Ref RM/E.xx), one of which states the time as 15:25 and the other as 15:58. Both of the NTK’s cannot be true as they state different times. The claimant also included 7 poor quality prints of photographs (Ref RM/E.xx), one of which does not look like any signage in the direct vicinity of where the car was located and of such low quality that the timestamp cannot read.
CLAIMANTS CORRESPONDENCE APPENDED AS EVIDENCE: RM/E.XX and RM/E.XX
13. No windscreen ticked was attached to the vehicle at the time. The claimant took photographs but did not place a ticket on the car. Additionally, as far I am aware, there are no uniformed wardens patrolling the site – photographs are taken in a secretive manner.
14. The claimant has not supplied to me any part of the contract with the landholder or any other document that demonstrated that PARKING CONTROL MANAGEMENT (UK) LIMITED had their authority to make a claim or an answer on whether the charges were based on damages for breach of contract or trespass, nor did I receive a full explanation on how the additional £60 on an £100 charge was calculated, only that it was incurred in facilitating the recovery. This appears to be an added cost with apparently no qualification and an attempt at double recovery.
15. The claimant did not send me a Letter before Action that complied with the Practice direction on pre-action conduct. The Letter before Action can be seen to miss the following information
a. A clear summary of facts on which the claim is based.
b. A list of the relevant documents on which their client intends to rely.
c. How the “charge amount” of 160 pounds has been calculated and justified.
d. Any form of possible negotiation or ADR offered
16. The claim form itself is vague and lacks pertinent information as to the grounds for the claimant’s case. The particulars of claim fail to meet CPR16.4 and PD16 7.3-7.5 and merely provide a date, location, and an "amount" consisting of a completely unsubstantiated and inflated three-figure sum, vaguely and incoherently adduced by the claimant's solicitors and demands payment within 14 days. The claim also states "parking charge " which gives no indication of on what basis the claim is brought, for example whether this charge is founded upon an allegation of trespass or 'breach of contract' or contractual 'unpaid fees'.
17. It is denied that the Defendant was the driver of the vehicle and the Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. If the claimant is perusing me as keeper under POFA, then the NTK’s must be fully compliant with POFA schedule 4, which in this case it is expressly denied that both the NTKs are fully compliant as they do not state the duration the vehicle was parked. Additionally each NTK states a different time and both cant be true. Even if the NTK’s had met the requirements of POFA to make the keeper liable, POFA does not allow the claimant to recover more than the value of the NTK, no additional charges are allowed
POFA APPENDED AS EVIDENCE: RM/E.XX
18. The claimant’s photographs show the car is parked on a section with double yellow lines. However, there are no upright signs or markings on the kerb on that side of the road indicating any restrictions. The car was not causing any obstructions and the driver would have only stopped there to pick up or drop off something from the school office on that side of the road. Additionally, as this is not a public road, double yellow lines on private land have no inherent meaning and in addition, even if they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting is not parking, and is allowed on public roads covered by DYL therefore, if the driver was boarding /alighting, there would still be no breach of any supposed contract, which is denied
LOCATION PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX
19. I believe the signage on entrance to the site and in the surrounding area parking signage in this matter was, without prejudice to my defence, woefully inadequate and incapable of forming the basis of a contract.
SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX
SIGNAGE VIDEO APPENDED AS EVIDENCE: RM/E.XX
20. The signage at the site entrance measures 450mm wide by 610mm high containing over 300 words in varying font size and at heights over two meters from the ground, some at first story height did not comply with the requirements of the Code of Practice of the Independent Parking Committee’s ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory.
SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX
IPC CODE OF PRACTICE 2016 APPENDED AS EVIDENCE: RM/E.XX
IPC CODE OF PRACTICE 2017 APPENDED AS EVIDENCE: RM/E.XX
21. The signage opposite the area where the vehicle was photographed is on the opposite side of the road, approximately 4 meters above ground with very small writing, making it illegible and does not mention what restrictions apply to the section of the road with the double yellow markings
SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX
22. I did not receive a fully completed directions questionnaire from the claimant, they only sent a blank form with additional paperwork that did not answer the questions set out in the DQ.
CLAIMANTS DQ APPENDED AS EVIDENCE: RM/E.XX
23. The Claimant has sent threatening and misleading demands which stated that further debt recovery action would be taken to recover what is owed by passing the debt to a recovery agent (which suggested to the Defendant they would be calling round like bailiffs) adding further unexplained charges with no evidence of how these extra charges have been calculated.
CLAIMANTS CORRESPONDENCE APPENDED AS EVIDENCE: RM/E.XX
24. I have yet to receive any documents that the claimant intends to rely upon at the hearing other than what I have already mentioned. I am therefore unable to present a full and proper defence for the claim.
25. I believe that the facts stated in this Witness Statement are true.
Signed xxxxxxxxxxxxxxxx
Dated xxxxxxxxxxx0 -
Independent Parking Committee ("IPC")
Nope, they are the International Parking Community nowadays.PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
Thanks Coupon-Mad. I'll correct. Does everything else look ok now?
Question on the documents to be sent to Gladstones by post. I have purchased folder separators for the court and my copy of the documents - whilst Gladstones version will be a copy of what I will send to the court, paginated etc, do I need to include separators or can I put their copy (in the correct order) but just loose inside an envelope?0 -
Yes, I would!can I put their copy (in the correct order) but just loose inside an envelope?
Typo here:If the claimant is perusing
I have only skim read it, so wait for more comments.PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
Thanks again Coupon-mad. I'll amend.
Nosferatu1001 mentioned and I've just seen a post from Bargepole that said dont include pofa as evidence but have a printed copy at hand should the judge want to see a copy, so I'll remove those references as well.
Question on Skeleton argument - does that need to be sent in with the Witness statement and evidence (including a copy to Gladstones) or is that submitted later?0
This discussion has been closed.
Categories
- All Categories
- 343.2K Banking & Borrowing
- 250.1K Reduce Debt & Boost Income
- 449.7K Spending & Discounts
- 235.3K Work, Benefits & Business
- 608K Mortgages, Homes & Bills
- 173.1K Life & Family
- 247.9K Travel & Transport
- 1.5M Hobbies & Leisure
- 15.9K Discuss & Feedback
- 15.1K Coronavirus Support Boards