VCS Parking - CCCF Letter Received - Defence helped needed

I've redrafted my defence below if you would so kind as to provide feedback. I've included the bits you mentioned and sharpened up the signage to 1 succinct point. I've also included the bit about 2 previously appealed tickets as, whilst it might highlight their goodwill, it also demonstrates I made reasonable effort to understand parking regulations (or lack of) in the area.

In the County Court Business Centre
Claim Number: D0QZ924M
BETWEEN:
Vehicle Control Services Ltd (Claimant)
vs
Saarchy (Defendant)
___________________________________________________________________________
Statement of Defence
I am Saarchy of Address, Postcode defendant in this matter.
It is admitted that the defendant was the registered keeper of the vehicle noted at the date of alleged breaches. However, the claimant has no cause of action against the defendant on the following grounds: -
1. Notwithstanding that the claimant claims no right to pursue the defendant as the registered keeper under The Protection of Freedoms Act 2012 (PoFA 2012); the Claimant has failed to meet the conditions of the Act and has never acquired any right to pursue the Defendant in this capacity if they cannot identify the driver.
2. It is denied that the Claimant served the required documents with statutory wording as prescribed under the POFA and as such, there can be no keeper liability in any event.
3. The Claimant alleges that parking charges notices were given for “failure to adhere to the advertised terms and conditions” but no terms are given nor is any valid breach established.
4. The place of the alleged breach is given as “development known as Globeside Business Park Infrastructure Marlow and Unit 3 Globeside Business Park” which contains many registered parcels of land as well as registered leaseholds on parts of these parcels of land, therefore strict proof is required as to the exact site of the breach.
5. Vehicle Control Services Ltd are not the lawful occupier of any land around Globeside Business Park Infrastructure Marlow and Unit 3 Globeside Business Park. Absent a contract with the lawful occupier of the land being produced by the claimant, or a chain of contracts showing authorisation stemming from the lawful occupier, I have reasonable belief that they do not have authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.
6. The Defendant was employed at the time of the alleged breaches at a company operating from leasehold properties at the Business Park which including parking allowances in adjacent parcels of land within the Business Park. These were signposted, including specific parking signs for the Defendant’s office near where parking charge notices were issued.
7. If it does transpire that the claimant is entitled to issue charges on the private land, certain parking spaces do not and cannot include spaces which are covered under the leases without specific authority being proved to be held from the owners of leases for each of those spaces.
8. The signage present in the area is woefully inadequate and at no point can be considered suitable for “Terms and Conditions” to be breached, or any form of contract whatsoever. This includes, but is not limited to, signage obstructed by hedgerow, ambiguously placed alongside parking bays, no parking signs on entry to Business Park etc.
9. No attempt was made by the claimant to provide suitable information on parking regulations within this Business Park. This is despite the Defendant’s direct request on appeal and the subsequent cancellation of two notices (VC0314065A and VC03473506) issued on 2nd September 2014 and 26th September 2014. This is over a year before the time of the alleged breaches in this claim.
10. At no point were any significant signage changes made between September 2014 and September 2016, or further information supplied to leaseholders on the Business Park, by Vehicle Control Services Ltd. As such, any further tickets can be considered erroneous given the implied parking permission by the Claimant on appeal, as well as the Defendant’s employer occupying adjacent office space.
11. PoFA 2012 only allows the recovery of the parking charge stated on the Notice to Keeper and not court fees, damages, indemnity costs or legal representative’s costs.
12. No contract, terms and conditions or sum payable were ever accepted by any driver.
13. The claimant’s notices attempt to make a forbidding offer, which isn’t an offer at all, therefore no contract exists.
14. The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed, the particulars of the claim are not clear and concise as is required by CPR 16.4 1(a).
15. The claimant failed to include a copy of their written contract as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice A7.1 which says that If you do not own the land on which you are carrying out parking management, you must have the written authorisation of the landowner (or their appointed agent). The written confirmation must be given before you can start operating on the land in question and give you the authority to carry out all the aspects of car park management for the site that you are responsible for. In particular, it must say that the landowner (or their appointed agent) requires you to keep to the Code of Practice and that you have the authority to pursue outstanding parking charges.
16. The Defendant believes that his personal details have been obtained unlawfully by the Claimant and asks that the Court does not to assist the Claimant to benefit from a wrongdoing. (Ex turpi causa non oritur actio).
The facts stated in this defence are true, to the best of my knowledge and belief.
Signed,
Saarchy