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  • FIRST POST
    • CircusFrog
    • By CircusFrog 26th Nov 16, 5:00 PM
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    CircusFrog
    COUNTY COURT CLAIM FORM (UKCPM, Gladstones)
    • #1
    • 26th Nov 16, 5:00 PM
    COUNTY COURT CLAIM FORM (UKCPM, Gladstones) 26th Nov 16 at 5:00 PM
    Hi,

    I've received a Claim Form from Gladstones Solicitors on behalf of UK Car Park Management Limited for three PCNs in November 2015.

    They're charging £150 per PCN - rounded to '£483.52 including £33.52 interest' + £35 Court Fee + £50 legal representative's fee.

    I did the wrong thing at the time and ignored the PCN and subsequent letters completely.

    The car park is a car permit car park, and I have a valid permit (as a resident), but I didn't have the permit on display (lost it!).

    I'm not sure I have much to go on if the PCNs are about the no permit display, but I don't have the original notices to be able to review exactly what they were about.

    The car park where I live is overcrowded, and sometimes I don't even park in a recognised bay, but have been ignoring the PCNs since probably 2014.

    If there's nothing to appeal with regards to the PCNs themselves, can I appeal the 'Legal Representative's fee of £50 at least?

    A bigger concern I have here is that this £568.52 is probably less than a tenth of the number of PCNs my wife and I have had outside of our own house and ignored in the last 2 years. Is there an option to discuss some sort of settlement with CPM that covers all of them - I'm not sure I want to bring it up.


    I'm ready to apply for the extension, but need to know if I even have a defense worth submitting first - being a permit holder, I'm not sure that I do?
Page 2
    • CircusFrog
    • By CircusFrog 27th Jun 17, 8:08 PM
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    CircusFrog
    The last letter (on 22nd March) I received, title "Notice of Allocation to the Small Claims Track (Hearing)" only includes the following dates:

    The Claimant must file and serve by 24 April 2017 an amended claim form verified by a statement of truth which complies with CPR 16 setting out a concise nature of the claim, the facts on which the Claimant relies. If the claim is based on a written argument then a copy must be served and filed.
    By 8 May 2017 the Defendant do file and server amended Defence, if so advised
    (I didn't, because I was waiting for the Claimant statement above).

    Each party shall deliver to every other party and to the court offices copies of all documents (including any experts' report) on which he intends to rely at the hearing no later than 14 days before the hearing.
    I've never received a letter with any mention of Witness Statements.

    I don't think my WS will differ much from the argument I put forward in my initial response, except attaching the Lease?

    That statement is as follows:

    i. As a resident of ****, the lease grants me the right to park one private domestic vehicle in any free parking space.

    It is asserted that the Lease with **** Management for the property ***** grants me the right to park on ****.

    Specifically, the Lease states:
    “[The lessor grants the lessee] The right in common with all others entitled thereto from time to time to park one domestic private motor vehicle only on the Estate in any free parking space other than those specifically allocated or to be allocated.

    The sign placed on the property by UK CPM states:
    “Terms of parking without permission: You do so at your own risk to property and personal injury and you are contractually agreeing to pay a parking charge fee.”

    The terms of the Lease on my residence give me permission to park on this private property, therefore I was parking with permission, just not UK CPM’s permission.

    It is asserted that signage on the property cannot replace the contract formed by the Lease, as found in CS038 Jopson vs Homeguard [2016] 9GF0A9E. In that case Judge Harris QC ruled:
    “ the respondent was not in any position unilaterally to override the right of access which the claimant had bought when she purchased the lease”

    In Link Parking Ltd vs J. Parkinson [2016] C7GF50J7, the Judge, referring to a similar case in Pace Recovery v Mr N [2016] C6GF14F0 ruled that:
    “…the Judge in that case found that the parking company could not amend the terms of the tenancy agreement to bind a tenant, but rather that it would have to be the other party to the contract, and it seems to me that the same principle applies here.”

    Accordingly, I assert that the Claimant has made no attempt to amend the terms of the Lease or to have them amended by the management company, ***** Management.

    The case law in this regard is strong: the terms of a tenancy agreement cannot be amended by the displaying of a sign.

    Solicitors’ Costs

    The claim includes a sum of £50, described as ‘Solicitor’s costs’. The Claimant is known to be a serial litigant, issuing up to 1,000 similar claims on a weekly basis, using the bulk processing service. Given a standard working week, the claimant’s solicitor can spend no more than a few minutes per claim, hardly justifying the £50. Since these are fully automated, no intervention is required by a solicitor, and the Claimant is put to strict proof to show how this cost has been incurred. The Claimant maintains case notes for each person who has accessed the case, and it is suggested this would be sufficient. The Claimant cannot rely on Nossen’s Letter Patent (1969) to justify the charge, as this is part of their everyday routine, and no ‘expert services’ are involved. The £50 is not valid because it is not incurred by the claimant, generating over £1.5 million a year in profit. 

    Additionally, as this is already included as part of the costs of the claimant, factored into the £100 parking charge, this is essentially double charging. 

    The defendant therefore puts the claimant strictly to proof, by way of timesheets or otherwise, that work was done by the litigant’s expert staff to the value of £50.
    ]
    • Coupon-mad
    • By Coupon-mad 27th Jun 17, 8:45 PM
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    Coupon-mad
    ''Each party shall deliver to every other party and to the court offices copies of all documents (including any experts' report) on which he intends to rely at the hearing no later than 14 days before the hearing.''

    I've never received a letter with any mention of Witness Statements.
    Oh good, you have time then, if the court date is more than a fortnight away. the Court letter doesn't call it a WS but that's what it means, and you are expected to file one with your evidence.

    I don't think my WS will differ much from the argument I put forward in my initial response, except attaching the Lease?
    And the transcripts of your case law, e.g. Jopson v Home Guard (a persuasive case heard on Appeal) and Link Parking Ltd vs J. Parkinson [2016] C7GF50J7, and Pace Recovery v Mr N [2016] C6GF14F0.

    All transcripts for those cases are hosted in the Parking Prankster's case law page (Google it).

    And were they VERY late in filing their amended claim, did they meet the April date?
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • CircusFrog
    • By CircusFrog 27th Jun 17, 8:48 PM
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    CircusFrog
    And were they VERY late in filing their amended claim, did they meet the April date?
    Well, their Statement of Truth is signed and dated 12th June. So I'm thinking, no?

    Thanks on the other stuff, I'll go and look at the links in the Newbie thread, include in the transcripts of the case law and put another re-write up here?

    Do I need to amend the Defense to address this from the Claimant?

    In view of the fact that the Defendant claims to be a resident, but hasn't received daily charges, it can be averred that they have displayed a permit on multiple occasions previously. In view of this, they accepted the charge
    • Coupon-mad
    • By Coupon-mad 27th Jun 17, 9:06 PM
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    Coupon-mad
    Do I need to amend the Defence to address this from the Claimant?
    Yes, you need to address that in the WS (you are not amending the defence, you can't now). You can explain in the WS that permits were issued by xxxxxxx (hopefully the Managing agents, not the claimant?) with nothing stated about any 'parking charge', and that residents displayed them as a courtesy, not in the knowledge or acceptance of any onerous 'contract'.

    Like here (this one is a defence but much of what this OP states can be used in a WS):

    http://forums.moneysavingexpert.com/showthread.php?p=72679759#post72679759
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • CircusFrog
    • By CircusFrog 27th Jun 17, 11:59 PM
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    CircusFrog
    Yes, you need to address that in the WS (you are not amending the defence, you can't now). You can explain in the WS that permits were issued by xxxxxxx (hopefully the Managing agents, not the claimant?) with nothing stated about any 'parking charge', and that residents displayed them as a courtesy, not in the knowledge or acceptance of any onerous 'contract'.

    Like here (this one is a defence but much of what this OP states can be used in a WS):

    http://forums.moneysavingexpert.com/showthread.php?p=72679759#post72679759
    Originally posted by Coupon-mad

    Unfortunately, no. I just found the letter that contained the permit, and it was from UKCPM:

    • Coupon-mad
    • By Coupon-mad 28th Jun 17, 12:16 AM
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    Coupon-mad
    It has some good things, well done for keeping that old letter!

    It states that the purpose of the scheme is to 'alleviate ongoing problems with unauthorised parking' and 'our aim is to provide a safer parking facility for all residents, whilst ensuring that residents can gain access and have exclusive right to their parking area'.

    And 'the parking areas are being protected by using a parking scheme'.

    Whilst it mentions a 'parking charge' it does not mention any sum, so no-one on the entire estate has agreed to pay £100, because it doesn't define any agreed sum (the only figure on that letter is a fiver).

    The second sheet 'instructions' is not written recognisably as a contract, by any stretch of the imagination, and merely tells a resident what to do, lulling you all into a false sense of security that your parking area is being somehow 'protected' for your convenience.

    In fact, it's more like a protection racket.
    Last edited by Coupon-mad; 09-07-2017 at 6:27 PM.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • CircusFrog
    • By CircusFrog 9th Jul 17, 1:31 PM
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    CircusFrog
    Right,

    First Draft of Witness Statement here: https://filetea.me/n3wyJCwOHGrQrqtZ5G5MLdhyg (pdf).

    Two thoughts:

    1) Do I need to prove residence? The Lease is actually with my husband.
    2) I still need to address their claim that having displayed the sign 'sometimes' constitutes a contract, I'll attach the letter above as evidence. Do I argue that the wording of the letter makes it clear that the intention was to protect residents (seems legally irrelevant) - or do I just emphasise no mention of a penalty fee in the letter?


    The letter also doesn't mention anything to the effect that displaying the permit constitutes accepting any terms.
    • CircusFrog
    • By CircusFrog 9th Jul 17, 6:25 PM
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    CircusFrog
    Re-reading the draft above, I wonder if the legal argument about the case law I've included should be made in a Skeleton Arguments intsead of this Witness Statement, which just needs to include them?
    • Coupon-mad
    • By Coupon-mad 9th Jul 17, 6:33 PM
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    Coupon-mad
    Do I argue that the wording of the letter makes it clear that the intention was to protect residents (seems legally irrelevant) -
    I would say (as an armchair lawyer, unqualified) that it's not irrelevant at all. And there is more than just the 'protect' wording, there were three things I picked out that were misleading about the intentions of the regime. Include them all, and a copy of that letter filed at evidence.

    In PE v Beavis, they were allowed to charge £85 because the Supreme Court held that there was a 'legitimate interest' (bearing in mind the specific interests of the landowner in a retail park) in charging Mr Beavis more than just nominal damages. You can use the above drivel letter from the parking firm, to demonstrate there can be no 'legitimate interest' in penalising residents, fully distinguishing this case from the Beavis case. Clearly that was never meant to be the aim, at least not the way the regime was painted to residents and to the Managing Agent.

    Re-reading the draft above, I wonder if the legal argument about the case law I've included should be made in a Skeleton Arguments intsead of this Witness Statement, which just needs to include them?
    Originally posted by CircusFrog
    Yes, if you have time then separate the legal stuff into a skeleton argument.

    The WS should be short and sweet - the facts of what happened, letters received etc.
    Last edited by Coupon-mad; 09-07-2017 at 7:00 PM.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • The Deep
    • By The Deep 9th Jul 17, 6:47 PM
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    The Deep
    No. 5 of the instructions threatens to immobilise the vehicle, do they mean clamping I wonder?

    Do they have permission from the head-lease holder to interfere thusly with the leasehold rights of the resident to quiet enjoyment of their property, but not showing a permit. It seems tyo mne that the whole scheme contravens quiet enjoyment rights.
    Last edited by The Deep; 09-07-2017 at 6:53 PM.
    You never know how far you can go until you go too far.
    • CircusFrog
    • By CircusFrog 9th Jul 17, 8:21 PM
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    CircusFrog
    Ok, here's a redraft, I've mentioned the letter they sent, specifically drawing on the fact that they said they're being introduced to deal with the problem of "unauthorised parking", which implies authorisation was granted before the parking scheme was in place.

    I've taken out all of the details of the case law, other than to say that the case law says lease trumps sign.

    I'm still at 21 points though, so wonder if I've drifted into legal arguments again?


    PDF Here:

    https://filetea.me/n3wLZ7iIaFHTKKuL9CL245H4w

    I need to have filed the witness statement by this Thursday, so need to post to court (and email to Gladstones) by Tuesday.
    • CircusFrog
    • By CircusFrog 10th Jul 17, 4:31 PM
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    CircusFrog
    Ugh, PDF wetn down, here's a copy and paste version:

    IN THE COUNTY COURT AT COUNTY COURT
    CLAIM NUMBER:
    BETWEEN:
    UK Car Park Management Limited (Claimant)
    - and -
    (Defendant)
    WITNESS STATEMENT
    1. I, of Close, am
    the Defendant in this matter, and I make this statement in response to the Claimant. In this
    Witness statement, the facts and matters stated are true and within my own knowledge, except
    where indicated otherwise.
    2. Exhibited to this Witness Statement are the following documents which I wish to reply upon in
    my Defence:
    A. my driving license, as proof of residence at Close,
    B. the Lease of Part relating to
    C. [Something proving owns the property];
    D. a letter from UK Car Park Management Ltd RE: Parking Restrictions and permits;
    E. Transcript of Appeal CS038 Jopson vs Homeguard [2016] 9FG0A9E;
    F. Transcript of Pace Recovery vs Mr N[2016] C6GF14F0;
    G. Transcript of Link Parking Ltd vs J. Parkinson [2016] C7GF50J7;
    H. Plot of Land;
    3. Schedule Part 1 - 11. of the Lease of Part [Appendix B] grants
    permission to park a private vehicle in any free parking space:
    “[The lessor grants the lessee] The right in common with all others entitled
    thereto from time to time to park one domestic private motor vehicle only on
    the Estate in any free parking space other than those specifically allocated
    or to be allocated”.
    LEASE OF PART , APPENDIX B
    4. As I will outline in my Skeleton Arguments, the case law in CS038 Jopson vs Homeguard
    [2016], Link Parking Ltd vs J. Parkinson [2016], and Pace Recovery vs Mr N[2016] asserts
    that signage placed on the property cannot replace the contract formed by the Lease.
    [Appendices E, F, G]
    The Claim
    References starting with a # are the paragraph numbers in the Claimant’s Witness Statement.
    5. The Claimant’s Witness Statement refers to a single parking charge in a number of places: #3,
    #4, #6, #7 and #8. The Schedule in #3 of her statement refers to three separate PCN incidents; I
    will respond as if ‘the charge’ in #3, #4, #6, #7, and #8 refers to the separate charge in each; but
    this is unclear.
    6. Regarding the Claimant's Statement that the Defendant is liable because “a valid permit was not
    on display at the time of the incident (sic.)” (Claimant Witness Statement #4):
    7. The Lease of Part (Appendix B, cited in my 3. above) does not require the displaying of a
    permit.
    8. The second charge listed in the Claimant’s Schedule (#3) has the description: “No Parking
    Outside of A Designated Area”. The Claimant has provided no evidence that they have the right
    to charge for this, and assert in #4 that, “a valid permit was not on display”.
    9. RE: “The Defendant was aware of the terms when they obtained the permit”. (#4)
    10. See again 3. RE: The Lease. The Lease is the contract with primacy, making the terms of any
    permit irrelevant.
    11. The permit was not ‘obtained’ by request, but sent to the anonymous “Resident / Occupier” By
    UK Car Park Management Limited. The Claimant cannot thus prove a level of awareness of the
    terms of the permit. (See Appendix D)
    12. RE: “The Defendant has not provided any evidence to support their alleged right to park.” (#5).
    As quoted in my defence, here in 3. and attached, the Lease and proof of residence (Appendix
    A) are the evidence to support the right to park, as is the case law.
    13. RE: “My Company has been instructed to manage the Relevant Land and without concession,
    the Defendant has failed to prove otherwise.” (#5). The Parking Enforcement Contractual
    Agreement (provided by the Claimant, included here as Appendix J), is between UK Car Park
    Management Ltd and Crabtree Property Management LLP. Neither of these entities have the
    right to revoke my right to park as set out in the Lease of Part to (See,
    again 3.)
    14. RE: “The residents’ indicated their acceptance of this service by displaying a valid permit… In
    view of this, they accepted the charge (sic.)” (#6).
    15. The Letter that was sent to residents introducing the permits does not in any part state that
    displaying a permit corresponds to acceptance of the service. [Appendix D]
    16. The Letter does not mention any specific charge, thus it is impossible for any resident to
    ‘accept’ such a charge from displaying the associated permit. [Appendix D]
    17. The Letter states; “This service will operate to alleviate the ongoing problems with
    unauthorised parking.”, which implies that the authorisation to park is not based on the
    displaying of a permit, but that authorisation pre-dates the introduction of the service by UK
    Car Park Management Ltd. [Appendix D]
    18. It is my assertion that the ‘authorisation’ to park on Close mentioned by UK Car
    Park Management is the authorisation provided by the Lease to each resident.
    19. This view, that residency is equivalent to authority to park, is further evidenced in the same
    letter: “This permit can be used by residents or issued to any visitor that may require
    parking.” [Appendix D]
    20. Consequently, the Defendant cannot be deemed to have been ‘unauthorised’ to park by not to
    displaying a permit which only notifies UK Car Park Management of their authorisation.
    I believe the facts stated in this Witness Statement are true
    • Coupon-mad
    • By Coupon-mad 10th Jul 17, 4:45 PM
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    Coupon-mad
    Looks good to go. Nice.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • CircusFrog
    • By CircusFrog 10th Jul 17, 7:23 PM
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    CircusFrog
    With all the transcripts, we're at 75 pages. Looking forward to Gladstones opening that email.
    • CircusFrog
    • By CircusFrog 24th Jul 17, 12:24 PM
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    CircusFrog
    Skeleton Arugments
    Skeleton Arguments:

    The Claimant’s Witness Statement is very hard to follow. It refers to a single parking in charge in #3, #4, #6, #7 and #8. In #3, the statement lists three separate PCNs. I’ll process as if ‘the charge’ in #3, #4, #6, #7, #8 is the Claimant’s claim for each separate charge in #3 - but this is unclear.
    As a resident of ********, the Lease of Part Schedule Part 1. 11. grants me the permission to park a private vehicle in any free parking space.
    “[The lessor grants the lessee] The right in common with all others entitled thereto from time to time to park one domestic private motor vehicle only on the Estate in any free parking space other than those specifically allocated or to be allocated”.
    lease of part, Schedule Part 1 11. 
witness statement (WS) appendix b (p. 28)

    The Claimant refers to the sign on the land as ‘i.e. the Contract’, but I assert that the signage on the property cannot replace the contract formed by the Lease of Part as found on appeal in CS038 Jopson vs Homeguard [2016] 9FG0A9E.
    In that case, Judge Harris QC ruled:
    “ the respondent was not in any position unilaterally to override the right of access which the claimant had bought when she purchased the lease”
    CS038 Jopson vs Homeguard ¶18. (WS Appendix E p.56)

    Also on the primacy of contract in this case, in Pace Recovery vs Mr N[2016] C6GF14F0, District Judge Coonan ruled:
    “I have before me a tenancy agreement which gives Mr [N. redacted] the right to park on the estate and it does not say “on condition that you display a permit”. It does not say that, so he has that right. What Pace Recovery is seeking to do is, unilaterally outside the contract, restrict that right to only when a permit is displayed. Pace Recovery cannot do that. It has got to be the other contracting party, Affinity Sutton, which amends the terms of the tenancy agreement to restrict the right to park on a place in circumstances in which a permit is displayed but that is not in this tenancy agreement and you as a third party cannot unilaterally alter the terms of the tenancy agreement.”
    Pace Recovery vs Mr N[2016] C6GF14F0 ¶1, (WS Appendix F, P. 63)


    My assertion is that the facts of this case are identical to the fact of Pace Recovery vs Mr N [2016].

    Referencing Pace Recovery vs Mr N[2016] C6GF14F0, In Link Parking Ltd vs J. Parkinson [2016] C7GF50J7 the Judge found that despite Pace Recovery v Mr N [2016] C6GF14F0 ‘not in any event binding him’:
    “…the Judge in that case found that the parking company could not amend the terms of the tenancy agreement to bind a tenant, but rather that it would have to be the other party to the contract, and it seems to me that the same principle applies here”
    Link Parking Ltd vs J. Parkinson [2016] C7GF50J7 ¶13., (Ws Appendix G, p. 72)

    The following were addressed in the Witness Statement, but may be better placed here:
    RE: “The Defendant was aware of the terms when they obtained the permit”. (#4): The permit was not obtained by request (WS #11.), and the anonymous “Resident / Occupier” letter from UK Car Park Management Ltd (WS Appendix D) does not establish the terms of the permit.
    RE: “The residents’ indicated their acceptance of this service by displaying a valid permit… in view of this they have accepted the charge (sic.)”:
    The letter introducing the service (WS Appendix D) states in no part that displaying a permit accepts any terms of a contract.
    The letter does not mention that the terms will provided on signage
    The letter does not mention any charges whatsoever, except a £5.00 charge for a replacement permit upon request.
    The letter does state, however:
    “The service will operate to alleviate the ongoing problems with unauthorised parking”
    Letter from UK CPM Ltd, (WS Appendix D, P47)

    This letter is dated 8th February 2013, prior to the service commencing on February 25th 2013. Given that the letter already accepts that there is ‘unauthorised’ (and thus, ‘authorised’) parking occurring prior to the start of their service. The Claimant is acknowledging residency as the primary (and thus, ultimate) authorisation for parking on the land.

    In any case, this letter and its associated permit do not take primacy over the signed Lease between the Lessor and Lessee, giving the Lessee the right to park on the land.
    RE: “The Defendant has not provide any evidence to support their alleged right to park” (#6):
    The Claimant addressed the Defendant exclusively at their address on ********, so was well aware of the residency, and the initial defence statement included the relevant portion from the lease. As a lay-defendant in this claim, this appears to be disingenuous.
    cFor clarity, however, the Witness Statement includes:
    the Driving License of the defendant as proof of residence ( WS Appendix A) - (this is, of course, where the Claimant got the Defendant’s address);
    The Land Registry Title Information as proof of ownership by [**********], husband of the Defendant (WS Appendix C);
    The Lease of Part relating to ********* establishing right to park and right of access. (Appendix B);
    The Legal Plan Plot of the land designating the areas included in right of access (not contended by the Claimant, but included for completeness) (WS Appendix H)
    Given the relevant cases on the primacy of the lease, and the addressing of the Claimants additional arguments here, it is asserted that this Claim should be dismissed.
    • Coupon-mad
    • By Coupon-mad 24th Jul 17, 8:01 PM
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    Coupon-mad
    Good example of a fightback, keep going!
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • CircusFrog
    • By CircusFrog 25th Jul 17, 3:21 PM
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    CircusFrog
    Case is day after tomorrow, was going to file Skeleton Arguments with the court tomorrow morning marked as urgent. Do I need to serve to Claimaint as well?
    • Johnersh
    • By Johnersh 25th Jul 17, 9:37 PM
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    Johnersh
    Technically you should, yes. The idea is that you should be able to win without an ambush.

    The skelly serves as a summary only to highlight key arguments to take the court direct to them. It should have nothing wholly new that the claimant won't have already seen/anticipated.
    • Coupon-mad
    • By Coupon-mad 25th Jul 17, 10:39 PM
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    Coupon-mad
    And your costs schedule if not already filed.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Johnersh
    • By Johnersh 26th Jul 17, 7:33 PM
    • 655 Posts
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    Johnersh
    25th Jul 17, 2:21 PM Case is day after tomorrow,
    All set for the hearing? What time are you on and in which Court?
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