Letter for money claims online and HM Courts and tribunals

I've taken some ideas and thoughts from other letters as well as adding my own views. Any thoughts and ideas on where I might need to edit this would be greatly appreciated

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DEFENCE STATEMENT
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I assert that I am not liable to the Claimant for the sum claimed, or any amount at all, for the
following reasons:

1.
I am the registered keeper of the vehicle in question. The Claim relates to an alleged debt arising from my vehicle having been parked in the Summer 2017 in Castle car park in Windsor.
2.
I was late by 10-12 minutes and requested that due to my recently torn calf muscle I be allowed to have some flexibility due to my injury. The injury can clearly be seen as I struggle to the car on crutches and I am in a walking cast.
The allegation appears to be an ‘overstay’ by 12 minutes, timed by their ANPR camera at the entrance and exit. However, the extra few minutes is explained by the longer time it takes me to get in and out of the car safely, with assistance, plus the time to drive in/out of the car park. The applicable 2014 BPA CoP states at 16: ‘The Equality Act 2010 says that providers of services to the public must make ‘reasonable adjustments’ to remove barriers which may discriminate against disabled people...
You and your staff also need to realise that some disabled people may take a long time...
You should allow the driver a reasonable period to leave the private car park after the parking contract has ended, before you take enforcement action.’
3.
I believe that your signs fail the test of 'large lettering' and prominence, as established in ParkingEye Ltd v Beavis. Due to my damaged leg (torn calf muscle) and allowing people to park in front of the sign I was unable to gain a close view of its terms and conditions.
4.
I followed all appeals procedures but the independent review procedure never sent me a letter to confirm whether my review case was declined or not. I am still waiting for the independent review letter or email or phone call to be sent or made.
5.
I offered what I deemed to be fair amount of 1 hour’s parking payment, for the 10-12 minutes of extra parking. This was rejected.
6.
I submit that I was not afforded any method by which to appeal, nor any information about complaints procedures to the landowner. This omission prevented me from being able to get this charge cancelled by the Retailer, a right that I believe existed as an exemption clause for shoppers written into the landowner contract/retailer user manual but a material fact which is withheld from consumers. If I could have appealed to POPLA or had been informed that the Retailer/landowner could deal with such complaints and cancel charges, I would have done so.
7.
In order to issue parking charges, and to pursue unpaid charges via litigation, the
Claimant is required to have the written authority of the landowner, on whose behalf they are acting as an agent. No evidence of such authority has been supplied by the Claimant or their legal representatives, and the Claimant is put to strict proof of same, in the form of an underacted and contemporaneous contract, or chain of authority, from the landowner to the Claimant. A Managing Agent is not the Landowner.
8.
The Claimant’s representatives,...., have artificially inflated the value of the Claim from £100 to £238. 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, ..... appear to be in contravention of the Solicitors ’Regulation Authority Code of Conduct.
9.
The letter I received from the lawyer to inform me that they were looking to be in contact, looked fraudulent due to the spelling and punctuation errors, including words inserted into the telephone number. This now includes the letter where apparently, I am of the female gender, when I am male.
10.
I did make a further offer to the solicitor of .... representing ..... but I have never heard back from them, in either voice message or email.
11.
The Court is invited to dismiss the Claim, and to allow such Defendant’s costs as are permissible under Civil Procedure Rule 27.14.
12.
Should you obtain the registered keeper's data from the DVLA without reasonable cause, please take this as formal notice that I reserve the right to sue your company and the landowner/principal, for a sum not less than £250 for any Data Protection Act breach. Your aggressive business practice and unwarranted threat of court for the ordinary matter of a driver using my car without causing any obstruction nor offence, has caused significant distress to me.
I do not give you consent to process data relating to me or this vehicle, nor have I ever given you consent to process data relating to me or this vehicle. I deny liability for any sum at all and you must consider this letter a Section 10 Notice under the DPA. You are required to respond within 21 days. I have kept proof of submission of this appeal and look forward to your reply.


I believe the facts stated in this Defence Statement are true...............................