IPC appeal PCN NW Limited

Coupon-mad

I think you can remove this bit about witness statements:


''It has also been widely reported that someparking companies have provided photocopied “witness statements” instead of therelevant contract. These highly questionable documents from parking operatorshave been exposed in the public domain as sometimes having had the date addedafter 'witness signature' by another person, adding a random date to suit acourt. These witness statements are therefore not relevant to a specific eventand the details are far too unreliable to confirm compliance of the contract asdefined in the BPA CoP and would fail to meet the level of certainty requiredfor a court decision. If PCN (NW) Ltd produce a 'witness statement' I contendthat there is no proof whatsoever that the alleged signatory on behalf of thelandowner has ever seen the relevant contract, or, indeed is even an employeeof the landowner. I require, if such a witness statement is submitted insteadof the landowner contract itself, that this is disregarded and that the ChiefAdjudicator is required to investigate this issue and consider carefully theserious irregularities known about these documents if the assessor in my caseis minded to consider one as evidence.''


...and I think you can reduce the stuff about James Simmons - just stick with two lines about what he did and state that he failed in his duty to mitigate any loss.


Post a reply with what you are then left with, tomorrow, so we can have another think in the daytime! We want you to win this, one of the first IPC cases.