CCJ and my Credit Score- All correspondence sent to address from 2013

zebrarose

zebrarose wrote: »

Also, what is it that gets sent off with the N244 set aside application?
So far I have:
-Draft order
-Witness Statement
- Schedule of costs
- PoFa schedule 4
- Part 27 of the Small Claims Track
- Annual 2015 Greenway understanding keeper liability
- Beavis case signage
- Case Law:

• PCM v Mr Bull
• Excel v Lamoureux
• Jopson v Homeguard
• Pace v Mr N
• Saeed v Plustrad
• Link Parking v Mrs P

- Copy of my Tenancy agreement
- Photographic evidence of the site and the signage
- Video evidence of the site and the signage
- Copies of each of my drivers licence's at every address I've lived at as a gesture of compliance


Thanks in advance for any assistance




Would anyone be able to look through my WS please?
https://1drv.ms/w/s!Apr4KxqM2VPBmHQsX8O_RCz9JbBr

Would anybody be able to assist with these questions please...

Could anyone please proof read the WS?

Timothea

Regarding rights of audience, I found two other sources that may help to clarify matters. The first is an article by District Judge Robert Hill in The Law Society Gazette in 2010, which is most illuminating:

https://www.lawgazette.co.uk/law/right-of-audience/57199.article

DJ Hill is (or was) a member of the Civil Procedure Rules Committee.

The second is statement by the Chartered Institute of Legal Executives of its members' rights of audience, which are basically the same as any other unqualified advocates:

http://www.cilex.org.uk/membership/practice_advice/rights_of_audience/members_rights_of_audience

I think that both of these could be helpful in court.

zebrarose

Timothea wrote: »

Regarding rights of audience, I found two other sources that may help to clarify matters. The first is an article by District Judge Robert Hill in The Law Society Gazette in 2010, which is most illuminating:

https://www.lawgazette.co.uk/law/right-of-audience/57199.article

DJ Hill is (or was) a member of the Civil Procedure Rules Committee.

The second is statement by the Chartered Institute of Legal Executives of its members' rights of audience, which are basically the same as any other unqualified advocates:

http://www.cilex.org.uk/membership/practice_advice/rights_of_audience/members_rights_of_audience

I think that both of these could be helpful in court.

Thank you for those. I have those printed for the judge.
Any help with the below:

In the County Court at Hertford

Claim No.: Xxxxxxxxx

Between:

Parking & Property Management Limited (Claimant)

-v-

Defendant Name

(Defendant)

DEFENDANT’S SCHEDULE OF COSTS





Ordinary Costs





Loss of earnings/leave, incurred through attendance at Court …../….../2017 £72.00

Return mileage from home address to Court (e.g. 2 miles x £0.45) £0.90

Parking near Court £5.00

Sub-total £77.90 ======



Further costs for Claimant’s unreasonable behavior, pursuant to Civil Procedure Rule 27.14(2)(g)

Research, preparation and drafting of documents (10 hours at Litigant in Person rate of £19 per hour) £190.00

Stationery, printing, photocopying and postage: £15.00


Reimbursement of Set Aside fee: £255.00


Loss of tenant referencing fee: £175.00

Sub-total £635.00 ======





£ 712.90 TOTAL COSTS CLAIMED

Coupon-mad

Yes, go for it. Including this bit:

Loss of tenant referencing fee: £175.00

Will mean you must take evidence for your planned counter-claim, to court with you, and ask for suitable Directions including the counter-claim once the CCJ is set aside.

zebrarose

Ok, I will prepare a counter claim. From my research, a counter claim is submitted with the defence after being served, right?

Coupon-mad

Yes, with the defence. And you would need to ask the court when to pay the £25 for your claim.

zebrarose

First things first though.... is anyone free to check my Witness Statement?

https://1drv.ms/w/s!Apr4KxqM2VPBmQPbNrOIeve2fBmQ

zebrarose

Is the skeleton submitted with the WS or defence?

zebrarose

Coupon-mad wrote: »

Yes but you'd have to write a counter-claim. You can tell the Judge at your set aside hearing that you intend to counter-claim once the case is set aside to start again, and ask if his/her Directions can take account of the intended counter-claim. You'd have to have details of that loss with you as well, to prove you have the basis of a case to counter-claim. Be prepared, take it all with you.

Alternatively, claim afterwards, once you've got through this, defended and won this case.

zebrarose wrote: »

Is Gladstones address:


22 Market Place, Arnold, Nottingham. Nottinghamshire, NG5 6ND
OR
The Terrace, High Legh Park Golf Club, Warrington Road, High Legh, Knutsford, Cheshire, WA16 6AA?


Also, is the Claimants name Gladstones or the PPC?


When referencing the Beavis case regarding the signage, is it this part:

2.3 At all material times since then, the Claimant has displayed about 20 signs at
the entrance to the car park and at frequent intervals throughout it. The Defendants
do not dispute that the signs are reasonably large, prominent and legible, so that
any reasonable user of the car park, including themselves, would be aware of their
existence and nature and would have a fair opportunity to read them if they wished.
2.4 The signs are worded as follows (the words I have underlined being especially
large and prominent, and the words I have italicised being in small print but still
legible if one wished to read them)

I also revisited the site and they have 5 very conspicuously placed signs covered by foliage and with small print. I took pictures to bring into court for when I finish this WS. My WS is so big it seems more or less the same as a skeleton. Is a skeleton necessary? I know it is supposed to help you and the judge see it clearly, but it is so overwhelming.


Could anyone please have a look at the link to what I have so far:
https://1drv.ms/w/s!Apr4KxqM2VPBmHQsX8O_RCz9JbBr

Do I submit the photos and video with the WS? What is an acceptable form of video I.e cd, USB or on your phone at the hearing?

DoaM

zebrarose wrote: »

Is the skeleton submitted with the WS or defence?

The skeleton is submitted ideally a few days before the hearing, but you can sometimes get away with just taking it on the day.

The point of the skeleton is to give a "Noddy's Guide" through your own Defence and Witness Statement.

What needs to be submitted when is covered in the Court section of the NEWBIES FAQ - post #2. Surely you've bookmarked the NEWBIES FAQ for ready-reference?