Parking Awareness Service (PAS) PCN

Coupon-mad

Yes you must mention all your exhibits and what aspect they support.

In relation to the signage, I have never in my life been to this car park and so I have absolutely no idea what the signage there is like.

We know. But you MUST cover signs - it is key!

Shift the burden to the claimant which is why I worded my suggestion the way I did, about them being put to proof that the driver would have seen a prominent contractual sign (my earlier words were better).

And you cannot miss the chunk of words you need about the DLUHC Code, from the WS I signposted you to (not his first attempt, his finished version, of course, which includes an extra paragraph about why the new code still matters, despite the parking industry blocking and delaying it). You must attack the extortion of the added £60.

johjames

Coupon-mad said:

Yes you must mention all your exhibits and what aspect they support.

In relation to the signage, I have never in my life been to this car park and so I have absolutely no idea what the signage there is like.

We know. But you MUST cover signs - it is key!

Shift the burden to the claimant which is why I worded my suggestion the way I did, about them being put to proof that the driver would have seen a prominent contractual sign (my earlier words were better).

And you cannot miss the chunk of words you need about the DLUHC Code, from the WS I signposted you to (not his first attempt, his finished version, of course, which includes an extra paragraph about why the new code still matters, despite the parking industry blocking and delaying it). You must attack the extortion of the added £60.

No problem, I will add to my WS, in relation to the signage and put the Claimant to strict proof. I will also add the section about the DLUHC Code. Once I've amended my WS, I'll see if I can post it properly here. Thanks once again for your kind help.

Le_Kirk

I, Dr. X, I am Dr X a medical doctor, of xx xxxx Road, xxxx xxx xxx and will state as follows:

You might be able to deal with a split appendix but we do not like split infinitives, just change as above.  Not sure either that you need to clarify what sort of Doctor you are unless it is relevant to the defence/WS.

Umkomaas

You might be able to deal with a split appendix but we do not like split infinitives

😄.        

johjames

Le_Kirk said:

I, Dr. X, I am Dr X a medical doctor, of xx xxxx Road, xxxx xxx xxx and will state as follows:

You might be able to deal with a split appendix but we do not like split infinitives, just change as above.  Not sure either that you need to clarify what sort of Doctor you are unless it is relevant to the defence/WS.

Thanks Le Kirk, I've amended, and thanks for brightening my day a little whilst I plod through this!

johjames

Thank you to all who provided advice on my WS. Is it possible to upload a PDF to a post on here please, so that I can attach the amended version for critique please? Thank you.

Coupon-mad

For some unexplained reason, PDFs are not allowed here but you can show a jpeg image - make sure it's fully sanitised of your data, claim number etc.

Or you can host a redacted PDF in Dropbox and post a shared link for 'anyone to view'.

johjames

Coupon-mad said:

For some unexplained reason, PDFs are not allowed here but you can show a jpeg image - make sure it's fully sanitised of your data, claim number etc.

Or you can host a redacted PDF in Dropbox and post a shared link for 'anyone to view'.

Thank you Coupon-mad, WS to follow!

johjames

To all that have commented and provided suggestions at every stage of this process to date, thank you, your input has been both kind and invaluable.
I have attached a Dropbox link to my anonymised WS file. On page 10, there is an exhibit reference number in red. This references the 125 pages of communications that I have had from PAS, legal firms and debt collectors in relation to these two PCN's. I'm aware that this is an enormous amount of paper to print and so I highlighted it. Is it worth including all these documents as evidence of the relentless nature of PAS's efforts to extort money from me?

https://www.dropbox.com/s/pxqguhrbycm5x3g/1 PAS trial bundle anon.pdf?dl=0

Coupon-mad

In 56 you have 'Despite of this' (a typo).

In 29 I would add that the Excel v Smith case was first decided wrongly by a District Judge and then was re-heard on appeal by a Circuit Judge. It is persuasive on parking claims dealing with the same fact of law.