PCN - help wanted please

duffyscouse

Cheers I will take a look and comply

duffyscouse

Looks like I have messed up - I have spotted (I foolishly tried to appeal)

and admitted I did go to the adjacent restaurant to collect food prior to going into the shop - my argument now cn only be poor unclear signage and that I was a customer as I made a purchase (They admit in their papers that I made a purchase AFTER I returned to the car) The 2 shops are adjacent and there are NO boundary marks or signs to let you know you are entering or leaving the area.

KeithP

Re-read posts #76 - #79 above, where lack of any site boundary is discussed.

Coupon-mad

Then you must stick with that story for consistency in your WS, but of course:

The 2 shops are adjacent and there are NO boundary marks or signs to let you know you are entering or leaving the area.

Have you got an aerial view from Google Maps to show the Judge where these shops are and that there are no fences between? Get one and include it with your WS and it supports your defence that - how could anyone know what constitutes 'off site'?

duffyscouse

Ideal I’d be far happier being completely truthful as I have remained thus far - it’s the principal I’m unhappy about, being hounded for unjust payment when I was a customer of the shop

Coupon-mad

Good, so let that all come across, but to convince the Judge from a contract law point of view, it's evidence that will win it. Hence an aerial view so he/she can see what you mean about this site with adjacent shops and no idea which shops you can and can't use.

Make sure you also put into evidence the proof you used the shop the PPC say you didn't, of course, to prove patronage, and the voice recording you mentioned earlier about their 'till clock' not being reliable:

I have a voice recording at a later date where I question the till time of another purchase on a different day that clearly involves the shop owner and I discussing the time stamp and it is wrong

How are you going to produce this voice recording now to the court and claimant in a format that they will be able to play easily (NOT JUST A LINK IN YOUR WS).

USB stick in the post, then take it with you plus your laptop on the day?

Plan now, and make sure ALL of your evidence is filed & served in a format that the other side can't object to (and put in your bundle for the hearing, proof of anything emailed or posted to the Claimant in case they pretend at trial that you never served it).

duffyscouse

Will do thanks

Redx

you could also add the recording as an mp3 to the storage on your phone and use any player to play it back, same as you would with music files

same applies as mp4 for video files

duffyscouse

The store owner posed happily for a photo on my smart phone - just after I left his store - guess what - it’s a live photo where he says I don’t have to pay and don’t listen to the ticket issuer - good dust I have just found and it’s date stamped

Coupon-mad

Good to have that too, albeit it's not his decision!

Make sure you do file & serve these with your WS and other evidence in advance tomorrow, so no-one can object to you playing them.