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PCM Gladstones
HarryJimBob
Posts: 6 Forumite
Hi all
I'm finding this forum a massive help so I would like to start by saying thank-you to everyone on here!
The back story to this is that the driver had been to this flat for a few years but only recently they had changed the parking there to permit spaces only.
The driver didn't realize it had changed. The driver arrived late one evening and did not see the signs. Durning the middle of the night a Notice To Owner is issued on the widscreen. There is photographic evidence of this, however, you can see that the flash had to be used to be able to see the signs.
*unable to upload picture due to new user*
This is the sign in the daylight.
This is currently where I am at with my defense.
IN THE COUNTY COURT
CLAIM No:
Gladstone Solicitors
-and-
1.It is acknowledged that the defendant,
, residing at
is the registered keeper of the vehicle.
2. It is denied that any "parking charges or indemnity costs" (whatever they might be) as stated on the Particulars of claim are owed and any debt is denied in it's entirety.
3.1.1.The Particulars of Claim (POC) fail to meet the requirements of Practice Direction 16 7.5. The POC are incoherent, make no sense, and do not disclose any legally recognizable claim against the Defendant.
3.1.2. The POC contains no facts and are not clear and concise as required by CPR 16.4 (a). The Claimants are serial issuers of generic claims like this 'roboclaim!!!8217; given away in this case by typical, generic lack of detail. The Claimant failed to state if it is pursuing the Defendant as keeper or driver, and has not elaborated on the alleged 'breach of terms'. The Claimant claims an unsubstantiated £160 for ''Parking Charges/Damages'' despite the fact parking charges cannot be claimed as damages except by a landowner as a remedy for trespass, and cites ''indemnity costs if applicable'' whatever that is supposed to mean, bearing in mind the Claimant previously alleged this was about a single £60 charge.
3.1.3. Practice Direction 3A referring Civil Procedure Rule 3.4 illustrates this;1.4 The following are examples of cases where the court may conclude that particulars of claim (whether contained in a claim form or filed separately) fall within rule 3.4(2)(a):
- those which set out no facts indicating what the claim is about, for example, Money owed £5000
- those which are incoherent and make no sense,
- those which contain a coherent set of facts but those facts, even if true, do not disclose any legally recognizable claim against the defendant.'
4. Gladstone solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.
5. I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.
6. No evidence has been supplied by this claimant as to who parked the vehicle. Under the Protection of Freedoms Act 2012, there is no presumption in law as to who parked a vehicle on private land nor does there exist any obligation for a keeper to name a driver. I choose to defend this claim as the registered keeper, as is my right.
7. It is denied that the Claimant has authority to bring this claim. The proper Claimant (if any debt exists, which is denied) would be the landowner.
8.Parking terms cannot be re-offered by a third party contractor on a day-to-day basis (on far more onerous and potentially, completely variable terms) because these were never incorporated into the permission to park as granted by the landowner, which was a stand-alone contract, concluded at the point in time of the provision of a permit which carried very few terms of use and no 'parking charges' nor 'indemnity costs'.
9. In the event that the court finds a contract based on signage can supersede the permit terms already agreed and the lease, I put the claimant to strict proof of a chain of contracts leading from the landowner to this claimant which enable these charges to be pursued in court by this contractor, for these alleged contravention(s), whatever they may be.
10. The alleged debt as described in the claims are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.
11. It is not believed that the Claimant has incurred additional costs - be it legal or debt collector costs or even their unlawful, fixed sum card surcharge for payments - and they are put to strict proof that they have actually incurred and can lawfully add an extra sums and that those sums formed part of the permit/parking contract formed with the resident in the first instance.
12. It is denied that there was any 'relevant obligation' or 'relevant contract' relating to any single parking event.
13. Notwithstanding the provisions of the POFA and/or the existing easements, rights of way and the permit agreement already concluded, it is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event
14. This case can be easily distinguished from ParkingEye v Beavis which the Judges held was 'entirely different' from most ordinary economic contract disputes. Charges cannot exist merely to punish drivers. This claimant has failed to show any comparable 'legitimate interest' to save their charge from Lord Dunedin's four tests for a penalty, which the Supreme Court Judges found was still adequate in less complex cases, such as this allegation.
15. I request the court strike out this claims for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.
I confirm that the contents of this statement are true to the best of my knowledge and belief.
Signature:
Date:
I must admit, pretty much all of it has come from this website. However, I have bits together lots of different parts to make it relevant to me. the only part I am struggling with is explaining that the signage was inadequately lit.
I would love to hear any thoughts or ideas on how i could improve this.
Thank-you in advance.
I'm finding this forum a massive help so I would like to start by saying thank-you to everyone on here!
The back story to this is that the driver had been to this flat for a few years but only recently they had changed the parking there to permit spaces only.
The driver didn't realize it had changed. The driver arrived late one evening and did not see the signs. Durning the middle of the night a Notice To Owner is issued on the widscreen. There is photographic evidence of this, however, you can see that the flash had to be used to be able to see the signs.
*unable to upload picture due to new user*
This is the sign in the daylight.
This is currently where I am at with my defense.
IN THE COUNTY COURT
CLAIM No:
Gladstone Solicitors
-and-
1.It is acknowledged that the defendant,
, residing at
is the registered keeper of the vehicle.
2. It is denied that any "parking charges or indemnity costs" (whatever they might be) as stated on the Particulars of claim are owed and any debt is denied in it's entirety.
3.1.1.The Particulars of Claim (POC) fail to meet the requirements of Practice Direction 16 7.5. The POC are incoherent, make no sense, and do not disclose any legally recognizable claim against the Defendant.
3.1.2. The POC contains no facts and are not clear and concise as required by CPR 16.4 (a). The Claimants are serial issuers of generic claims like this 'roboclaim!!!8217; given away in this case by typical, generic lack of detail. The Claimant failed to state if it is pursuing the Defendant as keeper or driver, and has not elaborated on the alleged 'breach of terms'. The Claimant claims an unsubstantiated £160 for ''Parking Charges/Damages'' despite the fact parking charges cannot be claimed as damages except by a landowner as a remedy for trespass, and cites ''indemnity costs if applicable'' whatever that is supposed to mean, bearing in mind the Claimant previously alleged this was about a single £60 charge.
3.1.3. Practice Direction 3A referring Civil Procedure Rule 3.4 illustrates this;1.4 The following are examples of cases where the court may conclude that particulars of claim (whether contained in a claim form or filed separately) fall within rule 3.4(2)(a):
- those which set out no facts indicating what the claim is about, for example, Money owed £5000
- those which are incoherent and make no sense,
- those which contain a coherent set of facts but those facts, even if true, do not disclose any legally recognizable claim against the defendant.'
4. Gladstone solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.
5. I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.
6. No evidence has been supplied by this claimant as to who parked the vehicle. Under the Protection of Freedoms Act 2012, there is no presumption in law as to who parked a vehicle on private land nor does there exist any obligation for a keeper to name a driver. I choose to defend this claim as the registered keeper, as is my right.
7. It is denied that the Claimant has authority to bring this claim. The proper Claimant (if any debt exists, which is denied) would be the landowner.
8.Parking terms cannot be re-offered by a third party contractor on a day-to-day basis (on far more onerous and potentially, completely variable terms) because these were never incorporated into the permission to park as granted by the landowner, which was a stand-alone contract, concluded at the point in time of the provision of a permit which carried very few terms of use and no 'parking charges' nor 'indemnity costs'.
9. In the event that the court finds a contract based on signage can supersede the permit terms already agreed and the lease, I put the claimant to strict proof of a chain of contracts leading from the landowner to this claimant which enable these charges to be pursued in court by this contractor, for these alleged contravention(s), whatever they may be.
10. The alleged debt as described in the claims are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.
11. It is not believed that the Claimant has incurred additional costs - be it legal or debt collector costs or even their unlawful, fixed sum card surcharge for payments - and they are put to strict proof that they have actually incurred and can lawfully add an extra sums and that those sums formed part of the permit/parking contract formed with the resident in the first instance.
12. It is denied that there was any 'relevant obligation' or 'relevant contract' relating to any single parking event.
13. Notwithstanding the provisions of the POFA and/or the existing easements, rights of way and the permit agreement already concluded, it is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event
14. This case can be easily distinguished from ParkingEye v Beavis which the Judges held was 'entirely different' from most ordinary economic contract disputes. Charges cannot exist merely to punish drivers. This claimant has failed to show any comparable 'legitimate interest' to save their charge from Lord Dunedin's four tests for a penalty, which the Supreme Court Judges found was still adequate in less complex cases, such as this allegation.
15. I request the court strike out this claims for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.
I confirm that the contents of this statement are true to the best of my knowledge and belief.
Signature:
Date:
I must admit, pretty much all of it has come from this website. However, I have bits together lots of different parts to make it relevant to me. the only part I am struggling with is explaining that the signage was inadequately lit.
I would love to hear any thoughts or ideas on how i could improve this.
Thank-you in advance.
0
Comments
-
1) Have you acknowledged the claim?
2) What is the issue date?
Unlit signs are found in lots of defences.0 -
If your case is that the signs are not visible in the dark, then why is your case not built around that as the major plank with photos galore, reference as to the IPC standards for signage in the IPC Code of Practice (Google it) and where their signs fail.
The rest are "technical" and a judge may or may not look favourably on the points you raise, but not being able to see signs recently erected is a genuine point.0 -
Guys Dad, don't pictures come later, at Witness Statement stage?
HarryJimBob has put up his Defence for review.
0 -
Guys Dad, don't pictures come later, at Witness Statement stage?
HarryJimBob has put up his Defence for review.
Yes, but the main defence point is around signage and that should be most prominent. It is currently not the case. Reference to photographs can be made in the defence statement.0 -
This is an entirely unregulated industry which is scamming the public with inflated claims for minor breaches of contracts for alleged parking offences, aided and abetted by a handful of low-rent solicitors.
Parking Eye, CPM, Smart, and another company have already been named and shamed, as has Gladstones Solicitors, and BW Legal, (these two law firms take hundreds of these cases to court each year). They lose most of them, and have been reported to the regulatory authority by an M.P. for unprofessional conduct
Hospital car parks and residential complex tickets have been especially mentioned.
The problem has become so rampant that MPs have agreed to enact a Bill to regulate these scammers. Watch the video of the Second Reading in the HofC recently.
http://parliamentlive.tv/event/index/2f0384f2-eba5-4fff-ab07-cf24b6a22918?in=12:49:41
and complain in the most robust terms to your MP. With a fair wind they will be out of business by Christmas.You never know how far you can go until you go too far.0 -
nosferatu1001 wrote: »1) Have you acknowledged the claim?
2) What is the issue date?
Unlit signs are found in lots of defences.
Yes, I have acknowledged the claim, last Monday the 30th. The issue date on the claim fourm is 9th of april.
Thanks.If your case is that the signs are not visible in the dark, then why is your case not built around that as the major plank with photos galore, reference as to the IPC standards for signage in the IPC Code of Practice (Google it) and where their signs fail.
The rest are "technical" and a judge may or may not look favourably on the points you raise, but not being able to see signs recently erected is a genuine point.
Thank-you. I have made ajustments.
IN THE COUNTY COURT
CLAIM No:
Gladstone Solicitors
-and-
1.It is acknowledged that the defendant, ----, residing at
, is the registered keeper of the vehicle.
2. It is denied that any "parking charges or indemnity costs" (whatever they might be) as stated on the Particulars of claim are owed and any debt is denied in it's entirety.
3. The Defendant relies upon ParkingEye Ltd v Barry Beavis (2015) UKSC 67 insofar as the Court was willing to consider the imposition of a penalty in the context of a site of commercial value and where the signage regarding the penalties imposed for any breach of parking terms were clear - both upon entry to the site and throughout.
3.1The signage on this site was inadequate to form a contract with the motorist.
8.1.1The signage on and around the site in question was unclear and not prominent and did not meet the British Parking Association (BPA) Code of Practice or the International Parking Community (IPC) Code of Practice.
3.1.2The parking enforcement took place outside of daylight hours 02.36am (as per picture evidence that the Claimant supplied). The Claimant did not ensure that signs are illuminated nor were there sufficient other lighting. Hence making them unreadable during the hours of enforcement
3.2The Defendant avers that the residential site that is the subject of these proceedings is not a site where there is a commercial value to be protected. The Claimant has not suffered loss or pecuniary disadvantage. The penalty charge is, accordingly, unconscionable in this context, with ParkingEye distinguished.
4.1.1.The Particulars of Claim (POC) fail to meet the requirements of Practice Direction 16 7.5. The POC are incoherent, make no sense, and do not disclose any legally recognisable claim against the Defendant.
4.1.2. The POC contain no facts and are not clear and concise as required by CPR 16.4 (a). The Claimants are serial issuers of generic claims like this 'roboclaim!!!8217; given away in this case by typical, generic lack of detail. The Claimant failed to state if it is pursuing the Defendant as keeper or driver, and has not elaborated on the alleged 'breach of terms'. The Claimant claims an unsubstantiated £160 for ''Parking Charges/Damages'' despite the fact parking charges cannot be claimed as damages except by a landowner as a remedy for trespass, and cites ''indemnity costs if applicable'' whatever that is supposed to mean, bearing in mind the Claimant previously alleged this was about a single £60 charge.
4.1.3. Practice Direction 3A referring Civil Procedure Rule 3.4 illustrates this;1.4 The following are examples of cases where the court may conclude that particulars of claim (whether contained in a claim form or filed separately) fall within rule 3.4(2)(a):
- those which set out no facts indicating what the claim is about, for example Money owed £5000
- those which are incoherent and make no sense,
- those which contain a coherent set of facts but those facts, even if true, do not disclose any legally recognisable claim against the defendant.'
5. Gladstone solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.
6. I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.
7. No evidence has been supplied by this claimant as to who parked the vehicle. Under the Protection of Freedoms Act 2012 there is no presumption in law as to who parked a vehicle on private land nor does there exist any obligation for a keeper to name a driver. I choose to defend this claim as the registered keeper, as is my right.
8. It is denied that the Claimant has authority to bring this claim. The proper Claimant (if any debt exists, which is denied) would be the landowner.
9.Parking terms cannot be re-offered by a third party contractor on a day-to-day basis (on far more onerous and potentially, completely variable terms) because these were never incorporated into the permission to park as granted by the landowner, which was a stand-alone contract, concluded at the point in time of the provision of a permit which carried very few terms of use and no 'parking charges' nor 'indemnity costs'.
10. In the event that the court finds a contract based on signage can supersede the permit terms already agreed and the lease, I put the claimant to strict proof of a chain of contracts leading from the landowner to this claimant which enable these charges to be pursued in court by this contractor, for these alleged contravention(s), whatever they may be.
11. The alleged debt as described in the claims are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.
12. It is not believed that the Claimant has incurred additional costs - be it legal or debt collector costs or even their unlawful, fixed sum card surcharge for payments - and they are put to strict proof that they have actually incurred and can lawfully add an extra sums and that those sums formed part of the permit/parking contract formed with the resident in the first instance.
13. It is denied that there was any 'relevant obligation' or 'relevant contract' relating to any single parking event.
14. Notwithstanding the provisions of the POFA and/or the existing easements, rights of way and the permit agreement already concluded, it is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event
15. This case can be easily distinguished from ParkingEye v Beavis which the Judges held was 'entirely different' from most ordinary economic contract disputes. Charges cannot exist merely to punish drivers. This claimant has failed to show any comparable 'legitimate interest' to save their charge from Lord Dunedin's four tests for a penalty, which the Supreme Court Judges found was still adequate in less complex cases, such as this allegation.
16. I request the court strike out this claims for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.
I confirm that the contents of this statement are true to the best of my knowledge and belief.
Signature:
Date:0 -
If the issue date on your Claim Form is 9 April, then to gain extra days to file your Defence, the Acknowledgement of Service should have been done before 4pm on 30 April.HarryJimBob wrote: »nosferatu1001 wrote: »1) Have you acknowledged the claim?
2) What is the issue date?
Yes, I have acknowledged the claim, last Monday the 30th. The issue date on the claim fourm is 9th of april.
I hope you were in time.
If not, your Defence was due on 30 April at 4pm.
Why did you leave the Aos to the very very last minute?0 -
Sorry, i got that completely wrong. I replied the money before. The 23rd.If the issue date on your Claim Form is 9 April, then to gain extra days to file your Defence, the Acknowledgement of Service should have been done before 4pm on 30 April.
I hope you were in time.
If not, your Defence was due on 30 April at 4pm.
Why did you leave the Aos to the very very last minute?0 -
Then, as you probably know, you have until 4pm on Monday 14th May to file your Defence.
You would be wise to remove your claim number from post #7.
In your Defence, the Claimant is not Gladstones Solicitors.
Who are they representing?
The Claimant is specified on the Claim Form.
Point 8.1.1 should be 3.1.1.
No need for 'residing at
,' in point 1.
Points 6. and 16. revert to 'first person'.0 -
Then, as you probably know, you have until 4pm on Monday 14th May to file your Defence.
You would be wise to remove your claim number from post #7.
In your Defence, the Claimant is not Gladstones Solicitors.
Who are they representing?
The Claimant is specified on the Claim Form.
Point 8.1.1 should be 3.1.1.
No need for 'residing at
,' in point 1.
Points 6. and 16. revert to 'first person'.
Thank-you for your reply.
IN THE COUNTY COURT
CLAIM No:
Parking Control Management
-and-
1.It is acknowledged that the defendant,
, is the registered keeper of the vehicle.
2. It is denied that any "parking charges or indemnity costs" (whatever they might be) as stated on the Particulars of claim are owed and any debt is denied in it's entirety.
3. The Defendant relies upon ParkingEye Ltd v Barry Beavis (2015) UKSC 67 insofar as the Court was willing to consider the imposition of a penalty in the context of a site of commercial value and where the signage regarding the penalties imposed for any breach of parking terms were clear - both upon entry to the site and throughout.
3.1The signage on this site was inadequate to form a contract with the motorist.
3.1.1The signage on and around the site in question was unclear and not prominent and did not meet the British Parking Association (BPA) Code of Practice or the International Parking Community (IPC) Code of Practice.
3.1.2The parking enforcement took place outside of daylight hours 02.36am (as per picture evidence that the Claimant supplied). The Claimant did not ensure that signs are illuminated nor were there sufficient other lighting. Hence making them unreadable during the hours of enforcement
3.2The Defendant avers that the residential site that is the subject of these proceedings is not a site where there is a commercial value to be protected. The Claimant has not suffered loss or pecuniary disadvantage. The penalty charge is, accordingly, unconscionable in this context, with ParkingEye distinguished.
4.1.1.The Particulars of Claim (POC) fail to meet the requirements of Practice Direction 16 7.5. The POC are incoherent, make no sense, and do not disclose any legally recognisable claim against the Defendant.
4.1.2. The POC contain no facts and are not clear and concise as required by CPR 16.4 (a). The Claimants are serial issuers of generic claims like this 'roboclaim’ given away in this case by typical, generic lack of detail. The Claimant failed to state if it is pursuing the Defendant as keeper or driver, and has not elaborated on the alleged 'breach of terms'. The Claimant claims an unsubstantiated £160 for ''Parking Charges/Damages'' despite the fact parking charges cannot be claimed as damages except by a landowner as a remedy for trespass, and cites ''indemnity costs if applicable'' whatever that is supposed to mean, bearing in mind the Claimant previously alleged this was about a single £60 charge.
4.1.3. Practice Direction 3A referring Civil Procedure Rule 3.4 illustrates this;1.4 The following are examples of cases where the court may conclude that particulars of claim (whether contained in a claim form or filed separately) fall within rule 3.4(2)(a):
- those which set out no facts indicating what the claim is about, for example Money owed £5000
- those which are incoherent and make no sense,
- those which contain a coherent set of facts but those facts, even if true, do not disclose any legally recognisable claim against the defendant.'
5. Gladstone solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.
6. It is suggested that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.
7. No evidence has been supplied by this claimant as to who parked the vehicle. Under the Protection of Freedoms Act 2012 there is no presumption in law as to who parked a vehicle on private land nor does there exist any obligation for a keeper to name a driver. I choose to defend this claim as the registered keeper, as is my right.
8. It is denied that the Claimant has authority to bring this claim. The proper Claimant (if any debt exists, which is denied) would be the landowner.
9.Parking terms cannot be re-offered by a third party contractor on a day-to-day basis (on far more onerous and potentially, completely variable terms) because these were never incorporated into the permission to park as granted by the landowner, which was a stand-alone contract, concluded at the point in time of the provision of a permit which carried very few terms of use and no 'parking charges' nor 'indemnity costs'.
10. In the event that the court finds a contract based on signage can supersede the permit terms already agreed and the lease, I put the claimant to strict proof of a chain of contracts leading from the landowner to this claimant which enable these charges to be pursued in court by this contractor, for these alleged contravention(s), whatever they may be.
11. The alleged debt as described in the claims are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.
12. It is not believed that the Claimant has incurred additional costs - be it legal or debt collector costs or even their unlawful, fixed sum card surcharge for payments - and they are put to strict proof that they have actually incurred and can lawfully add an extra sums and that those sums formed part of the permit/parking contract formed with the resident in the first instance.
13. It is denied that there was any 'relevant obligation' or 'relevant contract' relating to any single parking event.
14. Notwithstanding the provisions of the POFA and/or the existing easements, rights of way and the permit agreement already concluded, it is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event
15. This case can be easily distinguished from ParkingEye v Beavis which the Judges held was 'entirely different' from most ordinary economic contract disputes. Charges cannot exist merely to punish drivers. This claimant has failed to show any comparable 'legitimate interest' to save their charge from Lord Dunedin's four tests for a penalty, which the Supreme Court Judges found was still adequate in less complex cases, such as this allegation.
16. It is requested that the court strike out this claims for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.
I confirm that the contents of this statement are true to the best of my knowledge and belief.
Signature:
Date:
I am faily happy with this and shall be sending it.
i am wanting to send this via email so should i print it out, sign it and scan it back in? or would writing my name be adequate?0
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