Help required - OH Court date in under 3 weeks and been ill!

Stevey

Coupon-mad wrote: »

Yes you can.

They have to show the NTK anyway, but you can pre-empt it and put them to strict proof.

You can show a close up screenshot of the wording on that one from the thread I linked and say as one of her points in the WS, that whilst she has mislaid the Notice to Keeper, she has researched it and found that this Claimant does not use the POFA so have no grounds to pursue her as registered keeper (see evidence #11 - or whatever - which would be the close up of the typical HX wording saying they 'assume' the keeper is the driver).

You can also include barrister and parking law expert (erstwhile PATAS and POPLA Lead Adjudicator) Henry Greenslade's words from the POPLA Annual Report 2015, that state clearly that there is no such lawful presumption.

You do not have to say, unless the Judge directly asks your wife. If that happens then she can say she was, but otherwise, it's the Claimant's claim to prove.

To see other defences and WS that use that piece of evidence (one page from the report) search the forum for 'Greenslade defence Annual Report presumption'.

OK - First stab at Witness Statement so far - just missing some stuff in relation to spurious charges added on and stuff in relation to pre-action protocol compliance, which I'm not overly convinced will be a winner.

Many thanks for the help to even get this far - I would never have thought it when I first set out on this journey.

Witness Statement


Claim Number xxx

xxx (Claimant) v xxx (Defendant)

xxx
xxx
Post Code

Dated xxx



I am the Defendant in this matter, with no experience of Court procedures. I request that XXXX attend and act as my lay representative. If I do not set out documents in the way that the Claimant may do, I trust the Court will excuse my inexperience.
In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.



1. I am the registered keeper of the vehicle with VRN


2. On the (DATE) the driver of vehicle VRN parked in Westgate Arcade Car Park, walked to the pay and display machine, purchased a ticket for 1 hour.

3. I received an envelope containing a postal Parking Charge Notice to Keeper from HX Car Park Management Ltd, but I have misplaced this original letter.

4. However, having researched other Notice to Keepers by the Claimant online, I am confident the Claimant provided no evidence of who was driving the car and cannot presume that the Registered Keeper was the driver at the time of the alleged contravention.
The Registered Keeper can only be held liable under the Protection of Freedoms Act 2012 (POFA 2012) if the Claimant meets the Notice to Keeper obligations of Schedule 4 of POFA 2012. The Notice to Keeper does not include 9(2)f from Schedule 4, which is the mandatory warning about keeper liability after the prescribed 28 day period. Therefore according to POFA 2012, I cannot be liable as the keeper for the alleged debt of the driver. As the Claimant's notice is not fully compliant with the statutory wording, the Claimant is unable to hold the Keeper of car liable under the strict 'keeper liability' provisions.

5. To support this I rely upon the words of barrister and parking expert Lead Adjudicator for PATAS and POPLA, Henry Michael Greenslade, where he clarified in the POPLA Annual Report 2015 in a heading: 'Understanding Keeper Liability' that 'however keeper information is obtained, there is no reasonable presumption in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Further, a failure by the recipient of a notice issued under Schedule 4 to name the driver, does not of itself mean that the recipient has accepted that they were the driver at the material time. Unlike, for example, a Notice of Intended Prosecution where details of the driver of a vehicle must be supplied when requested by the police, pursuant to Section 172 of the Road Traffic Act 1988, a keeper sent a Schedule 4 notice has no legal obligation to name the driver.


6. Whilst HX Car Park Management Limited are listed as the claimant for this case, I have downloaded the title deeds and plan for the Westgate Car Park and can find no proof of whether there is any contractual arrangement between the Claimant and the owner or occupier of the land in question, or, if such a contractual arrangement exists, what the terms of that arrangement are. The Title Deeds for the land (Evidence Bundle Exhibit X) show the owner of the Land to be a company called Due West Limited (Incorporated in Cayman Islands B.W.I.).


7. I therefore assert that the Claimant has no Locus Standi to bring this claim because:

The party HX Car Park Management Limited in the Parking Contract, is claimed has the right to grant the rights in the Parking Contract. HX Car Park Management Limited is not the landowner or another entity proven to be authorised by the landowner. No proof of a formal agreement between the landowner Due West Limited (Incorporated in Cayman Islands B.W.I.) and HX Car Park Management Limited has been provided by the Claimant and therefore the Claimant has failed to establish an express conferral of rights has taken place pursuant to Section 1(1)(a) and 1(3) of the Contracts (Rights of Third Parties) Act 1999 which require terms to identify the Claimant and express terms granting the Claimant the right to enforce the contract; or the right to sue.

8. Also Part B Paragraph 1.1 of the the Independent Parking Committee (IPC) Code of Practice (CoP) that the Claimant is subject to as a Trade Association member specifically provides that the Claimant must have written authorisation of the landowner (see Evidence Bundle Exhibit X). Compliance with the CoP is mandatory. Implicit in this is that Claimant would have no rights under the Parking Contract if they were not granted by the landowner.


9. Strict proof is required that there is an assignment of contractual rights from the landowner to the Claimant. The Claimant has failed to establish an express conferral of rights has taken place pursuant to Section 1(1)(a) and 1(3) of the Contracts (Rights of Third Parties) Act 1999 which require terms to identify the Claimant and express terms granting the Claimant the right to enforce the contract; or the right to sue. This proof should also explain how such a legal assignment has taken place between a company based in the Cayman Islands, and HX Car Park Management Limited, a UK based company.

10. I also note from the Title Deeds to the land on which the Westgate Arcade Car Park is wholly situated upon, that the address of the land is completely different to the address to which the Parking Contract refers, which calls into question whether this contract can be assumed to have been formed correctly between the Driver and the Claimant. The address to which the Notice to Keeper refers is Westgate Car Park, Horton Street, Halifax, HX1 1PU. The Address of the land upon which the Westgate Car Park is wholly situated is in a different street, and has a different postcode, the address being 22-24 Westgate, Halifax, HX1 1DJ. As no Notice to Keeper has been sent for the address of land upon which the alleged contract was formed, it is held that no proper contract has been formed between Driver and Claimant.

11. I also deny that a contract was formed between the Claimant and the Defendant, as no offer was communicated by the Claimant, effectively or at all, that was capable of acceptance by the Defendant, expressly, by conduct, or at all.

12. Subsequent to receiving the Parking Charge Notice (PCN) I visited the car park in question, and I noticed a sign was in place at the entrance (See Evidence Bundle Exhibit XX). Having used this car park previously I did not remember the sign(s) being in place, and they looked new. I therefore went to look at online maps of the area, and found current images copyrighted for 2017, that showed no signs at the entrance to the car park. I have attached these images (See Evidence Bundle Exhibit XX) and I therefore put the Claimant to strict proof to demonstrate that the signs on site at Westgate Arcade Car Park were actually in place on the date that the alleged Parking Contract was formed. If the Claimant cannot demonstrate that the signs were actually in place at the date and time the alleged Parking Contract was formed, then this would contravene the IPC Code of Practice, Part B (2) Section 2.1,2.2 as no opportunity was provided for a Driver to agree to any contractual terms in relation to parking on private land, or in other words, there was no sign communicating any contractual terms to drivers.


13. Even in the event that the Claimant is able to demonstrate the current signs were in place at the time of the Drivers alleged contractual contravention, the current signage is also not sufficient to prove a contract was formed between the Driver and the Claimant.


14. The entrance sign mentions terms and conditions and lists them but does not go on to mention all of the terms and conditions. It references the sign at the pay & display machine for full terms & conditions. The pay & display sign does not contain full terms and conditions, there is only reference to full terms & conditions. This is contrary to the IPC Code of Practice, Part E, Schedule 1 - Signage, Entrance Signs. (See Evidence Bundle Exhibit XX).


15. The text size of the entrance signage means that it is not readable by a motorist in a moving vehicle, or at the very best not easily read contrary to IPC Code of Practice, Part E, schedule 1 - Signage, Text size. (See Evidence Bundle Exhibit XX).
Signage is not clearly legible and placed in such position that a driver is able to clearly see them on entering and parking a vehicle, contrary to IPC Codes of Practice, Part E, Schedule 1, signage, Other Signs, condition 4. Example of signage where the vehicle was parked, (See Evidence Bundle Exhibit XX). This sign is fixed to a wall some 7ft 10inch (236cm) high (measured from pavement to bottom of the sign).

16. Signage does not contain text appropriate to position and relative position of the person who is reading it, this is particularly apparent with the entrance sign and repeater signs around the car park. Pages 32,37,38, contrary to IPC Codes of Practice, Part E, Schedule 1 - signage, Other Signs, condition 6. (See Evidence Bundle Exhibit XX).

17. I have also checked with the local planning authority, Calderdale Council, and I can find no advertising consent for either the signs in the Westgate Car Park. The Claimant is put to strict proof to demonstrate that they do indeed hold the required advertising consent. Failure to demonstrate this would mean the Claimant is likely committing a criminal offence under Regulation 30 of the Town and Country Planning (Control of Advertisements)(England) Regulations 2007 (as amended), because advertising consent has not been given by Calderdale Council for the signs. Should this be the case I believe the court should not lend its aid to a Claimant who founds a claim based on an unlawful act pursuant to the doctrine ex dolo malo non oritur actio.




I believe that these facts stated in this witness statement are true.

Coupon-mad

3. I received [STRIKE]an envelope containing[/STRIKE] a postal Parking Charge Notice [STRIKE]to Keeper[/STRIKE] from HX Car Park Management Ltd, but I have misplaced this original letter.

The 'envelope containing' is unnecessary and made me think it was a windscreen PCN.

Independent Parking Committee (IPC)

Not any more

=

International Parking Community (IPC)

KeithP

Superfluous word either in paragraph 17.

Stevey

Coupon-mad wrote: »

The 'envelope containing' is unnecessary and made me think it was a windscreen PCN.




Not any more

=

Hmm - kicking myself for the Schoolboy error - now removed.

Thanks

Coupon-mad

OK I have deleted the quote.

Stevey

Coupon-mad wrote: »

OK I have deleted the quote.

OK - I've slightly updated my Witness Statement, and have gone to town on the charges as well. Any further thoughts welcome - intending to submit these to the Claimant in the near future.

A few questions regarding the statement and the bundle:

1) Do I need to include copies of CPR where referenced? I would assume the Judge will be extremely familiar with these!

2) Where I am using photo evidence, can I also supply media with original photos eg a CD? This would allow better scrutiny of the photos of signs for instance.

3) I took a video of entering the car park, to demonstrate how difficult it is (impossible!) to form a contract when arriving - again what format should this be provided in - do I burn a CD, provide a memory stick?

4) I have quoted Henry Greenslade re: POFA - I couldn't find a copy of the Annual Report in question - can someone provide a link?

5) Is it OK to send the Witness Statement and then send the evidence Exhibits separately a few days later? It would give me more time to annotate the various exhibits in the bundle. If not, I'll do my best otherwise.

6) Main evidence question - the title deed I downloaded from OS Site says it is not Court Admissible, and that I have to write to them for such a version which will take a week, and cost £14. Can I send the interim versions with the Evidence bundle, and later send the "Legal" versions? Can I claim back these costs?

7) My actual proof of non compliance with advertising consent is a screenshot of the Planning portal showing no applications for the relevant property. Is this enough? If not, what would be needed from the Council to support this?

8) I've decided not to include anything on non-compliance with pre-action protocol - lack of time, and evidence are the main reasons, unless anyone feels it is really worth it?

Once again, thank you so much!

Witness Statement


Claim Number xxx

xxx (Claimant) v xxx (Defendant)

xxx
xxx
Post Code

Dated xxx




I am the Defendant in this matter, with no experience of Court procedures. I request that XXXX attend and act as my lay representative. If I do not set out documents or arguments in the way that the Claimant may do, I trust the Court will excuse my inexperience.
In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.



1. I am the registered keeper of the vehicle with VRN XXXX


2. On the (DATE) the driver of vehicle VRN XXXX parked in Westgate Arcade Car Park, walked to the pay and display machine, and according to the Claimant!!!8217;s letter purchased a pay and display ticket for 1 hour.

3. I received an envelope containing a postal Parking Charge Notice to Keeper from HX Car Park Management Ltd asking for a payment of £100, reduced to £60 if paid within 14 days, but I have misplaced this original letter.

4. However, having researched other Notice to Keepers by the Claimant online, I am confident the Claimant provided no evidence of who was driving the car and cannot presume that the Registered Keeper was the driver at the time of the alleged contravention.
The Registered Keeper can only be held liable under the Protection of Freedoms Act 2012 (POFA 2012) if the Claimant meets the Notice to Keeper obligations of Schedule 4 of POFA 2012. The Notice to Keeper from the Claimant does not include 9(2)f from Schedule 4, which is the mandatory warning about keeper liability after the prescribed 28 day period (See Evidence Bundle Exhibit X). Therefore according to POFA 2012, I cannot be liable as the keeper for the alleged debt of the driver. As the Claimant's notice is not fully compliant with the statutory wording, the Claimant is unable to hold the Keeper of car liable under the strict 'keeper liability' provisions.

5. To support this I rely upon the words of barrister and parking expert Lead Adjudicator for PATAS and POPLA, Henry Michael Greenslade, where he clarified in the POPLA Annual Report 2015 in a heading: 'Understanding Keeper Liability' that 'however keeper information is obtained, there is no reasonable presumption in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Further, a failure by the recipient of a notice issued under Schedule 4 to name the driver, does not of itself mean that the recipient has accepted that they were the driver at the material time. Unlike, for example, a Notice of Intended Prosecution where details of the driver of a vehicle must be supplied when requested by the police, pursuant to Section 172 of the Road Traffic Act 1988, a keeper sent a Schedule 4 notice has no legal obligation to name the driver. (See Evidence Bundle Exhibit X).


6. Whilst HX Car Park Management Limited are listed as the claimant for this case, I have downloaded the title deeds and plan for the car park that I parked in and can find no proof of whether there is any contractual arrangement between the Claimant and the owner or occupier of the land in question, or, if such a contractual arrangement exists, what the terms of that arrangement are. The Title Deeds for the land (Evidence Bundle Exhibit X) show the owner of the Land to be a company called Due West Limited (Incorporated in Cayman Islands B.W.I.).


7. I therefore assert that the Claimant has no Locus Standi to bring this claim because:

The party HX Car Park Management Limited in the Parking Contract, is claimed has the right to grant the rights in the Parking Contract. HX Car Park Management Limited is not the landowner or another entity proven to be authorised by the landowner. No proof of a formal agreement between the landowner Due West Limited (Incorporated in Cayman Islands B.W.I.) and HX Car Park Management Limited has been provided by the Claimant and therefore the Claimant has failed to establish an express conferral of rights has taken place pursuant to Section 1(1)(a) and 1(3) of the Contracts (Rights of Third Parties) Act 1999 which require terms to identify the Claimant and express terms granting the Claimant the right to enforce the contract; or the right to sue.

8. Also Part B Paragraph 1.1 of the the Independent Parking Committee (IPC) Code of Practice (CoP) that the Claimant is subject to as a Trade Association member specifically provides that the Claimant must have written authorisation of the landowner (see Evidence Bundle Exhibit X). Compliance with the CoP is mandatory. Implicit in this is that Claimant would have no rights under the Parking Contract if they were not granted by the landowner.


9. Strict proof is required that there is an assignment of contractual rights from the landowner to the Claimant. The Claimant has failed to establish an express conferral of rights has taken place pursuant to Section 1(1)(a) and 1(3) of the Contracts (Rights of Third Parties) Act 1999 which require terms to identify the Claimant and express terms granting the Claimant the right to enforce the contract; or the right to sue. This proof should also explain how such a legal assignment has taken place between a company based in the Cayman Islands, and HX Car Park Management Limited, a UK based company.

10. I also note from the Title Deeds to the land on which the Westgate Arcade Car Park is wholly situated upon, that the address of the land is completely different to the address to which the Parking Contract refers, which calls into question whether this contract can be assumed to have been formed correctly between the Driver and the Claimant. The address to which the Notice to Keeper refers is Westgate Car Park, Horton Street, Halifax, HX1 1PU. The Address of the land upon which the Westgate Car Park is wholly situated is in a different street, and has a different postcode, the address being 22-24 Westgate, Halifax, HX1 1DJ. As no Notice to Keeper has been sent for the address of land upon which the alleged contract was formed, it is held that no proper contract has been formed between Driver and Claimant.

11. I also deny that a contract was formed between the Claimant and the Defendant, as no offer was communicated by the Claimant, effectively or at all, that was capable of acceptance by the Defendant, expressly, by conduct, or at all.

12. Subsequent to receiving the Parking Charge Notice (PCN) I visited the car park in question, and I noticed a sign was in place at the entrance (See Evidence Bundle Exhibit XX). Having used this car park previously I did not remember the sign(s) being in place, and they looked new. I therefore went to look at online maps of the area, and found images copyrighted for 2017, that showed no signs at the entrance to the car park. I have attached these images (See Evidence Bundle Exhibit XX) and I therefore put the Claimant to strict proof to demonstrate that the signs on site at Westgate Arcade Car Park were actually in place on the date that the alleged Parking Contract was formed. If the Claimant cannot demonstrate that the signs were actually in place at the date and time the alleged Parking Contract was formed, then this would contravene the IPC Code of Practice, Part B (2) Section 2.1,2.2 as no opportunity was provided for a Driver to agree to any contractual terms in relation to parking on private land, or in other words, there was no sign communicating any contractual terms to drivers.


13. Even in the event that the Claimant is able to demonstrate the current signs were in place at the time of the Driver!!!8217;s alleged contractual contravention, the current signage is also not sufficient to prove a contract was formed between the Driver and the Claimant.


14. The entrance sign mentions terms and conditions and lists them but does not go on to mention all of the terms and conditions. It references the sign at the pay & display machine for full terms & conditions. The pay & display sign does not contain full terms and conditions, nor does it state that it does so. There is only reference to full terms & conditions. This is contrary to the IPC Code of Practice, Part E, Schedule 1 - Signage, Entrance Signs. (See Evidence Bundle Exhibit XX).


15. The text size of the entrance signage means that it is not readable by a motorist in a moving vehicle, or at the very best not easily read contrary to IPC Code of Practice, Part E, schedule 1 - Signage, Text size. I have included video evidence of entering the Westgate Car Park by car to demonstrate it would be not possible to form a contract (See Evidence Bundle Exhibit XX).
Signage is not clearly legible and placed in such position that a driver is able to clearly see them on entering and parking a vehicle, contrary to IPC Codes of Practice, Part E, Schedule 1, signage, Other Signs, condition 4. Example of further signage where vehicles were parked, (See Evidence Bundle Exhibit XX). This sign is fixed to a wall some 7ft 10inch (236cm) high (measured from pavement to bottom of the sign). It is near illegible, and again would not allow a contract to be formed by Driver and Claimant.


16. Signage does not contain text appropriate to position and relative position of the person who is reading it, this is particularly apparent with the entrance sign and repeater signs around the car park. Pages 32,37,38, contrary to IPC Codes of Practice, Part E, Schedule 1 - signage, Other Signs, condition 6. (See Evidence Bundle Exhibit XX).


17. I have also checked with the local planning authority, Calderdale Council, and I can find no advertising consent for the signs in the Westgate Car Park. The Claimant is put to strict proof to demonstrate that they do indeed hold the required advertising consent. Failure to demonstrate this would mean the Claimant is likely committing a criminal offence under Regulation 30 of the Town and Country Planning (Control of Advertisements)(England) Regulations 2007 (as amended), because advertising consent has not been given by Calderdale Council for the signs. Should this be the case I believe the court should not lend its aid to a Claimant who founds a claim based on an unlawful act pursuant to the doctrine ex dolo malo non oritur actio.


18. After receiving the Notice to Keeper I then received a further demand dated (DATE). (See Evidence Bundle Exhibit XX), and subsequently a !!!8220;Final Demand!!!8221; dated the (DATE) (See Evidence Bundle Exhibit XX), with an increased amount of £125 owing with no explanation for the increased amount other than !!!8220;Costs being incurred!!!8221; and this letter threatened me with further debt recovery (See Evidence Bundle Exhibit XX). No figure for additional charges was agreed, or communicated, nor could it have formed part of the alleged contract because no such indemnity costs were quantified on the Claimant's signs. Terms cannot be bolted on later with figures plucked out of thin air, as if they were incorporated into the small print, when they were not.


19. A Letter Before Claim (Evidence Bundle Exhibit XX) dated (DATE) was received. Once again the sum of money demanded had increased, this time to £160.00 with an explanation of !!!8220;time and resource spent facilitating the recovery of the charge!!!8221;. The generation of and postage of three letters by a !!!8220;robo-claims!!!8221; parking company cannot in any conscionable way be seen to amount to £60 of additional costs.


20. I would have responded to the Letter Before Claim had I understood legal procedures, but having never previously being involved in anything relating to Legal Proceedings, I did not understand the relevance of this letter.


21. I then received a Claim Form dated (DATE) (Evidence Bundle Exhibit XX). The Particulars of Claim set out in the Claim Form do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies what the terms of the alleged contract were, or how they were breached. The Particulars are not clear and concise as is required by CPR 16.4 1(a). There is no information regarding why the charge arose, what the original charge was, what the alleged contract was nor anything which could be considered a fair exchange of information. It just states breaching terms of parking on the land at Westgate Car Park Horton Street Halifax which does not give any indication of on what basis the claim is brought. The claimant also failed to provide a copy of their written contract as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A).


22. I dispute that the Claimant has incurred £50 Solicitors costs to pursue an alleged £100 debt, the costs of which are in any case not recoverable. The claimant has described the charge of £50 as legal representative's costs not contractual costs CPR 31.14 does not permit these to be recoverable in the Small Claims Court
The Claimant has at no time provided an explanation of how the sum claimed has been calculated, the conduct that gave rise to it or how the amount has climbed from £100 to the £160 now sought.


23. POFA sched 4 para 4 (5) ''The maximum sum which may be recovered from the keeper by virtue of the right conferred by this paragraph is the amount specified in the notice to keeper...!!!8221;(less any payments towards the unpaid parking charges which are received after the time so specified).'' Therefore the maximum the Claimant could be expected to recover is £100. Anything else would constitute unlawful double recovery.

24. The fact that the Driver apparently paid for parking according to the Claimant (Contravention being an overstay of pre-paid time paid for), and that the ANPR cameras pick up an alleged total stay period of XXXX, means that notwithstanding the allowed grace periods of 10 minutes for a Driver to purchase a ticket (stated on the Claimants Terms and Conditions on the Entrance sign now in place in the car park), and a grace period at the end of time paid for, as per the IPC CoP recommendations (Part B, 15.2, Page 13, Evidence Bundle Exhibit XX) which we could reasonably assume to be the same amount of time, means that in real terms the Claimant is asking for over £200 for effectively 20 minutes of parking. The fact that the Claimant actually charges £0.80 for 1 hour of parking, means they place a value of 20 minutes of parking of £0.27. It is rather more than disproportionate to expect a payment which is 880% more than the actual value the Claimant places on that amount of time parking in their Car Park.


I believe that these facts stated in this witness statement are true.

KeithP

KeithP wrote: »

Superfluous word either in paragraph 17.

Still there.

Stevey

KeithP wrote: »

Still there.

LOL - finally gone

Coupon-mad

what format should this be provided in - do I burn a CD, provide a memory stick?

Ring the Court tomorrow and ask what the Judge will allow, and suggest you bring your laptop and a copy with you to play if the Judge entertains it. Hearings are time limited so you might get a grumpy Judge who says 'no video, the photos are clear enough, next point?'

You MUST have filed a CD to the court and claimant, if you plan to rely on that CD.

You do not need to include the CPR.

Google Annual Report 2015 POPLA Henry Greenslade and you will find it.

I still don't like the superfluous words 'an envelope containing' which sounds like a windscreen PCN:

3. I received [STRIKE]an envelope containing[/STRIKE] a postal Parking Charge Notice

5) Is it OK to send the Witness Statement and then send the evidence Exhibits separately a few days later? It would give me more time to annotate the various exhibits in the bundle. If not, I'll do my best otherwise.

I would never do that, I have worked in admin Managerial roles all my working life and IMHO that sort of plan is likely to cause human error (one bit received, the other not matched up by the court). It's asking for a disaster, IMHO.

Ideally, the court needs their version in a file, such as a ring binder, with a contents page and page numbering.

6) Main evidence question - the title deed I downloaded from OS Site says it is not Court Admissible, and that I have to write to them for such a version which will take a week, and cost £14. Can I send the interim versions with the Evidence bundle, and later send the "Legal" versions? Can I claim back these costs?

Yes you may as well, then add the £14 to your costs schedule which you then file to the court with the replacement (court admissable) version.

And email the other side every time, they must also receive everything. COPY YOUR OWN EMAIL IN and print the 'sent items' and the 'received' cc emails for your bundle, in case they say ''my client didn't get that'' you can say ''oh yes you did, and here's the proof''.

7) My actual proof of non compliance with advertising consent is a screenshot of the Planning portal showing no applications for the relevant property. Is this enough? If not, what would be needed from the Council to support this?

Seems OK unless you have time to also get an email. If not, yes, it's evidence and puts them to prove otherwise.

Coupon-mad

Just adding this link for you:

https://forums.moneysavingexpert.com/discussion/5752249/pcn-date

The OP - a retired person, not legally trained - just won in 5 minutes flat at Bradford!

DJ Hickinbottom seems to have sussed the PPC scam and knows about no keeper liability...