ES Parking IAS

Tabz123

Think i may have found it at the bottom

Tabz123

Hi

Can someone kindly post the link to where Witness statements are posted. I have tried searching the Newbies link number 2 for one regarding a 'fluttering' ticket with nil success. A link would greatly help.

Thanks

Coupon-mad

Search the newbies thread (Control & F on your keyboard) for witness.

There are several shown.

Then if you want to find threads generally about fluttering tickets try searching the forum this time, using the advanced search box above the thread list, once back on the main parking tickets page of threads (NOT ON THE NEWBIES THREAD, or this thread), for Armtrac witness statement as they are always about fluttering tickets!

Tabz123

I have now prepared my witness statement. Please see below and provide any feedback:

In the County Court at Manchester
Claim No. ZZZZZZZZZ
Between
ES PARKING ENFORCEMENT LIMITED (Claimant)
and
XXXXXXXXX (Defendant)

---

Witness Statement

---

1. I am XXXXXXX, of XXXXXXXXXXXX, I am the Defendant in this matter. I am an unrepresented consumer who is not experienced at attending county court. In this statement I will refer to the documents contained in exhibit marked ‘Evidence Pack’, by page numbers. I will say as follows:

2. On XX/05/18, I visited CCP Parking on Gould Street, and parked my vehicle registration no XXXXX in the car park.

3. I purchased a ticket for 24 hours parking covering the period from XXXX to XXXX from the pay and display machine. I carefully displayed the ticket face up on the dashboard of my car, checking that it was visible as I left my vehicle.

4. I refer you to page X of my evidence documents, which shows the parking ticket covering the time of the alleged incident. Also, within the evidence pack I refer you to XX which shows the Parking Charge Notice (PCN) issued by the Claimant. It is key to note that the date of the ticket shows a different date to that of the PCN as the PCN displays an issue date of XX/05/18 and the ticket shows the following day’s date of XX/05/18 as this is the expiry date.

5. On return to my vehicle, which was before the parking ticket expired, I found that I had been issued with a Parking Charge Notice. Unfortunately, the ticket was now face down near the front vent of the vehicle.

6. On examination of the ticket you can see it is made of a flimsy piece of paper with no sticky part to it so that it could not be fixed in place on the dashboard or windscreen. Since this incident occurred, I am aware that there have been many occurrences of Parking Charge Notices resulting from similar circumstances. There have even been allegations of this Claimant's operatives blowing through vents, because the scam is so rife as to add up to thousands of reported instances every year. I expect the ticketer to appear as witness so that I can question them at the hearing regarding how the ticket overturned in this case, given that I was not in breach when I parked.

7. I refer to page x of the evidence pack which exhibits a photo taken by the Claimant. This shows a faint shadow of an item resting on the dashboard in the shape and size of a ticket. However due to a combination of the glare of the sun, the angle of pictures taken this is not clear to see via the picture however would have been clear to see in person, on the day. Furthermore, the photos of the car are not representative of how windy the big open car park was on the day.

8. The Claimant’s evidence of a specimen sign (Contract) states “A valid ticket must be purchased to park on this site and be displayed clearly in your front windscreen”. This from the Claimant’s own evidence was clearly adhered to since the ticket was visible from the windscreen. Any breach (which, for avoidance of doubt, is denied) was de minimis.

10. I dispute that the Claimant has incurred £50 Solicitors costs to pursue an alleged £160 debt. 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.


11. On the day in question I had every intention to pay for parking, and I did so, and I genuinely thought I had complied with the terms of parking in the car park (and was justified in that belief). Circumstances beyond my control must have occurred which caused the ticket to have flipped over when I was away from the car. This occurrence comes under the de minimis principle, particularly as the ticket has a serial/reference number on the back. I refer to page x of the evidence pack which exhibits a photo of the back of my ticket.

12. In Jolley v Carmel Ltd [2000] 2 –EGLR -154, it was held that a party who makes reasonable endeavours and takes reasonable steps to comply with contractual terms, should not be penalised for breach outside of their control.

13. Fluttering tickets are routinely accepted as a valid defence to Council Penalty Charge Notices and whilst contractual principles are not applied to such notices, it is indicative of the fact that circumstances out of your control, and where the driver has clearly paid for the parking, are deemed to be a good reason for those notices to be cancelled.

14. I include the views of Council Adjudicators regarding the well-known issue of 'flimsy fluttering tickets' because the Supreme Court (and the Court of Appeal Judges) in Beavis were happy to draw similarities with Council PCNs:

‘In DB05057D the adjudicator said: “…having seen the original ticket I note that it is made of rather thin paper which is likely to be dislodged when a car door is shut. It may be that the Council would argue that it is the driver's responsibility to ensure that the ticket is on display when the vehicle is left, but on the other hand if it chooses to issue pay and display tickets made of such thin paper it must expect that now and again this type of situation will arise.”
In HV05040D the adjudicator accepted the appellant’s evidence that she had displayed the ticket on the dash and checked after closing the door that it was still there. He said: “I am not aware of any signs in the car park suggesting the use of adhesives by motorists when parking their cars."’

15. Since the date of the incident I have received many letters from ES Parking Enforcement Ltd and subsequently from Gladstones Solicitors requesting ever increasing sums of money and giving warnings of County Court Judgements affecting my credit record.
16. I received a Claim Form on XX May XXXX (page xx of Evidence Pack). 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). It just states “The driver of the vehicle with registration XX XX XX parked in breach of the terms of parking stipulated on the signage” 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).

Costs on the claim - disproportionate and disingenuous

18. CPR 44.3 (2) states: ''Where the amount of costs is to be assessed on the standard basis, the court will –
(a) only allow costs which are proportionate to the matters in issue. Costs which are disproportionate in amount may be disallowed or reduced even if they were reasonably or necessarily incurred; and
(b) resolve any doubt which it may have as to whether costs were reasonably and proportionately incurred or were reasonable and proportionate in amount in favour of the paying party.

Whilst quantified costs can be considered on a standard basis, this Claimant's purported costs are wholly disproportionate and do not stand up to scrutiny.

19. The standard wording for parking charge/debt recovery contracts is on the Debt Recovery Plus website - ''no recovery/no fee'', thus establishing an argument that the Claimant is breaching the indemnity principle - claiming reimbursement for a cost which has never, in fact, been incurred. This is true, whether or not they used a third party debt collector during the process.

20. In fact it is averred that the Claimant has not paid or incurred such damages/costs or 'legal fees' at all. Any debt collection letters were a standard feature of a low cost business model and are already counted within the parking charge itself and there has been no legal advice or personal involvement by any solicitor in churning out this template claim.

21.The Parking Eye Ltd v Beavis case is the authority for recovery of the parking charge itself and no more, since that sum (£85 in Beavis) was held to already incorporate the minor costs of an automated private parking business model. There are no losses or damages caused by this business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages.

22.Unlike this mendacious and greedy Claimant, ParkingEye themselves took on board the Beavis case outcome and they never add fake costs on top of the parking charge. It is indisputable that an alleged 'parking charge' penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending upon the parking firm) covers the costs of the letters, and all parking firms are very familiar with this case.
23. Any purported 'legal costs' are also made up out of thin air. Given the fact that robo-claim solicitors and parking firms process tens of thousands of claims handled by an admin team or paralegals, the Defendant avers that no solicitor is likely to have supervised this current batch of cut & paste claims. The court is invited to note that no named Solicitor has signed the Particulars, in breach of Practice Direction 22, and rendering the statement of truth a nullity.

24. According to Ladak v DRC Locums UKEAT/0488/13/LA a Claimant can only recover the direct and provable costs of the time spent preparing the claim in a legal capacity, not any administration costs allegedly incurred by already remunerated administrative staff.

25.The Protection of Freedoms Act 2012, Schedule 4 (POFA) makes it clear that the will of Parliament regarding parking on private land is that the only sum potentially able to be recovered is the sum in any compliant 'Notice to Keeper' (and the ceiling for a 'parking charge', as set by the Trade Bodies and the DVLA, is £100). This also depends upon the Claimant fully complying with the statute, including 'adequate notice' of the parking charge and prescribed documents served in time/with mandatory wording. It is submitted the claimant has failed on all counts and the Claimant is well aware their artificially inflated claim, as pleaded, constitutes double recovery.

26. Judges have disallowed all added parking firm 'costs' in County courts up and down the Country. In Claim number F0DP201T on 10th June 2019, District Judge Taylor sitting at the County Court at Southampton, echoed earlier General Judgment or Orders of DJ Grand, who (when sitting at the Newport (IOW) County Court in 2018 and 2019) has struck out several parking firm claims. These include a BPA member serial Claimant (Britannia, using BW Legal's robo-claim model) and an IPC member serial Claimant (UKCPM, using Gladstones' robo-claim model) yet the Orders have been identical in striking out both claims without a hearing, with the Judge stating: ''It is ordered that The claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in ParkingEye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

27. That is not an isolated judgment striking a parking claim out for repeatedly adding sums they are not entitled to recover. In the Caernarfon Court in Case number FTQZ4W28 (Vehicle Control Services Ltd v Davies) on 4th September 2019, District Judge Jones-Evans stated:

''Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates [...] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court v Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared [...] the claim is struck out and declared to be wholly without merit and an abuse of process.''

28. In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant's vexatious conduct from the outset has been intimidating, misleading and indeed untrue in terms of the added costs alleged and the statements made, in trying to justify the unjustifiable.

29. There are several options available within the Courts' case management powers to prevent vexatious litigants pursuing a wide range of individuals for matters which are near-identical, with meritless claims and artificially inflated costs. The Defendant is of the view that private parking firms operate as vexatious litigants and that relief from sanctions should be refused.

30. The Court is invited to make an Order of its own initiative, dismissing this claim in its entirety and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14 on the indemnity basis, taking judicial note of the wholly unreasonable conduct of this Claimant.


Statement of Truth

I believe that the facts stated in this Witness Statement are true.

Signature
Date

Tabz123

Hi

If anyone can review my witness statement that would be greatly appreciated.
Thanks

Coupon-mad

Remove #10, #15 and #16 (which add nothing) and be aware you seemed to have no #17 anyway!

Then re-number.

Add as evidence (with exhibit numbers, NOT 'page x of my evidence').

Every item needs an exhibit number as well as pages numbers!). Add in:

- Debt Recovery Plus' leaflet about their free 'service' posted recently in the Abuse of Process thread by beamerguy

- the Caernarfon and the IOW judgments posted in post #14 of the Abuse of Process thread by beamerguy

- paragraphs 98 and 198 from P/Eye v Beavis with the bit highlighted where the Supreme Court held that an £85 (or similarly high £100) parking charge already more than covers all costs of the operation of a dubious automated parking fines business

Tabz123

Coupon-mad wrote: »

Remove #10, #15 and #16 (which add nothing) and be aware you seemed to have no #17 anyway!

Then re-number.

Add as evidence (with exhibit numbers, NOT 'page x of my evidence').

Every item needs an exhibit number as well as pages numbers!). Add in:

- Debt Recovery Plus' leaflet about their free 'service' posted recently in the Abuse of Process thread by beamerguy

- the Caernarfon and the IOW judgments posted in post #14 of the Abuse of Process thread by beamerguy

- paragraphs 98 and 198 from P/Eye v Beavis with the bit highlighted where the Supreme Court held that an £85 (or similarly high £100) parking charge already more than covers all costs of the operation of a dubious automated parking fines business

Below is my amended Witness Statement …..

Tabz123

In the County Court at Manchester
Claim No. ZZZZZZZZZ
Between
ES PARKING ENFORCEMENT LIMITED (Claimant)
and
XXXXXXXXX (Defendant)

---

Witness Statement

---

1. I am XXXXXXX, of XXXXXXXXXXXX, I am the Defendant in this matter. I am an unrepresented consumer who is not experienced at attending county court. In this statement I will refer to the documents marked as ‘exhibits, by page numbers. I will say as follows:

2. On XX/05/18, I visited CCP Parking on Gould Street, and parked my vehicle registration no XXXXX in the car park.

3. I purchased a ticket for 24 hours parking covering the period from XXXX to XXXX from the pay and display machine. I carefully displayed the ticket face up on the dashboard of my car, checking that it was visible as I left my vehicle.

4. I refer you to exhibit XX, which shows the parking ticket covering the time of the alleged incident. Also, I refer you to exhibit XX which shows the Parking Charge Notice (PCN) issued by the Claimant. It is key to note that the date of the ticket shows a different date to that of the PCN as the PCN displays an issue date of XX/05/18 and the ticket shows the following day’s date of XX/05/18 as this is the expiry date.

5. On return to my vehicle, which was before the parking ticket expired, I found that I had been issued with a Parking Charge Notice. Unfortunately, the ticket was now face down near the front vent of the vehicle.

6. On examination of the ticket you can see it is made of a flimsy piece of paper with no sticky part to it so that it could not be fixed in place on the dashboard or windscreen. Since this incident occurred, I am aware that there have been many occurrences of Parking Charge Notices resulting from similar circumstances. There have even been allegations of this Claimant's operatives blowing through vents, because the scam is so rife as to add up to thousands of reported instances every year. I expect the ticketer to appear as witness so that I can question them at the hearing regarding how the ticket overturned in this case, given that I was not in breach when I parked.

7. I refer to exhibit XX which is a photo taken by the Claimant. This shows a faint shadow of an item resting on the dashboard in the shape and size of a ticket. However due to a combination of the glare of the sun, the angle of pictures taken this is not clear to see via the picture however would have been clear to see in person, on the day. Furthermore, the photos of the car are not representative of how windy the big open car park was on the day.

8. The Claimant’s evidence of a specimen sign (Contract) states “A valid ticket must be purchased to park on this site and be displayed clearly in your front windscreen”. This from the Claimant’s own evidence was clearly adhered to since the ticket was visible from the windscreen. Any breach (which, for avoidance of doubt, is denied) was de minimis.

9. On the day in question I had every intention to pay for parking, and I did so, and I genuinely thought I had complied with the terms of parking in the car park (and was justified in that belief). Circumstances beyond my control must have occurred which caused the ticket to have flipped over when I was away from the car. This occurrence comes under the de minimis principle, particularly as the ticket has a serial/reference number on the back. I refer to exhibit XX which is a photo of the back of my ticket.

10. In Jolley v Carmel Ltd [2000] 2 –EGLR -154, it was held that a party who makes reasonable endeavours and takes reasonable steps to comply with contractual terms, should not be penalised for breach outside of their control.

11. Fluttering tickets are routinely accepted as a valid defence to Council Penalty Charge Notices and whilst contractual principles are not applied to such notices, it is indicative of the fact that circumstances out of your control, and where the driver has clearly paid for the parking, are deemed to be a good reason for those notices to be cancelled.

12. I include the views of Council Adjudicators regarding the well-known issue of 'flimsy fluttering tickets' because the Supreme Court (and the Court of Appeal Judges) in Beavis were happy to draw similarities with Council PCNs:

‘In DB05057D the adjudicator said: “…having seen the original ticket I note that it is made of rather thin paper which is likely to be dislodged when a car door is shut. It may be that the Council would argue that it is the driver's responsibility to ensure that the ticket is on display when the vehicle is left, but on the other hand if it chooses to issue pay and display tickets made of such thin paper it must expect that now and again this type of situation will arise.”
In HV05040D the adjudicator accepted the appellant’s evidence that she had displayed the ticket on the dash and checked after closing the door that it was still there. He said: “I am not aware of any signs in the car park suggesting the use of adhesives by motorists when parking their cars."’


Costs on the claim - disproportionate and disingenuous

13. CPR 44.3 (2) states: ''Where the amount of costs is to be assessed on the standard basis, the court will –
(a) only allow costs which are proportionate to the matters in issue. Costs which are disproportionate in amount may be disallowed or reduced even if they were reasonably or necessarily incurred; and
(b) resolve any doubt which it may have as to whether costs were reasonably and proportionately incurred or were reasonable and proportionate in amount in favour of the paying party.

Whilst quantified costs can be considered on a standard basis, this Claimant's purported costs are wholly disproportionate and do not stand up to scrutiny.

14. The standard wording for parking charge/debt recovery contracts is on the Debt Recovery Plus website - ''no recovery/no fee'', thus establishing an argument that the Claimant is breaching the indemnity principle - claiming reimbursement for a cost which has never, in fact, been incurred. This is true, whether or not they used a third party debt collector during the process.

15. In fact it is averred that the Claimant has not paid or incurred such damages/costs or 'legal fees' at all. Any debt collection letters were a standard feature of a low cost business model and are already counted within the parking charge itself and there has been no legal advice or personal involvement by any solicitor in churning out this template claim.

16.The Parking Eye Ltd v Beavis case is the authority for recovery of the parking charge itself and no more, since that sum (£85 in Beavis) was held to already incorporate the minor costs of an automated private parking business model. There are no losses or damages caused by this business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages.

17.Unlike this mendacious and greedy Claimant, ParkingEye themselves took on board the Beavis case outcome and they never add fake costs on top of the parking charge. It is indisputable that an alleged 'parking charge' penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending upon the parking firm) covers the costs of the letters, and all parking firms are very familiar with this case.
18. Any purported 'legal costs' are also made up out of thin air. Given the fact that robo-claim solicitors and parking firms process tens of thousands of claims handled by an admin team or paralegals, the Defendant avers that no solicitor is likely to have supervised this current batch of cut & paste claims. The court is invited to note that no named Solicitor has signed the Particulars, in breach of Practice Direction 22, and rendering the statement of truth a nullity.

19. According to Ladak v DRC Locums UKEAT/0488/13/LA a Claimant can only recover the direct and provable costs of the time spent preparing the claim in a legal capacity, not any administration costs allegedly incurred by already remunerated administrative staff.

20.The Protection of Freedoms Act 2012, Schedule 4 (POFA) makes it clear that the will of Parliament regarding parking on private land is that the only sum potentially able to be recovered is the sum in any compliant 'Notice to Keeper' (and the ceiling for a 'parking charge', as set by the Trade Bodies and the DVLA, is £100). This also depends upon the Claimant fully complying with the statute, including 'adequate notice' of the parking charge and prescribed documents served in time/with mandatory wording. It is submitted the claimant has failed on all counts and the Claimant is well aware their artificially inflated claim, as pleaded, constitutes double recovery.

21. Judges have disallowed all added parking firm 'costs' in County courts up and down the Country. In Claim number F0DP201T on 10th June 2019, District Judge Taylor sitting at the County Court at Southampton, echoed earlier General Judgment or Orders of DJ Grand, who (when sitting at the Newport (IOW) County Court in 2018 and 2019) has struck out several parking firm claims. These include a BPA member serial Claimant (Britannia, using BW Legal's robo-claim model) and an IPC member serial Claimant (UKCPM, using Gladstones' robo-claim model) yet the Orders have been identical in striking out both claims without a hearing, with the Judge stating: ''It is ordered that The claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in ParkingEye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

22. That is not an isolated judgment striking a parking claim out for repeatedly adding sums they are not entitled to recover. In the Caernarfon Court in Case number FTQZ4W28 (Vehicle Control Services Ltd v Davies) on 4th September 2019, District Judge Jones-Evans stated:

''Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates [...] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court v Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared [...] the claim is struck out and declared to be wholly without merit and an abuse of process.''

23. In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant's vexatious conduct from the outset has been intimidating, misleading and indeed untrue in terms of the added costs alleged and the statements made, in trying to justify the unjustifiable.

24. There are several options available within the Courts' case management powers to prevent vexatious litigants pursuing a wide range of individuals for matters which are near-identical, with meritless claims and artificially inflated costs. The Defendant is of the view that private parking firms operate as vexatious litigants and that relief from sanctions should be refused.

25. The Court is invited to make an Order of its own initiative, dismissing this claim in its entirety and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14 on the indemnity basis, taking judicial note of the wholly unreasonable conduct of this Claimant.


Statement of Truth

I believe that the facts stated in this Witness Statement are true.

Signature
Date

Tabz123

Coupon-mad wrote: »

Remove #10, #15 and #16 (which add nothing) and be aware you seemed to have no #17 anyway!

Then re-number.

Add as evidence (with exhibit numbers, NOT 'page x of my evidence').

Every item needs an exhibit number as well as pages numbers!). Add in:

- Debt Recovery Plus' leaflet about their free 'service' posted recently in the Abuse of Process thread by beamerguy - The link in the post you refer to no longer works and I could not locate another copy online

- the Caernarfon and the IOW judgments posted in post #14 of the Abuse of Process thread by beamerguy - I don't understand this point as I copied all the text from the relevant thread and could not see any additional references or links to documents which I could save down as part of my exhibits?

- paragraphs 98 and 198 from P/Eye v Beavis with the bit highlighted where the Supreme Court held that an £85 (or similarly high £100) parking charge already more than covers all costs of the operation of a dubious automated parking fines business

- I followed the link and have saved the document but the judgement was 111 pages long! Do I need the whole document as part of my witness statement pack ?

I am unsure I understand the referencing. Does each document need to be labelled Exhibit X etc? If so, how would I label documents which I have not prepared such as the Bevis judgement ? It is easy to add a title to images but not other documents. The only reference I could add is the page number unless I am really misunderstanding the point on exhibits and how they accompany a witness statement ...

Sorry for the questions but I have 2 days to post out my WS (due by 1st Nov) and my brain is now officially getting fried!

Coupon-mad

I followed the link and have saved the document but the judgement was 111 pages long! Do I need the whole document as part of my witness statement pack ?

No, only para 98 and 198 of Beavis are needed, to show the fact that the Supreme Court said that an inflated private parking charge already includes all the usual operational & letter costs.