Court Claim - AoS Complete

Tommer123

In the County Court at Bath, The Law Courts, North Parade Road, Bath, BA1 5AF

Claim No.

Between

PARKINGEYE LTD (Claimant)

and

MR XXXXXX (Defendant)


WITNESS STATEMENT

I, XXXXX, of XXXXXXXXX, will say as follows:

I am the Defendant in this matter. Attached to this statement is a paginated bundle of documents marked TH1 to which I will refer.

1. Before I describe what happened on the day I parked in the Rheidol Retail Park car park, I confirm that the essence of my defence to this claim is that:
a. I did not breach the terms and conditions of parking
b. The Claimant's signage did not make it clear whether the two hour free parking period offered included time spent after entering the site via its ANPR cameras looking for a space and parking in it and locating and reading the terms and conditions and deciding to accept them, and time spent when leaving the site via the same cameras exiting the space, driving round the car park's one way system and then driving out onto a public highway. It is trite law that any uncertainty in a contract should be resolved against the person who offered it under the contra preferentem rule;
c. Even if I did breach the terms, the Claimant is obliged by the compulsory Code of Practice of its own Accredited Trade Association to apply separate grace periods of at least 10 minutes at the start and end of each period of parking to allow for potential delays in finding a space, exiting the car park and to allow time for drivers to find and read the terms and conditions offered, and the 14 minute overstay is well within these grace periods.

2. On 30th May 2017 I was in Aberystwyth for business, after I had finished this meeting I went to do some shopping and parked in the Rheidol Retail Park. I read the signs and was aware that there was a 2-hour period for free parking. It was my first visit to this car park and I was not previously familiar with it, or the road layouts outside it or how busy they could be.

3. It took me a few minutes to find a space and park in it as the carpark was quite busy, I remember waiting for a few other cars to manoeuvre in and out of spaces before parking myself. When I got out of the car, I walked over to the closest parking sign to read it and immediately set a timer on my phone to make sure I got back to the car in time. Then I went shopping and returned to the car within two hours. I know that I did so because I remember being back at my car just before my alarm went off and also remember looking at my watch when I got back to the car to check that I was back in time (which I was).

4. The carpark was very busy. It took me a long time to reach the exit of the carpark, because I had to drive around its one-way system, stopping along the way to allow other cars to get in / out of spaces and out of junctions within the car park. I estimate that it took me around 10 minutes to get to the exit road. I can see from the evidence relied upon by the Claimant that there was a 14 minute period between the free 2-hour period expiring and me exiting the carpark. Some of this, of course, would have been taken up by the few minutes it took after entering the car park to park the car and read the signs.

5. I am not familiar with the car park layouts or how busy the area can be, but I made every reasonable effort to leave the car park within the 2-hour stay limit. When I reached the exit road, there was an enormous queue to get out onto the main road (Alexandra Road). At the end of the exit road is a roundabout which intersects the main road and on the day it was heavily congested which meant the traffic was almost at a standstill leading up to and going round the roundabout. I remember it all very clearly because it was a warm day and my car’s air-conditioning was broken and it was incredibly frustrating queuing up while only a single car at a time managed to get out onto the main road.

6. At page 1 of TH1 is a google earth aerial photograph of the carpark. I've marked on it in red roughly where my car was parked and in yellow dashes I have marked the route I took round its one-way system to the exit road. The Claimant's ANPR machine is, I believe, almost next to the junction to the exit road. The exit road is marked in blue, with the roundabout on Alexandra Road marked with a blue cross. The main road outside the carpark, where there was very slow moving traffic at the time, is marked in green on the photograph.

7. The traffic jams (both the one inside the carpark and the one on the public highway outside) were beyond my control and I could not have anticipated them. The Claimant, a company which manages the car park, should be aware of these issues and should make reasonable allowances for the foreseeable delays users may experience in exiting the car park.

8. I have considered the Code of Practice ("CoP") of the British Parking Association ("BPA"), of which the Claimant is an accredited member. A copy of paragraph 13 of the CoP, which relates to grace periods, is at page XXX of TH1. In order to be an accredited member of the BPA, compliance with the CoP is compulsory, and a copy of paragraphs 4.1 and 6 of the CoP is at page XXX of TH1. The significance of being a member of the BPA and subscribing to its CoP is that the Claimant is only entitled to ask the DVLA for the details of a car’s registered keeper if it is a member.

9. Paragraph 13 of the CoP clearly states that a grace period is to be applied to parking. The CoP makes clear that such grace periods are to be applied both at the start of any parking period and also at the end of any parking period. The whole point of these grace periods is to allow drivers time to find a parking space and to read the signage prior to commencement of the period of parking, and time to exit the carpark once they have finished parking. Grace periods are not defined, but the CoP requires them to be "a minimum of 10 minutes" either side of the actual parking (paragraphs 13.2 and 13.4).

10. In this case, the data produced and relied upon by the Claimant shows that the period passing between my car entering and leaving via the ANPR cameras was 14 minutes. Applying the "minimum" 10 minutes either side of the parking, the minimum total grace period I should have been allowed by the Claimant under its own compulsory CoP was 20 minutes. I was therefore well within the grace period. Whilst I accept that following the parking I was on site for around 10 minutes, this was because of the heavy traffic both inside and outside the carpark, a matter which was outside of my control. It is worthy of note that the recommended grace period is a minimum of 10 minutes, it is not a maximum. The Claimant should have taken a reasonable and proportionate approach, exercised common sense and applied a greater grace period than the minimum to take into account the bottleneck at the roundabout immediately next to the exit from the car park. The issue the court is being asked to deal with is de minimis and the court's valuable time should not have been taken up with this matter.

11. I have repeatedly drawn these matters to the Claimant's attention, but it has refused to see reason, including applying an appropriate grace period of "a minimum of 10 minutes" before and after parking, which it is actually obliged to do by its compulsory CoP.


The Court is invited to dismiss the claim and to award my costs of dealing with this claim and attendance at the hearing, such as are allowable pursuant to CPR 27.14.

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


Signature of Defendant:


Name:
Date: 24/08/2018

I'm still working on the attachments and will post copies here when complete.
Thanks again for your support.

Coupon-mad

Make sure you append the correct BPA CoP from the date of the parking event. The 2017 CoP was a bit wishy washy on Grace Periods, I think...

That WS looks good!

Loadsofchildren123

Tommer123 wrote: »

1. The Claimant asserts that I entered into a contract with it, that I breached that contract and must pay a contractual charge, with further undefined and unexplained additional charges. It claims that I was in the relevant car park for a total of 2 hours and 14 minutes, when only 2 hours was permitted. It is these 14 minutes with which the Claim is concerned.
   
2. Before I describe what happened on the day I parked in the Rheidol Retail Park car park (“the car park”), I confirm that the essence of my defence to this claim is that:
   a. I did not breach the terms and conditions of parking
   b. The Claimant's signage did not make it clear whether the 2 hour free parking period offered included time spent after entering the site via its ANPR cameras looking for a space and parking in it and locating and reading the terms and conditions and deciding to accept them, and time spent when leaving the site via the same cameras exiting the space, driving round the car park's one way system and then driving out onto a public highway. It is my case that it offered 2 hours of free parking, and that is the period I parked for. It is trite law that any uncertainty in a contract should be resolved against the person who offered it under the contra preferentem rule;
   c. Even if I did breach the terms, the Claimant is obliged by the compulsory Code of Practice of its own Accredited Trade Association to apply separate grace periods of at least 10 minutes at the start and end of each period of parking to allow for potential delays in finding a space, exiting the car park and to allow time for drivers to find and read the terms and conditions offered, and the 14 minute overstay is well within these grace periods.
   
   
3. At page 1 of TH1 is a google earth aerial photograph of the car park. I've marked on it in red roughly where my car was parked and the approximate location of the sign nearest to the car. In yellow dashes I have marked the route I took round its one-way system to the exit road. The Claimant's ANPR machine is, I believe, almost next to the junction to the exit road. The exit road is marked in blue, with the roundabout intersecting the public highway (Alexandra Road) marked with a blue cross. Alexandra Road, which is the main road outside the car park, and where there was very slow moving traffic at the time I exited the car park, is marked in green on the photograph.
   
   
4. Turning to the day of the parking, on 30th May 2017 I was in Aberystwyth for a business meeting. When the meeting was finished, I decided to do some shopping and parked in the the car park at Rheidol Retail Park. It was my first visit to this car park and I was not previously familiar with it, or the road layouts outside it or how busy they could be.
   
5. After driving in past the ANPR cameras at the entrance, it took me a few minutes to find a space and park in it as the car park was quite busy. I remember waiting for a few other cars to manoeuvre in and out of spaces before parking myself. When I got out of the car, I walked over to the closest parking sign to read it. I estimate that this took 3-4 minutes, possibly a little more. The sign and where I parked my car are marked on the photograph at TH1 in red. The sign stated that there was a free 2 hour period of parking. I immediately set a timer on my phone to make sure I got back to the car in time, left the car and went shopping. I know that I returned to the car within 2 hours, because my alarm went off after I was back at the car, and I also remember looking at my watch when I got back to the car to check that I was back in time (which I was).
   
6. It is my understanding that there are three elements to a contract: offer, acceptance and consideration. I could not possibly have accepted any contract offered by the Claimant at the precise moment I drove through the ANPR cameras, at the start of minute 1 of the 2 hours and 14 minute period, because at that point no offer had been made. An offer must be communicated to an offeree. There was no offer communicated at the entrance to the car park, but only inside it - the Claimant’s signage setting out the terms and conditions were dotted around the site and could not be seen immediately on entry, and I could not read them from my car. It took me 3-4 minutes to drive in, find a space, find a sign, read it and decide to avail myself of the parking. At that point I say an offer was made (insofar as the sign was capable of making an offer), and I accepted it.
   
7. Since no contractual terms were offered until I had read the sign, that leaves the remaining 10 minutes of my alleged overstay.
   
8. When I returned to my car, the carpark was very busy. I know that I reached my car within the 2 hour limit, because my alarm went off after I was back at the car. I did not remain parked when I returned to the car, I got straight in it and drove off, and at that point I was no longer making use of the car parking facility, but was exiting the car park.
   
9. It took me a long time to reach the exit road (marked in blue on the photograph at page 1 of TH1) and then drive out onto the public highway (marked in green), because I had to drive around the car park’s one-way system (marked in yellow on the photograph), stopping along the way to allow other cars to get in / out of spaces and out of junctions within the car park, and when I reached the exit, there was a traffic jam leading to the roundabout outside (marked with a blue cross). The roundabout is at the end of the exit road and intersects the main road (Alexandra Road, marked in green) and on the day it was heavily congested which meant the traffic was almost at a standstill leading up to and going round the roundabout. There were a lot of cars stuck inside the car park waiting to get out. I estimate that it took me around 10 minutes to get to the exit road and out of the car park, past the ANPR cameras. I remember it all very clearly because it was a warm day and my car’s air-conditioning was broken and it was incredibly frustrating queuing up while only a single car at a time managed to get out onto the main road.
   
   
10. I was not familiar with the car park layout or how busy the road outside it could be. The fact is that I returned to my car and drove it away from where it was parked within the 2 hour period and made every effort to exit the car park in a timely manner. I was delayed because of reasons beyond my control (the traffic jams both inside the carpark and on the public highway outside) and I could not have anticipated them. The entirety of the final 10 minutes spent in the car park were spent trying to exit it. The Claimant, a company which manages the car park, should be aware of these issues and should make reasonable allowances for the foreseeable delays users may experience in exiting the car park.
    
11. Contractually, the Claimant’s signage did not specify that the 2 hours of free parking included time spent finding a space and then leaving the car park via the ANPR cameras. Had this been clear to me, I would have returned to the car earlier. Of the 14 minute alleged overstay, 3-4 minutes (possibly more) were spent in the car park prior to any contract being formed. The 10 minute delay in leaving at the end of the 2 hours was beyond my control and unforeseeable. I made all reasonable endeavours to leave the car park and to remain parked for only 2 hours.
    
12. In addition to considering the contractual element of the claim, I have considered the Code of Practice ("CoP") of the British Parking Association ("BPA"), of which the Claimant is an accredited member. A copy of paragraph 13 of the CoP, which relates to grace periods, is at page XXX of TH1. In order to be an accredited member of the BPA, compliance with the CoP is compulsory, and a copy of paragraphs 4.1 and 6 of the CoP is at page XXX of TH1. The significance of being a member of the BPA and subscribing to its CoP is that the Claimant is only entitled to ask the DVLA for the details of a car’s registered keeper if it is a member (so without membership a private parking company would not be able to function without the ability to trace drivers/registered keepers).
    
13. Paragraph 13 of the CoP clearly states that a grace period is to be applied to parking. The CoP makes clear that such grace periods are to be applied both at the start of any parking period and also at the end of any parking period. The whole point of these grace periods is to allow drivers time to find a parking space and to read the signage prior to commencement of the period of parking, and time to exit the carpark once they have finished parking. Grace periods are not defined, but the CoP requires them to be "a minimum of 10 minutes" either side of the actual parking (paragraphs 13.2 and 13.4). It is worthy of note that the recommendation is a minimum of 10 minutes, not a maximum.
    
14. There is no explanation for why the Claimant has declined to apply any grace period at all in my case, which is a clear breach of the CoP.
    
15. In the now infamous parking case of Cavendish Square Holdings BV v Talal El Makdessi; ParkingEye Limited v Beavis, the Supreme Court made clear in its judgment that strict compliance with the CoP is paramount where a Claimant seeks to enforce a private parking charge. Paragraphs 96 and 111 of the judgment stated:
    96. ''The BPA Code of Practice is a detailed code of regulation governing signs, charges and enforcement procedures.''
    111. “''And, while the Code of Practice is not a contractual document, it is in practice binding on the operator since its existence and observance is a condition of his ability to obtain details of the registered keeper from the DVLA. In assessing the fairness of a term, it cannot be right to ignore the regulatory framework which determines how and in what circumstances it may be enforced.'' (emphasis added).
    
16. In this case, the data produced and relied upon by the Claimant shows that the period passing between my car entering and leaving via the ANPR cameras was 14 minutes. Applying the "minimum" 10 minutes either side of the parking, the minimum total grace period I should have been allowed by the Claimant under its own compulsory CoP was 20 minutes. I was therefore well within the grace period. Whilst I accept that following the parking I was on site for around 10 minutes, this was because of the heavy traffic both inside and outside the carpark, a matter which was outside of my control. The Claimant should have taken a reasonable and proportionate approach, complied with its own obligations under the CoP (not to mention exercised common sense) and should have applied the grace period, particularly in light of the potential bottleneck at the roundabout at the exit from the car park. Furthermore, the issue the court is being asked to deal with is de minimis and the court's valuable time should not have been taken up with this matter.
17. I have repeatedly drawn these matters to the Claimant's attention, but it has refused to see reason, including applying an appropriate grace period of "a minimum of 10 minutes" before and after parking, which it is actually obliged to do by its compulsory CoP.
    
    
    The Court is invited to dismiss the claim and to award my costs of dealing with this claim and attendance at the hearing, such as are allowable pursuant to CPR 27.14.
    
    I believe that the facts stated in this Witness Statement are true.
    
    
    Signature of Defendant:
    
    
    Name:
    Date: 24/08/2018

Played around with it a bit, wanted to emphasise the contractual issues a bit more. thought it was worth adding the bit about Beavis and what it said about complying with the CoP.

Loadsofchildren123

I'd rely on the up to date CoP. Let them say it's the wrong one. The fact that the up to date one firms up grace periods shows that it's an issue that PPCs needed pulling up on.

Coupon-mad

That's a good point, LOC123.

Tommer123

I'll post here what I have :-):beer:

Tommer123

In the County Court at Bath, The Law Courts, North Parade Road, Bath, BA1 5AF

Claim No. XXXXXXX

Between

PARKINGEYE LTD (Claimant)

and

XXXXXXXXX (Defendant)


WITNESS STATEMENT

I, XXXXXXXXX, of XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX, will say as follows:

I am the Defendant in this matter. Attached to this statement is a paginated bundle of documents marked TH1 to which I will refer.

1. The Claimant asserts that I entered into a contract with it, that I breached that contract and must pay a contractual charge, with further undefined and unexplained additional charges. It claims that I was in the relevant car park for a total of 2 hours and 14 minutes, when only 2 hours was permitted. It is these 14 minutes with which the Claim is concerned.

2. Before I describe what happened on the day I parked in the Rheidol Retail Park car park (“the car park”), I confirm that the essence of my defence to this claim is that:
a. I did not breach the terms and conditions of parking
b. The Claimant's signage did not make it clear whether the 2 hour free parking period offered included time spent after entering the site via its ANPR cameras looking for a space and parking in it and locating and reading the terms and conditions and deciding to accept them, and time spent when leaving the site via the same cameras exiting the space, driving round the car park's one way system and then driving out onto a public highway. It is my case that it offered 2 hours of free parking, and that is the period I parked for. It is trite law that any uncertainty in a contract should be resolved against the person who offered it under the contra preferentem rule;
c. Even if I did breach the terms, the Claimant is obliged by the compulsory Code of Practice of its own Accredited Trade Association to apply separate grace periods of at least 10 minutes at the start and end of each period of parking to allow for potential delays in finding a space, exiting the car park and to allow time for drivers to find and read the terms and conditions offered, and the 14 minute overstay is well within these grace periods.

3. At page 1 of TH1 is a google earth aerial photograph of the car park. I've marked on it in red roughly where my car was parked and the approximate location of the sign nearest to the car. In yellow dashes I have marked the route I took round its one-way system to the exit road. The Claimant's ANPR machine is, I believe, almost next to the junction to the exit road. The exit road is marked in blue, with the roundabout intersecting the public highway (Alexandra Road) marked with a blue cross. Alexandra Road, which is the main road outside the car park, and where there was very slow moving traffic at the time I exited the car park, is marked in green on the photograph.

4. Turning to the day of the parking, on 30th May 2017 I was in Aberystwyth for a business meeting. When the meeting was finished, I decided to do some shopping and parked in the car park at Rheidol Retail Park. It was my first visit to this car park and I was not previously familiar with it, or the road layouts outside it or how busy they could be.

5. After driving in past the ANPR cameras at the entrance, it took me a few minutes to find a space and park in it as the car park was quite busy. I remember waiting for a few other cars to manoeuvre in and out of spaces before parking myself. When I got out of the car, I walked over to the closest parking sign to read it. I estimate that this took 3-4 minutes, possibly a little more. The sign and where I parked my car are marked on the aerial photograph at pages 1 & 2 of TH1 in red. The sign stated that there was a free 2 hour period of parking. I immediately set a timer on my phone to make sure I got back to the car in time, left the car and went shopping. I know that I returned to the car within 2 hours, because my alarm went off after I was back at the car, and I also remember looking at my watch when I got back to the car to check that I was back in time (which I was).

6. It is my understanding that there are three elements to a contract: offer, acceptance and consideration. I could not possibly have accepted any contract offered by the Claimant at the precise moment I drove through the ANPR cameras, at the start of minute 1 of the 2 hours and 14 minute period, because at that point no offer had been made. An offer must be communicated to an offeree. There was no offer communicated at the entrance to the car park, but only inside it - the Claimant’s signage setting out the terms and conditions were dotted around the site and could not be seen immediately on entry, and I could not read them from my car. It took me 3-4 minutes to drive in, find a space, find a sign, read it and decide to avail myself of the parking. At that point I say an offer was made (insofar as the sign was capable of making an offer), and I accepted it.

7. Since no contractual terms were offered until I had read the sign, that leaves the remaining 10 minutes of my alleged overstay.

8. When I returned to my car, the carpark was very busy. I know that I reached my car within the 2 hour limit, because my alarm went off after I was back at the car. I did not remain parked when I returned to the car, I got straight in it and drove off, and at that point I was no longer making use of the car parking facility, but was exiting the car park.

9. It took me a long time to reach the exit road (marked in blue on the photograph at page 1 of TH1) and then drive out onto the public highway (marked in green), because I had to drive around the car park’s one-way system (marked in yellow on the photograph), stopping along the way to allow other cars to get in / out of spaces and out of junctions (shown on page 2 of TH1 in yellow) within the car park, and when I reached the exit, there was a traffic jam leading to the roundabout outside (marked with a blue cross). The roundabout is at the end of the exit road and intersects the main road (Alexandra Road, marked in green) and on the day it was heavily congested which meant the traffic was almost at a standstill leading up to and going round the roundabout. There were a lot of cars stuck inside the car park waiting to get out. I estimate that it took me around 10 minutes to get to the exit road and out of the car park, past the ANPR cameras. I remember it all very clearly because it was a warm day and my car’s air-conditioning was broken and it was incredibly frustrating queuing up while only a single car at a time managed to get out onto the main road.

10. I was not familiar with the car park layout or how busy the road outside it could be. The fact is that I returned to my car and drove it away from where it was parked within the 2 hour period and made every effort to exit the car park in a timely manner. I was delayed because of reasons beyond my control (the traffic jams both inside the carpark and on the public highway outside) and I could not have anticipated them. The entirety of the final 10 minutes spent in the car park were spent trying to exit it. The Claimant, a company which manages the car park, should be aware of these issues and should make reasonable allowances for the foreseeable delays users may experience in exiting the car park.

11. Contractually, the Claimant’s signage did not specify that the 2 hours of free parking included time spent finding a space and then leaving the car park via the ANPR cameras. Had this been clear to me, I would have returned to the car earlier. Of the 14 minute alleged overstay, 3-4 minutes (possibly more) were spent in the car park prior to any contract being formed. The 10 minute delay in leaving at the end of the 2 hours was beyond my control and unforeseeable. I made all reasonable endeavours to leave the car park and to remain parked for only 2 hours.

12. In addition to considering the contractual element of the claim, I have considered the Code of Practice ("CoP") of the British Parking Association ("BPA"), of which the Claimant is an accredited member. A copy of paragraph 13 of the CoP, which relates to grace periods, is at page 3 of TH1. In order to be an accredited member of the BPA, compliance with the CoP is compulsory, and a copy of paragraphs 4.1 and 6 of the CoP is at pages 4 & 5 of TH1. The significance of being a member of the BPA and subscribing to its CoP is that the Claimant is only entitled to ask the DVLA for the details of a car’s registered keeper if it is a member (so without membership a private parking company would not be able to function without the ability to trace drivers/registered keepers).

13. Paragraph 13 of the CoP clearly states that a grace period is to be applied to parking. The CoP makes clear that such grace periods are to be applied both at the start of any parking period and also at the end of any parking period. The whole point of these grace periods is to allow drivers time to find a parking space and to read the signage prior to commencement of the period of parking, and time to exit the carpark once they have finished parking. Grace periods are not defined, but the CoP requires them to be "a minimum of 10 minutes" either side of the actual parking (paragraphs 13.2 and 13.4). It is worthy of note that the recommendation is a minimum of 10 minutes, not a maximum.

14. There is no explanation for why the Claimant has declined to apply any grace period at all in my case, which is a clear breach of the CoP.

15. In the now infamous parking case of Cavendish Square Holdings BV v Talal El Makdessi; ParkingEye Limited v Beavis, the Supreme Court made clear in its judgment that strict compliance with the CoP is paramount where a Claimant seeks to enforce a private parking charge. Paragraphs 96 and 111 of the judgment stated:
96. ''The BPA Code of Practice is a detailed code of regulation governing signs, charges and enforcement procedures.''
111. “''And, while the Code of Practice is not a contractual document, it is in practice binding on the operator since its existence and observance is a condition of his ability to obtain details of the registered keeper from the DVLA. In assessing the fairness of a term, it cannot be right to ignore the regulatory framework which determines how and in what circumstances it may be enforced.'' (emphasis added).

16. In this case, the data produced and relied upon by the Claimant shows that the period passing between my car entering and leaving via the ANPR cameras was 14 minutes. Applying the "minimum" 10 minutes either side of the parking, the minimum total grace period I should have been allowed by the Claimant under its own compulsory CoP was 20 minutes. I was therefore well within the grace period. Whilst I accept that following the parking I was on site for around 10 minutes, this was because of the heavy traffic both inside and outside the carpark, a matter which was outside of my control. The Claimant should have taken a reasonable and proportionate approach, complied with its own obligations under the CoP (not to mention exercised common sense) and should have applied the grace period, particularly in light of the potential bottleneck at the roundabout at the exit from the car park. Furthermore, the issue the court is being asked to deal with is de minimis and the court's valuable time should not have been taken up with this matter.

17. I have repeatedly drawn these matters to the Claimant's attention, but it has refused to see reason, including applying an appropriate grace period of "a minimum of 10 minutes" before and after parking, which it is actually obliged to do by its compulsory CoP.


The Court is invited to dismiss the claim and to award my costs of dealing with this claim and attendance at the hearing, such as are allowable pursuant to CPR 27.14.

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


Signature of Defendant:


Name: XXXXXXX
Date: 07/09/2018

Tommer123

Tommer123

Coupon-mad

The BPA CoP section on grace periods should be 'TH1'. It's your first piece of evidence you rely on, you can't just mention it and not show the Judge the exhibit.

Then I would mention and adduce as an exhibit, Kelvin Reynolds' BPA article (easy to Google it) about grace periods not being a set time, depending upon factors not limited to disability' i.e. it supports your story about a busy car park holding you up. TH2.

This is very buried in #16, hidden almost! Make it near the top on its own:

Whilst I accept that following the parking I was on site for around 10 minutes, this was because of the heavy traffic both inside and outside the carpark, a matter which was outside of my control.

Then the aerial view evidence, will be TH3.

Then what about actual photos of the sign? TH4?