First Parking PCN

KeithP

zipadee said:

I have today received an email from DCBLegal that their client intends to proceed with the claim. They have sent their Directions Questionnaire.  I have downloaded the N180 DQ from the website and have filled out. There is a box at the top next to the claim number box, which says "In The". Can anyone confirm what should go in there. Is it my local County Court ? On the claimants DQ they have entered "the County Court Business Centre" in this box,

But you are not going to send it to your local County Court, are you?
Read what it says in that box on your County Court Claim Form.

Coupon-mad

The stages are all covered in the NEWBIES thread, including a question by question explanation of how to fill in a DQ, written by @bargepole in the thread I link for people to read, under the read heading 'IMPORTANT - KNOW WHAT HAPPENS WHEN'.

zipadee

I have just now received notice of the hearing set for 23rd September. The hearing will take place remotely via Teams

I have also recently received two letters from dcbltd chasing money for a second pcn from First Parking again at another car park at the University of Hertfordshire. I was expecting this. Will ignore until I get a letter of claim. Should I at that point ask for both claims to be consolidated ? 

Thanks

Coupon-mad

You can't because the 2nd one won't be filed in time if you are only getting letters from notoriously debt crawlers, DCB Ltd and not DCBLegal, yet.

zipadee

With a hearing set for 23rd September, is it sensible for me to start working on the witness statement now. This is a remote hearing and documents need to be delivered no later than three days before the hearing date.Thanks.

Coupon-mad

This is a remote hearing and documents need to be delivered no later than three days before the hearing date.

No they don't!! 

It is NEVER 3 days, that's just the electronic bundle date, appending documents that you MUST have filed and served well before that.  There is another deadline on that Order. Read it again.

zipadee

Thanks Coupon-mad. Indeed it is no later than 14 days before hearing. I have downloaded a copy of robertcox999 witness statement to use as a template but have also asked AlwaysTrying23 if I can use his witness statement as the basis for my own as there are many similarities and points to his case e,g, it is a university residential car park and users must be unloading all the time and also the contract the university has with First Parking has a lot of information redacted.

Thanks

zipadee

Hi. My hearing is 23rd September and I would like to submit my witness statement in the next week as I am on holiday from 3rd September. I have used a combination of robertcox999's and AlwaysTrying's to base mine on. 

I am really struggling with how to use photographs as evidence. First Parking have sent me a number of photos with SAR which generally are not very clear and I have used a couple which are date stamped but very difficult to read. Infact they are almost illegible. They also have sent clear picture of their sign which I think is just a standard photo they send.

I have also taken some photos myself this week of signs at the entrance to car park and then signs within. I'm just really not sure how to use these photos in the defence, despite examples I've seen in other WS. The bottom of a lot of the signs have writing in very small fonts which obviously is not clear signage. Can you provide any guidance in this area please.  I'm hoping to post my WS  this weekend and hope you folks can give me your thoughts.

Thank you.

Coupon-mad

Embed the date the image was taken, into each photo.

For an example about how to use photos as exhibits and what to say, have a look at the WS by @jrhys and replace the Britannia v. Crosby judgment and blurb with Excel v Wilkinson. 

That transcript is in the thread I started a couple of months ago about the Recorder Cohen judgment, where I provided two transcripts to be used with all witness statements.  

Click on my username and find that thread under my discussions.

zipadee

Hi

Here is a link to my first draft of WS. I have added The Recorder Cohen Appeal Decision comments as suggested by Coupon-mad. What is the best way to append the full transcript for this into my WS as an exhibit ? Can I copy and paste or just take screen shots of each page and copy those in ?

I have also added the Redacted Landowners Agreement as an exhibit. Is this necessary or are the comments under this section in the WS  sufficient. 

Your comments would be really appreciated.

https://www.dropbox.com/scl/fi/xzh7x1yz8vf60s48wwjuj/ZIP_Witness-Statement-and-Exhibits.docx?dl=0&rlkey=ab53uvkckea4t51d71v1e6yq9

Thanks