Period of validity

nosferatu1001

Yes'm include it as unreasonable behavoir. 

Why didn't you charge for
prparijg defence 
researching defence 
etc
its not just ws.  You itemise all time spent. 

Missaver

Yes, I mentioned :
Research, preparation and drafting of Defence and Witness Statement, 

nosferatu1001

Don't have it as a single line. 

It's easy to argue down 

Missaver

Question - but not related to this PCN that I am fighting - in the Lease, under the section for Owner's Covenant, Enforcement it states the following :  

If required by the Tenant and at the expense of the Tenant and against a suitable indemnity for costs to enforce the covenants on the part of the tenants contained in the Underleases of other Apartments and of other Premises in the Building.

What does this actually mean?  Does it mean that the Land Owner has the right to use a parking company to enforce charges..?

Coupon-mad

No it doesn't read as to be about parking at all.  It's about enforcing covenants and is not really a question that we have expertise in!

Have you seen the new thread today about telephone hearings and about anticipating them at WS & evidence stage, and that we are now saying to email the local court your documents, not take or post them to the court as per the usual advice?   

Save your printing ink and be ready for a Telephone Hearing Order.  Read that thread.

Missaver

Thanks, I will read that thread.
I anticipate a phone hearing if it comes to that, but I thought I read recently that face to face at Court is the best, even if the hearing gets delayed or I request to delay it. 

Missaver

I had emailed the Court to request filing the WS and everything else by email but am awaiting their reply. The automatic reply back does have an email attachment re email guidance and talks about printed paperwork should be max 50 pages.. With all the evidence and exhibits I have, I think it's over 50 pages. But let's see what their reply is when get round to seeing and replying my request. 

Coupon-mad

Read the Telephone Hearings thread, the advice has changed and print limits don't matter as there will be no printing.  Forget the request or waiting for a reply, crack on by email as advised in that new thread.

Missaver

Will do, thank you. 

Missaver

Update - I had a reply back from the Court re Electronic bundles, here is what they say : 
"Electronic bundles: the legal representative who arranges the telephone conference must send an electronic bundle for the hearing by email to the other party and to BOTH the following court email addresses by 4pm on the last working day before the hearing"

I had also emailed the solicitors my WS, Costs Summary and a link to a shared drive folder containing the Defence and all exhibits as separate PDFs, each labelled Exhibitxx01, etc.
When I email it to the Court, I will submit a single PDF as per advice below from your other thread re Phone hearings.
A single PDF file containing:
- Trial bundle contents page (with page and exhibit numbering clearly set out)
- your defence (in case the Judge does not have access to the case file)
- signed/dated witness statement (and supplementary WS if setting out the abuse of process issue separately)

Does the single PDF mean combining the WS, Defence, Costs Summary and 20+ Exhibit files into 1 large PDF ?  
(I hope that after trying to reduce the size, it can still be ok to email out..)

I also intend to list a 1 page summary of what each Exhibit number is, to email the solicitors and include in the submission to Court, is this ok?