Gladstones LBC received for residential parking spot (New World Facilities East Essex LTD)

BlueNine

Me again...so I submitted my defence on the 31st May and Gladstones' have contacted me with their DQ, but I haven't received mine from the CCBC yet (and MCOL isn't saying anything about one being sent, but not sure if it would?) so I'm looking at downloading one and doing it that way.



The advice is to send it to the courts and the claimant - would that be the CCBC address (Northampton?) and the Gladstones address on the Claim Form?

KeithP

Return your completed DQ to the CCBC in the same manner and to the same email address that you sent your Defence.

And yes, send a copy to the Claimant's 'address for documents' as stated on the Claim Form.

BlueNine

I have a court date!


So now I need to put together my witness statement and my...skeleton? Since they're pursuing me as keeper, is this the point where I identify the driver?


Also I'll be moving house before my date comes up, who do I let know about the change of address? I'm assuming the courts and gladstones, but do I need to let every debt collector that contacted me about this etc?

KeithP

BlueNine wrote: »

Since they're pursuing me as keeper, is this the point where I identify the driver?

No. Why would you want to do that?

BlueNine

KeithP wrote: »

No. Why would you want to do that?

Yeah good point.




So the move is done and I'm finally able to put some time into getting everything together for my court date (5 days to get all my evidence in, not the best timing!) and I'm going through the minimum checklist in the newbies thread:


a. Is the sign here http://parking-prankster.blogspot.com/2016/01/did-parkingeye-deceive-supreme-court.html a copy of the Beavis case sign as a comparison to show how awful the small print was?


b. I have photos showing the signage that supposedly formed the contract, the text size isn't as bad as Beavis but I'd argue it's still small enough not to see from a car. (can upload pics if that's adviseable?)


c. Plan to take a video tomorrow evening now that the clocks have gone back (as they were when I got the ticket) to show how the signage isn't greatly visible at night.


d. Schedule 4 of POFA saved as I am defending as keeper.


e. Copy of 'Keeper Liabililty' from POPLA Annual Report 2015 saved as I am defending as keeper.


f. I have scanned the relevant pages of my tenancy (just showing I had one at the time of PCN, and that I had Quiet Enjoyment included) and of the landlord's lease stating demise, right to use the parking space and quiet enjoyment. - question do I have to make fully copies of both of these documents? The landlords lease is a hefty 35ish pages!


g. Downloaded Jopson vs Homeguard 2016, Pace vs Mr N 2016 and PCMUK vs Bull et all 2016 which cover forbidding signage (one of the signs simply states "NO PARKING AT ANY TIME") and residential parking charges.


h. Don't think the IPC code of conduct applies...but it does have some stuff about signage so not sure



i. No pay & display ticket - I could provide proof of parking permit?


extras. Was thinking of going through my defence (posted earlier) and getting together everything I mentioned in there like Civil Procedure Rule 16.4, Civil Practice Direction 16 etc.


Witness statement. Since I'm defending as keeper I'm thinking my witness statement will along the lines of a "this is my name, I am the keeper of the vehicle reg xxxx parked in the space at [address] on [date], I received PCN letter on [date] and appealed unsuccessully, I received a NTK on [date], I invite the court to throw this out" kinda deal.


Tbh I'm not confident at all in this and kinda wish I'd just paid £60 2 years ago...but I guess that's what these leeches count on!

Coupon-mad

a. Is the sign here http://parking-prankster.blogspot.com/2016/01/did-parkingeye-deceive-supreme-court.html a copy of the Beavis case sign as a comparison to show how awful the small print was?

Yes.

b. I have photos showing the signage that supposedly formed the contract, the text size isn't as bad as Beavis but I'd argue it's still small enough not to see from a car. (can upload pics if that's adviseable?)

You mean your sign is bad (Beavis' was a ''good'' example so the Supreme Court said!

c. Plan to take a video tomorrow evening now that the clocks have gone back (as they were when I got the ticket) to show how the signage isn't greatly visible at night.

Good.

d. Schedule 4 of POFA saved as I am defending as keeper.

Yep. You will need to highlight the relevant paras (either 8 or 9) and the bit earlier on about 'adequate notice' of the parking charge on signs, and the requirement for a 'relevant obligation/contract' as you are saying there was no such obligation or contract that could interfere with the rights under your lease/tenancy.

e. Copy of 'Keeper Liability' from POPLA Annual Report 2015 saved as I am defending as keeper.

Good.

f. I have scanned the relevant pages of my tenancy (just showing I had one at the time of PCN, and that I had Quiet Enjoyment included) and of the landlord's lease stating demise, right to use the parking space and quiet enjoyment. - question do I have to make fully copies of both of these documents? The landlords lease is a hefty 35ish pages!

No, but take the full version in your bundle to the hearing.

g. Downloaded Jopson vs Homeguard 2016, Pace vs Mr N 2016 and PCMUK vs Bull et all 2016 which cover forbidding signage (one of the signs simply states "NO PARKING AT ANY TIME") and residential parking charges.

Good.

h. Don't think the IPC code of conduct applies...but it does have some stuff about signage so not sure

The IPC CoP applies but not a strong point so I wouldn't bother.

i. No pay & display ticket - I could provide proof of parking permit?

Yes you should attach it as evidence but saying there was never an obligation to display it that could override your rights and easements at this location.

extras. Was thinking of going through my defence (posted earlier) and getting together everything I mentioned in there like Civil Procedure Rule 16.4, Civil Practice Direction 16 etc.

No need to print out court rules, it won't come up and the Judge is familiar with them.

You also need to file a costs schedule as per other recent cases discussed here in Oct/Nov.

And the IOW and Caernarfon case judgments where PPC cases were struck out by Judges due to the fake added £60 which is an unfair term and double recovery. These are in post #14 of the Abuse of Process thread by beamerguy.

And print Schedule 2 of the CRA 2015 (Part 1) which is known as the 'grey list' where terms are likely to be unfair:

http://www.legislation.gov.uk/ukpga/2015/15/schedule/2/enacted

The added £60 fails para 10 and 14 of the grey list and a test of fairness MUST be considered by any court, whether a party to a claim raises the issue, or not!

And you can add the Guidance to the Consumer Rights Act 2015, pages 87 and 88 that talk about double recovery term being penal and unfair (I only recently discovered this wording):

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/450440/Unfair_Terms_Main_Guidance.pdf

5.14.3 Other kinds of penal provisions which may be unfair are clauses saying that the business can:
- claim all its costs and expenses, not just its net costs resulting directly from the breach;
- claim both its costs and its loss of profit where this would lead to being compensated twice over for the same loss; and
- claim its legal costs on an 'indemnity' basis, that is all costs, not just costs reasonably incurred. The words ‘indemnity’ and 'indemnify' are also objectionable as legal jargon – see the section on transparency in part 2 of the guidance.

The fairness of any term is assessed having regard to the other terms of the contract, and even if not excessive when considered separately, may be unfair if it could operate together with another term or terms so as to lead to the trader being compensated twice for the same loss.

5.14.4 Potentially penal terms.
A disproportionate financial sanction involving requirement to pay a fixed or minimum sum, in all circumstances, will be open to challenge if the sum could be too high in some cases.

5.14.5 Assessment of unfairness focuses on the effect terms could have, not just the purposes they are intended to serve. Thus a clause may be unfair if it allows the trader excessive discretion to decide the level of a financial sanction, or if it could have that effect through being vague, or unclear, or misleading about what consumers will be required to pay in the event of default. Consumers rarely know about technical issues such as ‘mitigation’ of loss (see below), and so can easily be misled into thinking that the trader can claim more than is really the case.

and also pages:

9
37
38
97
105
106

One of those pages confirms that CONSUMER NOTICES do not fall under the 'core exemption' about price terms...i.e. the test of fairness, prominence and transparency of the parking charge and specifically of the added £60 hidden extra, MUST be considered by a court and this 'price' (the added peal term of £60) is NOT exempt from that test.

In the Beavis case ParkingEye got away with it and even argued that last bit...but the hearing occurred before the CRA 2015 was enacted.

BlueNine

Excellent advice appreciated as always Coupon-mad.


Here's my WS first draft - I haven't quite got everything in yet, but I'm already wondering if I've got irrelevant parts in there as I've copied bits and pieces from elsewhere (a fair amount from otterpanda's thread who happens to be dealing with the same parking company as me!), plus I wanted to post one before I have to stop working on it for tonight.

[FONT=&quot]I am xx and I am the Defendant in this matter. If the documents are not set out in the way that the Claimant may do, I trust the Court will excuse this. The facts and matters stated are true and within my own knowledge, except where indicated otherwise.

I will say as follows:

Background
1. This Claim arises from an alleged breach of contract relating to a parking incident in my own parking space outside a flat that my partner and I rented from the owner.

2. The flat is at xx and also included allocated parking space number xx.

3. This is a flat which comes with unfettered rights to the parking space. When the land was leased to my landlord on xx, rights were given to use the parking space as well as the right to quiet enjoyment without interruption, these rights were demised to my partner and I as tenants of the landlord. A copy of the tenancy agreement has been attached as Exhibit A and the land lease as Exhibit B.[/FONT]
[FONT=&quot]
4. We also took possession of a parking permit disc for display in a car. A copy of this is shown at Exhibit C. However, this is submitted only as evidence of authorisation to park on the property. There was no obligation for it to be displayed that could override my rights and easements at this location.


Facts
5. There was a Lease in existence in relation to the flat and parking space - a copy of which was obtained from the land registry and I have reason to believe that the terms of the lease have not varied from the document dated xx.

6. I have attached a copy of the relevant excerpts from the lease document as Exhibit B and have highlighted the following points:[/FONT]
[FONT=&quot]
a. The page titled ‘Plan 2’ which shows the location of the parking space referred to in the land lease as defined on page 1, section 1.1.3.1 ‘Definition of ‘the Car Parking Space’’[/FONT]

[FONT=&quot]b. Page 5 – Section 2 ‘Demise’[/FONT]
[FONT=&quot]“The Landlord demises the Flat and the Car Parking Space to the Lessee with full title guarantee, together with the rights specified in Schedule 2 but excepting and reserving to the Landlord the rights specified in Schedule 3, to hold to the Lessee for the Term subject to all rights, easements, privileges, restrictions, covenants and stipulations of whatever nature affecting the Flat and the Car Parking Space including any matters contained or referred to in Schedule 9, yielding and paying to the Landlord without deduction or set-off;”[/FONT]

[FONT=&quot]c. Page 10 – Section 2-6 ‘Right to use the communal parking spaces’[/FONT]
[FONT=&quot]“The right, in common with the Landlord and all other persons having a like right, for the Lessee and all persons expressly or by implication authorised by him in accordance with such reasonable regulations as the Landlord may make from time to time for the benefit of the lessees of the Building to use the car parking spaces designated by the Landlord from time to time as available for common use by the lessees and occupiers of the flats in the Building and their visitors.[/FONT]

[FONT=&quot]d. Page 16 – Section 5-9.2.1 ‘Assignment, subletting and charging of part’[/FONT]
[FONT=&quot]“The Lessee must not assign, sublet, part with possession of, or charge part only of the Flat or Car Parking Space. The Lessee must not assign, sublet, part with possession of, or charge the Flat separately from the Car Parking Space or vice versa.”[/FONT]

[FONT=&quot]e. Page 19 – Section 5-31.2 ‘Use of the Car Parking Space’[/FONT]
[FONT=&quot]“The Lessee must use the Car Parking Space for car parking only of a single roadworthy private car, and must not carry out any servicing repairs or painting of any car on the Car Parking Space.”[/FONT]

[FONT=&quot]f. Page 21 – Section 6-1 ‘Quiet enjoyment’[/FONT]
[FONT=&quot]“The Landlord covenants with the Lessee to permit the Lessee peaceably and quietly to hold and enjoy the Flat and the Car Parking Space without any interruption or disturbance from or by the Landlord of any person claiming under or in trust for him.”[/FONT]

[FONT=&quot]7. I have attached a copy of Schedule 4 of the Protection of Freedoms Action 2012 which relates to the recovery of unpaid parking charges as Exhibit D and have highlighted the following points:[/FONT]

[FONT=&quot]a. Page 2 – Paragraph 2.2 and 2.3[/FONT]
[FONT=&quot]“2 (2) The reference in the definition of “parking charge” to a sum in the nature of damages is to a sum of which adequate notice was given to drivers of vehicles (when the vehicle was parked on the relevant land).[/FONT]

[FONT=&quot](3) For the purposes of sub-paragraph (2) “adequate notice” means notice given by –[/FONT]
[FONT=&quot](a) the display of one or more notices in accordance with any applicable requirements prescribed in regulations under paragraph 12 for, or for purposes including, the purposes of sub-paragraph (2); or[/FONT]
[FONT=&quot](b) where no such requirements apply, the display of one or more notices which – [/FONT]
[FONT=&quot] (i) specify the sum as the charge for unauthorised parking; and[/FONT]
[FONT=&quot](ii) are adequate to bring the charge to the notice of drivers who park vehicles on the relevant land.”[/FONT]

[FONT=&quot]b. Page 3 – Paragraph 4.1 and 4.2a[/FONT]
[FONT=&quot]“4 (1) The creditor has the right to recover any unpaid parking charges from the keeper of the vehicle.[/FONT]

[FONT=&quot](2) The right under this paragraph applies only if –[/FONT]
[FONT=&quot](a) the conditions specified in paragraphs 5, 6, 11 and 12 (so far as applicable) are met; and”[/FONT]

[FONT=&quot]c. Page 4 – Paragraph 6.1b ‘Conditions that must be met for purposes of paragraph 4’[/FONT]
[FONT=&quot]“6 (1) The second condition is that the creditor (or a person acting for or on behalf of the creditor) – [/FONT]
[FONT=&quot] (b) has given a notice to keeper in accordance with paragraph 9.”[/FONT]

[FONT=&quot]d. Page 5 – Paragraph 9.1, 9.2a, 9.2e and 9.7.[/FONT]
[FONT=&quot]“9 (1) A notice which is to be relied on as a notice to keeper for the purpose of paragraph 6(1)(b) is given in accordance with this paragraph if the following requirements are met.[/FONT]

[FONT=&quot](2) The notice must – [/FONT]
[FONT=&quot] (a) specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;”[/FONT]

[FONT=&quot]“ (e) state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper – [/FONT]
[FONT=&quot] (i) to pay the unpaid parking charges; or[/FONT]
[FONT=&quot] (ii) if the keeper was not the driver of the vehicle, to notify the creditor[/FONT]
[FONT=&quot]of the name of the driver and a current address for service for the[/FONT]
[FONT=&quot]driver and to pass the notice on to the driver;”[/FONT]

[FONT=&quot]“(7) When this notice is given it must be accompanied by any evidence prescribed under paragraph 10.”[/FONT]

[FONT=&quot]8. I have attached a copy of Schedule 2 of the Consumer Rights Act 2015 (Part 1) which relates to consumer contract terms which may be regarded as unfair as Exhibit M and have highlighted the following points:[/FONT]

[FONT=&quot]a. Page 2 – Paragraph 10[/FONT]
[FONT=&quot]“10 A term which has the object or effect of irrevocably binding the consumer to terms[/FONT]
[FONT=&quot]with which the consumer has had no real opportunity of becoming acquainted[/FONT]
[FONT=&quot]before the conclusion of the contract.”[/FONT]

[FONT=&quot]b. Page 2 – Paragraph 14[/FONT]
[FONT=&quot]“14 A term which has the object or effect of giving the trader the discretion to decide[/FONT]
[FONT=&quot]the price payable under the contract after the consumer has become bound by it,[/FONT]
[FONT=&quot]where no price or method of determining the price is agreed when the consumer[/FONT]
[FONT=&quot]becomes bound”[/FONT]

[FONT=&quot]9. I have attached a copy of pages 87 and 88 of the Guidance on the unfair terms provisions in the Consumer Rights Act 2015 as Exhibit N and have highlighted the following points:[/FONT]

[FONT=&quot]a. Section 5.14.3, 5.14.4 and 5.14.5[/FONT]
[FONT=&quot]“5.14.3 Other kinds of penal provisions which may be unfair are clauses saying that the business can:[/FONT]
[FONT=&quot]- claim all its costs and expenses, not just its net costs resulting directly from the breach;[/FONT]
[FONT=&quot]- claim both its costs and its loss of profit where this would lead to being compensated twice over for the same loss; and[/FONT]
[FONT=&quot]- claim its legal costs on an 'indemnity' basis, that is all costs, not just costs reasonably incurred. The words ‘indemnity’ and 'indemnify' are also objectionable as legal jargon – see the section on transparency in part 2 of the guidance.[/FONT]

[FONT=&quot]The fairness of any term is assessed having regard to the other terms of the contract, and even if not excessive when considered separately, may be unfair if it could operate together with another term or terms so as to lead to the trader being compensated twice for the same loss.[/FONT]

[FONT=&quot]5.14.4 Potentially penal terms.[/FONT]
[FONT=&quot]A disproportionate financial sanction involving requirement to pay a fixed or minimum sum, in all circumstances, will be open to challenge if the sum could be too high in some cases.[/FONT]

[FONT=&quot]5.14.5 Assessment of unfairness focuses on the effect terms could have, not just the purposes they are intended to serve. Thus a clause may be unfair if it allows the trader excessive discretion to decide the level of a financial sanction, or if it could have that effect through being vague, or unclear, or misleading about what consumers will be required to pay in the event of default. Consumers rarely know about technical issues such as ‘mitigation’ of loss (see below), and so can easily be misled into thinking that the trader can claim more than is really the case.”[/FONT]

[FONT=&quot]10. On xx my xx car registration xx was correctly parked in my allocated parking space number xx, no Notice to Driver was affixed to the windscreen at any point between then and xx when the PCN to me as Keeper was sent by Parking Collection Services (PCS) on behalf of NWFEEL. On xx I contacted the letting agent Nicholas Percival requesting information in order to appeal, and to complain about receiving the PCN, they responded on xx to state that they had passed the information on to the property management group, PMS.[/FONT]
[FONT=&quot]On xx PMS got in contact with me to say that “the owner of the flat has the absolute right to use the parking space and so I imagine that this right has been transferred to you via your tenancy agreement” (full transcript in Exhibit J), following this I completed the appeals process using PCS’ online appeals form and on xx was told that they can only accept an appeal from the driver on the date in question.[/FONT]

[FONT=&quot]11. I submit Exhibit L the Notice to Keeper I received on xx, as evidence that the NWFEEL have no right under to recover any unpaid parking charges from me as keeper of the vehicle as the notice given did not meet the requirements of Schedule 4 Paragraph 9 of POFA 2012. There were no specifics to the period of parking mentioned, there was a lack of statement declaring the creditor does not know the name of the driver and a current address for service, and the notice was accompanied by no evidence. [/FONT]

[FONT=&quot]12. As a tenant of xx which comes with allocated space xx, I was residing under the terms of the Lease demised to me as a tenant. This allowed unfettered rights to park in the allocated parking space.[/FONT]

[FONT=&quot]13. In relation to the lease, which underpins the conduct of tenancy I will refer to the following judgments which refer to the fact that the terms of a lease cannot be altered without formal consultation, and taking the appropriate steps.

14. As the tenant of the flat the Defendant has primacy of contract, being indisputably authorised and ‘sanctioned’ the right to park a car in the Defendant’s allocated space which is assigned to the apartment. There is no term or contract applicable to me as tenant nor the legal owner of the apartment flat, mandating the requirement to display a permit, or to pay a penalty to a third party for non-display of same.

15. NWFEEL’s signage at this site states “No parking at any time” and refers among other ambiguous and not clearly-worded headings: ‘‘residents & visitors must display a valid permit’’ and ‘‘authorisation to park in an allocated bay must be granted by the landowner’’.[/FONT]

[FONT=&quot]16. In the event that the Court believes there was an attempt at forming a contract, the Defendant will interpret the above clauses with their normal meaning and assert that parking was granted and ‘sanctioned’ and was not ‘unauthorised’.[/FONT]

[FONT=&quot]17. I submit that any contract that would be successfully formed using the signage in the area of xx would not be formed with NWFEEL as every sign in the area states that the company is registered in England & Wales with a company number of 8307526. This company number is for Scrimmage Productions Limited, a company which dissolved on 28 January 2015.[/FONT]

[FONT=&quot]18. It is submitted that this notice is attempting to make a contractual offer which is forbidding, and as such does not fulfil the basic requirement of a contract, i.e. each party to the contract must offer valuable consideration to the other party, on clear terms capable of acceptance. In this case, the parking operator is not offering anything to a party with leasehold title who already enjoys an unequivocal right to park and access the property, unhindered. The notices cannot reasonably be construed as having created a contractual relationship between the original parking operator and the Defendant, remembering that this Claimant was not that ‘parking operator’ anyway.[/FONT]

[FONT=&quot]19. I cite as Authority, the Judgment in the Appeal case of Jopson v Homeguard Services [2016] B9GF0A9E, Oxford County Court, 29 June 2016 (Appended as Exhibit E). In his Judgment, HHJ Harris QC states, at [18]: ‘It therefore seems clear to me that the respondent was not in any position unilaterally to override the right of access which the claimant had bought when she purchased the lease …’ and this Senior Circuit Judge commented that life in a block of flats would be unworkable if authorised access to properties by parties entitled to that grant, were to be subject to a penalty.

21. A similar case was recently heard at Croydon County Court, in PACE Recovery & Storage v Mr N (C7GF51J1) (Appended as Exhibit E), where District Judge Coonan stated in her Judgment at [18] ‘I have to be satisfied that the contract has been varied to include such a provision and I am not satisfied because I am not satisfied that clause 6(3) was complied with at any relevant stage. Therefore, the tenancy agreement takes precedence over the arrangement between Sutton and yourself, the claimant, Pace Recovery. As I have said, it is a pure matter of contract that I have to decide. Therefore, the claim is dismissed’. [/FONT]
[FONT=&quot]
22. In a similar case in UKPC v Masterson, B6QZ4H3R (Appended as Exhibit E) at Edmonton in May 2016, DDJ Ellington in the Judgement at [6], found that signage stating ‘no unauthorised parking’ made no offer. He held: ‘‘I am not able to consider that that is an open offer to contract to park at first sight. If anything, it prohibits unauthorised parking on my reading of it.’’

23. I submit that these cases provide persuasive authority for my contention that the property lease title has primacy of contract over the original creditor’s signage, which in any event exempts cars parked with authority or ‘sanction’. I consider that the attempt to impose a ‘fine’ on me for parking in the allocated bay of my rental property is a case of derogation from grant which is not something for the courts to support against a resident.

24. There is no comparable ‘legitimate interest’ as found at the Supreme Court in the complex and completely different (retail park) case of ParkingEye v Beavis [2015] UKSC 67. In the UKPC v Masterson case, DDJ Ellington also distinguished the case from Beavis: ‘‘I am unable to accept that the particular circumstances of this case reveal a contractual licence to park with a contract between the parking manager, in this case UKPC, in the Supreme Court authority ParkingEye, and the vehicle owner or driver, in this case the defendant, and in the Supreme Court authority, Mr Beavis.''

25. The particulars of claim include a substantial charge additional to the parking charge which it is alleged the defendant contract to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 not with reference to the judgement in Parking Eye vs 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 and is an attempt at double recover.[/FONT]

[FONT=&quot]26. The added charge in the particulars of claim also fail paragraphs 10 and 14 of Schedule 2 of the Consumer Rights Act 2015 and a test of fairness must be considered by the court. Section 5.14.3 of the Guidance to the Consumer Rights Act 2015 suggests that trying to claim all costs and expenses may be penal and unfair.[/FONT]

[FONT=&quot]27. The Court is invited to dismiss the Claim as being without merit, and further, in the event that the Claimant should discontinue this Claim, to maintain the listed hearing date of xx as a costs hearing, in order that I can apply for a Costs Order against the Claimant

I believe the facts stated in this Witness Statement are true to the best of my knowledge.[/FONT]

I'm wondering about how I've laid out the "I've attached this and point out these bits" part and whether I should do that at all, and if so if I should immediately follow up with how that applies to my case or if it's better all in one place.


Also when it says evidence has to be delivered to the other party & courts no later than 14 days prior to the hearing, does email count or is that postal?


I looked up the costs schedule, do I need to use an official form or is it more like a document setting out "I earn this much per hour x this many hours + travelled this many miles x a reasonable mileage rate + parking costs"?

KeithP

BlueNine wrote: »

I looked up the costs schedule, do I need to use an official form or is it more like a document setting out "I earn this much per hour x this many hours + travelled this many miles x a reasonable mileage rate + parking costs"?

There are examples of Costs Schedules linked from post #2 of the NEWBIES thread.

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/76445468#Comment_76445468

Costs schedule above. Also read the Portswood thread by CEC16 as you now need to cite the 11th November Southampton hearing where £160 charge was deemed manifestly excessive and contrary to the POFA, the Beavis case and the Consumer Rights Act 2015.

I edited to update post #14 of the Abuse of Process thread yesterday, with the words I suggest you put into a supplementary WS to stop this getting too long, and to keep your pages easier to read for the Judge.

BlueNine

Costs schedule done...it's coming out at around £350, is that too much? (it has taken me a long time to write this stuff up etc)


Also big question, for submitting the Witness statement etc - can I email it? if not and I have to post/hand deliver it, do I sent it to the county court where the hearing is taking place, or to the county court at the top of my notice of allocation to the small claims track (hearing) letter?




edit: and which court do I put on all the headers of my documents?