Witness Statement due

rainday81

Thanks for the quick reply. Presumably the points about the daylight pics being irrelevant need to go into the skeleton statement and not the witness statement? Whereas my friend’s signed statement would go into the witness statement?

System

Yes. Facts and evidence in one. Arguments in the other.

rainday81

Here's my final draft witness statement, please let me know if everything is in order and whether all the evidence is relevant

https://drive.google.com/file/d/1zuw9dlzvW0CmOFB8wEWMdU6VJA3RFfiM/view

I'll be emailing this out first thing if all is well. Thanks in advance.

rainday81

Quick one hopefully, can the WS be filed electronically with the courts. I looked at MCOL and couldn't find any info.

KeithP

rainday81 wrote: »

Quick one hopefully, can the WS be filed electronically with the courts. I looked at MCOL and couldn't find any info.

Once a case is transferred to your local court, MCOL plays no part.

Your Witness Statement and Evidence needs to be delivered to the court where the hearing is due to take place. As this is usually a court local to you, it is suggested that you hand deliver a neatly presented folder or binder to the court.
Each court has strict limits on the amount of printing of emails it will do and it would be more than a little disappointing if the 'documents you intend to rely on' were not placed before judge.

System

I'd like to echo Keith's points above plus have a spare copy. Courts are notorious for losing these so an additional one for the judge on the day saves having the case adjourned.

rainday81

Please can someone review my skeleton argument, I've struggled slightly to collate the relevant arguments

1. Not sure if I have grounds for Locus Standi
2. I guess their signage isn't forbidding so those arguments don't stand
3. Please can someone review the contract with the management company (in their witness statement) and let me know if there are any arguments I can post in this regard

Please find below the relevant docs
https://drive.google.com/drive/folders/1hg7wgGPdgOwCG9kjkkaQF2BAQWCIgY7x

rainday81

Anybody? Getting slightly anxious with the date looming

nosferatu1001

I cant see those links from work

DONT GET ANXIOUS - remember the skellie is a SUMMARY

1) What do you mean? Locus standi just means making them prove THEY have standing. Absent a contract, they have NOTHIGN
2) WHy do you guess that? What do the signs say?
3) No, you review it and tell us if it makes sense? DOes it have the right days? Is the MC the freeholder? Given they WILL NOT be the freeholder of the land, that means they still lack any form of authority - back to 1) again!

Castle

rainday81 wrote: »

Please can someone review my skeleton argument, I've struggled slightly to collate the relevant arguments

1. Not sure if I have grounds for Locus Standi
2. I guess their signage isn't forbidding so those arguments don't stand
3. Please can someone review the contract with the management company (in their witness statement) and let me know if there are any arguments I can post in this regard

Please find below the relevant docs
https://drive.google.com/drive/folders/1hg7wgGPdgOwCG9kjkkaQF2BAQWCIgY7x

The sign is more than forbidding; it's actually impossible to comply with because unless you already have a permit you can't park anywhere. Even stopping to collect a permit is not allowed as their sign states;-"Retrospective evidence of authority to park will not be accepted".

See Pace Recovery & Storage vs Lengyel:- http://www.parking-prankster.com/more-case-law.html


The photograph of the sign taken by the PPC at 9.20pm (on page 41) proves the £100 figure can't be read at night even with a flash on their camera.