Letter Before Claim

Scorpion84

That was quick. I do not know how you do that. thank you so much.

My partner needs to write a statement as well but I suppose it does not need to be long.

With regards to the evidence, POFA and Beavis, do I just photocopy the related paragraphs or whole documents (as it is over 120 pages?)

Also, can I use some of the photos that Claimant sent me previously and attached them in their own witness statementt as they support some of my points?

Scorpion84

Is this the correct cost schedule?

In the County Court at vvvvvvvvvvv

Claim No.: vvvvvvvvv
Between


parking company's name
(Claimant)


-v-



(your name)
(Defendant)




DEFENDANT'S SCHEDULE OF COSTS



Ordinary Costs



Loss of earnings/leave, incurred through attendance at Court xx/xx/2017 £xx.00

Return mileage from home address to Court (e.g. 5 miles x £0.45) £x.xx

Parking near Court £5.00

Sub-total £xxx.xx ======


Further costs for Claimant's unreasonable behaviour, pursuant to Civil Procedure Rule 27.14(2)(g)

Research, preparation and drafting of documents (3 hours at Litigant in Person rate of £19 per hour) £57.00

Stationery, printing, photocopying and postage: £15.00

Sub-total £xxx.xx ======




£ ______ TOTAL COSTS CLAIMED

Coupon-mad

With regards to the evidence, POFA and Beavis, do I just photocopy the related paragraphs or whole documents (as it is over 120 pages?)

Just the paragraphs of the Beavis case plonked into one page of A4. NOT 120 pages!

Plus Schedule 4 of the POFA, and Schedule 2 of the CRA 2015 with paras 6, 10, 14 AND ALSO 18 highlighted because in your case I say para 18 has also been breached by the trader failing to meet its own obligations to comply with the Trade Body Code of Practice and the CRA 2015 as regards clear terms about who can stay and for how long, and a workable system to exempt people who attend for parties that will take longer.

can I use some of the photos that Claimant sent me previously and attached them in their own witness statement as they support some of my points?

100% yes, I do. I often use their own evidence against them.

Also Google Streetview might be useful, as you can change the time of the image and compare signs and changes at various dates, using the little arrow under the top left thumbnail pic.

Yes that costs schedule is fine except the 2017 date of course and I would put down more hours than three, you must have spent more than 15 hours on all this...

Scorpion84

Everything already highlighted. Will correct mistakes tomorrow and add the extra bits you mention. Thank a lot again.

Scorpion84

One last qs: when everything is ready to be posted shall I add on the front letter that I have never received the Judge's directions therefore my statement arrives late?

Le_Kirk

KeithP wrote: »

C-m, we have seen several in the last couple of weeks headed Notice of Small Claims Hearing which do not have that date on them.

Here's one:

https://imgur.com/HyjYvQS - front

https://imgur.com/hHq8wnP - back

from that_girl's thread.

Yep and another one yesterday; suggested OP ring the court; no response yet.
ETA It was dollydoodar from yesterday

nosferatu1001

Yes, you need to state that there were no directions from the court on when to submit your bundle, so you have done so in good time befor ethe hearing
It cant be late if you were never ordered to produce it!

I would break your "unreasonable behaviour" down more
- time to write defence
- time to gathrer evidnece /site visits . etc
- time to write WS

and so on. Give each one its own time. Makes it WAY more plausible to someone looking at it.
You should also bullet point the Cs unreasonable behaviour to date, so it is right there on the costs schedule.