2 separate letters from BW Legal - Britannia Parking

Castle

A few more points I noticed:-
1-The witness states at both #76 and#78 that the charge is £100, not £70.
2-The "landowner" agreement at P1 claims that Jones Lang Lasalle are the landowner; they are not.
3-The undated signs at P4 & P6 have a 0845 enquires number which were banned in June 2014, as well as differing from the sign at P3.
4-The letters sent by BWL at P21 and P22 both refer to Britannia Parking Ltd as their client; (this is a totally different company).
5-The £60 is stated as being "initial legal costs" on the P21 letter, whilst on the P22 letter the £60 is classed as both "initial legal costs" and "debt recovery costs".

Coupon-mad

Well spotted, Castle. I missed those. Really important that the OP includes those observations as well.

Coupon-mad,

I do not have the words to express how thankful I am for what you have just done!

What a commitment and extraordinary kindness and selflessness.

Thank you sincerely and deeply from the bottom of my heart!

No problem!

I enjoy looking at PPC scam Witness Statements and that one is so full of lies (and yes, they are lies if they are saying the NTK was a POFA one when hey know it wasn't and you are not liable) they should be sanctioned by the Judge and hit with all your costs to send out a message to parking firms & BW Legal not to do this again.

Don't forget what I said about you later filing & serving next week, a large costs schedule with all your time at £19 per hour and your printing costs as well as your loss of salary/leave and travel/parking costs for the hearing

As English is not your first language it must have taken you well over, say, twenty hours of work over the past months, to do things like read the BPA CoP, understand keeper liability and compare it to the NTK, scrutinise the signage in evidence and read the WS and evidence and call them out on the untruths, as well as read all their letters and try to work out what the driver did wrong, and to understand why the alleged 'debt' changed every time they wrote to you!

When you come back to show us that costs schedule next week before you file it, remind us to help you list the unreasonable conduct/untruths that push this over the line for you to claim larger costs.

You need a 'crib sheet' to argue UNREASONABLE CONDUCT. We will help.

And don't forget the extra (separate) letter to the Judge re consolidating the 2 claims. Hand that letter in tomorrow, separately from your WS & evidence file, which must be nicely organised and with a 'contents page' and numbered pages.

Coupon-mad

Did you get this submitted to court and by email to the Claimant?

If not, never despair and get it done a couple of days late on Monday, no worries.

mixMZ

Coupon-mad wrote: »

Did you get this submitted to court and by email to the Claimant?

Yes, I was very stressed as thought it HAD to be done by requested date and time but managed to complete WS and sent it via email to BWlegal 10 min before 4pm on Friday, printed version took to court and filed in person.

I used all your points as suggested, plus some generic ones based on others WS that were adequate to my case.

Once again Thank you.

Coupon-mad

Well it did HAVE to be in by then to comply with the court directions, but I was just trying to reassure you as we do get far too many people screeching that they missed the deadline so may as well give up (wrong!).

OK, now start reading about court hearings and what happens. Search:

ANOTHER ONE BITES THE DUST

...to see all the wins going back years.

mixMZ

as the exhibits i attached: POFA2012 Schedule 4, BPA CoP v6 ,3 examples of Britanias POFA compilant NTK and Statement from Henry Greenslade about Keeper Liability.

I also noticed how they tried to manipulate my defence, and couldnt resist this statement:

Re#51.3 and #60: Mr Jackson tries to mislead the court again by citing my defence incorrectly.
"The Claimant`s Parking Charge Notice and/or Notice to Keeper failed to comply with
statutory and/or deadline set by the POFA"
Instead of

"The Claimant`s Parking Charge Notice and/or Notice to Keeper failed to comply with
statutory WORDING and/or deadline set by the POFA"

This clearly shows that Mr Jackson knows that Claimant issued nonPOFA-compliant NTK and is trying to hide
that fact deliberately. Already explained in point 7 - POFA para 8(2)f)

mixMZ

Just to clarify.
The WS is filed and served. The hearing for both claims will take place at the same time/date (2nd August). When should I file costs schedule and all other costs? does it needs to be done before hearing or served at the same time when case is dismissed?

Le_Kirk

Costs schedule a few days before the court hearing, served on the court and the claimant.

mixMZ

Today I received letter from Court saying this:

Upon referral
IT IS ORDERED THAT
1. Unless the Claimant files and serves the written statement (including any documents) ordered by the Court in the order dated 12 March by 4pm on 28 May 2019
2. The Claim is automatically struck out on that date at that time and the hearing is vacated.
3. To be referred back to the District Judge after 28 May 2019
4. This order having been made by the Court pursuant to Rule 3.3 of the Civil Procedure Rules 1998, any party affected by this order has the right to apply to set it aside, vary or stay it by application made not more than 7 days after this order was served on the party making the application.

Dated 7 May 2019

a bit confusing as the date on the letter (just below claim number) is 21 May 2019 ... ?

Before I filed my witness statement I phoned court to confirm of the claimant filed their bits and they also confirmed they already paid fees.

Any ideas?

Castle

What is the exact name of the claimant on the order?