What to do

Luce2120

so is the deadline for postage or for receipt? I will be hand delivering to court so no issue there but just thinking about Bw Legal copy

nosferatu1001

Receipt, same as everything yo uhave to SERVE BY the date given.

Luce2120

I am a little confused about the referencing of other cases with my Witness statement. If I reference a case, do I then HAVE to include evidence of this within my evidence pack. If so where would I find this information. Are all cases in writing somewhere online? Which part of a case should I be including? The whole thing?

Redx

Most transcripts are on parking pranksters website , or Google can turn them up , use whatever is required but try to avoid the whole thing where possible , so not all of the Beavis case etc

Read other Court case threads and you will see what they did and used , because coupon mad has answered those questions numerous times this year alone

Luce2120

Thanks. When you say Transcript is this just an extract quote? that can be copied and pasted directly into the witness statement?

Luce2120

It appears that bw legal intend to rely on Combined Parking Solutions v AJH Films (2015). I am unable to find an answer to this as the driver whoever this was must have been an employee. Although the vehicle had no business being there and was certainly not there in any interest of the company I have no way of proving this.

Luce2120

So here is first draft of my witness statement. Any advice would be much appreciated. I have had to spit into two posts as it is quite long.

IN THE COUNTY COURT AT xxxxx CLAIM NUMBER: xxxxxxxxx

KBT CORNWALL LTD T/A ARMTRAC SECURITY SERVICES
CLAIMANT
-V-

xxxxxxxxxxxxxxx
DEFENDANT
WITNESS STATEMENT OF xxxxxx

I xxxxxxx of xxxxxxx Ltd am the defending the Company in this matter.

I am unrepresented with no legal background or training and have had no previous experience of county court procedures. If I do not set out documents in the correct way, I trust the Court will excuse my inexperience.

I say as follows:

Introduction:
1. I am a company director of xxxxxxxx and as such am defending the company in this case. The matters to which I refer are within my own knowledge and are true to the best of my knowledge. I am duly authorised by the company to make this statement on its behalf.

2. I make this statement in preparation for the hearing on xxxxxxxxxx

3. This claim arises from an alleged parking incident on xxxxxxx

4. Attached to this statement is a paginated bundle of evidentiary documents marked Exhibit HC1 to HC14 to which I will refer.




Overview

5. xxxxxxxx first received correspondence from a company called Armtrac Security stating that a PCN (xxxxxx) had been issued on one of our vehicles and we should tell them who was driving the vehicle at this time, the 14 day period for a lesser £60 charge had already expired and they were demanding £100 be paid by the driver. The letter contained very sparse information and no supporting evidence. As we had not seen or received a PCN to my knowledge and I had no way of determining the driver without more evidence, I disregarded the letter and unfortunately threw it away assuming it was a scam.

6. xxxxxxx then received further threatening, aggressive and demanding letters asking for money and the driver’s identity and address for service.

8. We then received a final letter threatening debt recovery or court action if payment was not made and examples of how the balance owed might increase. Exhibit HC1.

8. The letter stated that if no payment was received within 14 days the matter would be passed to either THE TNC DEBT RECOVERY GROUP or Gladstones Solicitors.

9. We then received a letter from BW Legal, (neither of the aforementioned companies mention in paragraph 8 on Exhibit HC1) stating that the amount due was now £160 due to an added £60 for ‘initial legal costs’ (Exhibit HC2) and they would be commencing legal proceedings if payment was not made within 16 days.

10. Following this as I still had no evidence or information regarding the alleged contravention I issued a SAR to both BW Legal and Armtrac Security to try and ascertain the situation, BW legal did respond diligently however Armtrac Secutity refused most of the requested information and sent back nothing more than some pictures of a company vehicle parked at the entrance to xxxxxx, a copy of the Notice to keeper (Exhibit HC3 pages 1,2,3) and a copy of the final letter before debt recovery. (HC1).

Defence:
The defendant denies liability for the entirety of the claim for the following reasons.

11. No indication is given as to the claimant’s contractual authority to operate there as required by the claimants trade association’s Code of practice A7 (Exhibit HC4, paragraph 7.1 – 7.3)

(7.1) If you do not own the land on which you are carrying out parking management, you must have the written authorisation of the landowner (or their appointed agent). The written confirmation must be given before you can start operating on the land in question and give you the authority to carry out all the aspects of car park management for the site that you are responsible for. In particular, it must say that the landowner (or their appointed agent) requires you to keep to the Code of Practice and that you have the authority to pursue outstanding parking charges.
(7.2) If the operator wishes to take legal action on any outstanding parking charges, they must ensure that they have the written authority of the landowner (or their appointed agent) prior to legal action being taken.
(7.3) The written authorisation must also set out:
a. the definition of the land on which you may operate, so that the boundaries of the land can be clearly defined
b. any conditions or restrictions on parking control and enforcement operations, including any restrictions on hours of operation
c. any conditions or restrictions on the types of vehicles that may, or may not, be subject to parking control and enforcement
d. who has the responsibility for putting up and maintaining signs
e. the definition of the services provided by each party to the agreement.

12. I enclose Exhibit HC5. A blurred copy of the claimants contract with the land owner dated 21st September 2015. This contract has been tampered with but appears to state that the the contract expiry is 12 months from the date it was signed.

13. The identity of the driver of the vehicle on the date in question has not been ascertained.
(i) The claimant did not identify the driver
(ii) Being a LTD Company it is impossible that the registered keeper could have been the driver of the vehicle.

14.The Defendant has no liability, as they are the Keeper of the vehicle and the Claimant
must rely upon the strict provisions of the Protection of Freedoms Act 2012 in order to
hold the defendant responsible for the driver’s alleged breach.

15. I enclose a copy of schedule 4 of the Protection of Freedoms Act. Exhibit HC6.

16. Should the claimant allege Keeper Liability under the POFA 2012 then I would like to point out that the Notice to Keeper failed to give the statutory warning to the registered keeper about the '28 day period' which is mandatory wording as prescribed in paragraph 9(2)(f) of Schedule 4 of the Protection of Freedoms Act 2012. Consequently, the Claimant is unable to rely on the 'keeper liability' provisions of the POFA.

17. POFA 2012 also states that a Notice to Keeper must be accompanied by any evidence prescribed under paragraph 10 of Exhibit HC6. None was delivered.

18. I would like to place reliance on the judgment in the following cases.

i. Excel v Ian Lamoureux, C3DP56Q5 at Skipton. The Judge was critical of the claimants attempts to hold the keeper liable without being able to rely on POFA. The judge suggested that the only way Mr Lamoureux could be held liable was if he was the driver and Excel could prove he was (which they could not). The judge stated, ‘I think the claim against Mr Lamoureux is totally misconceived because it has no evidence that he is the driver and it seems to be relying on some assumption that the registered keeper is the driver because it is not seeking to rely on the Protection of Freedoms Act 2012.’ (Excel v Ian Lamoureux, C3DP56Q5 at Skipton n.d.).

ii. CS048 VCS v Quayle C1DP0H0J. Keeper not liable for driver’s actions if POFA not complied with (CS048 VCS v Quayle C1DP0H0J n.d.).

19. The claimant places reliance on the judgement in the appeal of Combined Parking Solutions v AJH Films (2015).

20. This case can be distinguished for the following reasons.

21. Although it is admitted that the Defendant company was the authorised registered keeper of the vehicle in question at the time of the alleged incident and that an employee of the Defendant was the driver of the vehicle. The driver was not on company business nor in any way acting 'on behalf of' the Defendant company.

22. Had this been the case then they would have been working from the back of the vehicle using the material stored within in order erect scaffolding.

23. In absence of the law of agency argument, to hold the Defendant liable in law, the Claimant company would have to have fulfilled all requirements of Schedule 4 of the Protection of Freedoms Act 2012 ('the POFA') and this is denied as stated in paragraph 16

Luce2120

24. As this is clearly not the case, the driver was not undertaking work duties, therefore the law of agency cannot apply and thus the Defendant company is not liable for the actions of this driver.

25. The Particulars of the Claim fail to specify on what legal basis has the claim been brought against the Defendant, the assumption being that it was under ‘keeper liability’.

26. Due to the sparseness of the Particulars of Claim it is unclear as to what legal basis the claim is brought, whether for breach of contract, contractual liability, or trespass. However, it is denied that the Defendant, or any driver of the vehicle, entered into any contractual agreement with the Claimant, whether express, implied, or by conduct.

23. Further and in the alternative, it is denied that the claimant's signage sets out the terms in a sufficiently clear manner which would be capable of binding any reasonable person reading them. The terms on the Claimant's signage are extremely faded, illegible and displayed in a font which is too small to be read from a passing vehicle. It is in such a position that anyone attempting to read the tiny font would be unable to do so easily. It is, therefore, denied that the Claimant's signage is capable of creating a legally binding contract.

24. I enclose exhibit HC7 a close up photo of the signage present at the entrance to Jenkins Court and exhibit HC8 a photo from the road as viewed by a passing motorist.

25. The claimant places reliance on the judgement in the appeal case Vehicle Control Services Limited v Alfred Charles Crutchley (2017). This can be dismissed as it was a case based on “stopping on a roadway where stopping is prohibited” in a private business park. There is no relevance to this case.

26. The Claimant, or their legal representatives, has added an additional sum of £60 to the original £100 parking charge, for which no explanation or justification has been provided. Schedule 4 of the Protection Of Freedoms Act, Exibit HC6 at 4(5), states that the maximum sum which can be recovered from the registered keeper is that specified in the Notice to Keeper, which is £100 in this instance, and that is ONLY where there has been adequate notice of the parking charge on signage that was seen (or 'so prominent that it was bound to be seen') by the driver. It is submitted that this is an attempt at double recovery by the Claimant, which the Court should not uphold, even in the event that Judgment for Claimant is awarded.

27. The claimant is intending to rely on Chaplair v Kumari to attempt to justify an unknown £60 “debt recovery charge”. This case is distinguished from the case above by the following facts; the Beavis case established that a parking firm cannot seek or plead a sum in 'damages'. Chaplair v Kumari is also distinguished, far from supporting this attempt at double recovery, Chaplair was a decision about contractual fees set in lease terms, whereas parking charges are capped by the POFA/the will of Parliament at the sum on any Notice to Keeper, and not higher, and the Beavis case confirmed this by only allowing £85 and no bolt on 'damages' or imaginary debt collector costs.

Costs on the claim - disproportionate and disingenuous

28. The Defendant disputes that the Claimant has incurred £50 solicitor costs.

29. The Defendant has the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £160 debt.

30. Notwithstanding the Defendant's belief, the costs are in any case not recoverable. The Claimant described the charge of £50.00 "legal representative’s costs" not "contractual costs". CPR 27.14 does not permit these to be recovered in the Small Claims Court.

31. CPR 44.3 (2) states: ''Where the amount of costs is to be assessed on the standard basis, the court will –
(a) only allow costs which are proportionate to the matters in issue. Costs which are disproportionate in amount may be disallowed or reduced even if they were reasonably or necessarily incurred; and
(b) resolve any doubt which it may have as to whether costs were reasonably and proportionately incurred or were reasonable and proportionate in amount in favour of the paying party.

32. Whilst quantified costs can be considered on a standard basis, this Claimant's purported costs are wholly disproportionate and do not stand up to scrutiny. In fact, it is averred that the Claimant has not paid or incurred such damages/costs or 'legal fees' at all. Any debt collection letters were a standard feature of a low-cost business model and are already counted within the parking charge itself.

33. Any purported 'legal costs' are also made up out of thin air. Given the fact that robo-claim solicitors and parking firms process tens of thousands of claims handled by an admin team or paralegals, the Defendant avers that no solicitor is likely to have supervised this current batch of cut & paste claims. The court is invited to note that no named Solicitor has signed the Particulars, in breach of Practice Direction 22, and rendering the statement of truth a nullity.

34.The Claimant is a serial offender on this regard and must be well aware that CPR 27.14 does not permit such charges to be recovered in the Small Claims track. According to Ladak v DRC LocumsUKEAT/0488/13/LA the Claimant can only recover the direct and provable costs of the time spent on preparing the claim in a legal capacity, not any administration cost allegedly incurred by already remunerated administrative staff.

35. The purported added 'costs' are disproportionate, a disingenuous double recovery attempt, vague and in breach of the Consumer Rights Act 2015 Schedule 2 'terms that may be unfair'. (HC9)

36. The arbitrary addition of a fixed sum purporting to cover 'administration/recovery costs' is also potentially open to challenge as an unfair commercial practice under the CPRs, where 44.3 (2) states: ''Where the amount of costs is to be assessed on the standard basis, the court will –
(a) only allow costs which are proportionate to the matters in issue. Costs which are disproportionate in amount may be disallowed or reduced even if they were reasonably or necessarily incurred; and
(b) resolve any doubt which it may have as to whether costs were reasonably and proportionately incurred or were reasonable and proportionate in amount in favour of the paying party.

37. The standard wording for parking charge/debt recovery contracts is on the Debt Recovery Plus website - ''no recovery/no fee'', thus establishing an argument that the Claimant is breaching the indemnity principle - claiming reimbursement for a cost which has never, in fact, been incurred. This is true, whether or not they used a third-party debt collector during the process.

38. Whilst quantified costs can be considered on a standard basis, this Claimant's purported added £60 'costs' are wholly disproportionate, are not genuine losses at all and do not stand up to scrutiny. This has finally been recognised in many court areas. Differently from almost any other trader/consumer agreement, case law and two statute laws hold that, when it comes to parking charges on private land, the parking firm's own business/operational costs cannot be added to the 'parking charge' as if they are additional losses.

39. Parking Eye Ltd v Beavis [2015] UKSC 67 ('the Beavis case') is the authority for recovery of the parking charge itself and no more, since that sum (£85 in the Beavis case) was held to already incorporate the costs of an automated private parking business model including recovery letters. There are no losses or damages caused by this business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages.

40. Unlike this greedy Claimant, ParkingEye themselves took on board the Beavis case outcome and they never add fake costs on top of the parking charge. It is indisputable that an alleged 'parking charge' penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending upon the parking firm) covers the costs of the letters, and all parking firms are very familiar with this case:
http://www.bailii.org/uk/cases/UKSC/2015/67.html

at para 98. {re ...The desirability of running that parking scheme at no cost, or ideally some profit, to themselves} ''Against this background, it can be seen that the £85 charge had two main objects. One was to manage the efficient use of parking space in the interests of the retail outlets, and of the users of those outlets who wish to find spaces in which to park their cars [...] The other purpose was to provide an income stream to enable ParkingEye to meet the costs of operating the scheme and make a profit from its services...''

at para 193. ''Judging by ParkingEye’s accounts, and unless the Chelmsford car park was out of the ordinary, the scheme also covered ParkingEye's costs of operation and gave their shareholders a healthy annual profit.''

at para 198. ''The charge has to be and is set at a level which enables the managers to recover the costs of operating the scheme. It is here also set at a level enabling ParkingEye to make a profit.''

* The Protection of Freedoms Act 2012, Schedule 4 ('the POFA') at paras 4(5) and 4(6) makes it clear that the will of Parliament regarding parking on private land is that the only sum potentially able to be recovered is the sum in any compliant 'Notice to Keeper' (further, the ceiling for a 'parking charge', as set by the Trade Bodies and the DVLA, is £100). This also depends upon the Claimant fully complying with the statute, including 'adequate notice' of the parking charge and prescribed documents served in time/with mandatory wording. It is submitted the claimant has failed on all counts and the Claimant is well aware their artificially inflated claim, as pleaded, constitutes double recovery.

41. Judges have disallowed all added parking firm 'costs' in County courts in England and Wales. In the Caernarfon Court in Case number FTQZ4W28 (Vehicle Control Services Ltd v Davies) on 4th September 2019, District Judge Jones-Evans stated: ''Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court in Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared the claim is struck out and declared to be wholly without merit and an abuse of process.''

42. That decision in Wales was appealed by VCS but the added £60 was still disallowed on 30 Oct 2019, where District Judge Jones-Evans stated that even in cases parking firms win, he never allows the £60 add on, and despite parking firms continuing to include it in their Particulars, most advocates have now stopped pushing for it at hearings. The Judge said that a contract formed by signage is a deemed contract, which the motorist does not have the opportunity to negotiate. That, and the fact that there is no specified sum on the signage, means that the extra £60 cannot possibly be recoverable. He said that the £60 was clearly a penalty, and an abuse of process. However, in light of the overriding objective he would allow the Claimant to proceed, but the £60 would not be awarded under any circumstances, and further, he ordered that the Claimant must now produce a statement of how they pleaded claims prior to Beavis, and subsequently.

43. In Claim numbers F0DP806M and F0DP201T - less than two weeks later but in England - the courts went further in a landmark judgment in November 2019 which followed several parking charge claims being summarily struck out in the IOW and Hants circuit. These included BPA members using BW Legal's robo-claim model and IPC members using Gladstones' robo-claim model, and the Orders from that court were identical in striking out all such claims without a hearing during a prolonged period in 2019, with the Judge stating: ''It is ordered that The claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in ParkingEye v 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. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

44. At the hearing for BW Legal's N244 application to appeal against two 'test' cases that had been struck out by District Judge Taylor against Britannia Parking for trying to claim for £160 instead of £100 parking charge, (HC10 a written report of the hearing) the Defendants successfully argued on all three counts including a citation of the Consumer Rights Act 2015 and the duty of the court to apply the 'test of fairness' to a consumer notice (a statutory duty that falls upon the courts, whether a consumer raises the issue or not). All three points were robustly upheld by District Judge Grand, sitting at the Southampton Court on 11 November 2019, where he agreed that:

(a) The Claimant knew or should have known, that £160 charge (howsoever argued or constructed) was in breach of POFA, due to paras 4(5) and 4(6).
(b) The Claimant knew or should have known, that £160 charge (howsoever argued or constructed) was unconscionable, due to the Beavis case paras 98, 193, 198 and 287.
(c) The Claimant knew or should have known, that £160 charge where the additional 'recovery' sum was in small print, hidden, or in the cases before him, not there at all, is void for uncertainty and in breach of the POFA para 9.

45. Further, it was successfully argued that the parking firm's consumer notice stood in breach of the Consumer Rights Act 2015, Schedule 2 (the 'grey list' of terms that may be unfair) paragraphs 6, 10 and 14 and due to the statutory duty upon the Courts to consider the test of fairness and properly apply schedule 2 of the CRA 2015 it was irrelevant whether or not the consumers' defences had raised it before. The Claimants were refused their request to appeal - given that the £160 claim in its entirety, was adjudged to have been 'tainted' by breaches of two statute laws and going behind a Supreme Court ruling - and both Defendants were awarded their costs.

46. Consumer notices - such as car park signs - are not excused by the 'core exemption' as set out in the CRA 2015. The CMA Official Government Guidance says: ''2.43 In addition, terms defining the main subject matter and setting the price can only benefit from the main exemption from the fairness test ('the core exemption') if they are transparent (and prominent) – see part 3 of the guidance.'' and at 3.2 ''The Act includes an exemption from the fairness test in Part 2 for terms that deal with the main subject matter of the contract or the adequacy of the price, provided they are transparent and prominent. (This exemption does not extend to consumer notices but businesses are unlikely to wish to use wording that has no legal force to determine 'core' contractual issues).''

47. The definition of a consumer notice is given at 1.19 and the test of fairness is expended at 1.20: ''A consumer notice is defined broadly in the Act as a notice that relates to rights or obligations between a trader and a consumer, or a notice which appears to exclude or restrict a trader’s liability to a consumer. It includes an announcement or other communication, whether or not in writing, as long as it is reasonable to assume that it is intended to be seen or heard by a consumer. Consumer notices are often used, for instance, in public places such as shops or car parks as well as online and in documentation that is otherwise contractual in nature. 1.20 Consumer notices are, therefore, subject to control for fairness under the Act even where it could be argued that they do not form part of the contract as a matter of law. Part 2 of the Act covers consumer notices as well as terms, ensuring that, in a broad sense any wording directed by traders to consumers which has an effect comparable to that of a potentially unfair contract term is open to challenge in the same way as such a term. There is no need for technical legal arguments about whether a contract exists and whether, if it does, the wording under consideration forms part of it.''

48. Exibit HC11 is a link to the complete Government guidance document on the CRA 2015

49. I also include HC12 a copy of pages 87 and 88 of the Guidance on the unfair terms provisions in the Consumer Rights Act 2015 and have highlighted the following points:

a. Section 5.14.3, 5.14.4 and 5.14.5
“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.”


50. In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant's vexatious conduct from the outset has been intimidating, misleading, harassing and indeed untrue in terms of the added costs alleged and the statements made.

51. The Defendant is of the view that this Claimant knew or should have known that to claim £160 for a parking charge on private land is disallowed under the CPRs, the Beavis case, the POFA and the CRA 2015 and that relief from sanctions should be refused and costs will be sought by the Defendant on the indemnity basis.

52. The Court is invited to make an Order of its own initiative, dismissing this claim in its entirety (due to the similarities with the Southampton case where the entire claim was deemed 'tainted') and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14 on the indemnity basis, taking judicial note of the wholly unreasonable conduct of this Claimant.


Statement of Truth:

I believe that the facts stated in this Witness Statement are true.

Coupon-mad

Luce2120 wrote: »

It appears that bw legal intend to rely on Combined Parking Solutions v AJH Films (2015). I am unable to find an answer to this as the driver whoever this was must have been an employee. Although the vehicle had no business being there and was certainly not there in any interest of the company I have no way of proving this.

Look on the members' list for Edna Basher. He writes about company defences a lot, and is a bit of a forum legend in that front.

Click on his username to read his posts about that case, or:

Search the forum for AJH Films to see all this covers umpteen dozen times on various threads where companies are involved.

Luce2120

So I am due in court on Thursday morning and suffice to say I am !!!!!!!! myself.

What should I wear? Is it a full suit affair? (not my usual attire).

Will I have to speak in court? I am not confident at all with speaking in situations like this and public speaking?

Will I be asked a million questions? I am worried that I will be quizzed on my witness statement amongst other things and I wont be able to recall details.

Will people be trying to trip me up with my answers and make me make mistakes etc?

What should I take with me? A copy of my own witness statement and evidence bundle? Anything else?

I think I may have missed the post when sending my witness statement to BW Legal, will they use this against me if it was late? (the courts copy was hand delivered so no issue there).

How many people will be there?

Can I bring someone with me for moral support?

What do I do if I win? Asking my costs be paid etc?

What do I do if I lose? Who do I pay?

How long should I get in the pay and display car park? Don't want anymore parking problems.

I am sure I have a million other questions but this is what is springing to mind at the moment. Thanks in advance.