PCM, Gladstones, Service acknowledged. Defence help needed

Donotdealwithorigin

Hello Parking Experts,

Although I've been a member of the MSE Forums, I didn't discover this excellent resource until a little too late to help my son with a PCN from PCM, so apologies if my wavering from the recommended inital route causes any headaches. He initially tried to deal with this, but despite wanting to fight the unfairness of the ticket, got rather scared when the debt collection letters showed up, the Gladstones letters and then the Court letter. He still wants to fight and whilst I've been hand-holding through it, I am now at the limit of being sure what to do. He knows he is going to have his day in court and will have to stick up for himself at that point, however in preparation I am asking for your help.

The ticket was issued in November last year. He uses a gym and parked on the land in question, that is a yellow hatched line area of some 15x5 yards in area set in a car park (without parking charges or restrictions) on an industrial estate. He had been told he could park there by the gym manager and it is regularly used by gym members when the main car park is full, being in front of the premises. He had parked here many times, as had his friends and fellow gym members for many months.

When he got the ticket, he told the gym manager who said he would get it cancelled. Of course, as you can guess, it wasn't. Frankly the gym manager doesn't want to now get involved for one of his customers and his last comment was that "no one gets taken to court for a parking charge, forget it mate". Great advice!. My son didn't appear to receive a reminder letter, so he thought that it was all dealt with, until he got a letter from TRACE Debt Recovery in late February. He replied, copies to PCM and TRACE, with my help, being very honest, admitting he was the driver, that the gym had given permission, many people park there without problem etc etc:

Ticket ref:
Dear Sir/Madam,

With reference to your recent debt collection letter relating to a ticket issued at …….. gym on ……. I am unable to meet your demand for payment, as I do not believe the ticket was issued validly and until this letter I have received no communication from you after being told by the gym that this matter would be resolved and the ticket removed against my car.

I parked in a part of the gym property that is used by many other gym users, and I can obtain testimony to back this up, where permission has been given by the gym to park there. When the ticket was issued, I took it up with ……… who is the manager of the gym and was assured this was a mistake and it would not be valid. As the owner/tenant of the land and the reassurance that this matter would not be pursued by the parking agents was given, the matter was forgotten, quite rightly on my part. I then never received any further communication from the parking company or anyone else until the recent letter asking for payment of inflated “costs”. They are unreasonable and in my opinion unenforceable as have the vast majority of tickets been in similar situations. This is simply a misunderstanding and mistake on the part of the person who issued the ticket and according to the gym is unenforceable. I understand that the gym has a meeting between themselves and parking agents, if that is who you are and representing to resolve this issue and insist on both a retraction and apology for wasting my time issuing this spurious ticket. If you have a problem, please take this up with .......... gym.

Your ticket is not a penalty, it is simply a civil demand for money that should not and will not be paid and I will defend myself in civil court if necessary with full evidence that supports me.

I have seen no proof that an error occurred on my part and I await your retraction and apology by return.

Yours faithfully,

Another demand for payment arrived and he sent this to PCM and TRACE:

Letter to parking company.

Dear .....

Thank you for your recent letter regarding your parking ticket. Unfortunately you have failed to deal with the issue. I recently had a meeting with ........ of .....Gym who informed me that it was agreed at his meeting with ........ of your company, vehicles parked where mine was should not have been ticketed and will not be in future. Therefore this sets a legal precedent and I am not appealing, merely pointing out that your ticket was issued in error and that you are not to pursue me any further in this matter.

Please kindly confirm this with the parties concerned and write back to me stating that you are complying with the wishes of the Gym, your client.


Letter to debt collection agency.

Thank you for your recent letter that does not acknowledge my letter of ....... I reiterate my points in my letter and ask you to speak to the parking company to cancel this demand. I also enclose my last letter to the parking company to show the ticket should not have been issued. It was an error on their part and in any case, as I did not receive any of the parking company letters after I had been told the ticket had been cancelled by the landowner, I have not been offered due process and any further action you might take is in my opinion bound to fail.


Of course, the gym manager has now pulled the rug from underneath him since the letters, however he does have other customers who might write in support of his account that pakring there has been allowed by the gym. I realise this now means we are on to defending "technically" rather than anyone at the parking company or in court listening to the actual argument and point of how he was treated unfairly. He had now missed the opportunity to go through appeal and PCM seemed to have great delight in telling him this.

Since that, it has been the letters from Gladstones, to which the reply starting with (below) was sent, with the 9 requests for info.

Dear Sirs,

I am in receipt of your Letter Before Claim of ... July 2018.
Your letter contains insufficient detail of the claim and fails to provide copies of evidence your client places reliance upon.

As proceedings have not been issued, if your client intends to pursue the matter further they are on notice that since 01 October 2017 a protocol is applicable. Your letter lacks specificity and therefore this letter should be treated as a formal request for all of the documents / information that the protocol now requires your client to provide. Further, I trust that no proceedings will be issued without complying with that protocol. I reserve the right to draw any failure of the Claimant to comply with the protocol to the attention of the court when costs come to be considered.....

Gladstones responded in September, not in any detail, with a covering letter that simply stated

Further to your request for more information, I have attached the photographs our client would seek to rely on should a claim in the matter be issued.

In light of the attached, please make payment of £160 before ...October 2018.

In the event payment nor correspondence is received, we will proceed with our Client's current instructions in this matter to issue a claim without any further correspondence.


Despite requests for 9 items, the only thing they did send was an overhead shot of the site with signs marked (none on the entrance to the car park), a picture of the sign, stating no parking in the hatched area and a parking charge of £100 if you do and photos taken of the car and environs (seemingly confirming it was dark and their sign is not exactly visible) at the time of the ticket. I was going to attach pictures, but the porum is asking for a URL, and I cannot seem to copy and paste in.

In response we sent an altered version of the first letter (as follows), stating their omission of most of the requests and to comply to tie them up for a bit longer and try and see sense:

Dear Sirs,

I am in receipt of your correspondence dated ...September 2018, with enclosures.
Your letter still contains insufficient detail of the claim and, whilst you have provided copies of photographs and of correspondence, it still fails to provide the copies of evidence your client places reliance upon.

I will restate, that as proceedings have still not been issued, if your client intends to pursue the matter further they are on notice that since 01 October 2017 a protocol is applicable. Despite a formal request for all of the documents / information that the protocol now requires your client to provide, this has not been received and I trust that until this request has been fully addressed that no proceedings will be issued without complying with that protocol. I reserve the right to draw any failure of the Claimant to comply with the protocol to the attention of the court when costs come to be considered.

This action on the part of your client remains a clear breach of its pre-action obligations set out in the Practice Direction - Pre-Action Conduct, with which as solicitors you must surely be familiar (and with which your client, a serial litigator of small claims, must also be familiar). As you (and your client) must know, the Practice Direction binds all potential litigants, whatever the size or type of the claim. Its express purpose is to assist parties in understanding the claim and their respective positions in relation to it, to enable parties to take stock of their positions and to negotiate a settlement, or at least narrow the issues, without incurring the costs of court proceedings or using up valuable court time. Quite frankly, I still find it astounding that a firm of Solicitors are sending a consumer a vague and unevidenced 'Letter before Claim' and furthermore, with disbelief, to receive a response with only a small portion of the evidence, to my very clear request.

Nobody, including your client, is immune from the requirements and obligations of the Practice Direction.

I required your client to comply with its obligations by sending me the following information/documents:

1. an explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of POFA 2012
4. what the details of the claim are; where it is claimed the vehicle was parked, for how long, how the monies being claimed arose and have been calculated
5. Is the claim for a contractual breach? If so, provide a copy of that contract bearing my signature. Or is the claim for trespass? If so, provide details.
6. a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the IPC code of practice section B, clause 1.1
7. a plan showing where any signs were displayed
8. details of the signs displayed (size of sign, size of font, height at which displayed)
9. Details of the additions to the original charge, what that represents and how it has been calculated.

I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).

You appear to have only addressed point number 7 (above) fully, namely, “a plan showing where any signs were displayed”, which confirms a clear breach of the Code of Practice of the Trade Body that your client is a member of. However, I have not been provided any of the remaining specific evidence requested, fully or at all and therefore, as it remains outstanding, it remains a brazen clear breach of pre-action obligations set out in the Practice Direction.

I remind you, if your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) !!!8211; Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16. I will draw to the court the fact that I have expressly requested this information, yet your client has refused to provide it, saying that it will not do so until this matter reaches the court and the matter is closed.


Until your client has fully complied with its obligations and provided this information, I remain unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.


Their response was to issue a court claim, despite having no intention of providing the evidence requested, save for a few photos.

I was trying to go alone with this one and thought that there really is an issue there as they have not proved they have a contract to look after and enforce on the land, as only the hatched area appears to have any restriction, is it not a trespass as how can they ask for a "parking charge" as parking is not allowed in the whole are specified, however I feel I am now up to my neck in it and would greatly value some input and the defence(s) that might work best, beyond just stating to the court that Gladstones has not complied with fair and reasonable requests for evidence.

There is no sign on the entrance to the car park to state that there are any restriction, nor is there a sign referencing the hatched area contained in the car park.. It was dark and the sign was not lit, although of course he has admitting using the hatched area before (yes, I know that probably wasn't our best move, but in trying to be honest, fair and reasonable...).

I've tried to be as complete as possible, however, please excuse me, I am new to this and expect I have left some holes and questions.


Thanks in advance


I.

KeithP

What is the Issue Date on your son's Claim Form?

And stop reading that LazyDaisy thread. It is far too old.

Donotdealwithorigin

10th December Yes, I know, please don't kick me too hard for my son having his head in the sand for a bit and not getting moving. The acknowledgement was sent, I think on 21st or 22nd online.

KeithP

With a Claim Issue Date of 10th December and having done the Acknowledgement of Service in a timely manner, you have until 4pm on Monday 14th January 2019 to file your Defence.

That's just over two weeks away. Loads of time to produce a good Defence, but don't leave it to the very last minute.


When you are happy with the content, your Defence should be filed via email as suggested here:

Print your Defence.
1. Sign it and date it.
   
2. Scan the signed document back in and save it as a pdf.
   
3. Send that pdf as an email attachment to CCBCAQ@Justice.gov.uk
   
4. Just put the claim number and the word Defence in the email title, and in the body of the email something like 'Please find my Defence attached'.
   
5. Log into MCOL after a few days to see if the Claim is marked "defended". If not chase the CCBC until it is.
   
6. Do not be surprised to receive a copy of the Claimant's Directions Questionnaire, they are just trying to put you under pressure.
   
7. Wait for your DQ from the CCBC, or download one from the internet, and then re-read post #2 of the NEWBIES FAQ sticky thread to find out exactly what to do with it.

Post #2 of that already mentioned NEWBIES FAQ sticky thread should give some ideas on how to construct a Defence.

Everywhere where I have said 'you' or 'your' above, I do of course mean the Defendant.

Donotdealwithorigin

Thanks, KeithP, amazed at you coming back to me so quickly! As for using out of date LazyDaisy info, I hope the stuff I sent was only past it's best before date, not it's use by!

I thought it was 4 weeks to post a defence, is it 14th Jan because of the 3 bank holidays?

KeithP

It's 28 days from Date of Service to file a Defence.

Date of Service is five days after the Issue Date, therefore the Defence is due thirty-three days after the Issue Date.

In your case, as the calculated due date falls on a Saturday, you are allowed until 4pm on the next working day to file the Defence.

Donotdealwithorigin

Just a couple of thoughts before attempting to prepare a defence:


* Both Gladstones letters are not signed, pure robo-letter. Is there a requirement that they sign their letters?
* Should my son send a SAR request to PCM even though we are now in the court stage?
* On the IPC trade body site, it mentions that signs should be at the entrance to the car park, or in this case industrial estate. There wasn't one, so I know I should mention this, however it makes no reference to minimum text size but that it should legible to the driver, nor the actual recommended size of sign, as on another trade body. Save the omission of the correct amount and placement of signs, is there a "test" for signs being fair and reasonable?
I have a picture of the sign by the hatched area, however I'm not allowed to post links, nor can I copy and paste pictures on here. Does anyone have any suggestions for me to post pictures, please? The picture of the sign in question is in the daylight (it was dark and the sign unlit when the ticket was given)

* Am I assuming rightly that I can use the argument that if parking is not allowed in the hatched area so parking cannot be authorised, no parking charge can be levied, therefore no contract can exist. Perhaps expand to it to seemingly being a fine for trespass or obstruction, not a parking fee as they cannot have a parking charge for somewhere they say he cannot park?


Would appreciate your input before I get copying, pasting and altering to suit this particular case.

Redx

I wouldnt get hung up on signatures on letters from Gladrags

he should DEFFO send a SAR to the DPO at PCM, asap

you can look at the BPA guidance and the IPC guidance in their CoP , as well as any guidance on public signs like roadsigns

host your pics on tinypic and add a dead url to your reply, by changing http to hxxp

any evidence pics should replicate the actual time and place, so unlit night time pics, not daytime pics

yes you are correct, no parking contract offered and forbidding signs , so if no contract to park is offered , then no contract is accepted , meaning trepass only by the landowner

Donotdealwithorigin

[IMG]hxxp://i64.tinypic.com/2s9dkx5.jpg[/IMG]


Thanks, Redx, here is the sign, just to check it works.

Donotdealwithorigin

Here is the draft defence for my son. A couple of questions, if anyone kindly has the time to read and comment:


1. Does he submit pictures with the defence or leave this until the witness staement?
2. Probably a stupid question, however very brain tired at pulling all this together. Does the defence just go to MCOL or do I need to send a copy to Gladstones (it doesn't mention this on the claim notes, just to send to MCOL)?


IN THE COUNTY COURT

CLAIM NO: XXXXXXX

BETWEEN:

PARKING CONTROL MANAGEMENT (UK) LIMITED (Claimant)

-and-

xxxxxxxxxxxxxxxxxxx (Defendant)



Preliminary Matters.

(1). The claimant failed to include a copy of their written contract as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice B1.1 which says
1.1 If you operate parking management activities on land which is not owned by you, you must supply us with written authority from the land owner sufficient to establish you as the ‘Creditor’ within the meaning of the Protection of Freedoms Act 2012 (where applicable) and in any event to establish you as a person who is able to recover parking charges. There is no prescribed form for such agreement and it need not necessarily be as part of a contract but it must include the express ability for an operator to recover parking charges on the landowner’s behalf or provide sufficient right to occupy the land in question so that charges can be recovered by the operator directly. This applies whether or not you intend to use the keeper liability provisions.

(2). The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed the particulars of claim are not clear and concise as is required by CPR 16.4 1(a). The Claimants are known to be serial issuers of generic claims similar to this one. HM Courts Service have identified over 1000 similar sparse claims. I believe the term for such behaviour is roboclaims and as such is against the public interest.

Practice Direction 3A which references Civil Procedure Rule 3.4 illustrates this point:

1.4 The following are examples of cases where the court may conclude that particulars of
claim (whether contained in a claim form or filed separately) fall within rule 3.4(2)(a):
1. those which set out no facts indicating what the claim is about, for example ‘Money
owed £1000’,
2. those which are incoherent and make no sense,
3. those which contain a coherent set of facts but those facts, even if true, do not disclose any legally recognisable claim against the defendant.

(3). The Claimant has not complied with the pre-court protocol.

1. I'd refer the court to Para 4 on non-compliance and sanction, and I'd also point out that there can be no reasonable excuse for the Claimant's failure to follow the Pre-action Conduct process, especially bearing in mind that the Claim was issued by their own Solicitors so they clearly had legal advice before issuing proceedings.

On the basis of the above, the Defendant requests the court strike out the claim for want of a cause of action.


DEFENCE

1. The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all.

2. The facts are that the vehicle, registration XXXX, of which the Defendant is the registered keeper, was parked on the material date in parking site allocated to Company XXXX at XXXX Industrial Estate, and had permission to park from the lessee/owner of the business attached to the land parked on.

3. The Particulars of Claim state that the Defendant was driving the Vehicle and/or is the Keeper of the Vehicle.’ These assertions indicate that the Claimant has failed to identify a Cause of Action, and is simply offering a menu of choices. As such, the Claim fails to comply with Civil Procedure Rule 16.4, or with Civil Practice Direction 16, paras. 7.3 to 7.5. Further, the particulars of the Claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached.

4. Due to the sparseness of the particulars, 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.

5. It is admitted that the Defendant is the registered keeper of the vehicle in question.

6. The defendant has no liability as they are the Keeper of the vehicle, and the Private Parking Company has failed to comply with the strict provisions of PoFA 2012 to hold anyone other than the driver liable for the charges.

6(i) The driver has not been evidenced on any occasion.

6(ii) There is no presumption in law that the keeper was the driver and nor is a keeper obliged to name the driver to a private parking firm. This was confirmed in the POPLA Annual Report 2015 by the POPLA Lead Adjudicator and barrister, Henry Greenslade, when explaining the POFA 2012 principles of 'keeper liability' as set out in Schedule 4.

7. The terms on the Claimant's signage are also displayed in a font which is too small to be read from a passing vehicle, is unlit, as the matter was alleged to have occurred in the hours of darkness and is in such a position that anyone attempting to read the tiny font would be unable to do so. It is, therefore, denied that the Claimant's signage is capable of creating a legally binding contract.

8. The Claimant has not complied with the pre-court protocol.
I'd refer the court to Para 4 on non-compliance and sanction, and I'd also point out that there can be no reasonable excuse for the Claimant's failure to follow the Pre-action Conduct process, especially bearing in mind that the Claim was issued by their own Solicitors so they clearly had legal advice before issuing proceedings.

The defendant wrote to the claimant on xxxxx asking for:
1. an explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of POFA 2012
4. what the details of the claim are; where it is claimed the vehicle was parked, for how long, how the monies being claimed arose and have been calculated
5. Is the claim for a contractual breach? If so, provide a copy of that contract bearing my signature. Or is the claim for trespass? If so, provide details.
6. a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the IPC code of practice section B, clause 1.1
7. a plan showing where any signs were displayed
8. details of the signs displayed (size of sign, size of font, height at which displayed)
9. Details of the additions to the original charge, what that represents and how it has been calculated.

The claimant has completely failed to provide any of the above, with the exception of point 6, despite being asked to provide this as pre-court protocol on more than one occasion.

9. The Claimant claims that the Defendant “incurred the parking charge(s) on 14/11/2017 for breaching the terms of parking on the land at xxxxxx xxxx Industrial xxx(postcode)” when they do not state which bit of land they refer to or the exact actual location. Xxxxxx xxxx is a large industrial estate with many businesses, with free, without-permit parking across most of the site. Furthermore, there is no signage at the entrance to the site, therefore there are no clear terms of parking for the industrial estate. This is a clear and flagrant breach of the Claimant’s trade body (Independent Parking Community) guidelines, which state:

“Entrance Signs should:
a) Make it clear that the motorist is entering onto private land
b) Refer the motorist to the signs within the car park which display the full terms and conditions.
c) Identify yourself (where you are a limited company. This should be by reference to your full company name, your company number and the jurisdiction within which your company is registered).”

10. 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.

11. The defendant cannot contractually agree to do something in the signage that is forbidden (parking in the “hatched areas”). The claim and signage are in error in being unclear as to whether parking constitutes a contract or a trespass, in that a contract could not have been formed and there is no signage for trespass. The claimant cannot have the argument being in their favour both ways, it is one or the other, both unenforceable in the unclear signage.


12. By stating “Retrospective evidence of authority to park will not be accepted” on the Claimant’s signage, it creates an unfair situation that cannot pass the test of reasonableness, in that the Claimant has, in advance, disallowed a reasonable invitation to approach the lessee/owner of the gym and clarify the permission that the Defendant was granted to park.

13. The driver was allowed the right to park by ……. Gym, relying on an express verbal agreement with the manager. . This permission created the prevailing and overriding contract - the only contract - and the business was concluded as agreed, at no cost or penalty.

14. The Claimant is put to strict proof that it has sufficient proprietary interest in the land to unilaterally remove or interfere with the overriding rights enjoyed by the lessee company and extended to permitted drivers who were expressly allowed on this area of land, or that it has the necessary authorisation from the landowner to issue parking charge notices, and to pursue payment by means of litigation.

15. Even if there were a contract, the Claimant is trying to recover additional charges such as legal costs £50.00 and court fees £25.00. The Protection of Freedoms Act (POFA) 2012 does not permit the Claimant to recover a sum greater than the parking charge on the day before a Notice to Keeper was issued. The Claimant cannot recover additional charges. The Defendant also has reasonable belief that the Claimant has not incurred the stated additional costs and is put to strict proof they actually have occurred. As a small Claim, the legal costs cannot be recovered and be struck out.

16. Further and alternatively, the provision requiring payment of £247.57 is unenforceable as an unfair term contrary to the Consumer Rights Act 2015.

17. This charge represents a breach of the well-known and well-established principle of promissory estoppel, i.e. that a promise is enforceable by law, even if made without formal consideration, when party A has made a promise to party B, who then relies on that promise to his subsequent detriment.

18. This charge represents a breach of the well-known and well-established principle that 'a grantor shall not derogate from his grant'. This rule embodies a general legal principle that, if A agrees to confer a benefit on B, then A should not do anything that substantially deprives B of the enjoyment of that benefit.

19. Parking Control Management (UK) Limited is not the lawful occupier of the land. I have the reasonable belief that they do not have the authority to issue charges on this land in their own name and that they have no rights to bring action regarding this claim.
1. The Claimant is not the landowner and is merely an agent acting on behalf of the
landowner and has failed to demonstrate their legal standing to form a contract.
2. The claimant is not the landowner and suffers no loss whatsoever as a result of a
vehicle parking at the location in question
3. The Claimant is put to proof that it has sufficient interest in the land or that there are
specific terms in its contract to bring an action on its own behalf. As a third party
agent, the Claimant may not pursue any charge

20. The Claimant has at no time provided an explanation how the sum has been calculated, the conduct that gave rise to it or how the amount has climbed from £100 to £160. This appears to be an added cost with apparently no qualification and an attempt at double recovery, which the POFA Schedule 4 specifically disallows. The Protection of Freedom Act Para 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper.

21. In 'Saeed v Plustrade Limited [2001] EWCA Civ 2011' a tenant was granted a right in common with others to park on such part of the forecourt as might from time to time be specified by the landholder, who later proposed to reduce the availability of parking and to charge for it. On appeal it was held that the landholder was only entitled to change the location of spaces, not to reduce their number, nor to unreasonably restrict parking previously offered, nor to charge for it. Such restrictions would interfere with easements enjoyed under the lease.

22. In summary, it is the Defendant's position that the Claim discloses no cause of action, is without merit, and has no real prospect of success. Accordingly, the Court is invited to strike out the Claim of its own initiative, using its case management powers pursuant to CPR 3.4.



Statement of Truth:


I confirm that the contents of this statement are true to the best of my knowledge and belief.

Name
Signature
Date

KeithP

To answer your questions:

1) pictures come later as part of the Witness Statement and Evidence stage - as described in post #2 of the NEWBIES thread.

2) Defence gets filed with the County Court Business Centre - as described in post #4 above.