help with claim form

1505grandad

Heading - usual to put (Claimant) and (Defendant) after the names.

Para 2 - "......UK PARKING PATROL to strict proof that any contract can exist between the Claimant and themselves." UK PPO are the claimants!!

Para 3 - typo - "so I was therefor(e) liable."

The experts will be along in due course with any comments on contents or missing paras i.e. Abuse of Process if needed in this case.

jordcharl

thanks 1505 grandad, well spotted and have now changed

jordcharl

anybody??? please im running out of time

jordcharl

i have amended my witness statement and hope someone can check it for me as i have to send by tomorrow at 4pm


In the matter of

UK PARKING PATROL OFFICE LIMITED (Claimant)
v
XXXXX (Defendant)

Claim no: XXXXXXX


Witness statement of XXXXXXXX,



1. I am the Defendant in this matter, I am unrepresented, with no experience of Court procedures. If I do not set out documents in the way that the Claimant may do, I trust the Court will excuse my inexperience.
In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.



2. The Defendant denies being the registered keeper at the time of the supposed event, and therefore puts UK PARKING PATROL to strict proof that any contract can exist between the Claimant and myself.



3. There was no requirement upon myself as former keeper to respond to what appeared to be junk mail in early 2016, however I did ring UK PARKING PATROL to explain that I had sold the car on 13/01/2016 and I was no longer the registered keeper. I was then told by their representative that I was noted as the registered keeper, so I was therefore liable. I then appealed on 20/04/16 through their online system (I have marked this document evidence 1 in my evidence) and explained once again that I was not the registered keeper and that I had been in touch with the DVLA and they were going to get in touch with the new keeper and update their records accordingly as it looked like the v5c I had posted had gone missing. I then received a confirmation of sale from DVLA stating I had sold the vehicle on the 13/01/2016. I have since lost that confirmation of sale, so I contacted DVLA and asked if they could send me proof of the date I sold the car and I received a document dated 15/03/19 showing I no longer owned the vehicle from 13/01/19. (I have marked this document as evidence 2 in my evidence which has information on both sides so will appear as 2 documents) I also emailed UK PARKING PATROL the new keepers’ details and thought that would be the end of it.


4. I have also included in my evidence (I have marked this as evidence 3 in my evidence) an email from DVLA confirming I purchased vehicle tax on my new vehicle registration number XXXXXX on 14/01/16.

5. I stated in my defence that I would produce evidence of my insurance on my new car at the time I sold my old one, unfortunately I have not been able to acquire that document as the insurance company wont release it from so long ago, the only document they could send me was proof of no claims bonus which shows the registration of my car XXXXXX and that I ended the policy on 29/03/17 due to me changing that particular vehicle. (I have marked this as evidence 4 in my evidence)

6. I have included a picture which I received from UK PARKING PATROL which clearly shows a lady getting into the driver’s seat and another lady passenger with her, clearly proving I was not driving or even there at the time of the incident. (I have marked this as evidence 5 in my evidence).

6. My DVLA data was supplied for the single strict purpose of enquiring who owned the vehicle, not for storing for three years then suing me as if I can now be held liable, in the hope I will not defend, will have lost the paperwork, will have moved house, or even better, that I will be so scared that I will pay over £250 including three years' interest, for what was apparently an unproven £60 charge. Had the UK PARKING PATROL taken the time to read and act on my appeal, (which they have had over three years to do so) they would have known the DVLA had amended the new keeper details and known the vehicle was sold on the date I told them it was.

7. From receiving the first parking fine from UK PARKING PATROL I have been bombarded with threatening letters about taking me to court and bailiffs coming to my property if I don’t pay the fine, the total amount they say I owe keeps rising. I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress. It has also put a great deal of strain on my relationship with my mother and has nearly resulted in me having to move out of my home as she was terrified bailiffs were going to come and force entry into our home to seize goods.

8. I have listed my evidence from 1 to 5 and attached these documents with this witness statement proving that I cannot be held liable for the alleged offence.



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

Signature


[FONT=&quot]Date[/FONT]

KeithP

jordcharl wrote: »

anybody??? please im running out of time

So you post absolutely nothing for over six months, the suddenly show us a Witness Statement this afternoon saying you need to post it tonight.

Sorry, but it is unfair to expect others to make up for your lack of forward planning.

Good luck.

jordcharl

KeithP wrote: »

So you post absolutely nothing for over six months, the suddenly show us a Witness Statement this afternoon saying you need to post it tonight.

Sorry, but it is unfair to expect others to make up for your lack of forward planning.

Good luck.

I havnt posted on here for a while as i had nothing to post about so did not want to bother anyone until i needed to. I have literally just finished getting all the evidence i needed to gather and have only just finished my witness today after being messed about for over a week with the insurance company only to been told i cant get the insurance document i was relying on, I only wanted someone to look it over before i submitted it but its fine im sorry for bothering you and i wont post again!!

KeithP

But you could've posted your WS statement here weeks ago.