3D Parking / BW Legal County court claim

Coupon-mad

What evidence could/should I provide to verify this about the IAS?

None, as it's neither here nor there in terms of successfully defending a claim.

bib_bob_euroslap

Ok I have further updated the witness statement above, I would be grateful for any further feedback.
I have until this Saturday morning to get this in the post so not long for any final tweaks.

Coupon-mad

If you want us to look at the WS and supplementary WS (about the false added £60 costs) and your own planned 'costs schedule' again, please post them in new replies as it's easier for us.

bib_bob_euroslap

Ok, here we go.

Witness statement:

In the County Court at XXXXX

Claim No. XXXXX

Between

3D PARKING LIMITED (Claimant)

and

MR XXXXXX (Defendant)


WITNESS STATEMENT



I, XXXXX, of XXXXXXXX, will say as follows:

I am the Defendant in this matter.

The facts and matters set out in this statement are within my own knowledge unless otherwise stated, and I believe them to be true. Where I refer to information supplied by others, the source of the information is identified; facts and matters derived from other sources are true to the best of my knowledge and belief.

Attached to this statement is a paginated bundle of documents marked ‘XXX1’. All references to documents in this statement are to Exhibit XXX1 unless otherwise stated.

Before I describe what happened on the day I parked in Hollybush Lane, I confirm that the essence of my defence to this claim is that:

• The Claimant has not adequately set out the legal basis of its Claim.
• The Claimant's signage did not make it clear there are terms applicable to parking at the site and is in breach of the International Parking Community Code of Practice.
• The basis of the claimants Claim is a breach of contractual terms. However it is denied that the Defendant entered into any contractual agreement with the Claimant, whether express, implied, or by conduct and as it is trite law that any uncertainty in a contract should be resolved against the person who offered it under the contra proferentem rule.
• The claim includes a £60 charge in addition to the £100 contractual charge alleged to have been agreed to, which represents an abuse of process and a breach of the Consumer Rights Act 2015.

1. On 31st July 2018 I parked my vehicle, registration no XXXXX, at the side of the road on Hollybush Lane to catch a train from nearby North Camp station. I have parked here on a few occasions previously on the basis that there were no restrictions to parking, as confirmed by the Google Streetview picture on page X of XXX1. This also shows the so called ‘car park’ is merely just a road.
   
2. On the date in question I was unaware that pay and display restrictions were now in place and I therefore did not purchase a pay and display ticket.
   
3. As I was entering Hollybush Lane I did not see any signs saying I was now entering a car park and as I was parking and leaving my vehicle I did not see any signs alerting me to the change of parking rules from unrestricted to pay and display, nor any signs telling me I had to pay to park here. Thus, I did not enter into any contractual agreement. Had I seen any such signs I would have duly bought a pay and display ticket.
   
4. On 16th August 2018, 16 days after the 31st July, the Claimant sent the parking charge notice by post. The IPC Code of Practice states this must be given to be received within 14 days of the parking event (Para 5.1.m, page xx of XXX1).
   
5. Upon receiving the parking charge notice from the Claimant I revisited the site and I have seen that there is indeed signage present, however there are multiple flaws with this. The signs are so poorly displayed and positioned and the text displaying the terms is so small that the driver of a passing vehicle cannot easily read them. Additionally the terms stated on said signs are unclear:
   
6. The only sign showing drivers are entering the ‘car park’ is positioned above the driver’s eye level, so when turning in to Hollybush Lane the sign is in a blind spot of the driver. This is shown in the photographs exhibited at pages XX and the video X filed with the court.
   
7. The signage displaying the parking terms is positioned side on to the direction of travel as shown in the photograph at page X. The signs are on the opposite side of the road to where my vehicle was parked and behind a wooden fence on some scrub land, as shown in the photograph at page x. The signage states ‘By entering or remaining on this land…’ This implies one must travel past the front face of the sign in order to enter the land, which does not happen due to their side on position. There is also no definition of the area of land to which it relates. This is unclear and anyone reading the sign could well assume it only applies to the land on which it is placed, which is separated from the road by the wooden fence. It is therefore not obvious to drivers parking on the road that the signs relate to parking along it.
   
8. The site was lacking any signs to alert drivers to the change of parking rules from unrestricted to pay and display. This means anyone who may have parked at the site previously when there were no restrictions in place may well be lured into incurring parking charges through no fault of their own.
   
9. The Claimant is part of an accredited trade association, the International Parking Community (‘the IPC’), which has its own Code of Practice (Exibit xx), to which operators must abide. The facts stated in paragraph's 6-8 above are in breach of this on multiple counts :
   
10. Schedule 1, pages xx-xx of XX1 states that:
11. ‘Entrance Signs should: a) make it clear that the Motorist is entering onto private land’
12. ‘[Entrance] Signs should, where practicable, be placed at the entrance to a Car Park. Otherwise the signage within the Car Park must be such as to be obvious to the Motorist.’
13. ‘[Repeater Signs should...] ensure that any parking conditions are adequately brought to the attention of the motorist.‘
14. ‘[Other signs] You must adequately display any signs intended to form the basis of contract between the creditor and the driver. Such signs must: (4) Be clearly legible and placed in such a position (or positions) such that a driver of a vehicle is able to see them clearly upon entering the site or parking a vehicle within the site’
15. ‘[Change in Operator’s Terms and Conditions] Where there is any change to any pre-existing terms and conditions that would not be immediately apparent to a person visiting the site and which materially affects the motorist you should place additional (temporary) signage at the entrance making it clear that new terms and conditions/charges apply, such that regular visitors who may be familiar with the old terms do not inadvertently incur Parking Charges.’
    
16. It was noted by the Supreme Court in Parking Eye vs. Beavis 2015 (Exhibit xx) that:
    
17. ‘Since 2007, the policy of the Secretary of State has been to disclose the information for parking enforcement purposes only to members of an accredited trade organisation. The criteria for accreditation were stated in Parliament to include the existence of ‘a clear and enforced code of conduct (for example relating to conduct, parking charge signage, charge levels, appeals, procedure, approval of ticket working and appropriate pursuit of penalties’’ (Para 96, Parking Eye vs. Beavis 2015, Exhibit xx)
    
18. ‘A competent lawyer representing a user in individual negotiation might be expected, among other things, to argue that the supplier should at least commit to following the code of practice’ (Para 311, Parking Eye vs. Beavis 2015, Exhibit xx)
    
19. On [DATE] I appealed the Claimant’s charge stating the above facts 4, 5 and 6 and referred to the IPC Code of Practice. However, the Claimant has rejected my appeals and numerous letters disputing the charge, each time failing to address the points that I raised and have instead replied with generic template letters and now electing to pursue this matter via litigation. I exhibit these letters at pages XX to XX.
    
20. On [DATE] I further appealed through the IPC’s Independent Appeals Service (IAS) and this was also rejected, as referred in the Claimant’s witness statement (paras xx-xx), however I later learnt the IAS do not appear to be a truly independent service as the IPC itself is a self-serving body funded by parking companies. It is therefore unlikely that the process would have been fair or robust.
    
21. I have conducted further research into the Claimant and their associates (Trace Debt Recovery and BW Legal) which has revealed that they are pursuing claims like these on an industrial scale using intimidation tactics and threatening court action to force people in to paying charges for which they are not necessarily lawfully liable. They have abused the courts, and threats of using the courts, as a cheap form of 'debt' collection and acquiring default CCJ's, in the knowledge and hope that many people would not have the determination to fight through the many threats.
    
22. The Claimant’s threats gave the impression that if I did not pay immediately then a CCJ was inevitable and that it would destroy my ability to borrow money and destroy my career prospects. There were many times I felt like giving in to the Claimant’s demands despite strongly believing I do not owe the money demanded.
    
23. The Claimant has added a further £60 to the original £100 charge applied under the banner of a ‘debt recovery charge’(Claimant Witness Statement, para xx), which represents an abuse of process and an attempt at double recovery. In the recent claim F0DP201T, District Judge Taylor struck out the claim as 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".
    
24. This is a tactic that has been used by multiple private parking charge companies, including the Claimant, and has most recently been demonstrated to not only be an abuse of process, but also to be in breach of Schedule 2 of the Consumer Rights Act 2015. This is detailed further in the Supplementary Witness Statement at pages xx.
    
25. The fact that the Claimant has inflated its Claim in the face of court action further increases the suggestion that it is reliant on individuals not defending themselves and abusing the courts in order to obtain default CCJs.
    
26. It is my position that the Claimant has no standing, or cause of action, to litigate in this matter. The issue the court is being asked to deal with is trivial and the court's valuable time should not have been taken up with this matter.
    
27. I have repeatedly drawn these matters to the Claimant's attention, but it has refused to see reason.

The Court is invited to dismiss the claim and to award my costs of attendance at the hearing, such as are allowable pursuant to CPR 27.14.

Statement of Truth

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


Signature of Defendant:


Name:
Date:

bib_bob_euroslap

Supplementary Witness Statement

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

The arbitrary addition of a fixed sum purporting to cover '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.

Alleging that the letters the parking firm sent have caused an additional loss, is simply untrue. The standard wording for parking charge/debt recovery contracts is that of ''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.

The Defendant has the reasonable belief that the Claimant has not incurred an additional £60 in damages or costs to pursue an alleged £100 debt. The arbitrary addition of a fixed sum purporting to cover 'damages/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.

Whilst quantified costs can be considered on a standard basis, this Claimant's purported added £60 'damages/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, when it comes to parking charges on private land, binding case law and two statute laws have the effect that the parking firm's own business/operational costs cannot be added to the 'parking charge' as if they are additional losses.

The Beavis case is against this Claim
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. 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.

5.1. This charge is unconscionable and devoid of any 'legitimate interest', given the facts. To quote from the decision in the Beavis case at Para [108]: ''But although the terms, like all standard contracts, were presented to motorists on a take it or leave it basis, they could not have been briefer, simpler or more prominently proclaimed. If you park here and stay more than two hours, you will pay £85''. Ad at [199]: ''What matters is that a charge of the order of £85 [...] is an understandable ingredient of a scheme serving legitimate interests.''

5.2. In the Beavis case it was said at para [205]: ''The requirement of good faith in this context is one of fair and open dealing. Openness requires that the terms should be expressed fully, clearly and legibly, containing no concealed pitfalls or traps. Appropriate prominence should be given to terms which might operate disadvantageously to the customer.''

5.3. 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...''

5.4. 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.'' and 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 POFA 2012 and the ATA Code of Practice are against this Claim
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.

The Consumer Rights Act 2015 ('the CRA') is against this claim
Further, the purported added 'costs' are disproportionate, vague and in breach of the CRA 2015 Schedule 2 'terms that may be unfair'. This Claimant has arbitrarily added an extra 60% of the parking charge in a disingenuous double recovery attempt that has already been exposed and routinely disallowed by many Courts in England and Wales. It is atrocious that this has been allowed to continue unabated for so many years, considering the number of victims receiving this Claimant's exaggerated Letter before Claim, or the claim form, who then either pay an inflated amount or suffer a default judgment for a sum that could not otherwise be recovered. It is only those who defend, who draw individual cases to the attention of the courts one by one, but at last in 2019, some areas noticed the pattern and have moved to stop this abuse of process at source.

7.1. 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.''

7.2. That decision in Wales was contested in a N244 application by VCS, but the added £60 was still disallowed on 30 Oct 2019. 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. The considered sum in that case was reduced to £100 with a full case hearing to follow, 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.

7.3. In Claim numbers F0DP806M and F0DP201T - BRITANNIA PARKING -v- Mr C and another - less than two weeks later - the courts went further in a landmark judgment in November 2019 which followed several parking charge claims being struck out in the area overseen by His Honour Judge Iain Hamilton-Douglas Hughes QC, the Designated Civil Judge for Dorset, Hampshire, Isle of Wight & Wiltshire.

7.3.1. Cases summarily struck out in that circuit 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 the Beavis case. 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...''

7.3.2. BW Legal made an application objecting to two 'test' cases that had been struck out by District Judge Taylor against a parking firm for trying to claim for £160 instead of £100 parking charge. This has been repeated conduct in recent years, on the back of the Beavis case, where parking firms have almost unanimously contrived to add £60, or more, on top of the 'parking charge'. Members of both ATAs who have influence on their self-serving 'Trade Bodies' have even voted to have this imaginary 'damages/debt collection' sum added to their respective two Codes of Practice, to create a veil of legitimacy, no doubt to allow their members to confuse consumers and to enable them to continue to 'get away with it' in several court areas which are still allowing this double recovery.

7.3.3. That N244 application to try to protect the cartel-like position of some of the 'bigger player' parking firms, was placed before the area Circuit Judge and a hearing was held on 11th November 2019, with other parking charge cases in that circuit remaining struck out or stayed, pending the outcome. The Defendants successfully argued on points including a citation of the CRA 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 below were robustly upheld by District Judge Grand, sitting at the Southampton Court, who 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 Consumer Rights Act 2015, Schedule 2 (the 'grey list' of terms that may be unfair) paragraphs 6, 10 and 14.

7.3.4. At the hearing, the Judge refused their request to appeal. It was successfully argued that the parking firm's consumer notice stood in breach of the CRA 2015, Schedule 2 (the 'grey list' of terms that may be unfair) paragraphs 6, 10 and 14. Using 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, which they had not. The same issues apply to this claim.

7.3.5. A transcript will be publicly available shortly. In his summing up, it was noted that District Judge Grand stated: ''When I come to consider whether the striking out of the whole claim is appropriate, that the inclusion of the £60 charge means that the whole claim is tainted by it, the claimant should well know that it is not entitled to the £60. The very fact that they bring a claim in these circumstances seems to me that it is an abuse of process of the court, and in saying that, I observe that with any claim that can be brought before the court that if a party doesn't put in a defence to the claim, default judgments are entered. So, the Claimant, in bringing the claims is, in other cases, aware that if the defendant doesn’t submit a defence, the Claimant is going to get a judgment of a knowingly inflated amount. So I conclude by saying that I dismiss the application to set aside Judge Taylor’s ruling.''

7.4. Consumer notices - such as car park signs - are not excused by the CRA 'core exemption'. The CMA Official Government Guidance to the CRA 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).'' The parking industry is the exception to this rule because they have no consumer 'customers' yet are consumer-facing. Their intention is very clearly in many cases (including this case) for a consumer not to see the onerous terms hidden in their notices and it is averred that no regard is paid to consumer law.

7.5. The definition of a consumer notice is given at 1.19 and the test of fairness is expanded 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. [...] 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.''

In December 2019 in a different Court circuit, Deputy District Judge Joseph sitting at Warwick County Court had clearly heard about the decisions affecting the IOW, Hampshire, Dorset and Wiltshire circuit because he summarily struck out another parking ticket claim. The Judge mentioned the POFA 2012 and the Beavis case, and determined that ''it is an abuse of process for the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover.'' Further, in issuing his Order without a hearing, the Judge stated that he had ''considered S71(2) of the Consumer Rights Act 2015 for the fairness of the contract terms and determined that the provision of the additional charge breached examples 6, 10 and 14''.

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.

The Defendant is of the view that this Claimant knew or should have known that to claim in excess of £100 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.

If this claim is not summarily struck out for the same reasons as the Judges cited in the multiple Caernarfon, Southampton, IOW and Warwick County Court decisions, then due to this Claimant knowingly proceeding with a claim that amounts to an abuse of process, full costs will be sought by the Defendant at the hearing, such as are allowable pursuant to CPR 27.14.



Statement of Truth:

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


Name

Signature


Date

bib_bob_euroslap

Schedule of Costs:

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 24/01/2020 £55.00

Return mileage from home address to Court (e.g. 14 miles x £0.45) £6.30

Parking near Court £5.00

Sub-total £66.30 ======


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

Research, preparation and drafting of documents (5 hours at Litigant in Person rate of £19 per hour) £95.00

Stationery, printing, photocopying and postage: £15.00

Sub-total £110.00 ======



£166.30 TOTAL COSTS CLAIMED

beamerguy

I like it :T

Anything is possible but be prepared for £95

bib_bob_euroslap

beamerguy wrote: »

I like it :T

Reassuring to hear that, thank you.
Still no sign of the BW witness statement so could be some last minute rushed amendments on Saturday morning if it shows up by then. 😬

Evidence wise, this is what I’ll be including. Anything I’ve missed? Anything I don’t need?

Photos
Street view images
Video
IPC code of practice pages 17, 22-24
Cases and court reports: parking eye vs Beavis paras 96 +311. F0DP201T & F0DP806M Britannia Parking vs Mr C and another. F2QZ4W28 Vehicle control services vs Davies. E8GF1V7V UK Car parking vs Esplanade ltd.
3D parking, trace & bw letters
My letters /appeals
POFA paras 4(5) and 4(6)
CRA Schedule 2 paras 6, 10, 14

Thanks 🙏

Coupon-mad

Maybe add one of the two judgments from DJ Joseph in the Warwick court threads, as he spells out the CRA 2015 issue and struck out multiple claims as a result.

Here is one, and CrystalTips has agreed to post hers as well:

https://forums.moneysavingexpert.com/discussion/6079858/bw-legal-premier-park-thanks-for-all-your-help

Deputy District Judge Joseph
CLAIM NUMBER: F5DP2D6Y dated 6th Dec 2019

It's a good exhibit to go alongside the Southampton one.

You need to add some more numbering to the end of your supplementary WS.

You shouldn't need these letters:

3D parking, trace & bw letters
My letters /appeals

bib_bob_euroslap

BW have now served their witness statement. It was sent by email. Can they do that?
I didn’t give them permission to use my email but they have it as I sent a copy of my defence and responded to some letters. I served my witness statement to them by email (missed the last post on Saturday) so probably don’t have much ground to stand on.

Thoughts?

I will try to get a copy of the WS uploaded and posted here for reference and in case it’s useful to any others...