Defence to VCS - please help and advice/proof read

Loadsofchildren123

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

Loadsofchildren123

Sorry, I'm making comments as I'm reading it.

Would it be a faff for you to add at the start of the exhibit an aerial photo of the carpark. Mark on it all the key points A, B, C etc, in red or blue. Add in a dotted coloured line where you now believe the carpark is divided - it will be obvious from the aerial photo that there is no boundary feature between the two, but make this point. You can get an aerial photo from google earth. I'd also add in a line in a different colour to show the route you took from entrance to parking, and where the signage is that you refer to.

Then before para 4 I'd put something like this:

It transpires that at the time my car was parked in the car park, it was divided into two separate parts, each operated/controlled by a different entity. However, there was no boundary feature or signage to indicate where one car park ended and the other began, or that there were two different carparks being operated by two different entities. At HC1 is an aerial photograph of the carpark in question, on which I have marked all the relevant points to which I will refer in this statement. I will refer to this as the "master plan". The first thing I would point out is the [blue/green whatever] dotted line, which is the approximate location of the notional division between the two car parks. However, this is not at all obvious on the ground, in the carpark itself. Marked with a [red/yellow, whatever] A on the master plan is the entrance through which I drove, and marked with a [colour] B is where my car was parked. [then run through the other markings - eg where the first sign was, the machine you used to pay etc].

I think it would be helpful to have this "master plan", and then refer to it as you refer to your other exhibits. So eg your existing para 4:
On the morning of the 12th of December 2018, I drove into the entrance of the Car Park in question. I instinctively turned right straight away, following the rules of the one-way sign (Exhibit HC1 and HC2) on the wall in front of me, and parked into the first available space. The route I took is shown by the [colour] line on the master plan, and the location of the signs at HC[will now be 2 and 3] is shown marked A and B.
I just think it will help for there to be one plan for the judge to refer back to.

Loadsofchildren123

You'd need to add reference to the master plan, if you decide to do one, at paras 8, 9 and 11. I realise reading on that the C has produced an aerial plan/photo, but I'd still produce your own (I like the description of it as an invisible boundary.

38 - say which judge it was

17 - visit, not visitation

1505grandad

Also just a couple of typos:-

.Ltd missing from claimant's name in heading.

Para 16. "I believes that this untrue" - should be "I believe that this is untrue".

jonesthebones

Hi Loads of Children, thanks for your comments.
Oops my bad on para 1 must be one I forgot to change *facepalm".

And in regards to your second post. That's a great idea I really appreciate that. It may take some work and I have 2/3 hours left to do stuff on it so I will get to work on that straight away. If I have any questions I'll reply. But I am still blocked off my laptop on here for now. So it's a case of when I check my phone.

jonesthebones

1505 grandad, thank you for your typo pointers, as well as you LoC

jonesthebones

Loads of Children, would you like me to covert my word doc to PDF so you can view the exhibits, they are all at the end?

jonesthebones

Hi LoC, I think I have completed the "master plan". I am still blocked off using the forum on my laptop, so I am going to try and link it from my phone. It might take me a couple minutes so I will do another post with the link.

jonesthebones

I am typing this one out so apologies if it doesn't work.
file:///C:/Users/torzb_000/Documents/Heather/Official%20Witness%20Statement%20most%20recent.pdf
I couldn't just get one page, so it's a PDF to the whole thing, but scroll down to page 17 for the master plan you suggested. Truly a brilliant idea that....

If this doesn't work, im a bit stuck as I can't get on on the computer, I was aiming to post/hand this in tomorrow.

KeithP

A link to a file on the C: drive on your computer/phone isn't going to work.

You need to upload the file to a public hosting site, like maybe Dropbox, then post a link to that document.