UKPC LBC Residential parking

nosferatu1001

Le Kirk - that's true if this were a WS, it isn't, so the appendix usage is correct. 

xscape

@Le_Kirk Thanks, Is it just the Ladak argument to be removed there? The latest template by design only accommodates for personal circumstances to be added so by that reasoning I think that entire section can be removed, thoughts?

Le_Kirk

nosferatu1001 said:

Le Kirk - that's true if this were a WS, it isn't, so the appendix usage is correct. 

Quite right, that's what one gets for switching between reading WSs and defences!  OP ignore my comment about appendices and exhibits.

Le_Kirk

xscape said:

@Le_Kirk Thanks, Is it just the Ladak argument to be removed there? The latest template by design only accommodates for personal circumstances to be added so by that reasoning I think that entire section can be removed, thoughts?

I would just use the template as it is designed and add your personal circumstances in at paragraphs 16 & 17 as per the instructions.  Of course, if there are more circumstances just extend the number of paragraphs.

xscape

OK, the court date has been set for the end of Oct and the witness statement is due by 28th September. Not much time, but sufficient to pull the statement and evidence together, which is already in progress. No responses to the defence or witness statements have been received from SCS.

In addition to the arguments of primacy of contract and the claimants' legal advisor explicitly telling a "witness" what to put in their statement I note that supplementary witness statements for abuse of process are included in recent accounts.

Is this still current advice?

Coupon-mad

Not if you covered all that in your defence, no. That was stopgap advice for people who had short defences, to catch up.

Two examples of WS I wrote in the past 2 weeks are in the threads by @painbl and @blancswann  

xscape

Much appreciated (and lighting fast!) response, reading threads now.

Coupon-mad

AND - please now make a real difference - A TASK FOR SEPTEMBER.

The Government is (this month only) consulting about a new statutory code of practice (CoP) and framework to rein in the rogue parking firms.  Read and comment on the draft CoP proposal and the enforcement framework consultation, and get everyone you know to do the same.

You will need to register to comment on the CoP and enter an occupation even if you are retired or a homemaker, but otherwise it is easy to navigate, and comment upon each section/subsection individually. You can save comments to edit later and or submit comments once you are happy with them.

https://standardsdevelopment.bsigroup.com/projects/2020-00193#/section

You do not need to register to comment on the enforcement framework which can be found here. It has a link on page 5 to make comments.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/913272/Code_Enforcement_Framework_consultation.pdf

At the very least, we say the parking charge level should be £50/£25 or higher level £70/£35, as per Council PCNs in E&W.  

And we say the added fake 'debt recovery' costs are just double counting the cost of letters, and MUST GO because that is unfair and illegal.

Please be heard.  You can bet the hundreds of PPCs will be commenting.

No apologies for repeating this vital 'call for action' to consumers, on every thread this month!

Redx

Read the amateurgirl UKPC thread that won yesterday too , might be useful advice and info in it for you

amateurgirl

Thanks for recommending my thread Redx, I hope it helps you xscape. If you read the various iterations of my WS and Defence, they were written entirely with help from the regulars on this Forum and, if you read my post today about the hearing, you'll see that they were instrumental in my winning my case. You won't find better help anywhere. 
Very best of luck to you.