VCS CC claim- Defence by 09/06/19

nosferatu1001

For 44 (Vine vs...) I would nt say the Judge should DISMISS this case - surely it is on all fours with your case? ie your case has poor signage, therefore the ruling - that unseen signage cannot bind a driver - exactly fits? Or am i off piste here?

Mrs.Anon

Coupon-mad wrote: »

Change this as it's not good English:

Talking of the IPC CoP, are you putting in as an exhibit, the paragraphs in that CoP that set out the TWO distinct methods of issuing a PCN - neither of which allow this hybrid method?

And did you know VCS are admitting now that the DVLA has told them to stop this 'red card/not a PCN' confusing modus operandi? I would be asking them to put in evidence and bring to trial, copies of the correspondence or meeting minutes with the DVLA and/or the IPC, where this was decided, and what exactly was said by the DVLA, why the practice was banned, because you surmise that VCS are being disingenuous by continuing to sue registered keepers on the back of a banned practice.

And make it clear to the reader, that this is about the SAME Claimant!

nosferatu1001 wrote: »

For 44 (Vine vs...) I would nt say the Judge should DISMISS this case - surely it is on all fours with your case? ie your case has poor signage, therefore the ruling - that unseen signage cannot bind a driver - exactly fits? Or am i off piste here?

Thank you both very much for taking your time to review my statement. I will make changes as suggested.

With regards to IPC CoP & PoFA schedule, I am submitting the following exhibits;

- table with columns: Part/Section, Clause (quoted directly), Breach/comment
- copies of pages from IPC CoP & full POFA schedule I am relying on.

With regard to hybrid PCN & DVLA ban......how do I request this evidence from VCS? is this sufficient:

"The defendant has reason to believe that the Claimant has received orders from the DVLA banning the issuance of hybrid 'cards' affixed to the vehicles. The Defendant requests the Claimant to provide details (including outcomes) of meetings with the DVLA discussing the Claimant's procedures for issuing PCN's. The defendant believes this information to be significant to the evaluation of this claim."

With regard to your comment nosferatu1001, I completely agree and thank you for pointing this out!