This is a tough one!

Redx

correct , all those spurious charges are an abuse of process as detailed in the threads I mentioned

Umkomaas posted the correct breakdown for you , hence why you now add in the paragraphs written by CM in the abuse of process thread as an exhibit and reference it or them

draw up your own costs schedule too , add it , reference it


ps:- this fake £60 addon is not that £60 payment after the 40% discount when the pcn first arrived. the original pcn was £100 and will also be on the signs too , hence the £100 in the post by Umkomaas

Blazkowicz

Thanks!
My costs are:

<Requisite Heading>

Ordinary Costs

Loss of earnings/leave, incurred through attendance at Court <date of hearing here> £95.00

Return mileage from home address to Court (7.8 miles x £0.45) £3.51

Parking near Court £5.30

Sub-total £103.81 ======


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

Research, preparation and drafting of documents (6 hours at Litigant in Person rate of £19 per hour) £114.00

Stationery, printing, photocopying and postage: £15.00

Sub-total £129.00 ======

£232.81 TOTAL COSTS CLAIMED

Blazkowicz

Reading through the Abuse of Process thread - do I add Coupon Mad's #14 as an exhibit? Or within the wording of my WS?

Redx

Blazkowicz wrote: »

Reading through the Abuse of Process thread - do I add Coupon Mad's #14 as an exhibit? Or within the wording of my WS?

yes I believe you do, and reference it as an exhibit in your WS, because its a supplementary WS , so both

Blazkowicz

Sorry RedX - i'm lost. I have asked monkeynuts45 how he did it, as I am not sure how to set it out.
Do I mention it in a separate paragraph like for example:
17.
I provide attached F012: a supplementary Witness Statement listing relevant cases that support my case.

Then simply provide a word document with the wording in the 2nd quote box from #14?

Sorry if i'm being dense.

Blazkowicz

I think i've got it... I use Coupon Mad's post #14 from Abuse of Process as a 'Supplementary Witness Statement' exhibit, referring to it like so:
3.
Before I describe what happened on the day I parked in the **********car park, I confirm that the essence of my defence of this claim is laid out in my submitted defence, with the addition of a supplementary witness statement outlining more recent precedents for “abuse of process” as part of this witness statement. This supplementary witness statement is attached: <exhibit #>

Redx

That should do it , short and sweet in the WS , plenty of meat on the bones if they need picking over

Blazkowicz

RedX when you say "short and sweet in the WS" - I hope my WS doesn't read like a defence - it's quite long. But I have seen many that were longer! And some that were just 5 lines.

Redx

Better to have too much than not enough , a judge is experienced enough to cherry pick what they deem to be core issues and you only have to win on one point

My point is that each paragraph should be concise , numbered and reference exhibits , so your point 3 above does that for both the defence and the supplementary WS all in one go

The WS by some claimants can run to say 40 pages , mainly of templated irrelevance

Blazkowicz

Yes I have tried to write almost all of this in my own words to avoid a second accusation of copy and pasting. This is why I feel this it is a strong move to copy CouponMads #14 as an 'appendix' of sorts!