Gladstones LBC help to prepare

Coupon-mad

Because you'd stopped to unload glass (that was your plan at that stage, but you then moved) you were not 'parked' and even though this is not a residential site the situation has similarities with an important and persuasive appeal parking case.

You need to adduce Jopson v Homeguard.

Search the forum!

Also, you need a supplementary WS & a costs schedule, again - search.

Frozenfire

I have the jopson in my initial defense, I should probably reference to it in my WS.

Will look into supplementary ws
Thank you.

Coupon-mad

You need to append it as a transcript to your WS, not just mention it. The transcript is in the public domain, hosted on the Parking Prankster's case law pages.

You can't just mention a case in defence then not use it, especially as it was on appeal - higher than county court first hearing level and your Judge must 'pay regard' to it.

Yep, you must read up on the supplementary WS and stuff about the CRA 2015.

Frozenfire

Thank you.
So I assume, print the whole jopson appeal case and label as an Exhibit? Then refer to it from the WS.

I can't find much on supplementary WS but will keep looking.

Many thanks.

Le_Kirk

Frozenfire wrote: »

I can't find much on supplementary WS but will keep looking.

Many thanks.

Use forum search - Search this Forum, Advanced Search, Coupon-mad as User and Supplementary as keyword(s)

Frozenfire

Ok, So I 'm going to add post 14 of https://forums.moneysavingexpert.com/discussion/6014081/abuse-of-process-district-judge-tells-bwlegal

should I title it the same as my witness statement but add 'supplementary' instead?

many thanks.

Frozenfire

There is a lot on 'abuse of process' in my defence. so I need to put it all in a supplementary ws aswell?

Le_Kirk

Your defence is backed up and supported by your witness statement. If you did not mention Abuse of Process in the defence you would not be able to bring it up in the WS. Just produce a WS and, to prevent it being overly long, keep the Abuse of Process and all the points that Coupon-mad writes about in the supplementary WS which of course you entitle Supplementary Witness Statement, provided you refer to it in the main WS.

Frozenfire

Great, all points taken aboard.
witness statement amended and any errors rectified.
supplementary ws created to incude abuse of process in detail and refers to jopson transcript and also cra2015 excerpt.

all printed off x3 along with evidence.
index created so all organised. ring binder for the courts and cheap (but organised) folder for the claimant

I will post everything to the courts (evidence and ws) but will hold back ws from claimant until almost last minute.

I probably shouldn't of printed anything until I got claimants ws first but fingers crossed I won't need to amend.

many thanks all.

Coupon-mad

And your hefty costs schedule?