Please help- Please help !! PCN from Vehicle control services ltd

Fruitcake

C-m, I don't think the courts will accept an audio file as evidence by email. I think it must be on a durable medium such as a CD, DVD, or a memory-stick, so it must be sent by post.

SoJacob

Thank you both. Very quickly. I am just attaching the audio clips to the memory stick right? Not the other evidences I attached as PDF? 

Fruitcake

Correct, as long as the stick is identified as previously mentioned to include the fact that it is an exhibit and evidence in court case number NNNNN etcetera, and you have mentioned it in your WS/SWS index with a paragraph explaining what it is about.

SoJacob

Thank you all for your advice and guidance. Unfortunately, spend my weekend at the hospital with my son. I am trying to finish writing my draft defence hopefully by end of tonight.  

Fruitcake

If the hearing is on the 26th, anything by post isn't going to arrive in time and you are cutting it fine for sending anything by email. You should ask for relief from sanctions due to attending hospital.

Coupon-mad

It's OK it's only the draft defence that she needs 'in her head' for a CCJ set aside hearing @Friitcake

Coupon-mad

I'd remove your 7 and 8 that don't really add anything, and replace them with:

7.  The Claimant uses a predatory camera car, whose driver in this case took no account of the circumstances and needs of the passenger, whose mobility impairment meets the definition of disability under the Equality Act 2010 (the EA). Under the EA and the applicable EHRC Statutory Code of Practice, Service Providers must make 'reasonable adjustments' including for the disabled public at large.

8.  The applicable Airport byelaws allow for stopping under certain circumstances. It is contended that the Claimant paid no regard to the circumstances, the byelaws, the EA nor even whether the area was one where they are allegedly authorised to issue PCNs, given the lack of clear 'repeater' No Stopping signs nor even double red lines in their evidence photographs. The Claimant is put to strict proof of the above.

Para 13 'for each PCN' is OK, yes.


Not sure this is right, see what others say:

9.    The defended read a copy of the service agreement between the claimant and the London Southend airport company limited. According to the contract, Vehicle Control Services, Company Number 02881745 but Companies House says this is the company number for London Southend Airport Company Limited. The contract says the client is London Southend Airport Company Limited, Company Number 02078271, but Companies House says this is the company number for the East Midlands International Airport Limited, a completely different entity. – ?????Should I add this????

SoJacob

Thank you. How about point 31? 

Coupon-mad

The signs are not clear!

SoJacob

Can someone please advise me if I should add point 9? 

Also please kindly advise me what to expect during the hearing. Is there anything else I should be preparing other than understanding my witness statement?