County Court Claim form - Horizon Parking - Urgent help needed!

Redx

RedDragon123 wrote: »

Please can you guys check that this is okay as a final defence, also, can I use the online MCOL portal to put my defence up there or is scanning and emailing better to do so?

Maybe it's me but I cannot see your challenge on landowner authority unless it's point 8 ?
, which should be in there as well as signage and pofa , keeper liability and spurious costs objections, which are there

Read what KeithP tells you to do about emailing the defence as a PDF

Read what bargepole warns about the online portal issues

Nobody on here would ever tell you to use the online portal and I definitely wouldn't

You could sign a white piece of paper in black pen , take a picture or scan it and add to your document as a digital signature instead of printing and signing and scanning the whole thing

You could sign and date the empty N1 claim form and crop a picture of the signature area to add to the pdf

Then attach the signed pdf to your email and send

Don't go off piste at this stage , do what people tell you to do

Point 8 has spelling errors, suggest you spell check the whole document

Le_Kirk

8. The Claimant is put to strict proof that it has sufficient prorpietary interest in the land, or that it has the necessary authorisation from the landowner to issue parking charge notices, and to pursue payment by means of litigation.

Should be: -
proprietary.

Your paragraph after 15 starting "The judge stated" needs either a paragraph number or should be joined to paragraph 15. The rest of it seems to contain all the usual points and arguments.

RedDragon123

Redx wrote: »

Maybe it's me but I cannot see your challenge on landowner authority unless it's point 8 ?
, which should be in there as well as signage and pofa , keeper liability and spurious costs objections, which are there

Read what KeithP tells you to do about emailing the defence as a PDF

Read what bargepole warns about the online portal issues

Nobody on here would ever tell you to use the online portal and I definitely wouldn't

You could sign a white piece of paper in black pen , take a picture or scan it and add to your document as a digital signature instead of printing and signing and scanning the whole thing

You could sign and date the empty N1 claim form and crop a picture of the signature area to add to the pdf

Then attach the signed pdf to your email and send

Don't go off piste at this stage , do what people tell you to do

Point 8 has spelling errors, suggest you spell check the whole document

I have corrected the spelling mistakes and updated. I will also put into a word document for printing and signing when it's ready.

I have updated this paragraph so please let me know if this is okay now.

Also, what do you mean by this: "Don't go off piste at this stage , do what people tell you to do"

Redx

It means don't start trying to do anything that you may think of , just because it's there

Bargepole clearly told everyone here not to use the portal , and why you should not use it , it's not up to date and not designed for this task

KeithP told you what to do , so all you do is follow his simple steps

Ie , don't ask , just do

Until they change the system to one like popla where you can upload a pdf document then emailing the defence is top of the shop in methods of submission , with royal mail second , delivery in person third and online portal comes at 99th and not fourth

That is what I mean , people here know what they are doing and why

RedDragon123

Hello! Urgent help needed please!
i requested a SAR back in 2019, they had emailed me back saying it was forwarded onto their data team but nothing was returned.

i now have a telephone court date for 2nd August.

what shall i prepare in my defence?

thanks for any help you guys can provide!

bargepole

RedDragon123 said:

what shall i prepare in my defence?

You have already filed your Defence, months ago.

You will have received a Notice of Allocation from the Court, requiring you to file and serve your Witness Statement, and any evidence relied upon, not later than 14 days before the date of the hearing. It looks like you didn't bother to read or understand that, nor did you read the info in the NEWBIES thread which explains this process - if you had done so, you could have prepared your statement in good time.

As it stands, you now have roughly 30 seconds in which to get that done. Lack of preparation and planning on your part does not create any urgency or emergency on our part.

nosferatu1001

So
- you didnt chase up the SAR, as you should have done
- you filed a defence months ago
- youre aware, as you have surely read the newbies thread, that you are at the point where you should almost cetainly have filed a WS as youve been told above. 

KeithP

RedDragon123 said:

i now have a telephone court date for 2nd August.

A court working on a Sunday?

Which court is that please?

Coupon-mad

As above, the 2nd August is a Sunday!

You obviously need to go back and read the witness statement and evidence section of the NEWBIES thread and get that done over the weekend for an August hearing date.  You've done a defence but you haven't stayed here or prepared!  Now you have a few days to copy other WS and evidence lists and do your costs assessment. 

By the way, it's easy...please read the examples in the NEWBIES thread and copy/adapt @Chefdave's documents to suit your case, and show us first.

dfightingfit

Hello @Coupon-mad, Reddragon123 here, the reset password function wasn't working.
Referring to my old post, 
Going through  @chefdave's witness statement and exhibits, how can i alter mine to match? As they are stating I breached the agreement 4. Also, there is a camera on entry of the car park which detects the number plate automatically. I did ask for a SAR previously but none was provided. I have now got the defendants witness statement with the images, letters and their car park management agreement with the landowner.
They have also mentioned how the signage has been audited by the BPA within their witness statement. Shall I be worried? Also, there was no date given as to when the evidence had to be filed by, even checking my small claims hearing letter.
Thank you so much for all your help and I'm sorry for not taking this more seriously earlier.
I've also gone to take pictures of the signage at the carpark and the signage upon entry has been destroyed?
I've attached that here, and then the signage upon parking is not fully visible due to the bush next to it, also attached.
Shall I mention in my witness statement how they did not provide PDT machine records from the days they're accusing me of breaching for?