Letter Before claim from Gladstones Solicitors

KeithP

IKG said:

I am also looking through the defence we wrote, will that also help?

Of course. You must understand it and be prepared to answer questions on it.

IKG

I am honestly very anxious about this whole thing, please hopefully the whole thing will  be over by 24th. I really appreciate all you help you guys  have given me over the last 2 years. just the last push, I will add the pictures in the WS once you approve the writing?
thanks

KeithP

In paragraph 2 you say:

2.      In my statement I shall refer to exhibits within the evidence supplied with this statement, referring to page and reference numbers where appropriate. 

...but you haven't referred to any exhibits at all.
Are you not going to show the court any evidence?
All evidence must be referred to in your Witness Statement.

I now see we were discussing this last weekend.

I don't think there is anything anyone can add until you show us your proposed finished article.

Coupon-mad

 I am happy to provide that evidence. 

No, you must append all the evidence you wish to rely upon and give each exhibit an exhibit number (your initials then a number).

You also need to add a point stating that you have seen no evidence that the Claimant has standing or authority from the landowner and what the enforcement boundary and definitions and restrictions were, at the material time.

Remove this (NEVER say you were not on the lookout for signs!):

7.     On that day I was not on the lookout for parking signs, since there had never been any restrictions there to my knowledge, and I did not see any signs indicating a change to parking allocations  or restrictions. 

This makes no sense and it looks as though you've copied it and not checked it.  Unless I've missed something, your parking wasn't later approved of and your para 9 isn't about that:

10.   However, there is no such legitimate interest where the landowner is not  disadvantaged by the motorists’ stay, as in this case where I parked in a manner later  approved of by the Claimant (as per paragraph 9). 

KeithP

@IKG we are going over the same ground again.

Back in mid April - on page 21 of this thread - the exact same points were being made when you then showed us your WS.

And you still haven't added a Statement of Truth.

IKG

@Coupon-mad
@KeithP
if images are not visible please find the word doc attached 

https://docs.google.com/document/d/1pgXNvS-vDGyykkbC5jK2qFfKznUlqkLhifuAV8_oRU4/edit?usp=sharing

thanks 

Umkomaas

IKG said:

@Coupon-mad
@KeithP
if images are not visible please find the word doc attached 

You can't attach a Word document or a pdf file. Try uploading to Dropbox and link it here. 

IKG

its a google doc 

KeithP

Unable to access...

IKG

https://docs.google.com/document/d/1pgXNvS-vDGyykkbC5jK2qFfKznUlqkLhifuAV8_oRU4/edit?usp=sharing

can you please try again