Help, got until 24th November to submit Defence for VCS

Leviathan747

D_P_Dance said:

It really is not, find a U Tube video of a typical hearing and watch it.  

Thanks DPD.  Not worried about the court hearing itself.....I mean, when is it even going to happen in amongst this pandemic??  It's all the legal language and putting the WS together when not really understanding how all the pieces fit and what to do, that's daunting.  Like trying to compile an argument in borrowed Russian!!  And I also hate wasting paper!! 

Fruitcake

Amongst other things, you need to check where you have copied and pasted. For example you need to put I not your. This is you making a statement so everything from you needs to be first person singular.
Where you refer to The Companies Act, you need to ensure you include a copy of section 44 and refer to it as an exhibit.

"5. Further, landowner authority states that parking is free for 2 hours, as stipulated in the contract with VCS. This was revealed in the VCS v Andrew Norton case in Jan 2020. EXHIBIT A."
I would add something like, "and can also be seen in the dated Google Maps images in Exhibit?"

"36. The front page of the Excel contract" provided by the claimant ...

37 ...
The signatures are not dated so there is no proof that the contract was signed before the date of your the alleged parking event.

38 … you I aver ...

 39. Where is the contract between VCS and the landowner or landholder?  I aver that there is not one because there is already a contract in place with Excel that predates the VCS letter. If it does exist, why haven't VCS shown it? Perhaps it states 2 hours free parking so the scammers have included a contract with a different company instead.

Don't ask questions, make statements. The other sentences needs adjusting accordingly. Also the statement about the Excel contract predating the VCS letter is the exact opposite of what it says in para 36.

40 ... you I aver ...

You haven't included a statement about the signs changing from VCS after August 2018 to Excel by May 2019, as evidenced by the dated Google Maps Street View images, exhibits? This supports your assertion that that the parking contract was indeed with Excel according to the dated contract provided by VCS.

Umkomaas

Leviathan747 said:

Umkomaas said:

You could chance leaving them out and rely on the Judge pulling the judgment up on his computer at the hearing, or you can help him/her and lay it out in front of them. 

Most of our advice is based on using our logic and thought processes to work out what is obvious. None of the regulars here are legally trained or qualified - yet increasingly we are being unreasonably and unrealistically asked for definitive legal advice. 

And what we find most frustrating is when people ask 'What's my next step?, 'What more can I add?', 'What do I do now?' 'Any further advice?', 'Do I have a leg to stand on?', 'Am I bang to rights?'.  Please think things through before just firing a question into a Comment box, give us your thoughts on what you would propose rather than expecting spoon-fed answers each and every time. 

Take care of yourself Umk, don't feel like you have to reply to everyone, because you really don't have to.

Thanks for your advice. Maybe I should take it.  Perhaps you'll take over?  Look forward to reading your input to others should I take a back seat.

Leviathan747

Umkomaas said:

Thanks for your advice. Maybe I should take it.  Perhaps you'll take over?  Look forward to reading your input to others should I take a back seat.

Definitely take the advice Umk. Just as an FYI, you've made 6 posts on this thread, two of which have been helpful.  So in your 27,000 posts, am sure you've helped loads of folk (THANK YOU), but just respectfully pointing out that you've not depleted your energies here. And no, I won't be 'taking over' lol.  But regardless of who will fill your void, life goes on.....and you obviously need to switch off and recharge for a bit.  Sounds like some R & R would do you the world of good!

Leviathan747

Fruitcake said:

"5. Further, landowner authority states that parking is free for 2 hours, as stipulated in the contract with VCS. This was revealed in the VCS v Andrew Norton case in Jan 2020. EXHIBIT A."
I would add something like, "and can also be seen in the dated Google Maps images in Exhibit?"

You haven't included a statement about the signs changing from VCS after August 2018 to Excel by May 2019, as evidenced by the dated Google Maps Street View images, exhibits? This supports your assertion that that the parking contract was indeed with Excel according to the dated contract provided by VCS.

Thanks for the suggestions Fruitcake.  Will make adjustments to V6! 

Leviathan747

Phoned Sheffield County Court this morning and the lady I spoke to said she was 90% certain that the case would be 'Vacated', because it was Small Claims.  Meaning it wouldn't be heard until after August.  Will be sending everything next week anyway.

Leviathan747

Hi guys.  Here is Version 6 of the Witness Statement.  Think this is pretty much the final draft:

In the County Court at SHEFFIELD, The law Courts, 50 West Bar, Sheffield, S3 8PH

Claim No. XX

Between VEHICLE CONTROL SERVICES LTD (Claimant)

and

XX

WITNESS STATEMENT

1. I am the registered keeper of the vehicle in this case. I am unrepresented with no legal background in county court procedures, I trust that the Court will excuse my inexperience, if need be, and if any of the documentation is not presented correctly. I note that the statement of truth supplied by and on behalf of the Claimant, has not been signed by the Claimant.

2. I deny that the Claimant is entitled to relief in the sum claimed, or at all.

3. Attached to this statement is a paginated bundle of evidence marked Exhibits A to K, plus Appendices A to C, to which I will refer. 

4. The Claim is made in the name of Vehicle Control Services Ltd. (Company No. 02498820), whereas the signage displayed at the location in question was, and is, in the name of Excel Parking Services Ltd. (Company No. 02878122), a separate legal entity. This fact can be confirmed by reference to the images contained in the Claimant’s bundle. Any contract, in a private car park, can only be formed by signage, and it is therefore submitted that if there was any contract, it would have been between Excel and the Defendant. VCS were not a party to such a contract, and therefore cannot sue on it.

5. Further, landowner authority states that parking is free for 2 hours, as stipulated in the contract with VCS, confirmed in Google Map images EXHIBIT A.  This was also revealed in the VCS v Andrew Norton case in Jan 2020. EXHIBIT B. 

6. Before providing further chronology and dispute of the supposed contractual breach that happened at Berkley Centre car park, I confirm that the essence of my defence to this claim is;

a. The actions of the Claimant to (a) offer a contract in the form of a sign, (b) establish a parking charge, and (c) to claim against the registered keeper; are in breach of procedures mandated by;

i. The Parking Trade Association for which it is affiliated.
ii. The Act for which the claimant relies on.

b. A contract was not in place with the driver or the defendant who is the registered keeper. Therefore, no breach of contract has ever occurred. They have the ability prescribed by law (POFA 2012) EXHIBIT C - to transfer the liability for the parking charge to the keeper if they do not know the name of the driver. As VCS have chosen not to use that right under POFA the keeper cannot be held liable.

c. Inadequate and illegible signage.

d. The sum of the claim brought forward includes £100 of a Parking Charge and an additional £60 for ‘debt recovery costs’ as previously indicated by the Claimant. The additional £60 is an attempt at double recovery and is an Abuse of Process. The current POFA 2012 law states...

"The claim contains a substantial charge additional to the parking charge which it is alleged the defendant contracted to pay, This additional charge is not recoverable under the protection of freedoms act 2012" it further goes on to state "artificially invented figures in an attempt to circumvent the Small Claims costs rules using double recovery."

e. Reasonable doubt as to validity of contracts

f. No advertising consent existed at the time of the alleged incident

g. The Defendant invites the court to dismiss this claim.

The Claimant’s breach of mandated Codes of Practise and ruling Act

7. Through the Claimant’s disregard for the very guidelines and law set out to aid their business, the Defendant believes that the company failed to meet the minimum obligations that would allow them to bring forward a parking charge and ultimately seek registered keeper liability.

Inadequate and illegible signage

8. The font sizes on the Excel signs are very small and packed with confusing patterns and symbols around them. The sign is a mass of confusing and contradictory words. The icon showing the PCN charges are hidden in the small print. It is not prominent or obvious to see by a motorist driving, even very slowly, past the sign. I submit that no reasonable person would agree that their terms were brief, clear and prominently proclaimed.

9.  I note that in the evidence presented to the court as part of the Claimant’s Witness Statement, that the Claimant does not include any images of signage taken at the site in real life conditions, either in the day or evening. I would contend their submitted photocopies of the signs are misleading, as they both exaggerate the font of the signs out of proportion, do not show how confusing the signs were at the time of the alleged incident, nor show the poor visibility of the signs in evening light, or other inadequate artificial lighting, such as broken street lamps. In addition, there are no dates on the two images of the signs submitted by the Claimant, so it is impossible to know if they applied to the alleged incident in 2019 or not.

10. Case law from Beavis would therefore lead to the conclusion that a vital ingredient is that the signage be ample, the charge clear. I submit that Excel do not comply.

11. In addition, a reasonable interpretation of Lord Denning’s 'red hand rule' and the BPA and IPC Code of Practice, taking all information into account, would require a parking charge and the terms to be displayed far more transparently and in larger lettering, with fewer words and more 'white space' as background contrast suited to an outdoor sign.

12. Breaches with regard to signage on the property mean that a valid contract could not have been offered to any individual (including visually impaired) and therefore with respect to this claim, no contract was ever in place; thus rendering a breach impossible.

13. On 06/06/2019 the driver entered Berkley Centre car park for the purpose of doing some shopping. In order to be able to read the signs on entry into the car park, the driver would have had to have stopped the car or left the car, in order to do so. The signs are not readable from a moving car.  EXHIBIT D

14. The driver parked and went to Tesco.  The view from their parking spot had no visible signage.  EXHIBIT E

15. All the current signs are facing in the opposite direction and are above head height and with small font. This is in contrast to the type approved in the Parking Eye v Beavis case. No contract was entered, and terms and conditions were not and could not be accepted.  EXHIBIT F

Costs on the claim – Abuse of process

16. In addition to the 'parking charge', the Claimant has artificially inflated the value of the Claim by adding costs of £60 which has not actually been incurred by the Claimant, and which are artificially invented figures in an attempt to circumvent the Small Claims costs rules using double recovery.

17. CPR 44.3 (2) states: EXHIBIT G

“Where the amount of costs is to be assessed on the standard basis, the court will – (a) only allow costs which are proportionate to the matters in issue. Costs which are disproportionate in amount may be disallowed or reduced even if they were reasonably or necessarily incurred; and (b) resolve any doubt which it may have as to whether costs were reasonably and proportionately incurred or were reasonable and proportionate in amount in favour of the paying party.”

18. The standard wording for parking charge/debt recovery contracts is on the Debt Recovery Plus website - ''no recovery/no fee'', thus establishing an argument that the Claimant is breaching the indemnity principle - claiming reimbursement for a cost which has never, in fact, been incurred. This is true, whether or not they used a third-party debt collector during the process.

19. In fact, it is averred that the Claimant has not paid or incurred such damages/costs or 'legal fees' at all. Any debt collection letters were a standard feature of a low-cost business model and are already counted within the parking charge itself and there has been no legal advice or personal involvement by any solicitor in churning out this template claim.

20. The Parking Eye Ltd v Beavis case is the authority for recovery of the parking charge itself and no more, since that sum (£85 in Beavis) was held to already incorporate the minor costs of an automated private parking business model. There are no losses or damages caused by this business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages.

21. Unlike this mendacious and greedy Claimant, ParkingEye themselves took on board the Beavis case outcome and they never add fake costs on top of the parking charge. It is indisputable that an alleged 'parking charge' penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending upon the parking firm) covers the costs of the letters, and all parking firms are very familiar with this case.

22. The Defendant refers to the following paragraphs given in the judgement on the 4th of November 2015 in ParkingEye v Beavis:

a. At para’ 98, {re ...The desirability of running that parking scheme at no cost, or ideally some profit, to themselves};

“Against this background, it can be seen that the £85 charge had two main objects. One was to manage the efficient use of parking space in the interests of the retail outlets, and of the users of those outlets who wish to find spaces in which to park their cars [...] The other purpose was to provide an income stream to enable ParkingEye to meet the costs of operating the scheme and make a profit from its services...”

b. At para’ 193;
“judging by ParkingEye’s accounts, and unless the Chelmsford car park was out of the ordinary, the scheme also covered ParkingEye’s costs of operation and gave their shareholders a healthy annual profit.”

c. At para’ 198.
“The charge has to be and is set at a level which enables the managers to recover the costs of operating the scheme. It is here also set at a level enabling ParkingEye to make a profit.” EXHIBIT H

23. In relation to parking on private land, it is settled law from the Supreme Court, that a parking charge must be set at a level which includes recovery of the costs of operating a scheme.  However, this Claimant is claiming a global sum of £160. This figure is a penalty, far exceeding the £85 parking charge in the ParkingEye Ltd v Beavis case. 

 

24. The global sum claimed is unconscionable and it was not shown in large lettering on any consumer signs, and it is averred that the charge offends against Schedule 2 of the Consumer Rights Act 2015 (‘the CRA’), where s71(2) creates a duty on the Court to consider the fairness of a consumer contract.  The court’s attention is drawn (but not limited to) parts 6, 10, 14 and 18 of the list of terms that are likely to be unfair. EXHIBIT I

 

25. Even if the Claimant had shown the global sum claimed in the largest font on clear and prominent signs - which is denied - they are attempting double recovery of costs. The sum exceeds the maximum amount which can be recovered from a registered keeper, as prescribed in Schedule 4, Section 4(5) of the Protection of Freedoms Act 2012 (‘the POFA’).  It is worth noting that in the Beavis case where the driver was known, the Supreme Court considered and referred more than once to the POFA.

 

26. Claims pleaded on this basis by multiple parking firms have routinely been struck out ab initio in various County Court areas in England and Wales since 2019.  Recent examples are appended to this defence; a February 2020 Order from District Judge Fay Wright, sitting at Skipton County Court (Appendix A)  and a similar Order from Deputy District Judge Josephs, sitting at Warwick County Court (Appendix B ).

 

27. Applications by AOS member parking firms to try to reach the usually low threshold to set aside multiple strike-out orders have been reviewed by more than one area Circuit Judge, including His Honour Iain Hughes QC, occasioning District Judge Grand at Southampton to hear submissions from a barrister on 11th November 2019. The court refused to set aside the Orders and, tellingly, no appeal was made. 

 

28. The Judge found that the claims - both trying to claim £160, with some ten or more similar cases stayed - represented an abuse of process that ‘tainted’ each claim.  It was held to be not in the public interest for a court to let such claims proceed and merely disallow £60 in a case-by-case basis, thus restricting and reserving the proper application of the relevant consumer rights legislation only for those relatively few consumers who reach hearing stage.  That Judgment is appended (Appendix C).

 

29. The CCBC and/or the allocated Court Judge is invited to read the Appendices at the earliest opportunity.  The Defendant avers that parking firm claims which add a duplicitous ‘costs’ sum to the parking charge are now easily identified to be unlawful. Such claims are against the public interest, requiring no further assessment, and listing such cases for trial should be avoided.  The Court is invited to exercise its case management powers pursuant to CPR 3.4 to strike out this claim, which is entirely tainted by abuse of process and breaches of the CRA.

 

 

Leviathan747

30. Should this claim continue, the Claimant will no doubt try to mislead the court by pointing to their Trade Association ‘ATA’ Code of Practice (‘CoP’) that now includes a hastily-added clause 'allowing' added costs/damages.  The Defendant points out that the CoP is a self-serving document, written in the parking firms’ interests. Further, the ‘admin fee’ model was reportedly invented by a member of the British Parking Association Board, Gary Osner, whose previous firm, Roxburghe (UK) Limited, folded after being declared ‘unfit’ by the Office of Fair Trading who refused to renew their consumer credit licence due to ‘unfair and misleading’ business practices. Mr Osner states in an article that has been in the public domain since 2018: ''I created the model of ‘admin fees’ for debt recovery because ticket value was so low that nobody would make any money. Parking is business and business is about money, after all.''  

 

31. The two competing ‘race to the bottom’ ATAs have engineered a veil of legitimacy to protect this industry for too long.  They are not regulators and have failed consumers so badly, that Parliament is currently working on replacing them with a new CoP overseen by the Secretary of State, following the enactment of the Parking (Code of Practice) Act 2019.  Many courts have now recognised that a predatory parking firm Claimant using unfair and predatory business practices and inflating their claims with false ‘admin fees’, is not the ‘innocent party’ in a dispute.  In stark contrast to the BPA Board member’s mindset, the will of Parliament as set out in the new 2019 Act is very much consumer-focussed, aiming for:  ''good practice...in the operation or management of private parking facilities as appears to the Secretary of State to be desirable having regard to the interests of persons using such facilities.''  

 

32. In the alternative, the defence is prejudiced and the court is invited to note that, contrary to the Pre-Action Protocol for Debt Claims, the Letter Before Claim omitted evidence of any breach and failed to append the wording of the sign or consumer notice.  Further, the Particulars of Claim are embarrassing and incoherent, lacking specificity re the location of the event and status of the contracting parties and failing to detail any conduct or liability that could give rise to a cause of action.  There is insufficient detail to ascertain the nature, basis and facts of the case but the sum claimed includes unrecoverable costs/damages and is clearly an abuse of process.

 

33. The court is invited to note that the Beavis case would not have passed had it been pleaded in damages by ParkingEye, and the penalty rule applies to charges that are penal or unconscionable in their construction.  The Supreme Court held at [14] ‘‘where a contract contains an obligation on one party to perform an act, and also provides that, if he does not perform it, he will pay the other party a specified sum of money, the obligation to pay the specified sum is a secondary obligation which is capable of being a penalty.’’  And at [99] ‘‘the penalty rule is plainly engaged.’’

 

34. Unlike in this case, ParkingEye demonstrated a commercial justification for their £85 parking charge which included all operational costs and was constructed in such a way and offered on such ‘brief and clear’ signs with terms set in the interests of the landowner, that they were able to overcome the real possibility of the charge being struck out as penal and unrecoverable.  The unintended consequence is that, rather than persuade courts considering other cases that all parking charges are automatically justified, the Beavis case facts and pleadings set a high bar that other claims fail to reach.  Unusually for this industry, it is worth noting that ParkingEye do not add false ‘debt letter costs/damages’ to their parking charges and as a consequence, their own claims have escaped any reports of being summarily struck out.

 

35. This Claimant has failed to plead their case, or to set out their terms or construct their contractual charges in the same way as in Beavis and the penalty rule remains firmly engaged.  Paraphrasing from the Supreme Court, deterrence is likely to be penal if there is a lack of an overriding legitimate interest in performance extending beyond the prospect of compensation flowing directly from the alleged breach.  The intention cannot be to punish drivers nor to present a motorist with concealed pitfalls or traps, nor to claim an unconscionable total sum.

 

Reasonable doubt as to validity of contracts

36. The front page of the Excel contract provided by the Claimant is dated the 28th of September 2018, but the letter from VCS dated the 5th of December says, "Thank you for returning the contract for parking enforcement at the Berkley Centre. Please find enclosed your signed copy along with a VCS welcome pack." This letter predates the purported Excel contract by over three weeks and implies a parking enforcement contract between VCS and Lambert Smith Hampton was already in place at the time Excel signed theirs. This puts reasonable doubt onto what company actually had a parking contract in place at the time.

37. Google images show that parking signs changed from VCS after August 2018, to Excel by May 2019 (EXHIBIT J). This supports the assertion that the parking contract was indeed with Excel. VCS were not a party to such a contract, and therefore cannot sue on it.

38. According to section 44 of the Companies Act 2006 (EXHIBIT K), for a contract to be executed (in other words, valid) it must be signed by TWO authorised persons from each party, or a Director AND a witness. Since there is only one signatory from each party, the contract fails to have been properly executed. The signatures are not dated so there is no proof that the contract was signed before the date of the alleged parking event.

39. The contract refers to the "landholder" but not the landowner. Anyone could say, "I'm authorised to sign contracts on behalf of the landowner," but for that to be true there would need to be a written contract between the landowner and the landholder, signed by two authorised persons from each party, authorising the landholder to form contracts with a third party. Since such a contract has not been provided, I aver that it does not exist and therefore the contract between Excel and LSH is invalid.

40.  If a contract exists between VCS and LSH, I aver it states 2 hours free parking, so the scammers have included a contract with a different company instead.

41. The Excel contract is signed by someone called K. Brindley who alleges he/she was a director of LSH underneath the full name, Lambert Smith Hampton. According to Companies House records, the annual "Full accounts made up to 31 December 2018" for this company do not show K Brindley as being a director at the time. Even if a judge accepts that VCS had a contract with the landholder because they own Excel, I aver the signatory of the client was not a director of LSH at the time the contract was drawn up, the contract is therefore fraudulent and invalid.

42. The contract is signed by Simon Renshaw Smith on behalf of Excel and K Brindley on behalf of Lambert Smith Hampton, but the Claimant letter is from VCS.  VCS own Excel outright, but they are completely separate operating companies with different company numbers registered at Companies House. Vehicle Control Services Company number is 02498820.  Excel Parking Services Limited Company number is 02878122.  Signs and ticket machines mention both Excel and VCS.

No advertising consent existed at the time of the alleged incident

43. On 24 March 2020, my partner received an email from Mahmood Khalid, Planning Enforcement Officer.

“Dear XXX, 

I write with reference to your recent enquiry regarding the signage, CCTV at the Berkley Precinct car park. The matter has been investigated and it has been determined that advertisement consent is required for the signs erected within the car park. I have informed the Management Company to submit an application to regularise this”

Advertising consent did not exist at the material time and it cannot be applied retrospectively. Not having it is a criminal offence, therefore the claim was illegally issued. 

44. Ex turpi causa non oritur action.  The Claimant cannot pursue legal remedy, if it arises in connection with his own unlawful act.

Addressing individual points and distinguishing cases referred to in the claimant’s witness statement

45. In Paragraph 32 of the Claimant’s Witness Statement, the Claimant refers to ‘Vine v Waltham Forest’.

46. The Court of Appeal on this case ruled in favour of the Defendant on the basis that a person cannot be presumed bound by terms and conditions on signage that they haven’t seen. It would appear that the Claimant is attempting to wrongfully persuade the court by mis-quoting Roch L.J. The full quote is this;

“Alternatively, and this is the ground principally urged upon us by Mr. Mott, the question whether a person voluntarily assumes a risk or consents to trespass to his or her property is to be judge objectively and not subjectively. Once it is established that sufficient and adequate warning notices were in place, a car driver cannot be heard to say that he or she did not see the notice. Were that to be the law, it would be too easy for car drivers who trespass with their cars to evade the only method landowners have of stopping the unauthorised parking of cars in parking spaces or parking areas on their property.”

47. As you can see, Lord Justice Roch was simply reading one side of the argument. Roch L.J. found in favour of the motorist in this case. Therefore, this case can be immediately dismissed as it has no bearing on this case in question.

48. Paragraph 34 states the Claimant is intending to rely on the ParkingEye v Beavis (2015) case.

49. This case can be fully distinguished from my case due to the following facts;

a. There was no contractual offer made giving a licence to park nor any promise made, or contract agreed based on any prominent signs.

b. There is no comparable legitimate interest or commercial justification for charging more than the landowner could claim by way of restitutionary damages.

50. In Paragraph 61, The Claimant is intending to rely on Chaplair v Kumari (2015) to attempt to justify an unknown £60 “debt recovery charge”.

51. This case is distinguished from the case above by the following facts; the Beavis case established that a parking firm cannot seek or plead a sum in 'damages'. Chaplair v Kumari is also distinguished. Far from supporting this attempt at double recovery, Chaplair was a decision about contractual fees set in lease terms, whereas parking charges are capped by the Protections of Freedoms Act (the POFA)/the will of Parliament at the sum on any Notice to Keeper, and not higher, and the Beavis case confirmed this by only allowing £85 and no bolt on 'damages' or imaginary debt collector costs.

Conclusion

52. The Claimant is in breach of the very rules in place to protect its business and through obscuring the procedures as set out in trade associations codes of Practise and POFA schedule 4, the Claimant maintains a way of confusing motorists and harassing them for grossly inflated Parking charges.

53. The Claimant's Particulars disclose no legal basis for the sum claimed. This Claimant knew, or should have known, that an exaggerated ‘parking charge’ claim where the alleged ‘debt’ exceeds the £100 ATA CoP ceiling is disallowed under the CPRs, the Beavis case, the POFA and the CRA, The Judge in the instant case is taken to the Appendices, demonstrating that several court areas continue to summarily strike out private parking cases that include an extravagant and unlawful costs sum.

54. I invite the Court to dismiss this claim in its entirety, and to award my costs of attendance at the hearing, such as are allowable pursuant to CPR 27.14.

Statement of Truth

I believe that the facts stated in this Witness Statement are true.

Signature of Defendant:
Name:
Date:

Leviathan747

Thanks for your super helpful suggestions Fruitcake!  Got into a bit of a tangle with the Excel/VCS timeline (found it a little complicated to digest and unpick), so simplified point 40 to one sentence.  Have added a paragraph re Google Images at 37.

Apparently there is a box outside the building, that I can post the bundle into at the court.  Will staple a proof of post to VCS on the front, as suggested by CM.

Le_Kirk

Not sure you should be using the word "scammers" for your point 40!  Do you really need to include your defence again?  Surely you have already submitted that?