HX / Gladstones Hearing today!

abz1000

Le_Kirk said:

You have two point 6.  The first one seems to be the instructions (to yourself); that is the one to remove, the other one is OK.  Your numbering goes 1, 6, 2, 3 ..........

Sorry kirk that is really confusing could you send which point needs removing? the two point 6 threw me off a little haha

Were_Doomed

This:

1. I am xxxxxx xxxxxx of (postal address) and I am the defendant against whom this claim is made.   The facts below are true to the best of my belief and my account has been prepared based upon my own knowledge.  My defence is repeated and I will say as follows: 

 

6. Talk about the signs and refer to your photo evidence in your own words.  

Give each photo an exhibit number. 

When finished, do an Index page for the front and give every page a number as well (except for transcripts like Excel v Smith, they represent one page).

 

2. Firstly, it should be noted that the claimant has appended to their witness statement an inaccurate site plan which is nothing more than a birds eye view with coloured dots scattered over the highlighted area. I have appended the actual location of the sign upon entering the car park, photographed myself on 22nd November 2019.

abz1000

Were_Doomed said:

This:

1. I am xxxxxx xxxxxx of (postal address) and I am the defendant against whom this claim is made.   The facts below are true to the best of my belief and my account has been prepared based upon my own knowledge.  My defence is repeated and I will say as follows: 

 

6. Talk about the signs and refer to your photo evidence in your own words.  

Give each photo an exhibit number. 

When finished, do an Index page for the front and give every page a number as well (except for transcripts like Excel v Smith, they represent one page).

 

2. Firstly, it should be noted that the claimant has appended to their witness statement an inaccurate site plan which is nothing more than a birds eye view with coloured dots scattered over the highlighted area. I have appended the actual location of the sign upon entering the car park, photographed myself on 22nd November 2019.

oh! yeah i was totally aware of that part I left it in so I dont forget to do the index and page numbers etc.

Le_Kirk

Well, that is the point 6 to remove!

abz1000

Le_Kirk said:

Well, that is the point 6 to remove!

Ok will do, would you suggest anything else?
So to confirm I just need to add all the evidence labelled as each exhibit and also do i need to add any transcripts?

Le_Kirk

Just go through and check for grammar, spelling errors and that it makes sense to someone who is not involved, i.e. the judge.  Make sure that there are no repetitious points. 

abz1000

Le_Kirk said:

 I have appended the actual location of the sign upon entering the car park, photographed myself on 22nd November 2019.

Better as: -

 I have appended the actual location of the sign upon entering the car park, photographed by me myself on 22nd November 2019.

Presumably you will take out your first point 6, which are the instructions!

stopping is both impossible due to the double yellow lines and traffic not being able to pass.

It is permitted to stop on double yellow lines for loading/unlading provided there are no "kerb blips"

4. As you approach the car park which is directly next to the wheelchair ramp/path to the train tracks and notice board.(Exhibit xxx) Due to the lack of lighting, signage, weather conditions and unmarked bays you can clearly see how a driver might mistake this unmarked land for a place to drop off or pick up a passenger. This is just a concealed pitfall or trap.

Your first sentence in this point just stops!  Maybe something like: -

4. As you The approach to the car park which is directly next to the wheelchair ramp/path to the train tracks and notice board and, due to the lack of lighting and signage, the weather conditions on the day and with the parking bays being unmarked you can it is clear to see how a driver might mistake this unmarked land area for a place to drop off or pick up a passenger. This is just a concealed pitfall or trap. (Exhibit xxx)

Your point 5 is confusing.  I would query the way you have written this as, if a sign is not visible, how do you know it is not readable?  Maybe rewrite it so it says what you want it to say and explains to anyone else reading it (a judge for example) what impression you are trying to create.

Could you explain the double yellow line kerb lip part you mentioned don't quite understand what you meant there.

KeithP

Put kerb blip into google.

Were_Doomed

The Highway Code is your friend. https://www.highwaycodeuk.co.uk/road-markings.html

On the kerb or at the edge of the carriageway

Loading restrictions on roads other than Red Routes

Yellow marks on the kerb or at the edge of the carriageway indicate that loading or unloading is prohibited at the times shown on the nearby black and white plates. You may stop while passengers board or alight. If no days are indicated on the signs the restrictions are in force every day including Sundays and Bank Holidays.
ALWAYS CHECK THE TIMES SHOWN ON THE PLATES.

abz1000

Were_Doomed said:

The Highway Code is your friend. https://www.highwaycodeuk.co.uk/road-markings.html

On the kerb or at the edge of the carriageway

Loading restrictions on roads other than Red Routes

Yellow marks on the kerb or at the edge of the carriageway indicate that loading or unloading is prohibited at the times shown on the nearby black and white plates. You may stop while passengers board or alight. If no days are indicated on the signs the restrictions are in force every day including Sundays and Bank Holidays.
ALWAYS CHECK THE TIMES SHOWN ON THE PLATES.

Just checked on google maps there is no kerb blips at all approaching or near the car park or train station.