Court claim letter received

The_Deep

Ibbotson is very old now though, and is trumped by the ParkingEye v Beavis case

But surely mitigation of losses still applies? Am I wrong in thinking that it is a basic tenet of Law?

nosferatu1001

How is it entrapment?
that term has no meaning in UK law, and I fail to see how they are entrapping anyway - are they offering to let you park then going "aha yo ucant park!" when you do?

AB0013

Hi All, Would be good to know if i'm missing anything here. Defence needs to be submitted by Tues 10th December but would like to do asap - but it has to be right of course!!

Appreciate if the Masters can take a look for me and advise asap :0) Thanks a million!

AB

Claim Number: FXXXXXXX BETWEEN:

UK CAR PARK MANAGEMENT LIMITED (Claimant) vs XXXXXXXXXXX (Defendant)

__________________________________DEFENCE STATEMENT_________________________________

I am name xxxxxxxxxxxxxxxxxxxxxx of address is the defendant in this matter. As an unrepresented litigant-in-person I seek the Court's permission to amend and supplement this defence as may be required upon disclosure of the claimant's case.

Rebuttal of Claim - It is denied that:
a) A contract was formed
b) There was an agreement to pay a parking charge
c) That there were Terms and Conditions prominently displayed around the site
d) That in addition to the Parking charge there was an agreement to pay additional and unspecified additional sums
e) The claimant company fully complied with their obligations within the terms of Schedule 4 of the Protection of Freedoms Act 2012
f) The claimant company fully complied with their obligations within the International Parking Community Code of Practice of which they were member at the time
g) That the defendant is liable for the purported debt. It is further denied that the defendant owes any debt to the claimant or that any debt is in fact owed or that any debt exists or could ever exist or has ever existed. That in any event the claimant has failed to comply with the requirements of the Civil Procedure Rules and that their claim is both unfounded and vexatious.
h) The claimant is put to the strictest proof of their assertions.

The defence to this claim relies principally these main points, as follows:

a) The defendant disputes liability for this parking charge as the 'out of bay' area in question has NO specific signage to make it clear that this bay (the bay they were issued a PCN for) differs from the other central retail park bays. The 8 bays are all exactly the same size, but 7 are for 3 cars, so it is reasonable to assume that (all 8) including the bay in question is also for 3 cars and not 2.Since being issued a ticket the Defendant was made aware of the pale grey brick outline on the floor, which supposedly identifies the bay outline and is even more difficult to see in dusk lighting or rain etc. so it is proposed that it is not sufficient to identify as 'clearly marked'. Tesco’s have been notified directly by the Defendant and are taking the matter up directly with the landowners as they have seen first hand how it's misleading and has caused problems to their customers.

b) No ticket was issued to the defendant’s car and the defendant only became aware of the incident when they received a letter from a debt recovery company. The Defendant appealed to the Claimant company via the Independent Appeal Service whereby the Claimant lied about the positioning of signage that does not actually exist and the appeal was subsequently refused.

However it was noted that other cases (for the same parking space) who appealed via IAS have been allowed:

In a previous case at the same location the independent adjudicator stated:
"This is not the first appeal I have dealt with regarding this site, and the same comments apply - the signage is inadequate - see operator photographs showing no signage in evidence, and the markings on the brickwork are confusing where spaces usually allocated for three cars are reduced to two. These larger spaces are not even allocated to disabled drivers and when seeing two cars parked here with a space in between them it is natural to assume there is another space to park in. Appeal Allowed"

c) As the Claimant is not the owner of this land they cannot form a contract with the person they claim to be the driver without the express authorisation from the landowner. As per their own code of conduct they must follow to issue parking charges the company must:

a) provide the written authorisation of the landowner (or their appointed agent)

b)The written confirmation must be given before they can start operating on the land in question and give them the authority to carry out all the aspects of car park management for the site that they are responsible

d) The Claimant has included unquantified costs of £60 to the claim however CPR 44.3 (2) states: ''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.

e) Whilst quantified costs can be considered on a standard basis, this Claimant's purported costs are wholly disproportionate and do not stand up to scrutiny. 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.

f) 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. It is indisputable that the alleged 'parking charge' itself is a sum which the Supreme Court found is already inflated to more than comfortably cover the cost of all letters.

g) Judges have disallowed all added parking firm 'costs' in County courts up and down the Country. In Claim number F0DP201T on 10th June 2019, District Judge Taylor sitting at the County Court at Southampton, echoed an earlier General Judgment or Order of DJ Grand, who on 21st February 2019 sitting at the Newport (IOW) County Court, had struck out a parking firm claim. The judges stated, ''IT IS ORDERED THAT The claim is struck out as an abuse of process. 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, Schedule 4 nor with reference to the judgment in Parking Eye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

h) In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant's vexatious conduct from the outset has been intimidating, misleading and indeed mendacious in terms of the added costs alleged.

I) There are several options available within the Courts' case management powers to prevent vexatious litigants pursuing a wide range of individuals for matters which are near-identical, with meritless claims and artificially inflated costs. The Defendant is of the view that private parking firms operate as vexatious litigants and that relief from sanctions should be refused.


Conclusion
The defendant denies that being liable to the Claimant for the sums claimed, or any amount at all. The defendant invites the Court to strike out the claim as being without merit, and with no realistic prospect of success.

All evidence referred to will be provided at least 14 days before any hearing date.

Signed


Statement of Truth:

I believe that the facts stated in this Defence are true.


Name

Signature

Coupon-mad

Your letters rather than numbers are hugely confusing and repeated, and you've missed out what should be (c) somewhere(!) and it's impossible to follow properly.

Change to numbered paragraphs and ditch a, b, c, d, !

And ditch the word 'statement' in the heading and the first line as you need to name and address because your name as defendant already appears at the top in the headings and in the signature under the statement of truth at the end.

STATEMENT_________________________________

I am name xxxxxxxxxxxxxxxxxxxxxx of address

Your points about the added £60 are out of date. Replace all that with the wording in post #14 of Beamerguy's Abuse of Process thread.

AB0013

Thanks Coupon Mad! Have made a couple of changes - hopefully ok to send (fingers crossed)

Claim Number: FXXXXXXX BETWEEN:

UK CAR PARK MANAGEMENT LIMITED (Claimant) vs XXXXXXXXXXX (Defendant)
___________________________DEFENCE_____________________________


Rebuttal of Claim - It is denied that:
a) A contract was formed
b) There was an agreement to pay a parking charge
c) That there were Terms and Conditions prominently displayed around the site
d) That in addition to the Parking charge there was an agreement to pay additional and unspecified additional sums
e) The claimant company fully complied with their obligations within the terms of Schedule 4 of the Protection of Freedoms Act 2012
f) The claimant company fully complied with their obligations within the International Parking Community Code of Practice of which they were member at the time
g) That the defendant is liable for the purported debt. It is further denied that the defendant owes any debt to the claimant or that any debt is in fact owed or that any debt exists or could ever exist or has ever existed. That in any event the claimant has failed to comply with the requirements of the Civil Procedure Rules and that their claim is both unfounded and vexatious.
h) The claimant is put to the strictest proof of their assertions.

The defence to this claim relies principally these main points, as follows:

1. The Defendant was the registered keeper and driver of vehicle registration number XXXXXXX on the material date. The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all. Accordingly, it is denied that the Defendant breached any of the Claimant's purported contractual terms, whether express, implied, or by conduct.


2. The Defendant disputes liability for this parking charge as the 'out of bay' area in question has NO specific signage to make it clear that this bay (the bay they were issued a PCN for) differs from the other central retail park bays. The 8 bays are all exactly the same size, but 7 of them are for three cars, so it is reasonable to assume that (all 8) including the bay in question is also for three cars and not two. Since being issued a ticket the Defendant was made aware of the pale grey brick outline on the floor, which supposedly identifies the bay outline and is even more difficult to see in dusk lighting or rain etc. so it is proposed that it is not sufficient to identify as 'clearly marked'. Given this lack of clarity, no contract can be construed from the Claimant's signage, under the contra proferentem principle.

3. No ticket was issued to the Defendant’s car and the Defendant only became aware of the incident when they received a letter from a debt recovery company. The Defendant appealed via the Independent Appeal Service whereby the Claimant lied about the positioning of signage that does not actually exist and the appeal was subsequently refused. However it was noted that other cases who appealed (for the same) via IAS have been allowed.

4. As the Claimant is not the owner of this land they cannot form a contract with the person they claim to be the driver without the express authorisation from the landowner. As per their own code of conduct they must follow to issue parking charges the company must

a) Provide the written authorisation of the landowner (or their appointed agent)

b) The written confirmation must be given before they can start operating on the land in question and give them the authority to carry out all the aspects of car park management for the site that they are responsible

The purported added 'costs' are disproportionate, a disingenuous double recovery attempt, vague and in breach of both the CPRs, and the Consumer Rights Act 2015 Schedule 2 'terms that may be unfair'.

5. The arbitrary addition of a fixed sum purporting to cover 'recovery costs' is also potentially open to challenge as an unfair commercial practice under the CPRs, where 44.3 (2) states: ''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.

6. Alleging that the letters the parking firm sent have caused an additional loss, is simply untrue. The standard wording for parking charge/debt recovery contracts is/was 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.

7. The Defendant has the reasonable belief that the Claimant has not incurred an additional £60 in damages or costs to pursue an alleged £100 debt. The arbitrary addition of a fixed sum purporting to cover 'damages/costs' is also potentially open to challenge as an unfair commercial practice under the CPRs, where 44.3 (2) states: ''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.

7.1. Whilst quantified costs can be considered on a standard basis, this Claimant's purported added £60 'damages/costs' are wholly disproportionate, are not genuine losses at all and do not stand up to scrutiny. This has finally been recognised in many court areas. Differently from almost any other trader/consumer agreement, when it comes to parking charges on private land, binding case law and two statute laws have the effect that the parking firm's own business/operational costs cannot be added to the 'parking charge' as if they are additional losses.

The Beavis case is against this Claim

8. Parking Eye Ltd v Beavis [2015] UKSC 67 ('the Beavis case') is the authority for recovery of the parking charge itself and no more, since that sum (£85 in the Beavis case) was held to already incorporate the costs of an automated private parking business model including recovery letters. 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. 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.

8.1. This charge is unconscionable and devoid of any 'legitimate interest', given the facts. To quote from the decision in the Beavis case at Para [108]: ''But although the terms, like all standard contracts, were presented to motorists on a take it or leave it basis, they could not have been briefer, simpler or more prominently proclaimed. If you park here and stay more than two hours, you will pay £85''. Ad at [199]: ''What matters is that a charge of the order of £85 [...] is an understandable ingredient of a scheme serving legitimate interests.''

8.2. In the Beavis case it was said at para [205]: ''The requirement of good faith in this context is one of fair and open dealing. Openness requires that the terms should be expressed fully, clearly and legibly, containing no concealed pitfalls or traps. Appropriate prominence should be given to terms which might operate disadvantageously to the customer.''

8.3. 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...''

8.4. 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.'' and 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.''

The POFA 2012 and the ATA Code of Practice are against this Claim
9. The Protection of Freedoms Act 2012, Schedule 4 ('the POFA') at paras 4(5) and 4(6) makes it clear that the will of Parliament regarding parking on private land is that the only sum potentially able to be recovered is the sum in any compliant 'Notice to Keeper' (further, the ceiling for a 'parking charge', as set by the Trade Bodies and the DVLA, is £100). This also depends upon the Claimant fully complying with the statute, including 'adequate notice' of the parking charge and prescribed documents served in time/with mandatory wording. It is submitted the claimant has failed on all counts and the Claimant is well aware their artificially inflated claim, as pleaded, constitutes double recovery.

The Consumer Rights Act 2015 ('the CRA') is against this claim
10. Further, the purported added 'costs' are disproportionate, vague and in breach of the CRA 2015 Schedule 2 'terms that may be unfair'. This Claimant has arbitrarily added an extra 60% of the parking charge in a disingenuous double recovery attempt that has already been exposed and routinely disallowed by many Courts in England and Wales. It is atrocious that this has been allowed to continue unabated for so many years, considering the number of victims receiving this Claimant's exaggerated Letter before Claim, or the claim form, who then either pay an inflated amount or suffer a default judgment for a sum that could not otherwise be recovered. It is only those who defend, who draw individual cases to the attention of the courts one by one, but at last in 2019, some areas noticed the pattern and have moved to stop this abuse of process at source.

10.1. In the Caernarfon Court in Case number FTQZ4W28 (Vehicle Control Services Ltd v Davies) on 4th September 2019, District Judge Jones-Evans stated: ''Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates [...] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court in Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared [...] the claim is struck out and declared to be wholly without merit and an abuse of process.''

10.2. That decision in Wales was contested in a N244 application by VCS, but the added £60 was still disallowed on 30 Oct 2019. District Judge Jones-Evans stated that even in cases parking firms win, he never allows the £60 add on, and despite parking firms continuing to include it in their Particulars, most advocates have now stopped pushing for it at hearings. The Judge said that a contract formed by signage is a deemed contract, which the motorist does not have the opportunity to negotiate. That, and the fact that there is no specified sum on the signage, means that the extra £60 cannot possibly be recoverable. He said that the £60 was clearly a penalty, and an abuse of process. The considered sum in that case was reduced to £100 with a full case hearing to follow, but the £60 would not be awarded under any circumstances, and further, he ordered that the Claimant must now produce a statement of how they pleaded claims prior to Beavis, and subsequently.

10.3. In Claim numbers F0DP806M and F0DP201T - BRITANNIA PARKING -v- Mr C and another - less than two weeks later - the courts went further in a landmark judgment in November 2019 which followed several parking charge claims being struck out in the area overseen by His Honour Judge Iain Hamilton-Douglas Hughes QC, the Designated Civil Judge for Dorset, Hampshire, Isle of Wight & Wiltshire.

10.3.1. Cases summarily struck out in that circuit included BPA members using BW Legal's robo-claim model and IPC members using Gladstones' robo-claim model, and the Orders from that court were identical in striking out all such claims without a hearing during a prolonged period in 2019, with the Judge stating: ''It is ordered that The claim is struck out as an abuse of process. 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, Schedule 4 nor with reference to the judgment in the Beavis case. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

10.3.2. BW Legal made an application objecting to two 'test' cases that had been struck out by District Judge Taylor against a parking firm for trying to claim for £160 instead of £100 parking charge. This has been repeated conduct in recent years, on the back of the Beavis case, where parking firms have almost unanimously contrived to add £60, or more, on top of the 'parking charge'. Members of both ATAs who have influence on their self-serving 'Trade Bodies' have even voted to have this imaginary 'damages/debt collection' sum added to their respective two Codes of Practice, to create a veil of legitimacy, no doubt to allow their members to confuse consumers and to enable them to continue to 'get away with it' in several court areas which are still allowing this double recovery.

10.3.3. That N244 application to try to protect the cartel-like position of some of the 'bigger player' parking firms, was placed before the area Circuit Judge and a hearing was held on 11th November 2019, with other parking charge cases in that circuit remaining struck out or stayed, pending the outcome. The Defendants successfully argued on points including a citation of the CRA 2015 and the duty of the court to apply the 'test of fairness' to a consumer notice (a statutory duty that falls upon the courts, whether a consumer raises the issue or not). All three points below were robustly upheld by District Judge Grand, sitting at the Southampton Court, who agreed that:
(a) The Claimant knew or should have known, that £160 charge (howsoever argued or constructed) was in breach of POFA, due to paras 4(5) and 4(6).
(b) The Claimant knew or should have known, that £160 charge (howsoever argued or constructed) was unconscionable, due to the Beavis case paras 98, 193, 198 and 287.
(c) The Claimant knew or should have known, that £160 charge where the additional 'recovery' sum was in small print, hidden, or in the cases before him, not there at all, is void for uncertainty and in breach of the Consumer Rights Act 2015, Schedule 2 (the 'grey list' of terms that may be unfair) paragraphs 6, 10 and 14.

10.3.4. At the hearing, the Judge refused their request to appeal. It was successfully argued that the parking firm's consumer notice stood in breach of the CRA 2015, Schedule 2 (the 'grey list' of terms that may be unfair) paragraphs 6, 10 and 14. Using the statutory duty upon the Courts to consider the test of fairness and properly apply schedule 2 of the CRA 2015 it was irrelevant whether or not the consumers' defences had raised it before, which they had not. The same issues apply to this claim.

10.3.5. A transcript will be publicly available shortly. In his summing up, it was noted that District Judge Grand stated: ''When I come to consider whether the striking out of the whole claim is appropriate, that the inclusion of the £60 charge means that the whole claim is tainted by it, the claimant should well know that it is not entitled to the £60. The very fact that they bring a claim in these circumstances seems to me that it is an abuse of process of the court, and in saying that, I observe that with any claim that can be brought before the court that if a party doesn't put in a defence to the claim, default judgments are entered. So, the Claimant, in bringing the claims is, in other cases, aware that if the defendant doesn’t submit a defence, the Claimant is going to get a judgment of a knowingly inflated amount. So I conclude by saying that I dismiss the application to set aside Judge Taylor’s ruling.''

10.4. Consumer notices - such as car park signs - are not excused by the 'core exemption' as set out in the CRA 2015. The CMA Official Government Guidance says: ''2.43 In addition, terms defining the main subject matter and setting the price can only benefit from the main exemption from the fairness test ('the core exemption') if they are transparent (and prominent) – see part 3 of the guidance.'' and at 3.2 ''The Act includes an exemption from the fairness test in Part 2 for terms that deal with the main subject matter of the contract or the adequacy of the price, provided they are transparent and prominent. (This exemption does not extend to consumer notices but businesses are unlikely to wish to use wording that has no legal force to determine 'core' contractual issues).'' The parking industry is the exception to this rule because they have no consumer 'customers' yet are consumer-facing. Their intention is very clearly in many cases (including this case) for a consumer not to see the onerous terms hidden in their notices and it is averred that no regard is paid to consumer law.

10.5. The definition of a consumer notice is given at 1.19 and the test of fairness is expended at 1.20: ''A consumer notice is defined broadly in the Act as a notice that relates to rights or obligations between a trader and a consumer, or a notice which appears to exclude or restrict a trader’s liability to a consumer. It includes an announcement or other communication, whether or not in writing, as long as it is reasonable to assume that it is intended to be seen or heard by a consumer. Consumer notices are often used, for instance, in public places such as shops or car parks as well as online and in documentation that is otherwise contractual in nature. 1.20 Consumer notices are, therefore, subject to control for fairness under the Act even where it could be argued that they do not form part of the contract as a matter of law. Part 2 of the Act covers consumer notices as well as terms, ensuring that, in a broad sense any wording directed by traders to consumers which has an effect comparable to that of a potentially unfair contract term is open to challenge in the same way as such a term. There is no need for technical legal arguments about whether a contract exists and whether, if it does, the wording under consideration forms part of it.''

11. In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant's vexatious conduct from the outset has been intimidating, misleading, harassing and indeed untrue in terms of the added costs alleged and the statements made.

12. The Defendant is of the view that this Claimant knew or should have known that to claim in excess of £100 for a parking charge on private land is disallowed under the CPRs, the Beavis case, the POFA and the CRA 2015, and that relief from sanctions should be refused.

13. If this claim is not struck out for the same reasons as the Judges cited in the multiple Caernarfon and Southampton cases, then full costs will be sought by the Defendant at the hearing, such as are allowable pursuant to CPR 27.14.

All evidence referred to will be provided at least 14 days before any hearing date.

Statement of Truth:

I believe that the facts stated in this Defence are true.


Name

Signature


Date

Umkomaas

You are still using a, b, c ....... as your bullet point list. That should now be 1, 2, 3 ....... to match your expanded defence.

Your latest draft is 3,600 words long cf your prior draft of 1,360. In my view, it's far too unwieldy now.

Apart from making a short reference to the CRA and Abuse of Process points of defence, I'd hold all the detailed verbiage for your Witness Statement later in the process, should it get that far.

AB0013

Ahh That makes sense - thank you! Added the detailed verbiage based on a previous post advice.

Appreciate the advice

AB0013

Sorry please Can someone clarify as i'm sure it was strongly advised to use the long version for the defence!

"ABUSE OF PROCESS must be highlighted and as coupon-mad has already written a defence on this for you to use ....... please do so

ABUSE OF PROCESS .... POST # 14 by coupon-mad
https://forums.moneysavingexpert.com/discussion/6014081/abuse-of-process-district-judge-tells-bwlegal"

Also do I even need the bulleted defence at the top of the page (I've seen many without it)

I have until 4pm tomorrow but want it in today ideally!

Thanks a million guys/gals!!

beamerguy

Bullet points are important which distinguishes each point

As you are using using coupon-mad's text, I cannot see any way to reduce this. As more and more scammers get spanked, this will get longer.

Whilst I agree with Umkomaas about such a long defence, it is difficult to see how you can reduce it and get your point across at the same time

AB0013

Thanks a millionBeamerguy!!