PCN escalated to Court proceedings **EDIT - I WON**

Littlewadie

 Nosferatu1001 said this in a few posts above.
7) No, thats lifted from your defence. It is an argument, not a fact. Your WS is full of facts. Never arguments. Same for 8) . 
Number 8 was the part about the extra £60

Coupon-mad

I am going to re-write and add a few things to make your WS punchier.

You could, in addition to your (undated?) photos, attach this Google Street View pic of the lack of entrance and disabled bay signs (if this is the place in 2014?):

https://goo.gl/maps/yBrmWCQQTQzYywoy8

Make sure your photo evidence is dated if they are digital pics and you can access the Metadata to show that as a fact.

Remember that I said this is an exhibit too, in my earlier post a while back on page 2:

Also put this article in as an exhibit, and cite INDIRECT DISCRIMINATION*:
http://news.bbc.co.uk/1/hi/uk/8488737.stm
Now, that goes back to 2010 and pre-dates the Equality Act 2010 (the EA) but is VERY relevant and still correct today, and relates to ANY private car park, not just supermarkets, where there is a max stay time limit and an absence of any prominent info (usually nothing!) telling disabled people how to claim more time:
''BBC Breakfast contacted 200 large supermarkets from the four main chains.
Of the 124 that imposed parking time limits, about two-thirds said they did not give disabled people any extra time to shop, which is a breach of the law.  Neil Coyle, from the charity Disability Alliance, said: "Supermarkets need to acknowledge there is a problem, and secondly, very quickly they need to ensure their car parking procedures conform with the law.
"You or I can stamp our feet and say how outrageous it is but at the end of the day there is a law that protects disabled people from this happening." ''

And also attach as an exhibit, copies or scans of your current Blue Badge and your ESA letter.  You will see what I mean when you read the new WS draft.

You do not have to attach any pages from the POFA or from Beavis.

And I encourage you to write a Summary Costs Assessment to attach, to try to get your costs (time take on all this, and printing, even though you are on ESA so not working you can try for those costs because the claimant has reached the Dammerman test for unreasonableness):
http://www.portner.co.uk/news/unreasonable-behaviour-in-relation-to-costs-in-the-small-claims-track

So, how many hours have you spent, approx please, on these (please reply with hours next to each):
- appealing in 2014 and re-sending it
- reading any pre-action letters in the years between and any other responses you made to them
- reading the Letter before Claim and responding, in 2019, if you did?
- reading the Claim form & documents and researching what to do and putting in a defence
- Mediation call
- writing this WS and putting together and printing all the evidence
- printing & postage of the appeal in 2014 (twice) and any other letters you printed before court
- printing and posting of everything you did from court claim onwards
- costs to get to court in March (travel and parking)
- costs of your husband accompanying you as your carer (if that's your plan) - i.e. let's try for HIS loss of a day's work

Coupon-mad

IN THE COUNTY COURT AT DARLINGTON

CLAIM No: xxxxxxxxxx

BETWEEN:

Premier Park Limited (Claimant)

-and-

xxxxxxxxxxxx (Defendant)

________________________________________

Witness statement 
________________________________________

1. I am XXXXX XXXXXXXX  of  XX XXXXX XXXXX, XXXXXXX, the Defendant in this matter. I will say as follows:

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

3. The Claimant is aware that I was a genuine patron of the retail park, correctly parked in a disabled bay and has been told in appeals and in my defence about my illness, which was the direct cause of any 'overstay'.  My medical conditions have affected my daily life for many years and at the time of this witness statement and hearing, I am awaiting the second part of my surgery, am unable to work and I am in receipt of Employment and Support Allowance.  The Claimant has never asked me for further details and failed to respond (at all) to my appeals in 2014, but for the avoidance of doubt, my current Blue Badge and my ESA letter are both appended in my evidence file (MW1) and (MW2).

3.  It is my position that the conduct of the Claimant is specifically unlawful and far more serious than just a hopeless claim.  The Court's attention is drawn to this and the Claimant's other conduct, including but not limited to:
(i) multiple breaches of their Trade Body (the British Parking Association) Code of Practice ('the BPA CoP');
(ii) failing to respond to two 2015 appeals in which I informed them of the medical reason for any 'overstay';
(iii) failing to provide adequate notice of the parking charge, with no contractual signs at the Blue Badge bays;
(iv) delaying litigation for 5 years - with a dormant 4 year period - yet claiming an unconscionable £34.42 interest;
(v) breaches of the UTCCRs as applied at the time, distinguishing this case from ParkingEye Ltd v Beavis;
(vi) obtaining my data from the DVLA without 'reasonable cause' due to failure to identify & exempt disabled drivers;
(vii) breaches of the Data Protection Act 1998, where the Claimants were/are data controllers acting unlawfully;
(viii) breaches of the Equality Act 2010 in terms of 'indirect discrimination', disadvantaging a person (myself) with protected characteristics and causing me anxiety, hurt feelings and distress which has impacted on my family life.  This conduct is illegal immediately, from the point of the event onwards (even before the claimant knew about my medical condition).  Even allowing for a dormant period of silence, the Claimant's course of conduct spanning five years has included hostile and intimidating correspondence and this hearing comes at the end of a series of highly alarming, unwanted and specifically unlawful contact.  Pursuing me with unwarranted debt demands, given that I am a disabled driver who appealed and did everything right - and that my time spent in the parking bay falls squarely within my rights - constitutes ongoing unlawful harassment arising from an issue caused by symptoms of my disability.


4.  Further, the Particulars of Claim are incoherent and provided insufficient detail for me to be able to ascertain the nature of the case as pleaded, hence my fairly short, factual defence in response.  Although the cause of action appears to be breach of contract, the Claimant has: 
(i) failed to serve a Letter before Claim with a copy of the sign (the contract) as per the Protocol for Debt claims;
(ii) failed in their Particulars, to provide sufficient detail regarding in what manner the alleged contract was breached;
(iii) failed to state in what capacity the Claimant (a non-landowner) is entitled to recover any part of the sum;
(iv) included a false 'contractual charge' sum of £60, which the Claimants and their legal advisors (both) already know - from recent parking charge claims that have been struck out and which they failed to appeal - is an abuse of process;

Unreasonable behaviour and risk of discontinuance - my Summary Costs Assessment is attached
5.  For the reasons set out in 3 and 4 above, and given the facts in my defence and witness statement below, it is my position that the test has been met in Dammerman v Lanyon Bowdler LLP [2017] EXCA Civ 269 (12 April 2017), the Court of Appeal authority and guidance on how the courts should approach applications for costs under CPR 27.14 (2)(g).   The CoA in Dammerman concluded that the meaning of "unreasonable" cannot be different when applied to litigants-in-person in small claims cases.  The test is whether the conduct "permits of a reasonable explanation" which cannot be the case here.

6. In view of the facts of this case, the Claimant’s cavalier attitude and their failure to properly consider their legal position thus far, I believe there is a likelihood that they will now issue a Notice of Discontinuance ('NoD').  However, this means that I must raise the matter of my costs, as fairly assessed to the best of my ability at this stage (see my Summary Costs Assessment appended to this statement, which does not exceed the CPR ceiling of two thirds of the costs that may have applied if I had had the benefit of legal representation).   

7.  I respectfully ask that the Judge grants my costs anyway, in the event of a NoD, and uses the court's discretion to dispense with any formal application in this case because I qualify for help with fees (exemption) on income grounds and I have surely been put through more than enough by this litigation, and because the court has a wide discretion on the issue of costs where a party has crossed the line into "unreasonable behaviour" in pre and/or post-action conduct in the small claims track. 

8.  Litigation is not risk-free for a parking firm pursuing a person without justification (unlawfully in this case), and this Claimant must take his victim as he finds me.   The thin skull or 'egg-shell' rule is a well-established principle in both English law takes into account the physical, social and economic attributes of the other party, which might make them more susceptible to injury or distress, whether physical or mental injury is the result.  The principle requires the Claimant in this case to compensate me to the full extent of my distress and injury to feelings even though they may be more serious than expected because of my pre-existing conditions, predispositions, and vulnerabilities, and in this respect I ask that the Judge gives due consideration to a suitable percentage 'uplift' being applied to my Summary Costs Assessment, as the Judge sees fit, to send a message to this parking firm that they cannot breach consumer and disability laws.  This Claimant has indisputably caused serious distress to me, affecting my peace of mind and upsetting my husband and family for five years, finally dragging me to court, and (I fear, in some ways more than I dread the hearing) will now issue a NoD at this late stage and expect to walk away.

Background - the facts and unlawful conduct
9.  The facts are that the vehicle was parked by me on the 20th December 2014 in a marked Disabled bay with a valid Blue Badge in a space in the Halfords/former MFI stores car park in Russell Street, Darlington, which to my knowledge, used to be free and have no restrictions.   I did not know it had apparently changed to a restricted stay car park and subsequently I have discovered that the Claimant had introduced a 'maximum stay 2 hours' policy, yet there was no entrance sign alerting drivers to this, and no signs at the disabled bays that we could see, when in or out of the car (see Google Street View image from 2014 - MW3).

10.   In section 12 of the BPA CoP, it states that grace periods should be given when arriving and leaving the car park.  This was Christmas time and the shop was incredibly busy and had limited disabled parking spaces available, so we did not immediately get parked.  I recall (due to the subsequent nasty surprise of the PCN in the post, this event has played on my mind) that we had to wait for someone to load their car and leave the space we were waiting for.  This added to our time within the car park where we had not even got out of the vehicle, let alone had a chance to find any signs.  In fact, we saw none because this had been an unrestricted car park before, and nothing alerted us to any change in terms.  This is a further breach of the 2014 BPA CoP at 18.11 (exhibit MW6) ''Where there is any change in the terms and conditions that materially affects the motorist then you should make these clear on your signage. Where such changes impose liability where none previously existed then you should consider a grace period to allow regular visitors to the site to adjust and familiarise themselves with the changes.''

11.   Further, I would also like to state that the signs did not comply with the BPA CoP, with regards to letter sizing (see exhibit MW4 from BPA CoP applicable in late 2014 - Appendix B 'Mandatory Entrance Signs' and MW5, a photo taken with a tape measure for comparison) as the road it is entered from has a 30 mph speed limit.  The font size should be a minimum of 60mm.  The photograph shows that the font size on the sign is 25mm.  Therefore, the signage has failed to meet the 'mandatory' requirements of the British Parking Association - basic stuff for an AOS member that 'permits of no reasonable explanation'.  I fail to see why it is for me, as a disabled shopper back at Christmas 2014 - to be put to such trouble five years later and hope the Court agrees.

12.  Where they existed, the few signs were sparsely placed and unremarkable in a retail park, and not able to be viewed by a disabled person, a requirement as set out in the BPA CoP, see section 18.10 (exhibit MW6).  It also states that they must be 'conspicuous' in section 18.3, please see original photos (exhibits MW xx, xx and xx) taken on January 2015 from various angles of the car park, where signs can not be clearly seen and none are around the disabled parking bays and none are lower to the ground to be read easily. (See also exhibit MW8 for the Aerial view of the car park with regards to sign positioning).  Also the positioning of the camera was off to the left side away from the entrance which is shown on original photos from 2015 ( see Exhibit MWxx ), I also attach a recent photo of relocated camera and extra signage placed next to the door at the entrance to Halfords Taken September 2019 ( see exhibit MWx) 

13.  In section 16.5 of the BPA Code of Practice ('CoP') 2014 (from the material time) it states that if the land owner provides a concession that allows parking for disabled people, ''if a vehicle displays a valid blue badge, you MUST NOT (my emphasis) issue it with parking charge notices''.  (See exhibit MWx).  


14.  So this Claimant obtained my DVLA data against the strict rules of their own Trade Body and also acted against the DVLA 'KADOE' rules and Data Protection Act 1998, in that it had no 'reasonable cause' and should never have obtained my data in the first place, and this too 'permits of no reasonable explanation'. 

15.  By processing my personal data that it was never entitled to have, to demand monies it was never entitled to seek, for an unconscionable five years after receiving and ignoring my appeals, the Claimant stands in breach of their statutory duty under the Data Protection Act 1998 ('the 1998 Act') now repealed, and the Data Protection Act 2018.  The Claimants were thereby under a statutory duty to process my data only in strict accordance with a) the Data Protection Principles as set out in the 1998 Act Schedule 1, in particular Data Protection Principles 1, 2 and 5; and b) the GDPR Articles 5 (1)(a) and (b) and 6 (1)(f)).   


16.  Under the 1998 Act, Schedule 1, which was in force at the time that my data was illegally harvested from the DVLA, the data protection Principles provide that:- ''Principle 1: personal data shall be processed fairly and lawfully; 
Principle 2: personal data shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or purposes;
Principle 5: personal data processed for any purpose shall not be kept for longer than is necessary for that purpose...'' 
The Claimants’ use of the Defendant’s data breaches all three of those quoted principles and this again, 'permits of no reasonable explanation'. 


17.   The Claimants’ use of my personal data over five years was an abuse, and their storage and continued processing of it was unlawful and unfair.  


18.  A course of conduct of unreasonableness is already established before I even come onto the UTCCRs (now encompassed into the Consumer Rights Act 2015 - 'the CRA') regarding the duplicitous and false 'costs', and the Equality Act 2010 breaches in my case.

Coupon-mad

The Equality Act 2010 ('the EA') and the EHRC Statutory EA CoP for Service Providers are breached
19.   My rights under the Equality Act 2010 are in addition to, and stronger than rights under article 8 ECHR and I state that there has been discrimination under s15, s19 and s21 of the EA which permits of no reasonable explanation.  


20.  The unclear signs at this site put me at a disadvantage compared to an able-bodied person.  Reasonable adjustments would have been to place signs in larger font at a lower height, at the entrance and at the Blue Badge bays, and a notice on the approach on foot into the retail stores, to ensure that people saw the change of terms and had a fair opportunity to learn about the onerous parking charge. 


21.  The 2 hour inflexible time limit put me at a disadvantage compared to an able-bodied person.   Reasonable adjustments would have been either to enforce the disabled bays separately, with an employee/warden on foot to note and exempt vehicles and to check for valid Blue Badges (which ANPR does not), or to place clear advice and instructions on prominent signage, to tell disabled people at the Blue Badge Bays how to claim more time in store (such as giving their VRM to the Customer Service desk inside a store, to join an exempt - even if that means the staff - 'white list' as is done at many locations these days).


22.  It is no lawful excuse or justification for the Claimant to say, for example, that they operate ANPR for economic reasons and offer the same terms to all shoppers.  By doing so, they have made it impossible for themselves to fairly (or at all) distinguish between disabled Blue Badge holders and other drivers.  They have by this conduct, illegally ignored their statutory duty to make 'reasonable adjustments' of policies in anticipation of the needs of the disabled population 'at large'.  As well as removing physical barriers, this duty includes factoring in flexibility to a 'fixed' time limit, knowing that these timings are likely to cause difficulty and detriment to disabled visitors.  Those using the Blue Badge bays on a daily basis are almost certain to include people with mobility impairments which cause them to need more time physically to manage shopping in a large retail park, and to make purchasing decisions.  Whilst 2 hours might be considered enough for an able bodied visitor to nip round the shops and leave, this is not necessarily the case for disabled people and the Claimant knows that it was not enough for me, on the material date.

23.  A service provider (and the Claimant meets that definition as set out in the EHRC's Equality Act 'Services, public functions and associations' Statutory EA CoP) would only be considered to have taken 'all reasonable steps' to avoid discrimination, says the CoP ''if there were no further steps that they could have been expected to take''.   This is not true at all in this case and the EA CoP goes on: ''Although reasonable business needs and economic efficiency may be legitimate aims, a service provider solely aiming to reduce costs...cannot simply argue that to discriminate is cheaper than not to discriminate''. 


24. The Statutory EA CoP at Chapter 5: 'Indirect Discrimination' makes it clear that this offence cannot be justified by saying that a trader offering services (such as a parking firm) did not know that an individual was disabled at the time of the event.  This is because the duty to make 'reasonable adjustments' begins as an anticipatory duty to the population at large:  ''indirect discrimination may occur when a service provider applies an apparently neutral provision, criterion or practice which puts persons sharing a protected characteristic at a particular disadvantage''.   

25.  A BBC article quoting the charity 'Disability Alliance' supports the argument, that to restrict disabled people to the same time limit as able bodied shoppers is unlawful at retail parks.  (MW xx) ''BBC Breakfast contacted 200 large supermarkets from the four main chains. Of the 124 that imposed parking time limits, about two-thirds said they did not give disabled people any extra time to shop, which is a breach of the law.  Neil Coyle, from the charity Disability Alliance, said: "Supermarkets need to acknowledge there is a problem, and secondly, very quickly they need to ensure their car parking procedures conform with the law. "You or I can stamp our feet and say how outrageous it is but at the end of the day there is a law that protects disabled people from this happening.''

26.  I believe this was an act of 'indirect discrimination' (see Exhibit MWx from the EA CoP, section 5.39 - the example regarding a time limit ''A stately home has guided tours of grounds which depart at 30 minute intervals''), as the Claimant failed to offer any time adjustment to disabled users and have no information on how to appeal on this basis (breach of s19 of the EA).  Further, their camera system simply ignored the fact that I was using a disabled badge in a disabled parking space.   Even worse, by my appeals the Claimant was made aware that I was in a disabled parking space (thus a detriment under s15 was proven) and yet they still wish to pursue the matter via litigation.   Ignorance of the law is never an excuse; this entire course of conduct has demonstrated the worst of this industry and the Claimant is guilty of an abject failure to consider the needs of disabled people and an offence under the EA, which permits of no reasonable explanation. 

  

Landowner authority - either absent or inapplicable
27.  I have seen nothing that tells me that this Claimant had the written consent of the landowner at the material time and even if they did, it would undoubtedly have required them to comply with all applicable laws and the BPA CoP, and they have failed.  It is more than likely that a responsible landowner would set out exemptions for Blue Badge holders using those bays - just as the BPA CoP did - and it is not accepted that the Claimant has met the requirements of the BPA CoP part 7 'written authority of the landowner' nor that they had/have any standing to litigate in my case.  


Breach of the UTCCRs (now part of the CRA 2015) and false added costs - an abuse of process
28.  The UTCCRs were repealed by the Consumer Rights Act 2015 ('the CRA') with effect from 1 October 2015. The CRA applies to terms in contracts entered into from that date (with the UTCCRs continuing to apply to terms in consumer contracts entered into before then - e.g. this one).   Whilst in ParkingEye Ltd v Beavis [2015] UKSC67, it was held that the £85 charge in that case - involving a non-disabled driver and very prominent signage - did not breach the UTCCRs due to the facts unique to that Chelmsford location, the relevant regulations and test of fairness must still be considered in every case.


29.  Whilst the fairness of the charge was not raised in my defence, this is not an issue because s71(2) of the CRA provides for a duty upon the court to consider the fairness of all consumer terms (e.g. the policy to impose an inflexible time limit and then fail to identify disabled service users or provide instructions or a mechanism to exempt them) and the fairness of consumer notices (i.e. the sparse car park signs with tiny font), whether a consumer raises the issue, or not at all.  The CRA is in similar terms to the UTCCRs, with the same fairness test and a ‘grey list’ (repeated in Schedule 2, Part 1 of the new Act) and the added £60 is a disingenuous attempt at double recovery and certainly disallowed by the applicable consumer legislation (now and in 2014) with reference to paras 6, 10, 14 and 18 of the grey list of terms that are likely to be unfair.
.   

30.  It is my position that there can be no excuse for a Claimant parking firm filing a claim where £60 has been added, because the costs are already in the parking charge [REF- paras 98, 193 and 198 of ParkingEye v Beavis and previously, ref para 419 of ParkingEye v Somerfield at the High Court, a decision upheld by the Court of Appeal].   

30.1.  Judgments went against the industry when parking firms applied to set aside a series of parking claims that were summarily struck out for abuse of process; specifically, the parking firm Claimants adding an unrecoverable (double recovery of costs) sum of £60 to a parking charge - as in my case:
(i) MWxx - Premier Park claim struck out by Warwick County Court - same Claimant as this case (no appeal).
(ii) MWxx - multiple parking charge cases struck out by Southampton County Court.  This exhibit shows the Approved Judgment and reasoning of District Judge Grand, and whilst the Smark-Julien case (where the Defendant offered no facts) was appealed and re-set for a hearing later in 2020, the appeal judgmnt made no finding regarding the double recovery of costs and tellingly, the Crosby case where this was fully argued at the hearing for the application and the known facts were sufficient to strike out the claim (including a picture of the sign - the contract - added by the Claimant) was not appealed.  


31. Further, at Skipton County court on 27.2.2020 - an area where Judges are also summarily striking out every parking charge case where £60 has been falsely added - Excel Parking Services failed to overturn six strike-out orders, in a mirror image application hearing just like the one lost in Southampton.  They were refused leave to appeal, the application to set aside was dismissed and the Claimant was found to have behaved unreasonably . Costs of £331.10 were awarded to a lead Defendant in claim no F3QZ38JK (one of the six) because the District Judge Fay Wright held that the Dammerman test was met by the conduct of the parking firm.  

31.1. The private parking industry continues to demonstrate significant irregularities in their affairs and AOS member parking firms invariably trade in a way that fails to show integrity or a social conscience and disregards consumer law and the public interest, and the Court and my MP will be encouraged to report the conduct of this particular Claimant in my case, to the Secretary of State.

My costs and the Vento Guidelines - to be Summarily Assessed even in the event of a Discontinuance
32.  I request the Court to dismiss this claim in its entirety, and to award my fully assessed costs - not just for the attendance at the hearing - such as are allowable pursuant to CPR 27.14.  As stated above, I ask that my Summary Costs Assessment (attached) be granted and that a discretionary percentage or other sum is added, as the Judge sees fit for compensation for injury to feelings in my case, considering my physical and economic vulnerability as explained above and applying the doctrine that the Claimant takes their victim as they find me, as set out in paragraph 8 above.   

33.  The Vento guidelines stem from a landmark case from 2003 (Vento v Chief Constable of West Yorkshire Police) where the Court of Appeal set out clear guidelines for Courts and Tribunals to apply when they are assessing injury to feelings awards.  The Vento case decided that there are 3 ‘bands’ for compensation for injury to feelings:

• the lowest band – £900 to £8,800 for the least serious cases, e.g. where the discriminatory act is a one-off
• the middle band – £8,800 to £26,300, serious but where an award in the highest band would not be appropriate
• the highest band – £26,300 to £44,000; these are the most serious cases, e.g. a lengthy campaign of discriminatory harassment which has a profound effect on the victim.

STATEMENT OF TRUTH

Coupon-mad

(i) MWxx - Premier Park claim struck out by Warwick County Court - same Claimant as this case (no appeal).
https://onedrive.live.com/?authkey=%21AFoeBfyPOMwyD5c&cid=B05FB7882979432B&id=B05FB7882979432B%213964&parId=B05FB7882979432B%213392&o=OneUp

(ii) MWxx - multiple parking charge cases struck out by Southampton County Court
(see below link)

You will need to change all your evidence numbers as I added stuff like your Blue Badge and ESA letter and a GSV link to the entrance in 2014, and the BBC Article, as well as the above two!

You will need to write your hours spent on all this, and printing and post costs in your Summary Costs Assessment as per my earlier post above - you must sign & date that costs document, too.

Umkomaas

Ouch!!  A real stinger for PP to sweat over. Nice one CM. 

nosferatu1001

Love it!

Littlewadie

Wow, not sure what to say to that, speechless absolutely speechless.
let me work on costs, I have worked out costs for now but never thought about from the beginning.
I will be back later once I have looked at it.
Many thanks you legend Coupon-mad 

Littlewadie

Oh and forgot to say, yes that is the entrance back in 2014, I have a picture of it but it isn't as Clear as that one.
I also have a copy of a polar decision from another user from when he parked in the car park in 2014 and popla ruled it did  not comply with the BPA code of practice on font size, the decision was from 2016.

Littlewadie

Coupon-mad - how does this look?
So, how many hours have you spent, approx please, on these (please reply with hours next to each):
- appealing in 2014 and re-sending it **- trip to car park to take photos & return journey 5.6miles aprox 1hr.
then loading them onto my computer & writing a letter aprox 2hrs
Trip back to town to print photos as I had no printer at the time 5.8 miles & 8 photo's @ 35p each aprox 1 hr

- reading any pre-action letters in the years between and any other responses you made to them ** - maybe 10 min for each letter but then re reading many times.

- reading the Letter before Claim and responding, in 2019, if you did? **- never got one, I only received texts from bw legal which just said they needed to speak with me regarding a personal business matter they have wrote to me about, I blocked them after the first 2 messages as I thought it was a scam as I didn't know who they were. I also do not know how they got my number as it was not given out and it is a different number from when I got my PCN and even then I never gave Premier Park this info on my appeal.

- reading the Claim form & documents and researching what to do and putting in a defence **- Aprox 2 hrs reading a researching what it meant as I got the court letter before a letter came from BW legal saying they were taking me to court, then a trip to town to citizens advice 5.8 miles return journey & 3 hours waiting to see someone and discussing what to do next. then 3 hrs writing a defence.

- Mediation call **- what a joke spent 1 hour back and forth and they said my appeal letter was not valid because it was sent after the 14 days cut off point, when I argued that it says I have 28 days from receiving the letter to appeal they said they would have to get back to me as they need to contact Premier Park to see why it was not valid if that was the case, after 2 hours they said they never even got it!

- writing this WS and putting together and printing all the evidence **- tricky to determine this I spent a while looking up where to get help and found you lot here, then I spent about a week reading through what I could and starting a thread as I couldn't find one exactly like mine, then a few more weeks downloading and reading all the links from the newbies thread and trying to put it into my own, It could of been an hour here or there to a good 5 hours straight so I don't know an exact amount of time, what would be reasonable? I will be travelling to the court to hand everything in so another 6.6miles & 1 hour journey & 3 copies of everything.

- printing & postage of the appeal in 2014 (twice) and any other letters you printed before court **- writing  & postage cost for appeal £1 ish and same for second letter £1 ish can not remember what postage costs were back then.

- printing and posting of everything you did from court claim onwards **- sent my defence recorded £1.90 & sent my Form N180 recorded £1.90

- costs to get to court in March (travel and parking) **- 6.6 mile return journey all day parking £4.00

- costs of your husband accompanying you as your carer (if that's your plan) - i.e. let's try for HIS loss of a day's work **- tricky again, he is self employed and charges £200 per day as he works with his brother and if one doesn't work they both can not work as manual heavy lifting can be involved and needs 2 people at times. but year he is my witness as well as a carer.

I did read others and have started a cost sheet and understand I can charge for being a litigant in person? @£19 per hour? if so on hours alone that would be astounding.
Hope you understand this coupon-mad
Many Thanks