Advice re blue badge owner

[Deleted User]

IN THE COUNTY COURT AT PLYMOUTH

 

CLAIM No: xxxxxxxxx

BETWEEN 

 

PREMIER PARKING SOLUTIONS LIMITED
 -and
MR xxxxxxxxxx
 __________
WITNESS STATEMENT OF THE DEFENDANT AND PART 20 CLAIMANT
 __________

1. I, xxxxxxxx of xxxxxxxx am the Defendant and Counterclaimant in this matter will say as follows in support of my defence and counterclaim, both of which are repeated.

2. The facts and matters referred to in my witness statement are within my own knowledge, except where I have stated otherwise. Where the facts are within my knowledge, they are true. Where they are not within my own knowledge, they are true to the best of the information, resources, and belief to be correct.

3. Whilst parts of this Witness Statement may be familiar to the Claimant, as a litigant-in-person it would not be right to be criticised for using all relevant resources and advice that have been available to me and unlike the Claimant’s case; it deals properly and individually with the facts, the non-existent breach of contract, and the quantum.

4. Exhibited to this witness statement are the following attached documents which I will rely on to support the facts and arguments contained in this statement:

a) All correspondences received and made to Premier Parking Solutions Limited including photographic evidence and data entries obtained byway from a Subject Access Request made.

b) All correspondences to and from BW Legal.

5.   I have the medical conditions ME/CFS in addition to Chronic Migraine (exhibit xx-000) and subsequently suffer cognitive and mobility problems. As a result of this I have characteristics that are protected under the Equality Act 2010 and have significant disability. I have been issued with a blue badge permit for disabled persons, and have been awarded a badge since 2019 to the present day. I am no longer able to work and unfortunately now rely on state benefits, which include Personal Independence Payment (PIP) and Employment and Support Allowance (ESA)

6. To summarise this case before going into full details, starting on around a few days after the Claimant issued a Parking Charge Notice back in November 2019. They continued with numerous attempts seeking payments which I was never liable for and further enlisted a legal representative with increasing demands and similar threats, demand after demand and threatening letter after threatening letter were sent. Despite communications submitted in writing to the claimant, including a copy of my ‘Blue Badge’, (exhibit xx-01) constituting proof of my protected characteristics under the Equality Act 2010, the demands still continued. Nothing I ever did would stop it and the threats have continued for over two years. The threats were threefold in nature: those to start legal proceedings against me could cause considerable anxiety, distress and harm having bailiffs turn up at my door to remove goods and having a CCJ being recorded at the credit reference agencies for 6 years.

7. My counterclaim is that Premier Parking Solutions Limited’s course of conduct amounts to unlawful harassment pursuant under the Protection from Harassment Act 1997, breach of the Equality Act 2010 and data protection breaches, pursuant under the respective Data Protection Act 1998 and 2018 for unlawfully obtaining, processing and passing on my data. I am seeking remedy for £1,250 for distress, anxiety and alarm caused by the actions of the Claimant pursuant to the above respective acts. Vento v Chief Constable of West Yorkshire Police [2003] IRLR 102 awards amounts of between £990 - £9,900 in damages in its lowest band for discrimination under the Equality Act 2010. This appropriate for less serious cases, such as where the act of discrimination is an isolated or one off occurrence.

8. I am a victim of appalling abuse of process and vexatious use of the court system in a blatant attempt by the claimant to bully and enrich themselves without any lawful entitlement whatsoever. It is submitted that the principal object of my counterclaim is to bring Premier Parking Solutions Limited to book. They have spectacularly failed in their duty of care to ensure that the simplest of checks were made in the first instance and this could and should have been avoided. How a seasoned professional parking company got this wrong is beyond me. They should instead start taking responsibility for the running of their company in a competent, honest and ethical manner.

Sequence of events and signage

9. It was a Friday night on 22nd November 2019 and I was driving my daughter to a “taster” karate lesson at Ivybridge Methodist Church. I stopped outside in order to let my daughter in for her lesson.

10. I then drove to Keaton Rd car park, a car park that was not known to me and had never been visited prior, to wait for my daughter’s lesson to finish.

11. At the point of entry, the entrance terms and conditions sign is not visible or readable (Exhibit xx-02). It was dark and the signage was unlit.

12. After finding a place to park, I noted there was no visible signage readable from the driving position (Exhibit xx-04). I then walked to the payment machine but was unable to read the sign as it was unlit and the terms appeared complex and the combination of the small font and lack of illumination rendered them illegible. After some time, I was able to determine the amount payable and deposited 70p for an hour’s parking and returned to my car. My medical condition ME/CFS causes cognitive dysfunction including reduced attention span, brain fog/cognitive fog, cognitive overload, concentration problems and would have contributed to the time taken to attempt to process the information above.

13. After my daughter’s karate session had finished I crossed the road from the car park to collect her and returned to the car and drove us home.

14.. At the end of November 2019 I received a Parking Charge Notice (PCN) from Premier Parking Solutions for an expired session at Keaton Road, Ivybridge, PL21 9DH

15. The PCN contained two digital images of the car (front and back), however on them there were no landmarks nor street furniture identifying its location.

16. I decided to appeal the parking charge as there was insufficient signage and that the insufficient signage was not visible , in contravention of the International Parking Community (IPC) Approved Operator Scheme (AoS) version 7 2019 schedule 5 under which the claimant was a member at the time. I also wanted to alert the Claimant to my status as a disabled driver, with protected characteristics under the Equality Act 2010 so they would be able to cancel the PCN based on their duty to provide a reasonable adjustment of time.

17. It is therefore denied that the claimant’s signage is capable of creating a legally binding contract. 

18. The alleged overstay was 16 minutes but this would have been time spent in moving traffic, arriving, manoeuvring to a parking space, parking and locking the car. At the end of our visit a reasonable period of grace to leave is expected. This is not a ‘period of parking’ (under the POFA definition) that was in anyway exceeded.

19. Even if the Claimant can demonstrate that the car was indeed ‘on site’ and in the car park for a proven and synchronised 16 minutes in addition to the 20 minutes of free parking, this would have been entirely within the “sufficient” consideration period of 10 minutes prior to entering a contract to and a 10 minute grace period at the end of a parking event, set out in paragraph 13 of the IPC Code of Practice (IPC CoP) relevant version 2018. (Exhibit xx-00).

20. I have requested a response and evidence from the Claimant via BW Legal to show whether their pay and display machine clock is synchronised each day (or at all) with their ANPR camera clock. I repeated this request after they declined to provide evidence to support their claims. The claimant’s ANPR does not record parking time, only time on site. The IPC CoP v7, in use since November 2019 section 13, (exhibit xx-02), section 13.1 states that motorists should be allowed a “sufficient” consideration period to read the terms and conditions before payment. I doubt it only took a mere 4 minutes their two clocks allow to drive in, park, get out, lock the car, walk slowly to the signs and machine, read the ambiguous terms, check my watch and decide to pay for one hour at the correct 'before 6pm' rate, and then go through the steps and buttons to press to pay, including inputting the VRM. I am a disabled person with protected characteristics under the Equality Act (2010), entitled to a reasonable adjustment of time.

[Deleted User]

21. Under the Equality Act (2010) it is against the law to discriminate against someone because of disability, known as protected characteristics. Exhibit xx-00 lists my medical conditions. The claimant has been aware of my disabled status since they received my appeal on 17/12/2019 to which I enclosed a copy of my Blue Badge (exhibit xx-01). The claimant even continued to deny my disabled status in their reply to my counterclaim. I then provided the claimant with ample evidence (exhibit xx-00) of my disabled status, yet they still have made no attempt at any stage to fulfil their obligation under the Act to make a reasonable adjustment of time. Consequently the claimant has failed in their duty under the Act, and their behaviour since 17/12/2019 constitutes direct discrimination.

22. It was noted at a later date that the claimant’s ticket machine printed an expiry time of 6pm (exhibit xx-00), giving just five minutes parking instead of the advertised hour.  By any reasonable interpretation, this is a misleading action under the CPUTRS. The Claimant offers a tariff that applies to cars that park before 6pm and a different tariff that applies to drivers who park after 6pm, and uses that against consumers, to entrap and unfairly penalise drivers who pay correctly. They have used that as a 'concealed pitfall or trap' (a phrase from the Supreme Court in ParkingEye v Beavis about a parking charge situation of poor practice that would not have been enforceable) to generate wholly improper parking charge notices.

23. A key factor in the leading authority from the Supreme Court, was that ParkingEye were found to have operated in line with the relevant parking operator’s code of practice and that there were signs that were clear and obvious and 'bound to be seen'. I have included a copy of this sign in exhibit xx-09 for comparison.  In this case, the signage fails to adhere to the standards laid out by The International Parking Community (IPC).  The IPC Code of Practice says “The size of the text on the sign must be appropriate for the location of the sign and should be clearly readable by a Motorist having regard to the likely position of the Motorist in relation to the sign. ” It also states that “If parking enforcement takes place outside of daylight hours you should ensure that signs are illuminated or there is sufficient other lighting.”

ParkingEye v Beavis is distinguished

24. Unlike in this case, ParkingEye demonstrated a commercial justification for their £85 PCN and overcame the possibility of it being dismissed as punitive.  However, their Lordships were clear that ‘the penalty rule is plainly engaged’ in these cases.  Their decision mentioned a 'unique' set of facts including the legitimate interest, site location and prominent, clear signs with the parking charge in the largest/boldest text.  The unintended consequence is that, rather than persuading Judges that these charges are automatically justified, the Beavis case facts (and in particular, the brief and conspicuous yellow/black warning signs) set a high bar that this Claimant has failed to reach. (Exhibit xx-10)

25. Without the Beavis case to support the claim and no alternative calculation of loss/damage, this claim must fail.  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. 

26. The Supreme Court held that the intention cannot be to punish a motorist - nor to present them with concealed pitfalls, traps, hidden terms or unfair/unexpected obligations - and nor can a firm claim an unconscionable sum. In the present case, the Claimant has fallen foul of those tests.

(Exhibit xx-11 for paragraphs of ParkingEye v Beavis)

POFA and CRA breaches

27. Pursuant to Schedule 4 paragraph 4(5) of the Protection of Freedoms Act 2012 ('the POFA') the sum claimed exceeds the maximum potentially recoverable from a registered keeper, even in cases where a firm may have complied with the other requirements (e.g. adequate signage, correct wording and dates of Notice to Keeper, and the existence of a relevant contract/relevant obligation that was properly communicated). 

28. Claiming unexpected ‘costs/damages’ on an indemnity basis is stated to be unfair in the Unfair Contract Terms Guidance (CMA37, para 5.14.3), the official Government guidance on the Consumer Rights Act 2015 ('CRA').  The CRA goes further than the UTCCRs, introducing a requirement for 'prominence' of both contract terms and 'consumer notices' (i.e. signage and any other notices/communications, including the timely service of any PCN in parking cases).

29. Section 71 provides for the duty of court to consider the test of fairness. This includes whether all terms and notices were unambiguously and conspicuously brought to the attention of the consumer.  In the case of letters/the PCN, this means such communications must have been served.   In the case of signage, this must be prominent, plentiful, well placed and lit, and the terms clear and unambiguous.  The Defendant avers that the CRA has been breached due to unfair/unclear terms and notices, pursuant to s62 and having regard to the requirements for transparency and good faith and as guidance, examples 6, 10, 14 & 18 of Schedule2. 

Lack of landowner authority evidence and lack of ADR

30. DVLA registered keeper data is only supplied to pursue parking charges issued on private land, where there is an independently signed landowner agreement (this is part of the KADOE rules for AOS BPA or IPC members).  It is not accepted that the Claimant has adhered to the landholder's definitions, exemptions, grace period, etc. and there has been no evidence that the freeholder authorises this Claimant to issue PCNs at the place where the vehicle was and/or for the reasons given.  Nor is it known what the land enforcement boundary and start/expiry dates are or were.  The Claimant is put to strict proof of same and that they have standing to enforce charges by means of civil litigation in their own name.

31. The Defendant further avers that the Claimant failed to offer a genuinely independent Alternative Dispute Resolution (ADR).  Both the rival parking Trade Bodies provided 'appeals services' which reportedly fail to consider facts and rules of law properly, and find in favour of parking firms most of the time: e.g. despite purporting to be decided by legally qualified Adjudicators, the IPC's version upheld appeals in just 4% of decided cases, as reported in their 2020 Annual Report.  Both POPLA and the IAS will be replaced by the DLUHC's new Appeals Service as soon as possible and looking at the Appeals Annex in the new Code, disputed cases such as this would very likely have been cancelled without the need for court, had a proper ADR existed.  The fact is, there was no fair ADR on offer and - whether or not a defendant engaged with it - the Claimant's reliance upon it is not something that should sway the court into a belief that a fair process was followed before litigation.

Abuse of process - the quantum

 

32. The quantum and interest has also been enhanced.  It is denied that the sum sought is recoverable and a significant chunk of this claim represents a penalty, per the authority from two well-known ParkingEye cases.  Attention is drawn to paras 98, 100, 193, 198 of ParkingEye Ltd v Beavis [2015] UKSC 67.  Also ParkingEye Ltd v Somerfield Stores Ltd ChD [2011] EWHC 4023(QB) where the same modern penalty law rationale was applied, yet here, the learned Judge also considered added 'costs'.  The parking charge was set at £75 (discounted to £37.50 for prompt payment) then 'admin costs' inflated it to £135.  At paras 419-428, HHJ Hegarty sitting at the High Court (decision ratified by the CoA) found that adding £60 to enhance the sum sought to £135 'would appear to be penal', i.e. unrecoverable.

 

33. The Defendant's stance regarding this punitive add-on is now underpinned by Government intervention and regulation.  The Department for Levelling Up, Housing and Communities ('DLUHC') published on 7 February 2022, a statutory Code of Practice which all private parking operators must comply with, found here: https://www.gov.uk/government/publications/private-parking-code-of-practice

 

34. Adding 'debt recovery' costs, damages or fees (however described) on top of a parking charge is banned. In a very short section called 'Escalation of costs' the new statutory Code of Practice now being implemented says: "The parking operator must not levy additional costs over and above the level of a parking charge or parking tariff as originally issued." 

 

35. This particular Claimant's legal team routinely continues to pursue a sum on top of each PCN, despite indisputably knowing that these are banned costs.  The claim is exaggerated by inclusion of a false, wholly disproportionate and unincurred 'damages' enhancement of £60 upon which the Claimant seems to have also added interest at 8% calculated from the date of parking.  Clearly an abuse of the court process.

  

[Deleted User]

36. The DLUHC considered evidence and took over two years to consult a wide mix of stakeholders before deciding this contentious issue.  According to the DLUHC, almost a fifth of all respondents in 2021 'called for the proposal to be scrapped and debt collection to be banned altogether'.  This despite the parking industry flooding both public consultations, some even masquerading as consumers. The DLUHC saw through this and exposed as fact, in its published Response to the Technical Consultation (also on 7/2/22) that some respondents were 'parking firms posing as motorists'.  Genuine consumer replies pointed out that successful debt recovery does not trigger court proceedings and the debt recovery/robo-claim law firms operate on a 'no win, no fee' basis and are effectively Trade Body Board member colleagues passing motorists' data around electronically and inflating parking charges.  This Claimant has not incurred any additional costs (not even for reminder letters) because the full parking charge itself more than covers what the Supreme Court in Beavis called a 'letter chain' business model that generates a healthy profit.

 

37. The Ministerial Foreword to the new Code is unequivocal about abusive existing cases such as the present claim: "Private firms issue roughly 22,000 parking tickets every day, often adopting a labyrinthine system of misleading and confusing signage, opaque appeals services, aggressive debt collection and unreasonable fees designed to extort money from motorists." 

 

38. These are now banned costs which the Claimant has neither paid nor incurred, and were not quantified in prominent lettering on signage. Introducing the purported 'costs' add-on in later debt demands is a moneymaking exercise to extract a high fixed sum from weaker motorists, and came far too late. I did not agree to it.

 

39. Whilst the new Code is not retrospective, it was brought in due to the failure of the previous two competing (self-serving) BPA & IPC codes of practice and the Ministerial Foreword is indisputably talking about existing cases when declaring the add-on to be 'designed to extort money'. A clear steer for the Courts from now on.

 

40. This overrides the mistakes and presumptions in the appeal cases that the parking industry had been relying upon (Britannia v Semark-Jullien, One Parking Solution v Wilshaw, Vehicle Control Services v Ward and Vehicle Control Services v Percy).  Far from being persuasive or assisting with clarifying the law, regrettably these one-sided appeals were findings by Circuit Judges who appeared to be inexperienced in niche private parking law and where the litigant-in-person consumers had no financial wherewithal to appeal further.

 

41. It is pertinent to note that the Britannia v Semark-Jullien appeal judgment by HHJ Parkes criticised the District Judges at Southampton, for apparently not having enough evidence to conclude that Britannia 'knew' that their added costs were abusive (unincurred, unpaid and unjustified). Unbeknown to HHJ Parkes, of course all District Judges deal with template, generic evidence and arguments from parking operators every week, and BPA member firms including Britannia, certainly had been told this by Judges up and down the Country for many years.  And the decision and words used by the DLUHC show that DJ Grand and DJ Taylor were right all along.  As was HHJ Jackson in Excel v Wilkinson (not appealed - see Exhibit xx-12) where she went into great detail about this abuse.

 

42. The Semark-Jullien case is now unreliable going forward, and is fully distinguished now that the Government has at last stepped in and exposed and published the truth.  This Claimant indisputably has knowledge (and always had knowledge) that they have not paid a penny in debt recovery costs, nor incurred any additional costs that the £100 parking charge is not designed to more than cover.  The abuse is now clearly established and a new judgment re-stating this position, in the light of the damning words in the Foreword and the Explanatory Document published alongside the Code of Practice and stating (for the avoidance of doubt) the knowledge that District Judges have from years of experience of seeing these template enhanced claims and telling this Claimant to stop bringing exaggerated parking claims to court, would be welcomed to bring much-needed clarity for consumers and Judges across England and Wales.

 

43. In case this Claimant tries to rely upon those old cases, significant errors were made.  Evidence - including unclear signage and Codes of Practice -was either ignored, even when in evidence at both hearings (Wilshaw, where the Judge was also oblivious to regulatory DVLA KADOE rules requiring landowner authority) or the judgment referred to the wrong rules, with one Judge seeking out the inapplicable BPA Code after the hearing and using it erroneously (Percy).  In Ward, a few seconds' emergency stop out of the control of the driver, was inexplicably aligned with Beavis. The learned Judges were led in one direction by Counsel for parking firms, and were not in possession of the same level of facts and evidence as the DLUHC.

 

CPR 44.11 - further costs

 

44. I am appending with this bundle, a fully detailed costs assessment which also covers my proportionate but unavoidable further costs and I invite the court to consider making an award to include these, pursuant to the court's powers in relation to misconduct (CPR 44.11).   In support of that argument, I remind the court that I appealed and engaged with the Claimant at every step.Not only could this claim have been avoided and the Claimant has no cause of action but it is also vexatious to pursue an inflated sum that includes double recovery.

 

My fixed witness costs - ref PD 27, 7.3(1) and CPR 27.14

 

45. As a litigant-in-person I have had to learn relevant law from the ground up and spent a considerable time researching the law online, processing and preparing my defence plus this witness statement.  I ask for my fixed witness costs.  I am advised that costs on the Small Claims track are governed by rule 27.14 of the CPR and (unless a finding of 'wholly unreasonable conduct' is made against the Claimant) the Court may not order a party to pay another party’s costs, except fixed costs such as witness expenses which a party has reasonably incurred in travelling to and from the hearing (including fares and/or parking fees) plus the court may award a set amount allowable for loss of earnings or loss of leave.

The fixed sum for loss of earnings/loss of leave apply to any hearing format and are fixed costs at PD 27, 7.3(1) ''The amounts which a party may be ordered to pay under rule 27.14(3)(c) (loss of earnings)... are: (1) for the loss of earnings or loss of leave of each party or witness due to attending a hearing ... a sum not exceeding £95 per day for each person.''

Statement of truth:

I believe that the facts stated in this Witness Statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

SIGNATURE

……………………..

xxxxxxxxxxxxx

DATE    xx/xx/xxxx

[Deleted User]

Please ignore my comments in relation to exhibits, I haven't compiled those yet and will include those correctly in a final version i'll stick on here after I've amended after feedback from kind users here. Thank you.

Coupon-mad

I am not seeing a WS in support of your counterclaim or a skeleton argument about the counterclaim and all the case law that goes with that.  As seen in the threads last year by @Eminowa and @Nosy for example.

If you revisit their threads, I think they set out their counterclaim with a separate skeleton argument or second WS...I can't recall.  But yours reads like a 'normal' WS defending a claim and does nothing to assist your case to counterclaim and under what law and rationale.

[Deleted User]

Coupon-mad said:

I am not seeing a WS in support of your counterclaim or a skeleton argument about the counterclaim and all the case law that goes with that.  As seen in the threads last year by @Eminowa and @Nosy for example.

If you revisit their threads, I think they set out their counterclaim with a separate skeleton argument or second WS...I can't recall.  But yours reads like a 'normal' WS defending a claim and does nothing to assist your case to counterclaim and under what law and rationale.

Hello @Coupon-mad and thanks for the reply.

 

I've looked at this from @Eminowa https://forums.moneysavingexpert.com/discussion/6193350/ncp-parking-ticket-i-won/p14 and this from @nosy https://forums.moneysavingexpert.com/discussion/6040768/pcn-driver-not-registered-keeper-dcbl/

These are the correct threads?

I can't see anything specific to @Eminowa counter-claim above. I can see @Nosy counterclaim, thanks.

Looking at my counterclaim I previously submitted some law and rationale. So I should repeat all of this again with information about my disabilities already included above under a separate "counterclaim" heading or just summarise this info?

Thanks.

Coupon-mad

You have to provide transcripts if the case law you are relying on and I'm sure @Eminowa had a case like yours with a WS about the Equality Act.

Both Nosy snd Eminowa had two threads, have you read it all?

[Deleted User]

Coupon-mad said:

You have to provide transcripts if the case law you are relying on and I'm sure @Eminowa had a case like yours with a WS about the Equality Act.

Both Nosy snd Eminowa had two threads, have you read it all?

Thanks for the reply

Re @Nosy

I can see a couple of threads (below). First one doesn't appear to have a counterclaim

https://forums.moneysavingexpert.com/discussion/6210723/county-court-claims-form-defence-template/p16

This one has the counterclaim:
https://forums.moneysavingexpert.com/discussion/6040768/pcn-driver-not-registered-keeper-dcbl/p20

Re @Eminowa

I can see their WS here:
https://forums.moneysavingexpert.com/discussion/6193350/ncp-parking-ticket-i-won/p15

I can see another WS from them here:
https://forums.moneysavingexpert.com/discussion/5980545/county-court-claim-form/p7

Another thread I can see doesn't appear to be related to the first and about a different PCN:
https://forums.moneysavingexpert.com/discussion/6332036/letter-of-claim-from-bwlegal/p1

[Deleted User]

Hello again everyone

Just so I'm 100% clear, I need to find complete transcripts for every court case referred to in my defence?

I can find the below cases in my defence:

1. ParkingEye Ltd v Beavis [2015] UKSC 67 

2. para 419 of HHJ Hegarty’s High Court decision in ParkingEye Ltd v Somerfield Stores Ltd ChD [2011] EWHC 4023(QB)

3. Britannia v Crosby

4. Spurling v Bradshaw [1956] 1 WLR 461 (the ‘red hand rule’ case) 

5. Thornton v Shoe Lane Parking Ltd [1970] EWCA Civ 2, both leading authorities confirming that an unseen/hidden clause cannot be incorporated after a contract has been concluded; 

6. Vine v London Borough of Waltham Forest: CA 5 Apr 2000,

For counterclaim:

7.  Ferguson v British Gas Trading Ltd [2009] EWCA Civ 46

8.  Harrison v Link Financial Ltd [2011] EWHC B3 (Mercantile) and other similar authorities as well as primary statute law. 

9. Vidal-Hall v Google Inc [2015] EWCA 311 confirms that pecuniary loss is not necessary for compensation to be payable and that pure distress is enough.

10. (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 for pure distress

11. judgment at the Leeds County Court, 3SP00071 - Blamires v LGO - which was a claim for damages including disability discrimination and a breach of the DPA

12. National Car Parks Ltd v Revenue And Customs [2019] EWCA Civ 854 (ref: paras 16, 18) affirmed that the contract was brought into being when the green button was pressed

I'm assuming I don't need to print off and include sections of law? Eg Equality Act 2010? CRA 2015? CPUTRs 2008?

Do I need to regurgitate and repeat what I wrote about the EA and how it applies in my case or is what I already included in my defence and counterclaim enough?

I'm going to start on my WS again, and will put a section titled "counterclaim" after "sequence of events" and before "Beavis is distinguished".

If any of the above is incorrect please let me know.

[Deleted User]

Hi, sorry. Another quick question.

Do I need to take photos of the car park in the same light conditions as the time of the PCN? It was dark, the signage is not lit.

I'm relying on the lack of lighting and resulting illegibility in my WS. 

Can I just use google maps and screenshot from their daylight streetview and use these photos?