Premier Park Ltd CCBC

nosferatu1001

What was the specific reason given on BOTH PCNs - the same? different? No valid permit or permit not on show?

D_P_Dance

Acquaint yourself with unreasonable behaviour costs under CPR27.14(2)(g)

Simza24

nosferatu1001 said:

What was the specific reason given on BOTH PCNs - the same? different? No valid permit or permit not on show?

They were different; one was no permit on show, the other was an invalid permit on show. 

nosferatu1001

So you need to make the difference clear in your WS, whereas currently this is not. 
You can point out that when the vehicle was left by the driver the permit was on display, and when yuo returned it had mysteriously fallen to the floor. Regardless, as this vehicle was known at this location for x days/weeks/months/years, the lack of any permit on display would not mean the vehicle couldnt be on a white list and wasnt already known to be authorised, and it is not the drivers job to ensure that somehow the permit remains on display, when it could have been blown off by the wind or the vehicle could have been bumped

Edit for concision. You get the idea I hope. 

Simza24

Thanks once again everyone for your help. I ended up compiling a bundle of 32 pages in Microsft Word. Original size around 8mb. I then used Word to convert to PDF, and this reduced to 4mb with no issues. 
Email sent to Bath Court with editable DO, and received an automatic reply almost instantly. Also been sent to Claimant's litigation team. 

Simza24

Received BW Legal's WS in post today, signed by a paralegal from BW. It says mostly about how all the signs are prominent, driver breached T&Cs, cut&paste Defence, and propriety interest in the land. The exhibits are largely irrelevant, and most of which I have included as part of my own evidence anyway. 
Telephone court date is set for just other a month away...

Umkomaas

Telephone court date is set for just other a month away...

Are you content with a telephone hearing?

KeithP

Simza24 said:

Received BW Legal's WS in post today, signed by a paralegal from BW. 

How can a BWL paralegal be a witness?

What is he/she a witness to?

Coupon-mad

Your WS will have much more clout to the Judge.

Have you read the TELEPHONE HEARINGS thread?

Simza24

Umkomaas said:

Telephone court date is set for just other a month away...

Are you content with a telephone hearing?

As a young student, it was going to be quite daunting any which way! But as I'll be in my own surroundings, I feel as if I will be a bit more relaxed. After speaking to the Court, the Judge saw my cover email but wanted me to write in my contact number again so I believe it's still going to go ahead over the phone as usual. 

KeithP said:

Simza24 said:

Received BW Legal's WS in post today, signed by a paralegal from BW. 

How can a BWL paralegal be a witness?

What is he/she a witness to?

You raise a very valid point! Her name was also brought up here not too long ago... https://forums.moneysavingexpert.com/discussion/comment/76747116#Comment_76747116

Coupon-mad said:

They always do these third party WS.  Yours will have much more clout to the Judge.

Have you read the TELEPHONE HEARINGS thread?

Yes, mostly up to date with it, thanks! Will go over everything a couple of days before the hearing to see any updates.