BW legal CLAIM FORM from CCBC Northampton

Coupon-mad

If you are confused about the procedures, read the links under the red heading in the NEWBIES thread, 'IMPORTANT - KNOW WHAT HAPPENS WHEN' which takes you to bargepole's thread about COURT PROCEDURES.

Please please no asking us what to do with your DQ form, when you get it after defending, please no. Absolute bugbear on this forum right now and we need to stop people asking that.

Anyway, show us your draft defence whcih we are more than happy to check.

Redx

provide the proof , but do not wait for the SAR reply

you were told to draft your defence and post it , this is your priority once the SAR has been sent, you have had a week already, so in blunt terms

GET ON WITH DRAFTING YOUR DEFENCE and post it below for checking and critique (it is not dependent on the SAR reply which probably wont arrive in time anyway)

Redx

why has it got the BPA grace periods in it when Napier are IPC members ?

and why is the BPA mentioned in several other paragraphs ? as an IPC member , not BPA member

why havent you got the abuse of process paragraphs in it (by coupon mad) ?

Redx

IPC member you mean

I am not saying that its irrelevant

I am saying you are posting a defence for an IPC member yet most of it mentions the BPA CoP

their simple rebuttal would be

we are IPC members and so follow the IPC CoP

ps:- there are no "regulations"

Coupon-mad

BW Legal (Napier parking)

This is not the Claimant's company name as stated on the Claim form. BW Legal are not the Claimant and Napier's name is not as you typed it.

Coupon-mad

This bit is fine (needs paragraph numbers added though) and the end is fine:

DEFENCE
________________________________________

The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all.
It is admitted that the Defendant was the authorised registered keeper of the vehicle in question at the time of the alleged incident.

It is denied that the Defendant, or any driver of the vehicle, entered into any contractual agreement with the Claimant, whether express, implied, or by conduct.

But the paragraphs after the above up to #8 are from a POPLA APPEAL!

You shouldn't even be reading appeals threads. You need a defence.

Le_Kirk

You appear to have taken out landowner authority. I would move paragraph 7 to after paragraph 9 and that way the flow concerning additional costs is better.

Umkomaas

I’ve got loads of pictures etc to prove the points if need be.

They will need to be included in your Witness Statement - further on in the process - not with your Defence.

At WS stage you need to provide to the court and the other side everything you intend to rely on; you can't rock up on the day of the hearing with a pile of photos not already revealed.

beamerguy

I like it, good defence