Letter before action Wells quay

finchman

No there is no mention ofANPR in pofa the first letter received was a pcn addressed to me the second letter was a notification regarding keeper liabity about a month later. If I am honest I cant see a difference 

Coupon-mad

Why haven't you just copied another CEL defence wording about Wells?  Don't send off a weak defence.  Copy from other threads.

You've completely missed saying this car park is covered by byelaws.  Missed saying anything about the signs being at ankle height.  Missed saying anything about grace periods, if that applies to your case? I can't tell what the PCN was for?

finchman

Thanks Coupon-mad the pcn was overstay of 34 seconds the harbour estate confirmed the land is under statutory control 

nosferatu1001

Of course it doesnt mention ANPR. It doesnt need to. 
POFA tells you clearly in 8 that it deals with a notice placed on a windscreen. If there was no such notice placed on a windscreen, then para 9 aplies. 

Coupon-mad

the pcn was overstay of 34 seconds

No, it wasn't. That's not allowed.

finchman

Is this a better paragraphs 18
In a letter from the Harbour master to Norman Lamb MP on 21 May 2019,the Harbour master states that operation of the carpark has been reviewed, with the conclusion that the grace period was changed from 10 minutes to more reasonable 15 minutes. The evidence sent by the claimant shows signage photographed after this change.Thus norelevant evidence has been provided of contemporaneous signage facing the road at the entrance of the carpark or within the carpark. The Wells Harbour estate is covered by bye laws, the land on which the carpark sits is under statutory control as confirmed by the Harbour Master 

Coupon-mad

This is a separate point from the stuff about the 15 minute grace period:

The Wells Harbour estate is covered by bye laws, the land on which the carpark sits is under statutory control as confirmed by the Harbour Master 

finchman

I thought the idea was to put down a series of arguments as to why the defendant was  not liable

nosferatu1001

Yes, it is. Most of which are already in the defence template. 
What you dont do is muddle things up. A single para must not contain multiple arguments. Thats what youve been told above; not to include byelaws in a para about grace periods, because the two are completely different arguments. 

finchman

Thanks nosferatu1001 this is where I m confused do I not add the bye law  issue in para 18 if not where