PCN - Letter Before Action - help

Castle

Le_Kirk said:

The usual reason for offering a reduction is because they feel "on dodgy ground" with their claim and that you have a good defence.

With CEL it's normally "Quicksand"

anged

Prepared my WS and link it below.
Any comments, suggestions are welcome please.

https://www.dropbox.com/scl/fi/ymheijbhesahc0u3vmq9i/DRAFT-WITNESS-STATEMENT.doc?dl=0&rlkey=r2ocaiwfaspfc6klhlabqvzjr

Thank you

anged

Its just the draft up to now.
I know I still have to add my costs and the exhibits at the end but just wanted to get the main body sorted out first.

1505grandad

CEL are BPA AoS members not IPC.

Coupon-mad

As well as replacing the IPC CoP with the correct BPA version (from the year of parking) change every time you've called yourself 'The Defendant' to 'I'.

Change 'penalty notice' to 'parking notice'.

Change 'the mother in law' (Twice) to my mother in law!

anged

Seems that the BPA  AoS is more in depth and CEL seems to be quite compliant with regard to the signage.
Version 7 of 2018 I've had to use to cover the date of CPN.
There isn't any wording in it that is the same as I've originally quoted.
Do you think it's best I remove my paragraph in my WS

https://www.dropbox.com/h?preview=AOS+CoP+-.PNG

My original wording of my paragraph read;

1.        I re visited the row of shops to take photographs of the parking area and of any parking restriction signage that was displayed.

2.        It is noted that the claimant’s signage is excessively wordy and the print size excessively small, and contains text that is almost illegible, therefore, I deny that it is capable of creating a legally binding contract (ex 2)

3.        The IPC’s CoP (ex 3) states that text size must be such that signs are ‘clearly readable’ by a motorist, I believe that the claimant’s signs do not adhere to this guidance.

And here are the pictures of the signage.

Coupon-mad

That Dropbox link only takes me to my Dropbox homepage, not a file.  And we can't see pics of the sign.

anged

Sorry, hopefully these should work;

https://www.dropbox.com/s/pfqzvm5480th98u/AOS CoP -.PNG?dl=0

https://www.dropbox.com/scl/fi/wt5e6zj7wgp66hh89kpj5/Area-Signage.doc?dl=0&rlkey=pcfz96z695sb1sxjldwlvqsjr

anged

Just off on my jollies, see you in a week.

Coupon-mad

The parking charge itself is on such small text that it is unreadable.  Are you sure the BPA CoP isn't useful re legibility and size of text?