Now at Mediation

Le_Kirk

5.       Now please look at Exhibit B, Point A shows the manned security gate. Point B shows the permanently locked gate. Point C shows where car was parked. Point D shows the crossing for construction workers. To the left of Point, A shows Edmund Halley Way, where the parking eye should have been mapped to monitor.

9.       I would like to point out that the incident occurred inside a cordoned off building site, and that the parking eye had not been programmed properly to ignore this section of road, which the public would have no access to.

What do you mean by this and this?  Do you mean ANPR camera?  I think you should rewrite the WS so that it starts with the important facts first and backs up what you said in your defence.  Leave the explanation of the evidence until the end.  You need to catch the judge's attentions straight away.

MrEnigma

quote  ** What do you mean by this and this?  *** quote
The claimant refered to the parking eye in their statement. Should I point out ANPR (Parking eye) instead then?

Le_Kirk

MrEnigma said:

quote  ** What do you mean by this and this?  *** quote
The claimant referred to the parking eye in their statement. Should I point out ANPR (Parking eye) instead then?

Since this is not a ParkingEye claim but a UKCPM, I would assume that the WS provided by the claimant is referring to the camera.  I would use ANPR camera to avoid confusion.
I posted this some weeks ago about what sort of thing to put in your WS: -

If that is the whole of your defence, you are going to have your work cut out to rescue it.  Your witness statement will have to have an explanation of why you attended and why you were given permission to enter via controlled access and who gave you permission.  All backed up by evidence.  Is it possible (at this late stage) to get witness statements from whoever let you in the gate?

MrEnigma

Le_Kirk said:

MrEnigma said:

quote  ** What do you mean by this and this?  *** quote
The claimant referred to the parking eye in their statement. Should I point out ANPR (Parking eye) instead then?

Since this is not a ParkingEye claim but a UKCPM, I would assume that the WS provided by the claimant is referring to the camera.  I would use ANPR camera to avoid confusion.
I posted this some weeks ago about what sort of thing to put in your WS: -

If that is the whole of your defence, you are going to have your work cut out to rescue it.  Your witness statement will have to have an explanation of why you attended and why you were given permission to enter via controlled access and who gave you permission.  All backed up by evidence.  Is it possible (at this late stage) to get witness statements from whoever let you in the gate?

Yep, thats my defence.
I will edit parking eye, with ANPR

1505grandad

Please diligently proof read before posting for review.

There are numerous errors in the draft  -  some below just for starters:-

should be "Beavis" in contents list

full name of claimant (UKCPM (Claimant)) still not stated

para 10  -  "10.   Contract with Landowner. UKPCM does not own the land and are assumed to be merely agents for the owner or legal occupier. UKPCM LTD ..."  -  WRONG INITIALS FOR CLAIMANT (ALSO WRONG ELSEWHERE)

PARA 10  -  "Within the IPC CoP Part B, paragraph 2.1 states the requirement of such an agreement."  -  QUOTED PART/PARA RELATES TO SIGNS NOT LANDOWNER CONTRACT.

MrEnigma

1505grandad said:

Please diligently proof read before posting for review.

There are numerous errors in the draft  -  some below just for starters:-

should be "Beavis" in contents list

full name of claimant (UKCPM (Claimant)) still not stated

para 10  -  "10.   Contract with Landowner. UKPCM does not own the land and are assumed to be merely agents for the owner or legal occupier. UKPCM LTD ..."  -  WRONG INITIALS FOR CLAIMANT (ALSO WRONG ELSEWHERE)

PARA 10  -  "Within the IPC CoP Part B, paragraph 2.1 states the requirement of such an agreement."  -  QUOTED PART/PARA RELATES TO SIGNS NOT LANDOWNER CONTRACT.

Thank you, and will do

Coupon-mad

Yes you have the wrong acronym everywhere, change all UKPCM to UKCPM or 'the Claimant'.

Remove the stuff you have where you cite VCS v HMRC which makes no sense in a witness statement.  I can't understand what point it's being used to make.

And this tells me that the Judge will want evidence of what job you do.  Have you added that, in which case give it an exhibit number and refer to it here:

3.       On 22nd March 2019 I was asked by XXXXXX XXXXXX (Mace Construction Ltd) who was instructed by Knight Dragon (Landowners) to attend site on 23rd March 2019 to deal with an urgent Electrical changeover that needed to take place to keep the construction up and running for over 400 employees the following Monday.

Can you then show us what it looks like again, with all the changes made?  We are on page 10 now and it's already back on page 9.

nosferatu1001

You need to realise your defence was rubbish, so youre having to rescue this at WS stage. So heed the advice given above by Le_kirk, TWICE now, and make sure this is absolutely clear

D_P_Dance

Nos is right, you need to align your waterfowl, these companies can ruin your life. 

MrEnigma

1505grandad said:

Please diligently proof read before posting for review.

There are numerous errors in the draft  -  some below just for starters:-

should be "Beavis" in contents list

full name of claimant (UKCPM (Claimant)) still not stated

para 10  -  "10.   Contract with Landowner. UKPCM does not own the land and are assumed to be merely agents for the owner or legal occupier. UKPCM LTD ..."  -  WRONG INITIALS FOR CLAIMANT (ALSO WRONG ELSEWHERE)

PARA 10  -  "Within the IPC CoP Part B, paragraph 2.1 states the requirement of such an agreement."  -  QUOTED PART/PARA RELATES TO SIGNS NOT LANDOWNER CONTRACT.

Thank you kind sir/madam
I have corrected the 5 mistakes