Discontinuance - All claims discontinued - Thank you for your help

Coupon-mad

You can evidence it by finding that road on the Local Council's Traffic Order or emailing them to ask to confirm that they operate decriminalised statutory parking enforcement in that road.  That would be evidence, and that's what you need.

What does this mean?  Windscreen, not window shield, BTW, but what do you mean, what was paid?

3. Upon receipt of a parking charge notice from the Claimant first time on the window shield, I assumed that the ticket issuer has legitimacy of issuing parking charge notices. The parking charge notice was also paid out of goodwill as Exhibit B. However, it has been proved I was wrong.

Linda992

Coupon-mad said:

You can evidence it by finding that road on the Local Council's Traffic Order or emailing them to ask to confirm that they operate decriminalised statutory parking enforcement in that road.  That would be evidence, and that's what you need.

What does this mean?  Windscreen, not window shield, BTW, but what do you mean, what was paid?

3. Upon receipt of a parking charge notice from the Claimant first time on the window shield, I assumed that the ticket issuer has legitimacy of issuing parking charge notices. The parking charge notice was also paid out of goodwill as Exhibit B. However, it has been proved I was wrong.

I contacted local council but they didn't get back to me. T-T
Now all the signage around the area I parked have been removed. Would it be an evidence to support my argument that UKCPM don't have the authority to issue parking notice in this area?
The first parking notice I saw was attached on the windscreen and I paid for it. After this payment, I received another 3 by post.
 

Coupon-mad

Signs being removed suggests they were kicked out, but that only helps to show the operation was predatory and causing complaints.  Are the Traffic Orders for the town not on the Council's website as maps and links?

ampersand

Am I missing something else here?
Shouldn't Linda992 also be seeking refund of monies paid in response to an illegally issued demand and redress along same lines as advised?
Or would experienced msers' advice be that this be done after a successful outcome concerning the others?

Linda992

Coupon-mad said:

Signs being removed suggests they were kicked out, but that only helps to show the operation was predatory and causing complaints.  Are the Traffic Orders for the town not on the Council's website as maps and links?

I checked the council websites - unfortunately this area is not restricted parking zone... T-T
The best evidence I have is the photos of signed being removed. I'll submit them with WS.

Coupon-mad

I checked the council websites - unfortunately this area is not restricted parking zone.

It doesn't need to be in a CPZ.

Are you saying it's not within any Traffic Order map?

The best evidence I have is the photos of signed being removed. I'll submit them with WS.

Good, but  this thread is long, please show us your WS draft again here in a reply (not a link, actual words here please) plus a list of your evidence exhibits, and your Summary Costs Assessment, and your Supplementary WS like the one shown in A_Seagull's thread today (about the added £60).

Coupon-mad

ampersand said:

Am I missing something else here?
Shouldn't Linda992 also be seeking refund of monies paid in response to an illegally issued demand and redress along same lines as advised?
Or would experienced msers' advice be that this be done after a successful outcome concerning the others?

If the lady is at WS stage then she can't add a counter claim, but could start a new claim later, if she wins this one.

Linda992

In the County Court at Chelmsford

Claim No. xxxxx

Between
UK CAR PARK MANAGEMENT LIMITED (Claimant)
and
 (Defendant)

Witness Statement

I am the Defendant in this matter, of xxxx. I am unrepresented, with no experience of Court procedures. If I do not set out documents in the way that the Claimant may do, I trust the Court will excuse my inexperience.

In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.

1. On 25 MAY 2018, I visited a friend who lived in Peartree Way, and parked my vehicle registration no xxxx in a tunnel near my friend’s flat. The car was parked on the material date on a public road, not on any yellow lines nor causing an obstruction.
2. There’s no distinctive markings or later particulars of claim any information where a reasonable person can identify the controlled parking area as Exhibit A.

3. Upon receipt of a parking charge notice from the Claimant first time on the window shield as Exhibit B I assumed that the ticket issuer has legitimacy of issuing parking charge notices. The parking charge notice was also paid out of goodwill as Exhibit C. However, the claimant decided to issue more parking charge notice by post after the first one was paid.

4. UK Car Park Management are not the lawful occupier of the land. I have the reasonable belief that they do not have the authority to issue charges on this land in their own name and that they have no rights to bring action regarding this claim. All signage the claimant stated in previous correspondence does not exist anymore as Exhibit C.
5. I invite the Court to dismiss this claim in its entirety, and to award my costs of attendance at the hearing, such as are allowable pursuant to CPR 27.14.

I believe that the facts stated in this Witness Statement are true.

Linda992

Summary Assessment of Costs - three claims F8GF2N50, F6GF72GM and F7GF0E1P

Ordinary Costs:

One half day loss of earnings for attending hearing - £50

Further costs for Claimant's unreasonable behaviour, pursuant to Civil Procedure Rule 27.14(2)(g):

a. reading Letter before Claim and N1 claim documents for claim #1  F8GF2N50 - 2 hours

reading Letter before Claim and N1 claim documents for claim #2 F7GF0E1P - 2 hours

reading Letter before Claim and N1 claim documents for claim #3 F6GF72GM - 2 hours

replying to LBCs - 3 hours

researching how to respond to county court claims - 3 hours

writing defences x 3 and submitting these and Directions questionnaires - 3 hours

preparing Defendant's own witness statement and evidence - 2 hours

b. Stationary, copying and printing - £15.00

£388 TOTAL COSTS CLAIMED

 

Linda992

Coupon-mad said:

I checked the council websites - unfortunately this area is not restricted parking zone.

It doesn't need to be in a CPZ.

Are you saying it's not within any Traffic Order map?

The best evidence I have is the photos of signed being removed. I'll submit them with WS.

Good, but  this thread is long, please show us your WS draft again here in a reply (not a link, actual words here please) plus a list of your evidence exhibits, and your Summary Costs Assessment, and your Supplementary WS like the one shown in A_Seagull's thread today (about the added £60).

Thank you so much for your help.
I cannot find it in any Traffic Order Map... I tried to reach borough of Greenwich but the person who answered the phone could not confirm it.
Actually it's not on a street. It's under a tunnel. I parked where the white car parked.  I've updated the WS and Cost summary in the reply. Need to post them to the court by tmr. 14 days before the hearing date is this Wed....