anybody knows S Wilson, solicitor for Civil Enforcement Ltd?

vol69

Le_Kirk said:

Please read the comment posted by Coupon-mad about your defence.

vol69 said:
Any comments on my defence itself, please?

Coupon-mad said:

No it isn't.  That is ancient.
And you don't attach anything to a defence except the attached Skipton Court judgment, as one example of many struck out parking cases, to support the part in your defence where you point out that the Claim is tainted by duplicity of the false added costs.
Please tell us the date of issue of the claim and you will get bespoke advice.

Coupons' mad comment about being 'ancient' was for another case (CEL v McCafferty appeal judgement), that I asked if I could use.

Appartently, now I have to attach to my defence Skipton and Southampton cases..

But is my defence consistent, please?

Le_Kirk

Your defence is a mix of technical and legal arguments (the defence) and narrative (the witness statement) You save the story of what happened on the day and subsequently for the witness statement stage.  If the PPC has added additional costs (however they are dressed up to appear legal) you could use the new Template Defence that Coupon-mad has published today: -
https://www.dropbox.com/s/02dk9z3pe2kb72n/Template defence 2020 without C.docx?dl=0
just adding your specifics in as indicated by Coupon-mad adjusting your paragraph numbers accordingly.

vol69

Le_Kirk said:

Your defence is a mix of technical and legal arguments (the defence) and narrative (the witness statement) You save the story of what happened on the day and subsequently for the witness statement stage.  If the PPC has added additional costs (however they are dressed up to appear legal) you could use the new Template Defence that Coupon-mad has published today: -
https://www.dropbox.com/s/02dk9z3pe2kb72n/Template defence 2020 without C.docx?dl=0
just adding your specifics in as indicated by Coupon-mad adjusting your paragraph numbers accordingly.

I think that only point 4 is for the witness statement.

Is any other of the points to be moved to the witness statement?

4. Mrs XXXXX XXXX, PA to Senior Managment Team & Complaints manager in XXXXX surgery mailed the Defendant after a complaint that “However the downside is that sometimes genuine patients are getting fines.” (Evidence XXXXXX email).

During his consultation the Defendant was diagnosed with a health condition(Evidence diagnosis report).

4.1 The appointment was due on 29th of April, 2019, at 15:30. (Evidence XXXXXX reception)

The Defendant arrived to South Bar House car parking with 10 minutes delay, due to work obligations and traffic.

The Defendant arrived in XXXX surgery reception at 15:42 and sent by reception into consultation immidately, at 15:43.

Even if XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX