Help/Advice needed regarding PCN

Hot_chocolate20

1505grandad said:

The claimant?:-

Bank Park Management Limited

WWW.BANKPARK.CO.UK

So it would be wise to refer to the relevant AoS   -   they are IPC members yet reference to the BPA CoP is stated many times. 

@1505grandad, I'll amend and re-upload 👍

Hot_chocolate20

Umkomaas said:

Hot_chocolate20 said:

Please see the enclosed link containing my WS 
https://onedrive.live.com/view.aspx?resid=83B5FD9A4030D10D!4317&ithint=file,docx&authkey=!AFkAwQu96rvr_Q0

The question I always ask when I see the documents someone submits to the court, running into a massive word count, as far as an extremely busy Judge having to read thousands upon thousands of words, would this be more or less beneficial to my case?

Think about it. 

Thanks @Umkomaas shall revise to see where I can trim it down a bit, I might squeeze exhibits into 2 pages rather than just 1 as my ws is only 5 pages

Hot_chocolate20

Coupon-mad said:

In paras 23 and 24 you mention CRA 2015. There is no previous mention of that Act.
It is introduced properly much later - in para 35.

What Keith means is, the first time you mention an Act, put it in full but with ('CRA 2015') in brackets immediately after, to signify that later mentions will call the Act that.  Your version has that back to front.

Thanks for clarifying @Coupon-mad 👍

Hot_chocolate20

KeithP said:

In paras 23 and 24 you mention CRA 2015. There is no previous mention of that Act.
It is introduced properly much later - in para 35.

Para 43 starts: 43. The Defendant appends with this bundle, a fully detailed costs assessment which also covers proportionate costs.
I wouldn't call Exhibit XX-19 fully detailed.
I suggest that even a Costs Schedule for ordinary costs should be far more detailed than yours.
Don't forget to take a payslip, or something similar, to the hearing to prove your loss of earnings.

Good observations and thanks for the feedback @KeithP shall amend. The challenge I have at the moment is that since my redundancy last sept I'm now self-employed - I may just all together scrap xx-19 as my first every salary will be paid to me on the day of the hearing (the irony) 😃

Hot_chocolate20

Quick question everyone - do I need to bring the driver with me to the hearing next month? Or does it not matter as I'm getting sued as the RK?
The driver of the vehicle was my wife and I chose to not  divulge that it was her

Le_Kirk

Only the person named on the court claim NEED attend.  Are you that person - the defendant?  If so, just you.

Umkomaas

Hot_chocolate20 said:

Quick question everyone - do I need to bring the driver with me to the hearing next month? Or does it not matter as I'm getting sued as the RK?
The driver of the vehicle was my wife and I chose to not  divulge that it was her

For what purpose would you take your wife with you (but isn't it a telephone hearing)?  Moral support - OK.  Entangling her somehow in the process of the hearing and opening her up for questions - no. Shoving her forward during the hearing on a 'wasn't me driving, Guv, it was her' 👉 - absolutely not!

Your wife has no useful part to play, other than as a bystander. 

Hot_chocolate20

Umkomaas said:

Hot_chocolate20 said:

Quick question everyone - do I need to bring the driver with me to the hearing next month? Or does it not matter as I'm getting sued as the RK?
The driver of the vehicle was my wife and I chose to not  divulge that it was her

For what purpose would you take your wife with you (but isn't it a telephone hearing)?  Moral support - OK.  Entangling her somehow in the process of the hearing and opening her up for questions - no. Shoving her forward during the hearing on a 'wasn't me driving, Guv, it was her' 👉 - absolutely not!

Your wife has no useful part to play, other than as a bystander. 

Hahahaha, love it 👌🤣 - I was thinking from the perspective of her telling her side. But to come to think about it she'd just crumble to pieces. Pyback for making me wake up with the little one for the past 4-years🤔 very tempting but pointless (sigh)

Hot_chocolate20

Le_Kirk said:

Only the person named on the court claim NEED attend.  Are you that person - the defendant?  If so, just you.

Thanks @Le_Kirk 👍

Coupon-mad

If you name your wife as driver/witness you'd be throwing her under the bus. 

Technically, although rare, they could pursue her if they fail with you.  ABSOLUTELY NOT!