CCJ N244 Application to set aside judgement advice

nosferatu1001

Not unless that was ordered by the court. And we dont know, because you didnt tell us
WHat did your SAR reveal? 
Too latye to send one now
What is your deadline, because again you have not told us. 

Dougsboy32

I missed the part about the SAR. Was too busy dealing with the death of a family member. But as you say: too late now anyway. I have been cagey about specifics as you always warn that the PPC's can see everything here too. However, the court date is March 29th.

Dougsboy32

I just went to the site and guess what? The ankle height sign has been removed and replaced with one at a higher elevation - but further away from the entrance and completely obscurable should a van park in front of it. I have a photo of the hole in the ground where the old sign was - but of course no use now.

Johnersh

To the contrary, it's prima facie evidence that the signage at ankle height was inadequate, such that the signage on a pole within the normal visual field of any visitor (we don't look at our feet the whole time) was necessary. 

Dougsboy32

I am looking at paragraph 5 in the 2020 defence template which mentions " the business model involved sending a series of automated demands to the keeper "  ..but as  I got none of them presumably I should delete this section?

KeithP

chrissage said:

I am looking at paragraph 5 in the 2020 defence template which mentions " the business model involved sending a series of automated demands to the keeper "  ..but as  I got none of them presumably I should delete this section?

No, do not delete that.

Just because they cannot manage to send them to the right place, does not alter the fact that that is their business model.

nosferatu1001

As above - companies dont do things for fun. the sign cannot have been adequate otherwise they would not have spent money to replace it!

Umkomaas

chrissage said:

I just went to the site and guess what? The ankle height sign has been removed and replaced with one at a higher elevation - but further away from the entrance and completely obscurable should a van park in front of it. I have a photo of the hole in the ground where the old sign was - but of course no use now.

Have got a time stamped photo of the new sign?  What about a short vid starting at the original point where the ankle high sign was up to and including the new siting. Have that up your sleeve and produce with any witness statement you need to make. 

Dougsboy32

Umkomaas - No I have no time stamped photo but will shoot a video as suggested thanks. From what you are saying can I take it that I do not have to submit everything with the WS and defence, and can hold back items for the actual hearing? 

nosferatu1001

that is the opposite of what they said!
They said PRODUCE WITH
Not after. With. At the same time as
You know, from the newbies thread, that you cannot ambush anyone