County court defence

pseek

Le_Kirk said:

pseek said:

Sorry I made a mistake to altered but now its back to original template.
I am waiting for SAR and I don't know why they issued a ticket only found DCB legal sent notice to me and mentioned ticket expired, So they never shown any proof. @Coupon-mad could you please make a paragraph #3 for me?

Well there is the reason - ticket expired - it is now your job to refute that in the defence and state that evidence will be provided at witness statement stage and also put the claimant to strict proof of the expired ticket.  The PPC (in fact any company) has 30 days to reply to your SAR submission; knowing when you submitted the SAR does the 30 days still give you time to submit your defence before deadline?

@Le_Kirk AOS was 23/11/2020 so I think deadline for defence only left 6 or 7 days left. so I am thinking to submit defence tomorrow. Could you make a paragraph for me please in #2 or #3? 

pseek

Please advise or alter on this:

The facts as known to the Defendant:

2.    It is admitted that the Defendant was the registered keeper of the vehicle registration number xxxxx but liability is denied. The Defendant paid the correct fee (£3.50) for parking on 11/10/2019 at Shaws Passage. The PDT issued the ticket and the defendant displayed it correctly on the dashboard of the car. Evidence of having purchased a ticket will be provided at the Witness Statement stage.

3. Accordingly, it is denied that the Defendant breached any of the Claimant's purported contractual terms, whether express, implied, or by conduct.

Umkomaas

Could you make a paragraph for me please in #2 or #3? 

This isn't what the forum does, this is a self-help forum.  It is not a legal aid forum.  A solicitor might be able to do it for you.  Otherwise, it's a case of drafting it yourself and seeing if anyone can help fine tune it. 

KeithP

pseek said:

Le_Kirk said:

pseek said:

Sorry I made a mistake to altered but now its back to original template.
I am waiting for SAR and I don't know why they issued a ticket only found DCB legal sent notice to me and mentioned ticket expired, So they never shown any proof. @Coupon-mad could you please make a paragraph #3 for me?

Well there is the reason - ticket expired - it is now your job to refute that in the defence and state that evidence will be provided at witness statement stage and also put the claimant to strict proof of the expired ticket.  The PPC (in fact any company) has 30 days to reply to your SAR submission; knowing when you submitted the SAR does the 30 days still give you time to submit your defence before deadline?

@Le_Kirk AOS was 23/11/2020 so I think deadline for defence only left 6 or 7 days left. so I am thinking to submit defence tomorrow. Could you make a paragraph for me please in #2 or #3? 

I hope you are not guessing at this stuff.

Only a few days ago, on 8 December at 3:16PM, I posted on your very own thread...

...you have until 4pm on Monday 21st December 2020 to file your Defence.

I also gave directions on how to file a Defence by email. A Defence filed by email, or anything sent by email, arrives almost instantly. There is no need for you to file your Defence tomorrow.

Stop panicking.

Le_Kirk

In this post by @Coupon-mad she suggested what to add to your point #2 & #3 12 December at 9:09PM <<<<<LINK.  I have also told you that you have not told the judge why you are defending the claim.

pseek

KeithP said:

pseek said:

Le_Kirk said:

pseek said:

Sorry I made a mistake to altered but now its back to original template.
I am waiting for SAR and I don't know why they issued a ticket only found DCB legal sent notice to me and mentioned ticket expired, So they never shown any proof. @Coupon-mad could you please make a paragraph #3 for me?

Well there is the reason - ticket expired - it is now your job to refute that in the defence and state that evidence will be provided at witness statement stage and also put the claimant to strict proof of the expired ticket.  The PPC (in fact any company) has 30 days to reply to your SAR submission; knowing when you submitted the SAR does the 30 days still give you time to submit your defence before deadline?

@Le_Kirk AOS was 23/11/2020 so I think deadline for defence only left 6 or 7 days left. so I am thinking to submit defence tomorrow. Could you make a paragraph for me please in #2 or #3? 

I hope you are not guessing at this stuff.

Only a few days ago, on 8 December at 3:16PM, I posted on your very own thread...

...you have until 4pm on Monday 21st December 2020 to file your Defence.

I also gave directions on how to file a Defence by email. A Defence filed by email, or anything sent by email, arrives almost instantly. There is no need for you to file your Defence tomorrow.

Stop panicking.

ok Sorry!

pseek

The facts as known to the Defendant:

2.    It is admitted that the Defendant was the registered keeper of the vehicle registration number xxxx but liability is denied. The Defendant paid the correct fee (£3.50) for 4 hours parking on 11/10/2019 at Shaws Passage. The PDT issued the ticket and the defendant displayed it correctly on the dashboard of the car. Evidence of having purchased a ticket will be provided at the Witness Statement stage. The Defendant unaware of overstayed at Shaw Passage on 11/10/2019. The Defendant struggled to make an informed decision due to the complete lack of evidence and put the Claimant to strict proof of any breach of clearly advertised terms.The Defendant has submitted a Subject Access Request to the Claimant on 9/12/2020 and is still waiting for reply from the Claimant .

Coupon-mad

Why do so many posters not simply add the obviously-needed words here: 'and the driver'?  You said you were admitting to driving but then you didn't!

2.    It is admitted that the Defendant was the registered keeper and the driver of the vehicle registration number xxxxx but liability is denied. 

The rest is fine except this section isn't written in good English:

 The Defendant is and was unaware of any purported 'overstay'  overstayed  at Shaws Passage on 11/10/2019. The Defendant has struggled to make an informed decision regarding responding to the allegations in the particulars of claim, due to the complete lack of evidence.  The Defendant puts and put the Claimant to strict proof of any breach of...


(..the rest is as you have it already)

pseek

Coupon-mad said:

Why do so many posters not simply add the obviously-needed words here: 'and the driver'?  You said you were admitting to driving but then you didn't!

2.    It is admitted that the Defendant was the registered keeper and the driver of the vehicle registration number xxxxx but liability is denied. 

The rest is fine except this section isn't written in good English:

 The Defendant is and was unaware of any purported 'overstay'  overstayed  at Shaws Passage on 11/10/2019. The Defendant has struggled to make an informed decision regarding responding to the allegations in the particulars of claim, due to the complete lack of evidence.  The Defendant puts and put the Claimant to strict proof of any breach of...


(..the rest is as you have it already)

Thank you so much @Coupon-mad.

pseek

Shall I submit my defence or wait for SAR? Please advise me.