Premier Parking County Court Defence

Castle

Umkomaas said:

I think @Castle was referring to any WW/PPL-specific signs dotted around the car park - there may be very few!  If there's a photo of one of those, can you let us see it please?

Correct; although the "20p per hour and £2.40 all day" sign will appear to contradict the other signs.

PChallenger

Castle said:

Umkomaas said:

I think @Castle was referring to any WW/PPL-specific signs dotted around the car park - there may be very few!  If there's a photo of one of those, can you let us see it please?

Correct; although the "20p per hour and £2.40 all day" sign will appear to contradict the other signs.

Thank you all for pointing me to the right directions and I now have an understanding of whom I'm dealing with.
I have updated statement 1 and 2 to reflect the signage at the entrance and reflect @Castle comment. Updated comment are marked as bold.

The facts as known to the Defendant:

2.        It is admitted that the Defendant was the registered keeper and driver of the vehicle in question, but liability is denied. As of 2nd March 2020, the signage on the entrance of the Car Park at 66 Cecil Street, Birmingham, B19 3SU stated, “20 pence per hour and £2.40 all day for parking”. Attached is the “Evidence 1 & 2” as proof showing this.

3.            On arriving at the car park, the Defendant paid £1 to cover 5 hours of parking based on the information on the entrance and on display (see evidence 1). The Defendant works with the Birmingham Women and Children Hospital and was attending a meeting at a nearby building with the Birmingham Children Trust. The Defendant found the payment information with an extra  payment statting 12 hours at 3.20 and up to 24 hours £3.50 (evidence 1) to contradict signage/ advert at the entrance (evidence 2) “20 pence per hour and £2.40 all day for parking”. However, due to time pressure to attend meeting and the fact that both entrance signage and payment information shows 20p an hour an guided the Defendant to the belief that he has paid the right amount to cover 3 hours with an extra 2 hours excess to cover for a probable delay.

Le_Kirk

Evidence is not sent with the defence, that goes later with the witness statement.  You could state that "evidence of ..... will be supplied at WS stage".

PChallenger

Le_Kirk said:

Evidence is not sent with the defence, that goes later with the witness statement.  You could state that "evidence of ..... will be supplied at WS stage".

What is the meaning of WS, please?

Le_Kirk

PChallenger said:

Le_Kirk said:

Evidence is not sent with the defence, that goes later with the witness statement.  You could state that "evidence of ..... will be supplied at WS stage".

What is the meaning of WS, please?

All acronyms are to be found in the NEWBIE thread however, WS = Witness Statement

PChallenger

Please see the updated statement below in bold:

The facts as known to the Defendant:

2.        It is admitted that the Defendant was the registered keeper and driver of the vehicle in question, but liability is denied. As of 2nd March 2020, the signage on the entrance of the Car Park at 66 Cecil Street, Birmingham, B19 3SU stated, “20 pence per hour and £2.40 all day for parking”. Evidence 1 & 2 are the proof showing this and will be supplied at Witness Statement (WS) stage.

3.            On arriving at the car park, the Defendant paid £1 to cover 5 hours of parking based on the information on the entrance and on display (see evidence 1). The Defendant works with the Birmingham Women and Children Hospital and was attending a meeting at a nearby building with the Birmingham Children Trust. The Defendant found the payment information with an extra  payment statting 12 hours at 3.20 and up to 24 hours £3.50 (evidence 1) to contradict signage/ advert at the entrance (evidence 2) “20 pence per hour and £2.40 all day for parking”. However, due to time pressure to attend meeting and the fact that both entrance signage and payment information shows “20p an hour and £2.40 all-day” guided the Defendant to the belief that he has paid the right amount to cover 3 hours with an extra 2 hours excess to cover for a probable delay.

Redx

Stating has one t , not 2

Coupon-mad

Remove this:

. Evidence 1 & 2 are the proof showing this and will be supplied at Witness Statement (WS) stage.

and remove '(evidence 1)' and '(evidence 2)'.

Redx

As above , save statements like those for the WS plus Exhibits stage , in several months time

PChallenger

Thank you @Le_Kirk, @Redx and @Coupon-mad for your reviews (not just for me but to all on this forum).
Below is my updated statement, is this good for submission now?

The facts as known to the Defendant:

2.        It is admitted that the Defendant was the registered keeper and driver of the vehicle in question, but liability is denied. As of 2nd March 2020, the signage on the entrance of the Car Park at 66 Cecil Street, Birmingham, B19 3SU stated, “20 pence per hour and £2.40 all day for parking”.

3.            On arriving at the car park, the Defendant paid £1 to cover 5 hours of parking based on the information on the entrance and on display. The Defendant works with the Birmingham Women and Children Hospital and was attending a meeting at a nearby building with the Birmingham Children Trust. The Defendant found the payment information with an extra  payment stating 12 hours at 3.20 and up to 24 hours £3.50 to contradict signage/ advert at the entrance “20 pence per hour and £2.40 all day for parking”. However, due to time pressure to attend a meeting and the fact that both entrance signage and payment information shows “20p an hour and £2.40 all-day” guided the Defendant to the belief that he has paid the right amount to cover 3 hours with an extra 2 hours excess to cover for a probable delay.