Claim Form from DCBLegal.

Robbo25

Is this all that is needed for paragraph 3 of the defence?

Robbo25

Fruitcake said:

I suggest you remove 3 (a).

When I say remove 3 (a), I mean remove 3 (a), not the sentence that comes after it.

This will be paragraph 3.

3.  On the 05/09/2019 the driver was delivering a washing machine to a tenant of 
Then to his surprise the defendant later received an Invoice/PCN (Parking Charge Notice) from the claimant, not to be confused with a (Penalty Charge Notice) issued by councils around the country.
The driver agreed to pay within 28 days and did not.
The Defendant will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services [2016] B9GF0A9E case where the judge said stopping/delivering is not parking.

KeithP

Why have you now added that sentence in quotes?

Robbo25

KeithP said:

Why have you now added that sentence in quotes?

Removed them.

Fruitcake

Robbo25 said:

Fruitcake said:

I suggest you remove 3 (a).

When I say remove 3 (a), I mean remove 3 (a), not the sentence that comes after it.

This will be paragraph 3.

3.  On the 05/09/2019 the driver was delivering a washing machine to a tenant of 
Then to his surprise the defendant later received an Invoice/PCN (Parking Charge Notice) from the claimant, not to be confused with a (Penalty Charge Notice) issued by councils around the country.
The driver agreed to pay within 28 days and did not.
The Defendant will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard [2016] B9GF0A9E (Services) case where the judge said stopping/delivering is not parking.

The word (Services) is in the wrong place.

Either say Jopson v Homeguard, or Laura Jopson v Homeguard Services.

Robbo25

KeithP said:

Why have you now added that sentence in quotes?

Robbo25 said:

KeithP said:

Why have you now added that sentence in quotes?

Removed them.

Is this adequate now?

KeithP

Robbo25 said:

KeithP said:

Why have you now added that sentence in quotes?

Robbo25 said:

KeithP said:

Why have you now added that sentence in quotes?

Removed them.

Is this adequate now?

I simply don't know.

Every time you show us something it differs in some way from what has been suggested.

You are about to send an official document to Her Majesty's Court Service.

You really really must try and think about what you are doing, rather than just throwing stuff at us and saying "is that ok?"

You've had plenty of help and guidance. You must do some thinking now.

Redx

If it was a postal invoice several weeks later , say so , received a postal invoice

If necessary , split it into 2 paragraphs numbered 3 & 4

Robbo25

Robbo25 said:

KeithP said:

Why have you now added that sentence in quotes?

Robbo25 said:

KeithP said:

Why have you now added that sentence in quotes?

Removed them.

Is this adequate now?

3.  On the 05/09/2019 the driver was delivering a washing machine to a tenant of 
Then to his surprise the defendant later received an Invoice/PCN (Parking Charge Notice) from the claimant, not to be confused with a (Penalty Charge Notice) issued by councils around the country.
The driver agreed to pay within 28 days and did not.
The Defendant will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services [2016] B9GF0A9E case where the judge said stopping/delivering is not parking.

Robbo25

Redx said:

If it was a postal invoice several weeks later , say so , received a postal invoice

If necessary , split it into 2 paragraphs numbered 3 & 4

3.  On the 05/09/2019 the driver was delivering a washing machine to a tenant of 
Then to his surprise the defendant later received a postal invoice/PCN (Parking Charge Notice) some weeks later from the claimant, not to be confused with a (Penalty Charge Notice) issued by councils around the country.
The driver agreed to pay within 28 days and did not.

4.  The Defendant will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services [2016] B9GF0A9E case where the judge said stopping/delivering is not parking.