I've made a Subject Access Request, they've sent me some info but is it enough?

nosferatu1001

If you know who the driver was, you canot state you do not. That should be obvious!
Dont use sub para. SIMPLE NUMBERING ONLY. Simply renumber the para after

Will44

Thanks all, I suppose the earlier stage of not admitting driving was hard to let go of!
The driver would have been myself or my partner, we genuinely can't remember who.

But maybe for the sake of argument it's easier to say I was the driver - that way I can concentrate on the fact that I returned to the car and bought a second ticket from the machine.

Ok, take 3:

2.       It is admitted that the Defendant was the registered keeper of the vehicle in question but liability is denied. The defendant was driving the vehicle on the date in question.

3. On the date in question – XXXX – the driver bought a ticket at the car park and went to the beach. The driver decided to stay longer on the beach, so went back to the car park before the first ticket expired and then bought a second ticket, which was also displayed in the vehicle.

4. Shortly afterwards the Defendant received a notice from the Claimant claiming a Parking Charge of £100 or £60 if paid within 14 days of the notice. The letter was unclear about why the Defendant was being charged other than providing the time the vehicle entered the car park and the time the vehicle departed the car park. It just said “Reason for issue: Session expired”.

5. The Defendant later discovered that on the same day friends and a family member had also received a similar Parking Charge notice despite having held tickets for the duration of their stay at the same car park.

6. The Defendant has since found evidence of multiple car park users at the same location buying tickets but still being issued Parking Charge notices. This evidence will be presented at the appropriate time.

7. Since the first letter the Defendant has been bombarded with multiple debts collection letters causing significant stress and anxiety. This whole process has also taken up hours of the Defendants time in terms of having to read through the legalities of this situation and make repeated requests for further information.

Thanks again

Redx

Seeing as you do not know which of you was driving , say so in 2 , that it could have been yourself or your partner , but cannot recollect on an unremarkable day a long time ago. This is not difficult !

You the defendant then become an occupant of the vehicle who bought a ticket and a second ticket etc !! So was a First person witness , driver or not !!

So change 3 onwards to being that occupant defendant and witness , explaining events on the day

Coupon-mad

The driver would have been myself or my partner, we genuinely can't remember who.

Then do NOT say you were driving.  The above (without the 'myself' or 'my' or 'we' which are not used in a defence written in the 3rd person) is what you say.  This has been covered in umpteen threads recently about the balance of probabilities not being tipped one way or the other, yadda, yadda, 

nosferatu1001

Gah! If you do not know who the drive rwas, then yolu CAN state that
What you cannot do is state you were the driver if you may not have been. 
You put them to strict proof of the identity of the driver, as well if you like 

Will44

Redx said:

Seeing as you do not know which of you was driving , say so in 2 , that it could have been yourself or your partner , but cannot recollect on an unremarkable day a long time ago. This is not difficult !

You the defendant then become an occupant of the vehicle who bought a ticket and a second ticket etc !! So was a First person witness , driver or not !!

So change 3 onwards to being that occupant defendant and witness , explaining events on the day

Thanks Redx.
So I've made your suggested change and also changed Defendant to Occupant in para 3.
Is that what you meant?

The facts as known to the Defendant:

2.       It is admitted that the Defendant was the registered keeper of the vehicle in question but liability is denied. It is not recalled who was driving the vehicle that day, it may have been the Defendant or the partner of the Defendant.

3. On the date in question – XXXX – the Occupant bought a ticket at the car park and went to the beach. The Occupant decided to stay longer on the beach, so went back to the car park before the first ticket expired and then bought a second ticket, which was also displayed in the vehicle.

4. Shortly afterwards the Defendant received a notice from the Claimant claiming a Parking Charge of £100 or £60 if paid within 14 days of the notice. The letter was unclear about why the Defendant was being charged other than providing the time the vehicle entered the car park and the time the vehicle departed the car park. It just said “Reason for issue: Session expired”.

5. The Defendant later discovered that on the same day friends and a family member had also received a similar Parking Charge notice despite having held tickets for the duration of their stay at the same car park.

6. The Defendant has since found evidence of multiple car park users at the same location buying tickets but still being issued Parking Charge notices. This evidence will be presented at the appropriate time.

7. Since the first letter the Defendant has been bombarded with multiple debts collection letters causing significant stress and anxiety. This whole process has also taken up hours of the Defendants time in terms of having to read through the legalities of this situation and make repeated requests for further information.

1505grandad

"3. On the date in question – XXXX –(the) Occupant bought a ticket ........."

That suggests there is only one occupant  -  the driver.
Use "an occupant" in places where (the occupant) is used  -  as per post by RedX

Le_Kirk

2.       It is admitted that the Defendant was the registered keeper of the vehicle in question but liability is denied. It is not recalled who was driving the vehicle that on an unremarkable day NN years ago, it may have been the Defendant or the partner of the Defendant.

Try the above.

Redx

As above , 3 is defendant , because the defendant was an occupant of the vehicle , there were 2 occupants , driver and passenger , but which person is which is unknown as in the last post above , but you the defendant bought 2 tickets , so that is definitely known whereas occupant is an unknown person , possibly the driver

2 looks better as per the rewrite above

Some of the other paragraphs seem to detract from the legal case as they are more of a rant , so I do not like them , but see what other comments you get after the amendments above are made

nosferatu1001

5,6,7 dont add any legal arguments. Ditch, to my mind