Court defence

Le_Kirk

What is wrong with the suggestion that @KeithP made?  You are given suggestions and then seem to make up some of your own.  Whatever you put needs to make sense and be grammatical.  You cannot start a sentence with "so"; your statement about "Liability is denied" just sits there on it's own with no connection to any part of a sentence or paragraph;  you've also put a full stop after "incident" and then start a sentence with "and".

D_P_Dance

Le Kirk is right, you need to get a grip on this, these companies ruin lives.  

kfrs9960

Redx said:

Liability must be denied , so not that one

This is why I didn't use this one.
I'm sorry, as I've said before my grammar isn't the best, but I am trying to take on board the suggestions of the forum members and combine bits from other peoples defences on this Forum. I'm finding this all very stressful situation. I have written many versions of section #2 so now I'm getting confused.
This is the last draft I made:

2.       It is admitted that the Defendant was the registered keeper of the vehicle in question. The Defendant was working night shifts, so was actually sleeping at home at the time of the alleged incident and could not possibly have been the driver. Liability is denied.  

3,      The Defendant first heard about this parking charge in Apr 2020 when they received a Notice To Keeper letter and  since that date have felt harassed by the constant bombardment of ‘debt recovery’ letters.  The defendant cannot be held liable due to the Claimant failing to comply with the keeper liability requirements of the Protection of Freedoms Act 2012 (“The Act”), Schedule 4, including paragraph 9 (2) (f). The Defendant also denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention, they would have been made such a requirement part of The Act.

Redx

In 2 , add this after the word question

but not the driver

Change the last part in 2 to

been the driver so keeper liability is denied

Then repost to see if we can all agree it or if further changes need to be made

nosferatu1001

2  It is admitted that the Defendant was the registered keeper of the vehicle in question, but was not the driver. The Defendant was working night shifts on the material date, and was in fact at home, asleep. Liability is denied.  

3 The defendant cannot be held liable due to the Claimant failing to comply with the keeper liability requirements of the Protection of Freedoms Act 2012 (“The Act”), Schedule 4, including paragraph 9 (2) (f). The Defendant also denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of Parliament, they would have made such a requirement part of The Act.

4,      The Defendant first heard about this parking charge in Apr 2020 when they received a "Notice To Keeper", and since that date have felt harassed by the constant bombardment of ‘debt recovery’ letters. This car park is a pay and display / whatever and the Defendant is accused of .... 

Try that

The bit in bold is the background we usually suggest including

kfrs9960

nosferatu1001 said:

2  It is admitted that the Defendant was the registered keeper of the vehicle in question, but was not the driver. The Defendant was working night shifts on the material date, and was in fact at home, asleep. Liability is denied.  

3 The defendant cannot be held liable due to the Claimant failing to comply with the keeper liability requirements of the Protection of Freedoms Act 2012 (“The Act”), Schedule 4, including paragraph 9 (2) (f). The Defendant also denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of Parliament, they would have made such a requirement part of The Act.

4,      The Defendant first heard about this parking charge in Apr 2020 when they received a "Notice To Keeper", and since that date have felt harassed by the constant bombardment of ‘debt recovery’ letters. This car park is a pay and display / whatever and the Defendant is accused of .... 

Try that

The bit in bold is the background we usually suggest including

Thank you,
That now makes sense, a lot better than I could write.
Do I need to include the bold section as the NTK was by ANPR ?
The car park was a max stay for 30 mins. no return within 2 hours. 
Do I need to repeat my defence again?

kfrs9960

nosferatu1001 said:

2  It is admitted that the Defendant was the registered keeper of the vehicle in question, but was not the driver. The Defendant was working night shifts on the material date, and was in fact at home, asleep. Liability is denied.  

3 The defendant cannot be held liable due to the Claimant failing to comply with the keeper liability requirements of the Protection of Freedoms Act 2012 (“The Act”), Schedule 4, including paragraph 9 (2) (f). The Defendant also denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of Parliament, they would have made such a requirement part of The Act.

4,      The Defendant first heard about this parking charge in Apr 2020 when they received a "Notice To Keeper", and since that date have felt harassed by the constant bombardment of ‘debt recovery’ letters. This car park is a pay and display / whatever and the Defendant is accused of .... 

Try that

The bit in bold is the background we usually suggest including

I think I will use 2 & 3 in my defence (The way its worded is better than mine version), if I can figure out how to I word section 4 I might add it

kfrs9960

Defence submitted and auto response. re. acknowledgment received.
Thank you everyone for your help and advice

kfrs9960

Sorry forgot to ask do i need to do anything on the 'Money claim online' site or is this email /acknowledgment sufficient?

Le_Kirk

Do not put anything in the box on MCOL - not even a full stop!