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Defence Witness statement help required

Hello All.  Thank you for all the help made available on this forum. 

I used CouponMad's defence template to submit a defence pre court action and have now received a court date with a condescending response from BW L representing Link Parking, directly challenging this forum's advice. (see images below)
I would be grateful for some help in presenting a response.

Details:
Received PCN from a predatory parking attendant on Christmas Eve Dec 2019 for parking in a private commercial car park.  I was moving office stuff for an office relocation. Went into the office to get the permit to display on my windscreen but when i came out to place the permit, the PA had already placed a PCN and left.
Claim issued Oct 2020
AOS submitted Nov 2020
DQ filed Jan 21 (using CM's template)
Claim transferred to my local County Court
Hearing Date 30 June 21 in person at the court.
Witness Statement must be submitted by 15 April,

I am attaching the Claimant's WS and would appreciate help to prepare a Defence.
















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Comments

  • Coupon-mad
    Coupon-mad Posts: 158,123 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 11 April 2021 at 10:58PM
    I am attaching the Claimant's WS and would appreciate help to prepare a Defence.
    No, you've done your defence.  You are at WS and evidence stage and the NEWBIES thread already tells and shows you what that looks like.

    A recent good example from this week is the WS by @jrhys so read that one, too.

    The reply from BW is a template, you will find it again and again on BW court claim threads - yawn.  We don't need to read it.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • SayNoToPCN
    SayNoToPCN Posts: 301 Forumite
    100 Posts Name Dropper
    Yep,,it looks a lot like their usual prolix WS. 
  • Fruitcake
    Fruitcake Posts: 59,527 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Was that everything? I don't see a copy of the alleged landowner contract, or images of the car parked at the location.
    I married my cousin. I had to...
    I don't have a sister. :D
    All my screwdrivers are cordless.
    "You're Safety Is My Primary Concern Dear" - Laks
  • Armhh
    Armhh Posts: 16 Forumite
    10 Posts Name Dropper
    Thank you @Coupon-mad .  I will have a look. 

    @SayNoToPCN, what makes me laugh is that they accuse me of copy pasting from this forum, without understanding what it is I'm copying (threatening to test my understanding in court), but their own statement is copy pasted - this is evidenced by their different gender references when referring to me and they make a reference to my father-in-law - I don't even have a father-in-law!!
    It's extremely time-consuming and stressful for someone who has never had to deal with legal speak and this type of document preparation over a long and protracted period of time, and I guess they rely upon people just throwing their hands up and giving in.

    @Fruitcake I excluded the landowner contract and car parked images to prevent being identified.

    Thank you all for responding.
  • Coupon-mad
    Coupon-mad Posts: 158,123 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 11 April 2021 at 10:59PM
    We need to see the landowner contract, there are often issues with it.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • SayNoToPCN
    SayNoToPCN Posts: 301 Forumite
    100 Posts Name Dropper
    edited 12 April 2021 at 9:23AM
    everyone is instructed to show us the landowner contract though. Same as every thread. Its the one vital thing we need to see. Similarl;y the car park would help as well. 

    Contrary to some, these companies are not stupid; they are however parasites, using the cvourts as part of business. No reputable company providing a legit service would need to use the courts in this way, and as a result they treat the process as most business would - they are commodotising is. That means reducing costs whereever possible, and creating template "witness" statements, that legally are no such thing, is just one way they do so.
  • Fruitcake
    Fruitcake Posts: 59,527 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 12 April 2021 at 8:07AM
    Show us the whole of the scammer's WS and exhibits. Only redact YOUR personal data.
    Tell us if the scammers have redacted anything.
    Do not hide anything from us except YOUR personal data.

    Uploading it to dropbox or similar then posting the link will make it easier for us to read as well.
    I married my cousin. I had to...
    I don't have a sister. :D
    All my screwdrivers are cordless.
    "You're Safety Is My Primary Concern Dear" - Laks
  • SayNoToPCN
    SayNoToPCN Posts: 301 Forumite
    100 Posts Name Dropper
    AS above: do not. Do not. do not redact the scammers contract in any way shape or form. Yes, you can show it us. no, you do not have to worry about data protection. 
  • Armhh
    Armhh Posts: 16 Forumite
    10 Posts Name Dropper
    Link Parking Contract with the landlord:

  • Armhh
    Armhh Posts: 16 Forumite
    10 Posts Name Dropper
    Photo of my car parked in the carpark with a totally illegible sign way too high to read (I'm only 5'2")
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