Claim Form Received BW Legal for Unauthorised Entry/Parking

brandsoda

I have drafted this schedule of cost, does it look good and do I need to produce at court or need to submit along with Witness statement ??

In the County Court at XXX

Claim Number: XXXXX

Hearing Date: XX/XX/2022

 

 

DEFENDANT’S SCHEDULE OF COSTS

 

Ordinary Costs

 

Loss of earnings through attendance at court hearing XX/XX/2022: £95.00

 

Further costs for Claimant’s misconduct, pursuant to Civil Procedure Rule 44.11

 

Research, preparation and drafting documents (16 hours at Litigant in Person rate of £19 per hour): £304

 

Stationary, printing, photocopying and postage: £31

 

 

 

TOTAL COSTS CLAIMED £430.00

 

 

Signature

…………………….

brandsoda

Also Do i need to share PCN received as in WS statement ??

1505grandad

Please make sure that any c & p elements are relevant to your case  -  i.e. para 8 refers to IPC

holderness

Just a very minor point but try to use the word stop or stopped rather than park or parked 

brandsoda

1505grandad said:

Please make sure that any c & p elements are relevant to your case  -  i.e. para 8 refers to IPC

thanks @1505grandad
Yes it's been picked up as C&P but certain part was relevant in my case so I used that. But I have other arguments and evidences in place so will better remove that.

While looking in to the concerned para I found few more issue like BPA CoP sections I used earlier were from older version(2012). now I am quoting according to newer version.

Jenni_D

I think the point being made was that if you refer to the IPC code of practice (I don't know if you do - I haven't read your WS), but the claimant is a BPA AOS member, then any references to the IPC CoP are irrelevant and you should pick up the BPA CoP relevant sections.

brandsoda

holderness said:

Just a very minor point but try to use the word stop or stopped rather than park or parked 

Thanks @holderness , I updated the WS for few instances as suggested. 

brandsoda

Jenni_D said:

I think the point being made was that if you refer to the IPC code of practice (I don't know if you do - I haven't read your WS), but the claimant is a BPA AOS member, then any references to the IPC CoP are irrelevant and you should pick up the BPA CoP relevant sections.

thanks @Jenni_D,   yes you are right in saying this, and I referred the section 19.2 as per BPA CoP

Jenni_D

You mean you've now changed your WS to refer to BPA CoP section 19.2? (Your WS as currently posted refers - in point 8 - to the IPC CoP).

Have you made sure to reference the correct version of the BPA CoP? (i.e. the version that was in force at the date or the PCN).

brandsoda

Jenni_D said:

You mean you've now changed your WS to refer to BPA CoP section 19.2? (Your WS as currently posted refers - in point 8 - to the IPC CoP).

Have you made sure to reference the correct version of the BPA CoP? (i.e. the version that was in force at the date or the PCN).

I have removed para 8 completely as there in another para mentioned about entrance and correct sign. I am referring BPA CoP Version 8 - January 2020 as the PCN is received on 08 NOv 2020.


12.     The BPA CoP Section 19.2 (exhibit xx-05) requires the Claimant to have a standard form of entrance sign at the entrance to the car park, which must follow some minimum general principles. Having inspected the site of the alleged contravention, the Defendant notes that the Claimant’s current entrance signage is positioned such that it cannot be read by drivers as they enter the car park.