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Help Needed - Defence for PPS PCN -WS Stage

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  • Umkomaas
    Umkomaas Posts: 43,886 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    No benefit in delaying sending. 
    Please note, we are not a legal advice forum. I personally don't get involved in critiquing court case Defences/Witness Statements, so unable to help on that front. Please don't ask. .

    I provide only my personal opinion, it is not a legal opinion, it is simply a personal one. I am not a lawyer.

    Give a man a fish, and you feed him for a day; show him how to catch fish, and you feed him for a lifetime.

    Private Parking Firms - Killing the High Street
  • I have received a Notice of Trial Date. The trial will be virtual via Teams and it will be held on 17 feb 2022. Could you please guide me about what I need to submit before that.
  • Coupon-mad
    Coupon-mad Posts: 155,731 Forumite
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    WS and evidence as per the NEWBIES thread guidance.
    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
  • Le_Kirk
    Le_Kirk Posts: 25,283 Forumite
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    Goodboy18 said:
    I have received a Notice of Trial Date. The trial will be virtual via Teams and it will be held on 17 feb 2022. Could you please guide me about what I need to submit before that.
    It is not a trial it is a hearing!
  • KeithP
    KeithP Posts: 41,296 Forumite
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    Le_Kirk said:
    Goodboy18 said:
    I have received a Notice of Trial Date. The trial will be virtual via Teams and it will be held on 17 feb 2022. Could you please guide me about what I need to submit before that.
    It is not a trial it is a hearing!
    Google N172.      ;)
  • Le_Kirk
    Le_Kirk Posts: 25,283 Forumite
    Part of the Furniture 10,000 Posts Photogenic Name Dropper
    I stand corrected - well actually I am sitting down.
  • Goodboy18
    Goodboy18 Posts: 24 Forumite
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    edited 30 January 2022 at 5:38PM
    WS stage:

    I have now got claimant's witness and I have redacted and uploaded it here:
    hxxps://www.dropbox.com/s/0ekxbc5o22n1pyb/Claimant%20-%20Witness%20Statement-redacted.pdf?dl=0

    The defence tht I had submitted:
    hxxps://www.dropbox.com/s/pttexk7ck1h72n5/Defence%20Letter-%20redacted.pdf?dl=0

    I would request if you can help on what all points should I expand in my WS based on C's WS:
    C has included wall plate (pg 14) in exhibits which is not at the site as seen the real pics.
    None of the parking plates are illuminated and the font on t&c is very small, i will include the beavis case wall plate image for comparison
    For the address difference - google maps clearly shows the odd numbered address are on one side of the road and even on other. My car has been pictured on the even numbered side of the road and the address mentioned on all their documentation is odd number -145. I will include google maps picture of the area.
    My defence is based on keeper liabililty, what should I write in sequence of events?



  • KeithP
    KeithP Posts: 41,296 Forumite
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    Goodboy18 said:
    I have now got claimant's witness statement
    When is the deadline for filing your Witness Statement and evidence?

    I am concerned that you have received the Claimant's Witness Statement.
    They have the same deadline as you and usually leave it to the last minute.
  • KeithP said:
    Goodboy18 said:
    I have now got claimant's witness statement
    When is the deadline for filing your Witness Statement and evidence?

    I am concerned that you have received the Claimant's Witness Statement.
    They have the same deadline as you and usually leave it to the last minute.
    The hearing is on 17 Feb, so that will give me upto 03 Feb isnt it?
  • KeithP
    KeithP Posts: 41,296 Forumite
    Part of the Furniture 10,000 Posts Name Dropper
    edited 30 January 2022 at 6:42PM
    Goodboy18 said:
    KeithP said:
    Goodboy18 said:
    I have now got claimant's witness statement
    When is the deadline for filing your Witness Statement and evidence?

    I am concerned that you have received the Claimant's Witness Statement.
    They have the same deadline as you and usually leave it to the last minute.
    The hearing is on 17 Feb, so that will give me upto 03 Feb isnt it?

    No-one here can answer that question.

    Often the filing deadline is 14 days before the hearing but it is very unwise to assume that.

    Look again at your Notice of Allocation. The Notice that gives the hearing date.
    Is there not a paragraph something like:
    Each party must deliver to every other party and to the court office copies of all documents on which he intends to rely at the hearing no later than [ . . . ] [14 days before the hearing].
    Might be on the back.
    Those documents on which you intend to rely are your Witness Statement and evidence.
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