Another Parking Fine @ Wise Campus Bristol

KeithP

I suggest you drop the word further from your paragraph 4.
It implies something you may not want to imply.

suckyfish

Thanks Keith! Any other suggestions?

suckyfish

Hi team, 

So I have my telephone hearing coming up in January and I am working on my witness statement. I had a question about whether I need to post my witness statement etc to the courts/Gladstones or whether email is enough? Looking at NEWBIES seems to suggest that email is fine for a telephone hearing but I have seen elsewhere people still sending by post? The thing is I am going abroad to visit family over Christmas, if I can email I will have more time to work on my witness statement as I will have my laptop with me while away. If I have to post however, I'll have to get it in before I leave next week. Can any of you clear this one up for me? 

Coupon-mad

Email is fine.  Don't use the CCBC email of course as that's not your local court.

Recent good example WS are in the threads by @jrhys and @Nosy.

suckyfish

Hey there,

Would one of you good people mind taking a look over the first draft of my witness statement?

https://drive.google.com/file/d/1p69ekPEad-Q9OrrHo7zg9a0CgS-Ga5np/view?usp=sharing

Le_Kirk

6. This is where the ANPR photograph of the vehicle was taken. In the initial PCN the Claimant refers to signage. The photograph of my the vehicle shown on the PCN (exhibit XX-03), the enhanced copy of which (exhibit XX-04) as provided by the Claimant following a Subject Access Request in August 2021, shows there are no visible signs at the entrance to the parking area at the date and time in question.

I might adjust as shown; by saying "my vehicle", you might imply you were driving!

Coupon-mad

Have a look at the other case I just replied on, where the OP was advised to add another transcript and the stuff from Clive Betts from the recent Select Committee, and the PAP that says the pre-action stage is not to be used as an excuse to 'run up costs'.  They need to add more than their draft so don't just copy their half-done effort.

Search the forum for 'run up costs' and you should find my entire post about it from earlier this month.  I quoted the PAP rules and people should use the lot.

You are also missing the second transcript the other poster was advised to use, Firescu-whatever by Recorder Cohen QC.

Plus you are missing the entire argument about 'no keeper liability'.

You must quote from the POFA (para 8 if there was a windscreen PCN first, or para 9 if no windscreen PCN) and point out that the NTK is driver liability only.

Did you spot that already, I assume not because you've not said as much in this WS?

Read that NTK and don't ask how I know it's driver only...read it again if you miss it.

suckyfish

Thank you!

Unfortunately the company were compliant with POFA with their NTK so I've been advised on this thread that the 'no keeper liability' avenue is a no-go for me. 

I will read through the posts you suggested and adjust accordingly.

KeithP

suckyfish said:

Unfortunately the company were compliant with POFA with their NTK so I've been advised on this thread that the 'no keeper liability' avenue is a no-go for me. 

That's the first time that has been mentioned on this thread.

Are you sure the NtK is POFA compliant?

Coupon-mad

We can all see it is not a POFA NTK...I did say:

Read that NTK and don't ask how I know it's driver only...read it again if you miss it.

There is a big clue - hint - look for the word 'driver' low down on page one.