Preparing a Defence for UK Park management

Daiapolon2021

great! Here is the revised version https://www.dropbox.com/s/vrmaql7u78hjoul/WS IPC v3.pdf?dl=0 any more comments @Coupon-mad ?

1505grandad

"33. It is submitted that, whilst a delay in payment occurred,........"

Does that refer to a payment that was supposed to have been made in the car park?

Daiapolon2021

@1505grandad no actually I need to amend that. Thanks for pointing it out.

Daiapolon2021

Hi all I am finalising my WS. I still don't know if the C paid the fee and the Court does not seem to answer on the phone. Any way I can check that? Once I do finish my WS what is the formality to send it? Do I need a cover email and send it to C and their lawyers and court via email? I am looking through the forum posts but I want to make sure I get it right for IPC. My hearing is 14 July, and as it says send all 14 days before I think 30 June 4pm is the cut off date. Can anyone please advise? I will keep researching of course but want to be 100% sure I get this right and not bin all the work and help!

Jenni_D

You email it to the court (Subject: Claim Ref: XXXXXXXXX Defendant's Witness Statement/Evidence) and also to the Claimant. If the C is using a legal then you email it to the legal rather than the C. Send to both parties using the same email (i.e. 2 recipients)

Google for the court's email address if you don't already have it. You DO NOT email the WS to the CCBC - they play no further part in this.

Coupon-mad

Point #7 is confusing as it sounds like you took a photo on the day of the parking event.  I think you mean this was part of your evidence-gathering visit on 7th June? If so, say so.

Daiapolon2021

here is the latest version https://www.dropbox.com/home/UKCPM?preview=WS+IPC+v4.pdf. All comments welcome. 

I received the WS from the solicitor. It says I stated to be lessee / hirer and also confirmed to be the RK in the appeal. Does this have any relevance for my case? Anything else to be careful on the WS I received? Thanks!

Le_Kirk

Daiapolon2021 said:

I received the WS from the solicitor. It says I stated to be lessee / hirer and also confirmed to be the RK in the appeal. Does this have any relevance for my case? Anything else to be careful on the WS I received? Thanks!

You cannot be the RK if you are lessee/hirer!  The relevance is that the claimant got it wrong; if they got that wrong, how much more is wrong or made up?  Can the court trust the claimant's WS?

Coupon-mad

You should be going through their WS, spotting the holes in their evidence and responding in your WS.  Assuming that by taking an extra day to do that, you are not making your filing and serving of this bundle late.

Daiapolon2021

btw Claimant will not attend. Is that normal or good for me?