Civil Enforcement Ltd - small claims court

Coupon-mad

 I was saying your point #3 actually tells the Judge who was driving and therefore exposes #2 as untrue. 

Woolmer67

Hi D_P_Dance 
No I haven’t. It was a private hotel so do you think it’s relevant? 

Woolmer67

Thanks Redx I have changed the wording as per your suggestion. Is this now 

The facts as known to the Defendant:

2.       It is admitted that the Defendant was the registered keeper of the vehicle in question but liability is denied. The vehicle is used by multiple drivers as it is a works vehicle and the defendant may or may not have been the driver on the day and there is no way to check after all this time.

 

3.  At the start of the contract the drivers were instructed to park in the car park of the hotel which was being refurbished and not open for business by the contractor who employed the defendant and their colleagues. When the defendant initially received a letter from the parking company the defendant’s employer told them to ignore it as it would be cancelled. All the trades people working on the hotel who had parked in the car park had received them. Eventually the hotel manager put bags over the parking cameras to stop the tickets being issued. The defendant has photographic evidence of this. The defendant felt harassed by the bombardment of ‘debt recovery’ letters as they thought that the ticket had been cancelled.

Woolmer67

sorry posted without finishing the sentence. I meant to ask if you thought this was now good enough to submit?

KeithP

Woolmer67 said:

The vehicle is used by multiple drivers as it is a works vehicle...

...

When the defendant initially received a letter from the parking company the defendant’s employer..

Sorry Woolmer, but I am struggling with this.

Are you, as an individual, the registered keeper of this vehicle, or are you, as a company, the registered keeper?

In other words, are you personally the Defendant?

Please be assured that I'm not trying to trip you up... just trying to save you being tripped up by the Court or the Claimant.

Redx

To clarify for me too

Why is your name in the frame ??
Who gave the parking company your name ?

We assume that you are the defendant , but I thought it was a hire vehicle so we have no idea why your name is in the frame. Did the hire company name you a hirer ?

As KeithP says , it's important to clear this up now , not later

Castle

Woolmer67 said:

Thanks Redx I have changed the wording as per your suggestion. Is this now 

The facts as known to the Defendant:

3.  At the start of the contract the drivers were instructed to park in the car park of the hotel which was being refurbished and not open for business by the contractor who employed the defendant and their colleagues. When the defendant initially received a letter from the parking company the defendant’s employer told them to ignore it as it would be cancelled. All the trades people working on the hotel who had parked in the car park had received them. Eventually the hotel manager put bags over the parking cameras to stop the tickets being issued. The defendant has photographic evidence of this. The defendant felt harassed by the bombardment of ‘debt recovery’ letters as they thought that the ticket had been cancelled.

So is the "contractor" your employer?

Woolmer67

Sorry for any confusion, I obviously haven't written it very well. I am the registered keeper. Myself and my colleagues use this van to go between jobs. 

Woolmer67

Hi Castle

Yes. The hotel was being renovated and the contract for some of the work was given to my employer. I am a carpenter and my employer told myself and colleagues to park in the hotel carpark. After a lot of PCNs were issued the hotel manager covered up the parking cameras with bags and we were told to ignore the tickets as they would be cancelled but they obviously weren't.

Umkomaas

Woolmer67 said:

Hi Castle

Yes. The hotel was being renovated and the contract for some of the work was given to my employer. I am a carpenter and my employer told myself and colleagues to park in the hotel carpark. After a lot of PCNs were issued the hotel manager covered up the parking cameras with bags and we were told to ignore the tickets as they would be cancelled but they obviously weren't.

Have you got back to the hotel manager about his seemingly failed promise/reassurance? Tell him you are now being sued through the courts and what is he going to do about that?