County Court Business Centre Claim & Civil Enforcement.

Coupon-mad

It being dark and the signs being poorly lit and not visible is a strong defence point.  Better then saying a sign was in Welsh (I assume you mean).

You should say more.  What was the alleged breach: not paying and displaying because you believed it was a free car park, or overstaying paid for time, or not knowing it was permit holders only, or what?

Redx

Good advice , but I do believe that one of those signs is probably in Turkish , my analogy being if it was in Welsh , Gaelic , Esperanto , french or russian it wouldn't matter , as long as there was a sign in English , which there is in the pictures , so complaining about foreign languages won't help your case

Poor , inadequate and unlit signage , at night , yes

silvial

Redx said:

So the big question is , do CEL know who was driving ? Have you told CEL ? 

No, I haven’t replied to CEL at all.

silvial

Yes but when I’ve approached this car park from the front, the gate were both of the signage where displayed was widely  opened and therefore you could not see the signage properly but on the fence there was only one signage and it was not in English. So approaching the car park from the front you could actually only seen the Turkish signage clearly. And the other 2 would be on your left after entering it. So I don’t know. 

Coupon-mad

So adjust your defence to briefly make that clear and to add that it was pitch black, if it was, and in fact no terms were seen at all, nor anything to indicate that it was private land snd you should look for signs.

silvial

Thank you Coupon-mad and Redx for your advice. 

I have taken your adviced and not mentioned about the signage in different language. 
Do you think is this fine now? 
Or should I change something?
And also with regards to POFA not being complied where shoul I mentioned it?
And lastly shoul I change the other paragrafs?

Thank you for all your help. 

2. It is admitted that the Defendant was the registered keeper of the vehicle in question and was the courier driver at the time when PCN was issued but liability is denied.

3.  The signage of the car park was inadequate, not visible and poorly lit. Entering the car park in the dark no terms were seen by the defendant. The alleged breach between the Defendant and Civil Enforcement Ltd with regards to payment not made with terms displayed on signage, the Defendant believed that the car park was free. Assuming that the car park was free, the Defendant parked to rest there between delivering goods to customers. As the signage was not visible and being poorly lit, the Defendant was not aware that payment was needed in accordance with terms displayed on signage which was not seen at all and inadequate.

Le_Kirk

You used the term "reassuring" that the car park was free!  Did you mean "assuming"?  The rest of your paragraph #3 seems to be a reworking of itself with repeated sentences.

Coupon-mad

You can't use the POFA if you choose to admit to driving.

silvial

Le_Kirk said:

You used the term "reassuring" that the car park was free!  Did you mean "assuming"?  The rest of your paragraph #3 seems to be a reworking of itself with repeated sentences.

Thank you, yes I meant ''assuming''. And yes there are repeated in a way as I did not know what else to add ?

1505grandad

Add "but liability is denied" at the end of para 2