County Court Business Centre Claim & Civil Enforcement.

silvial

Could anyone advice what with the other paragraphs in the defence. Should I change them?

silvial

1505grandad said:

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

Thank you. I've missed it.

KeithP

silvial said:

Could anyone advice what with the other paragraphs in the defence. Should I change them?

Tell us what you are proposing to change.

silvial

KeithP said:

silvial said:

Could anyone advice what with the other paragraphs in the defence. Should I change them?

Tell us what you are proposing to change.

I honestly don't know. Are they staying same?

silvial

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 and stayed in the van to rest between delivering goods to customers. As the signage was not visible and being poorly lit, the Defendant was not aware of the necessity of payment. 

Is this ok? Or should I change it? Any comments are welcome, please?

Coupon-mad

You could add an extra point 4, then change the numbering below it, quoting from the right version of the BPA Code of Practice that applied at the time, about signs having to be lit if wanting contractual terms to apply during hours of darkness.

You can Google for the right version, easy as they are all on the BPA website.

Redx

silvial said:

KeithP said:

silvial said:

Could anyone advice what with the other paragraphs in the defence. Should I change them?

Tell us what you are proposing to change.

I honestly don't know. Are they staying same?

They usually remain unchanged, apart from the numbering which does usually change once paragraph 2 onwards has been cleared for use, meaning approved

most people have between 3 and 5 paragraphs in place of 2 & 3 , then renumber from the old 4 after slotting them into the rest of the template defence

we rarely if ever advise anyone to change the rest of the template defence

silvial

Thank you very much for your reply and advice. I just went on the crime scene :-) and they actually changed all the signage. Before, on the fence there was only one in Turkish and now they removed it and put one in English and another big signage next to it. I do not have any photos evidence from before as the one I’ve posted previously was from google images.

silvial

Now there more visible 

silvial

Therefore I don’t know if my defence will be good enough?