JLA "Stopping" Charge

Fruitcake

That's a good solid piece of work. I noticed a grammatical error in para 4 of the WS,

"... this was avoided this ..."

Where you have included GSV images, I suggest you leave in the image capture date at the bottom as yours all appear to have been cropped out.

My apologies if I missed it, but have you mentioned that contracts are formed by signage, and amendments to the Ts and Cs  cannot be made afterwards? The signs mention the charge for stopping in a no stopping zone, but don't show the fake add-ons at all, let alone the amount. 
I think Thornton vs Shoe Lane, and Lord Denning's "Red hand rule" apply.
The claimant can't add on the fake admin or debt collection charges if they are not specified on the signs.

Router66

Thanks for your feedback @Fruitcake. Good spot with the grammar error, now corrected in my own file.
'amendments to the Ts and Cs  cannot be made afterwards?'
I have alluded to this on page 15 but not as explicitly as you. (I have re-worded based on your comments.)

Fruitcake

I didn't check, but have you included transcripts of the cases you have quoted in your WS as exhibits?

It's only a minor point, but the "Road Safety Unit" camera car is carrying out covert surveillance, and not stating on the van what the data will be used for is a breach of the CCTV CoP.

1505grandad

Not sure if it actually matters but there is not a para #21

Router66

Thanks@1505grandad...Eagle eyed as always. It was a pain re-numbering all the paras but now done.
@fruitcake, thanks again to you, also; I have linked the covert van point between the Introduction and Page 9.

I plan to append a second pdf containing the transcripts, the VCS contract and the GSV exhibits, with capture dates. The only reason they were cropped was to better display the image without having to zoom in.
I can stitch the second pdf to the first after page 33 so only one file going to VCS and the court.
I have only specifically made reference Thornton (on Page 15, in the text box under the signs)...is it OK just to add the page 14 transcripts for Spurling and Vine or do I need to elaborate more on why they are relevant?
I would prefer not to try and shoehorn-in any further arguments unless it is deemed important to do so.

 As always your help is much appreciated.
 

Router66

https://www.dropbox.com/s/0zvc0q9mb23w2d1/Redacted Final WS With Appendments - Copy.pdf?dl=0



Final Witness Statement is ready to go (thanks @Fruitcake and @1505grandad for your help)
Since I posted the draft I have appended the Transcripts, GSV Exhibits with missing capture dates and the VCS contract that they appear to be relying on. 
I note on a couple of the transcripts there is a warning about publishing without permission...I presume it is OK to include them since they are for the benefit of the court? I hope to submit the WS to the court and VCS this afternoon by Email. If I am missing anything please let me know.
Thanks. 

Coupon-mad

You don't put your defence into the bundle.  All parties/court have that already.

I can't see the usual headings? Claim number, court location, date of hearing, parties' names, etc.

Does every paragraph of the WS have a number and all pages are numbered?

Router66

You don't put your defence into the bundle.  All parties/court have that already. 
I did think it was overkill but another poster asked the question and was advised it was ok to do so. I must have misunderstood!
What are the consequences of leaving it in? I have cross referenced defence points with exhibits so it will be a pain to amend.
However I will do whatever you recommend. I have taken out the headings as part of the redaction process. Claim no. date of hearing and defendants name are all on the version going to The Court and claimant. All the paras and pages are numbered in the actual WS. I have appended the transcripts after the Statement of Truth; they were already in pdf form and don't contain page nos. or paragraph numbers.  

Umkomaas

What are the consequences of leaving it in? I have cross referenced defence points with exhibits so it will be a pain to amend.

There'll be no detriment, and if in having to re-jig paragraph numbers and cross references as a result, you might end up with far more problems than just leaving it in and letting it ride. 

Router66

Thanks Umkomaas, that's the pickle I got myself into when @1505grandad found I'd jumped from Para 20 to Para 22...