Received a Claim Form for an ANPR "fine" for £260.00, and don't think there's much of a defense?

1505grandad

"5. I drove into Parc Tawe North as per the claimant’s records.............."

However you then state:-

Para 30  -  "The driver has not been identified.........."

mylampisonthetable

> I would not call it 'two car parks' as you did near the start, because it's your case that the place looks like one car park.

Yes, that's absolutely a good shout. I'll adjust.

> 28 says ParkingEye by mistake!

Oops! Fixed.

> 29 and 31 make no sense because adding costs is not 'double dipping' - that is the phrase for visiting a car park twice.  Not relevant.

I am a bit confused about this. Can you please re-read and let me know if (a) it all needs to come out or (b) it just needs to be reworded?

> I didn't notice yet in this draft, the usual stuff we now say to use, about thd DLUHC and what they said about the false added 'debt fee'.  Copy the end half of the first WS by @ricky_balboa instead, as that's the latest wording about the added fake costs.

Can you please clarify the title of the thread I should be looking at in this person's history? And it would be helpful also to know which page number in the thread.

> You've mentioned Excel v Wilkinson but not attached it.  You must attach transcripts of cases if relying on them.

As in, the URL? Or a paraphrase? Or a quote?

> You need an index or cover sheet, and you need your costs.  See the thread I mentioned for what the whole bundle looks like.

It's a remote hearing so I don't think there is much in the way of costs to claim. In fact I've read elsewhere that defendants are often being rebuffed in hearings in regards to costs. Is it really worth pressing this?

Jenni_D

Costs - if you don't ask, you don't get.

WS structure/index sheet - see the relevant thread started by @jrhys (the name is a link to their profile). Same applies for the DLUHC wording - the name in C-m's post is a link

Excel v Wilkinson - if you are referencing another court case in support of your own, then you need to attach the transcript of it to your WS. I'm not sure how that can be any clearer. (A link, paraphrase or quote is not an attachment). The transcript is easily found.

Double dipping - this is a forum term for an ANPR camera catching a vehicle that visits twice but only records the first entry and last exit. Your 29 and 31 are more about double recovery, but the DLUHC comment supersedes this. So remove/reword as necessary using the DLUHC wording already mentioned

Coupon-mad

You don't need titles of threads when we give you the hyperlink to a poster's profile, which gives you their threads.  We've no idea without looking ourselves, what the title of their thread is, and us going looking defeats the object, which is for you to click on their username and go read their thread and learn from and use it.

mylampisonthetable

To clarify, is this jrhys' WS? https://drive.google.com/file/d/10_T0OSPwcewp5MrODOIvxFOa1GSKa7Oz/view

And is this ricky_balboa's WS (the second half I should be copying, points 17-37)? https://forums.moneysavingexpert.com/discussion/comment/79051082/#Comment_79051082

mylampisonthetable

Did I find the correct links?

Coupon-mad

You'll know once you read them.  That's the point of you looking for them, to copy and learn from them.

mylampisonthetable

OK here's draft 2 and I have a few hours left before I need to send it off.

https://www.dropbox.com/s/306yjoys4udfvjv/BW Legal Parking WS Review 2.pdf?dl=0

I have not yet attached a transcript of Wilkinson, and am struggling to do so therefore I might sent it by email as a separate attachment.

BTW I've already picked up on the weird numbering and am resolving it now.

Jenni_D

A few hours? If it was due today and you hadn't filed it by 4pm then there's no advantage in filing it before midnight as nobody will be there to process it. File it tomorrow morning after 9am.

Coupon-mad

You can only attach it as a separate document if it goes with the WS and everything else and is given an exhibit number and is referred to by exhibit number in your WS and added to the exhibits list at the top.

The other thing your draft lacks that could be quickly added is an intro like this one:

1.         I am Mr xxxx of xxxxxx and I am the defendant against whom this claim is made. The facts below are true to the best of my belief and my account has been prepared based upon my own knowledge. 

 2.         In my statement I shall refer to exhibits within the evidence supplied with this statement, referring to page and reference numbers where appropriate. My defence is repeated and I will say as follows: 

 

Email it all first thing (as long as the WS is signed & dated) to the local court (NOT the CCBC) and copy into the same email, the solicitor for the Claimant.