UK PARKING PATROL FORCE - RECEIVED CCJ

Le_Kirk

2. It is admitted that the Defendant was the keeper and driver of the hire vehicle registration: xx68 xxx vehicle in question but liability is denied. The Defendant does admit to being the driver of the hire vehicle registration: xx68 xxx.

Why not one sentence as above?

vnds_t

Some really good points made, I appreciate everyone's input so huge thank you to all. I think this has a nice flow to it now:

2.  It is admitted that the Defendant was the keeper and driver of the hire vehicle registration: xx68 xxx in question but liability is denied. 

3. The Defendant was attending the BOX PARK Wembley venue for an event as a seller with 200 pairs of shoes in shoeboxes, amongst multiple sellers also selling shoes. All sellers were recommended to park on Humphry Repton Lane, Wembley HA9 0GL by the event organisers. The organisers gave permission to unload and load at the venue for as long as it took, within reason. This was the first time this specific event was taking place in BOX PARK Wembley.

4. The Defendant arrived at Humphry Repton Lane in the morning of 24 November 2019. Due to the amount of sellers attempting to unload their stock simultaneously, the Defendant had to park his vehicle further down the road. Once the defendant parked his vehicle and entered the venue, he had to queue to receive a seller wristband, shown to a selling space and find tables within the venue to place stock before unloading.

5. After being allocated a selling space and finding tables, the Defendant amongst other sellers had to unload (and load in the evening) up to 200 shoeboxes each in the allotted time period, all through a narrow side door entrance. Not all the sellers were private sellers at the event, some were companies who were constructing and breaking down full exhibition stands so there were long waiting times to have access to the entrance of the location. As his vehicle was parked further down the road, walking stock towards the entrance took longer than it would have taken if the Defendant was able to unload closer to the entrance.

6. There were no prominent visible signs. During both the unload and load of his vehicle, there were many other large vehicles (both short and long-wheel based vans) parked on the same road at the same time, obscuring the view of the road due to the event taking place. During the load period, it was also dark and the area was not very well lit. 

7. The Defendant did not waste time or park his vehicle on Humphry Repton Lane for recreational purposes. Once the necessary work was completed, the vehicle was removed immediately.

If you think I need to change any wording to make it more snappier, please do let me know. Hoping to submit tomorrow.

Le_Kirk

I think you could make it snappier by removing a lot of the story and keeping it for the witness statement WS).  Keep the defence to short, punchy legal/technical arguments, almost like bullet points.  This opens the door for you to tell the whole narrative (story) later in the WS.  Keep paragraph 7 though, I like that.

vnds_t

Long time, hope you guys are well.

I have court in a few weeks, I've received a witness statement from BW Legal, it states this:

The defence appears to have been cut and pasted from websites containing parking forums, whose aim appears to be assist motorists on contesting parking charges notices on a variety of pre-determined technical basis, as witnessed by the Claimant's solicitors on a regular basis. One frequent used forum can be found on www.moneysupermarket.com.

Is this something I'll be asked about? If yes, what's the best way to answer?

Thanks.

Jenni_D

So what? (That's what a judge once said in a court hearing when a claimant made exactly that same comment).

If you've received their WS, have you completed and filed/served your WS? (You have exactly the same deadlines as they do). What have you been doing in the almost 10 months since you last posted in this thread?

vnds_t

Okay Jenni, thank you, just checking.
Yes completed my witness statement, thank you.
Waiting to attend court now, preparing myself for anything that comes up, is that okay?

Coupon-mad

Did you search the forum for a sentence or word from that WS to find this discussed before, and how to respond in your WS?

Have you sent your WS bundle already? That's a worry for us because things have changed a lot since 2021. The example WS in the NEWBIES thread is not up to date now.