Yet another UKPC / DCB Legal LTD - WS Bundle

KeithP

aphex007 said:

Is it appropriate to add to paragraph #2 the following in bold (not in bold on the submitted one though!):

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

No need to add that. Surely you will be referring to them as the Claimant throughout.

aphex007

Yeah good point @KeithP thanks.  Any other thoughts on my other draft paragraphs I posted?  Or is it best I get a more complete draft including photos, posted up as soon as I can?

Coupon-mad

A fuller draft with some photos will get more people looking, I expect.

Fruitcake

Normally you would just write, UK Parking Control Ltd (UKPC) the first time you use it, then just UKPC thereafter.

Use the same format for anything where you use the full version first then just the initials/abbreviation for things like, NTK, PoFA 2012 etcetera.

Rather than say things like, "I did not see ..." it might be better to phrase it as something like "There were no signs/surface markings/kerb markings visible ... and the claimant is put to strict proof that the opposite is true.

aphex007

Fruitcake said:

Normally you would just write, UK Parking Control Ltd (UKPC) the first time you use it, then just UKPC thereafter.

Use the same format for anything where you use the full version first then just the initials/abbreviation for things like, NTK, PoFA 2012 etcetera.

Rather than say things like, "I did not see ..." it might be better to phrase it as something like "There were no signs/surface markings/kerb markings visible ... and the claimant is put to strict proof that the opposite is true.

Thanks at @Fruitcake so your suggestion above or @KeithP suggestion of "the Claimant" would equally be acceptable then?

Coupon-mad

Either is fine.

aphex007

Coupon-mad said:

Either is fine.

Thanks @Coupon-mad

aphex007

Hi Team ,

As ever I would be very grateful if you good people could take a look at my Draft WS Bundle (redacted).  My deadline is fast approaching!

Please note I have redacted the photos (only for this version) and I will also be adding an auto stamped date and time to my own photos, as wisely suggested by @patient_dream and @Coupon-mad

Initially I'm not really sure about the CPR 44.11 - further costs that may be allowed and I certainly do not want to annoy the Judge over that.  I'm also unsure about my wording in paragraph 40 in regards to this and/or if it is even appropriate?

OK this is the NEW download link (no requirement to click on agreements):

Draft WS Bundle (redacted)

See Page 15 for v2

Le_Kirk

Your link requires us to click on various hyperlinks to agree stuff which I will not do.  Can you post a clean link?

aphex007

Le_Kirk said:

Your link requires us to click on various hyperlinks to agree stuff which I will not do.  Can you post a clean link?

@Le_Kirk all sorted now - thanks.