Liverpool Airport VCS PCN: Some questions re: Defence

VeryOldBailey

I now have a date for a hearing in the Crown Court.

I have also recently received a letter from VCS offering to accept £192 as a reduced settlement charge. I have no interest in paying that.

Am I right in thinking there's something called a drop hands offer in which VCS agrees to withdraw its claim and both sides meet their own costs?

If so, is there a form of words to use when contacting VCS to make such an offer?

Umkomaas

It won't be the Crown Court, unless they are co-located.  The County Court hears cases on the small claims track. 

Drop hands is an offer you can make (make sure your letter is headed 'Without Prejudice Save as to Costs'). There is no template, but a forum search might find one that's been used previously. 

The forum search function is powerful, but not intuitive, so follow the steps in the link below to get the most effective results from it. 

https://forums.moneysavingexpert.com/discussion/6289402/weve-updated-the-search-function/p1

VeryOldBailey

Umkomaas said:

It won't be the Crown Court, unless they are co-located.  The County Court hears cases on the small claims track.

You're right, of course. It is the County Court.

Thank you for the search link.

VeryOldBailey

VCS have rejected my 'drop hands' offer.

I would be grateful if someone could advise me on some questions I have concerning the WS as I'm at the stage where I'm bringing it all together (I think!)

1. Should there be a cover sheet?
2. How big should photographs, screenshots, etc.be?
3. When should an exhibit include the whole transcript of a case and when will a hyperlink or relevant excerpts be sufficient?
   
4. Is a skeleton defence argument (written in this case by a first-timer) superfluous / a nice thing to have / essential? And could it do more harm than good?
5. What is the best way to make my WS available to the kind people on this forum who could point out my errors and suggest improvements?
6. Is it permissable to paste a copy of my signature in the relevant place(s)?
7. I understand that some claimants refuse to accept bundles via email. Are they within their rights? Can I make the same stipulation of them?

I've probably forgotten some things I wanted to ask - please forgive my ignorance.

Sincere thanks in advance for any help you can give me.

Coupon-mad

A skeleton is good if you have lots of case law you want to append, but not needed usually.

Examples of WS bundles are in the threads by @jrhys (2021 but shows the cover sheet, costs assessment and bundle) and @ricky_balboa (his first WS, which includes the wording about the DLUHC banning debt recovery fake fees that 2021 versions, of course, don't have).

VeryOldBailey

Thank you very much @Coupon-mad.

DisruptiveLad

The case has been brought on a fraudulent claim. VCS has NO contract with LJLA. The airport's own parking Ts and Cs make it clear where VCS can operate. It is fraudulent - and that's not just me who has established that.

Coupon-mad

Do NOT accuse a Claimant of fraud.  Never.  Look what happened in the OPS v Wilshaw appeal (Google it).

VeryOldBailey

Please can you tell me which of the following is correct:

1. In my 'bundle' I need to send a copy of my WS to the court and the claimants.
2. In my 'bundle' I need to send a copy of my Defence as well as my WS to the court and the claimants.

Or is there something I've forgotten?

KeithP

VeryOldBailey said:

Please can you tell me which of the following is correct:

1. In my 'bundle' I need to send a copy of my WS to the court and the claimants.
2. In my 'bundle' I need to send a copy of my Defence as well as my WS to the court and the claimants.

Or is there something I've forgotten?

Either of those is ok.
I would use option 2 for a bit of belt and braces effect.

Of course you won't forget your evidence and costs schedule, will you?