UKPC / DCB Legal

Le_Kirk

You need the updated statement of truth, see witness statements by  @jrhys and @Nosy for examples of style and format.

IloveElephants

KeithP said:

IloveElephants said:

As you can see the vehicle was parked parallel causing no obstruction in front of the small signage board.  

That seems to show that the vehicle was parked with the driver's nose about 6ft from a sign.

Is that a parking sign? What does it say?

And that is precisely the main point of my defence , bay markings and signage are key elements of the parking contract , so poor markings and a possible trap are in my favour. When I returned to the vehicle in 2018 I remember another vehicle parked next to me on my left hand side. Again faded markings on the ground, no clear markings, no signs saying park in the white bays, nothing.

IloveElephants

Le_Kirk said:

You need the updated statement of truth, see witness statements by  @jrhys and @Nosy for examples of style and format.

Hi Le Kirk,

Is Nosy a good example as he did not win his case? Other than formatting and style does my WS have the correct content and convey my argument across clearly? 

Thanks 

KeithP

IloveElephants said:

KeithP said:

IloveElephants said:

As you can see the vehicle was parked parallel causing no obstruction in front of the small signage board.  

That seems to show that the vehicle was parked with the driver's nose about 6ft from a sign.

Is that a parking sign? What does it say?

And that is precisely the main point of my defence , bay markings and signage are key elements of the parking contract , so poor markings and a possible trap are in my favour. When I returned to the vehicle in 2018 I remember another vehicle parked next to me on my left hand side. Again faded markings on the ground, no clear markings, no signs saying park in the white bays, nothing.

I don't quite understand why you are replying to a post I made almost three months ago, but I'll repeat what I said then...
The vehicle was parked right in front of a sign. 
Is that a parking sign? What does it say?

Le_Kirk

IloveElephants said:

Le_Kirk said:

You need the updated statement of truth, see witness statements by  @jrhys and @Nosy for examples of style and format.

Hi Le Kirk,

Is Nosy a good example as he did not win his case? Other than formatting and style does my WS have the correct content and convey my argument across clearly? 

Thanks 

There is another one that @Coupon-mad has been recommending and that is by @ricky_balboa 

IloveElephants

KeithP said:

I'll say it again...
The vehicle was parked right in front of a sign. 
Is that a parking sign? What does it say?

Hi Keith, this is my point excatly, the sign says 

MEMBERS PARKING ONLY 2 HOUR MAXIMUM STAY Terms of parking apply at all time, 

UKPC information line,

in the small print or on the board it does not mention anywhere of "do not park" or no where in the carpark or board does it say "park only in marked bays"

This is a trap and and has caught out many people. 

The image is from the SAR, this is the board that I parked in front off. 

IloveElephants

Le_Kirk said:

IloveElephants said:

Le_Kirk said:

You need the updated statement of truth, see witness statements by  @jrhys and @Nosy for examples of style and format.

Hi Le Kirk,

Is Nosy a good example as he did not win his case? Other than formatting and style does my WS have the correct content and convey my argument across clearly? 

Thanks 

There is another one that @Coupon-mad has been recommending and that is by @ricky_balboa 

Thank you Le Kirk, I will look at it

I had a look at Ricky balboas template document, its very clear and concise. I will add my WS and format it so it resembles something like that. 

Coupon-mad

@Nosy did win his case.  A great counterclaim case!  He's had two threads.  Maybe you read the wrong one, but a counterclaim WS isn't the best one for you anyway.

The most recent WS example is the one by Ricky (NOT his supplementary WS, his first one).  You need the stuff about the DLUHC.

IloveElephants

Coupon-mad said:

@Nosy did win his case.  A great counterclaim case!  He's had two threads.  Maybe you read the wrong one, but a counterclaim WS isn't the best one for you anyway.

The most recent WS example is the one by Ricky (NOT his supplementary WS, his first one).  You need the stuff about the DLUHC.

Hi Coupon-mad, 

Thanks for clarifying about Nosy winning his case. Great work!

I have downloaded Rickys 30 page word document template, it has the part about DLUHC in it. 

I will add my WS draft to this template and use this framework. 
Thank you Coupon-mad

IloveElephants

Hi Please see my draft WS 

https://www.dropbox.com/scl/fi/flfhpnoxqglnsf8prvd1y/Final-witness-draft-version1.docx?dl=0&rlkey=5s23q20r7lhs3kqf5f7lidigc

Please let me know if you cannot see it, Ignore the content page as I need to renumber it at the very end along with the photo exhibits at the end. Thank you everyone