We won today

Coupon-mad

Looks good but I still saw no explanation of why you are trying to hold an old ticket to the new statutory Code that isn't even implemented yet. 

As I explained earlier, somewhere you have to say why this new (non-retrospective) code is persuasive and matters - is my wording about that somewhere before you first refer to the new Code?

BelladonnaTook

Is this not enough mention of it?

Coupon-mad

Yes but that's only talking about the added costs, not the other stuff you've quoted it for (signage, etc).  Was it not on this thread? I gave some wording today about saying that the Code is 'nothing new' and just cements 'best practice' and what was in the trade body Code of Practice already, and trite law such as the 'prominence' of terms and consumer notices requirements of the good old CRA...

BelladonnaTook

hmmm... oh well

Fruitcake

When I click on your link, it brings me straight back to this thread. One is confused.

BelladonnaTook

Hellsbells
Thank you @Fruitcake !

Is this any better?
https://www.dropbox.com/s/f9u5eouxriu0bwq/REDACTED%20Supplementary%20Witness%20Statement%20for%20Dropbox.pdf?dl=0

Johnersh

Jesus wept. 11 pages of single spaced barely contained anger. A judge won't read it. 

Also, no-one should ever tell a judge what to order. You can suggest the claim is without merit and even on their own evidence the claim isn't made out, but you can't say it fails.

There appear to be 2x points. One is that the contract doesn't cover the car park the op was parked in and the other is that there is some sort of irregularity in the execution of the contract, such that the statement served from the paralegal (which merely restates what her client tells her to say and is therefore not really factual at all) is unreliable.

If I'm right in that, make the best points prominent and can the rest.  If I've missed anything, that's because I couldn't be bothered to read 11 pages either, which is kinda my point. 

BelladonnaTook

Thanks.
I calmed down earlier and rewrote it anyway before seeing your response!

BelladonnaTook

Okay, this is VCS' WS https://www.dropbox.com/s/j2puo223mgmxlqf/REDACTED%20VCS%20CLAIMANT%20WS%20for%20Dropbox.pdf?dl=0

and this is the Supplementary WS in response to VCS' WS
https://www.dropbox.com/s/ze0sftu4m81tuiz/REDACTED Supplementary Witness StatementX.pdf?dl=0

I know I have been a pain in the a**** about this - I sincerely apologise for that and shouldn't make excuses.However, I have had CPTSD for years as my ex spouse was extremely abusive (almost fatally) in every way -  and maleficent bullies like these awful PPCs trigger me deeply.

I would truly appreciate any help with this SWS before it is signed and sent. Please be gentle with me though - i need critique but without mocking hostility. I hope the reader understands this. 

Thank you to anyone kind enough to advise me. 

Fruitcake

Your SWS looks good, albeit rather long.

Nowhere in the claimant's WS does it appear to show images of your vehicle parked, which supports your version that it was not parked in the "controlled area", but merely passed and repassed the claimant's cameras and was actually parked elsewhere.

A smartphone with location tracking enabled, or dashcam footage would have supported your case, but it is too late to include that.