Claim form from UK Parking Control LTD

Coupon-mad

Happy reading, get up to speed with the new Code of Practice from the DLUHC. 

https://forums.moneysavingexpert.com/discussion/comment/79013061/#Comment_79013061

That thread explains why it matters even to existing cases and it's not even in the Template Defence yet because it's so new. There will be lots there that helps and especially the Government ban on damages/debt recovery add-ons.

John919

Can please someone help me with correct wording in defence ,not sure if its good idea to post it here?

Coupon-mad

Definitely post your paragraph 3 facts here, we always do it openly on the forum and the Claimant will see your defence later this month anyway.

You are using the new March 2022 Template Defence?

I have now edited it to cover the new Code of Practice and the fact that add-ons of £60 or £70 per PCN are now banned.  All you need to add is the facts as you know them.

John919

Made few pictures yesterday, just easier to explain .JD sign wasnt there before,instead  pale yellow heart

John919

John919 said:

Made few pictures yesterday, just easier to explain .JD sign wasnt there before,instead  pale yellow heart

Members of one gym permitted to park on yellow marked bays and other gym is white. Where I parked it was joined parking bays as far as I know now

Coupon-mad

Ok, can you copy & paste your para 3 here as that's easier?  Photos are used as evidence later, not with the defence.

John919

Driver arrived at 5.30am to gym  and parked vehicle at parking bay which at the time believed to belong to Pure gym,parking bay marking was misleading as 1/3rd of lanes painted in white and 2/3rd yellow,not well visible at 5.30am as still dark

John919

I think its good idea to send it today, can please someone help with correct wording in para 3,Thanks

Le_Kirk

John919 said:

The dDriver informed the defendant that they arrived at 5.30am to at the gym and parked the vehicle at in a parking bay which, at the time the driver believed to belong to Pure gym. Later research proved that the parking bay marking was misleading as 1/3rd of lanes were painted in white and 2/3rd in yellow, which would not have been well very visible at 5.30am as it was still dark.

Maybe adjust as above.  However, your paragraph 4 goes on to state that the defence all comes from your own knowledge, which is not true if you are being told the sequence of events by the driver.

Coupon-mad

This is all about being unable to discern surface markings in poor light at 5.30am. Admit in #2 to being the driver and keeper (if you were) for this one.

Explain in #3, that two gyms use the same parking yard but it simply isn't clear where to park for each and customers of both gyms are being penalised unfairly.  There is no barrier, fence or prominent delineation..  Use the phrases 'poor light' and 'unable to discern surface marking colour which would only be apparent in clear broad daylight'.