Excel Parking LBC following PCN after 14 days

westcoast888

My WS has to be in by 12pm 8th March. Do I email both court and the claimant or do I have to post?

Coupon-mad

Email the bundle once you're happy with it.

Not to the CCBC email of course.

westcoast888

I’ve read a few of the Ws’s on the forum what one would be a good one to give me some direction please

Le_Kirk

Two are recommended @aphex007 and @SJRRJS assuming it is standard WS after defence and not a set-aside.

B789

Just a quick note in their WS:

Page 23 para(87): they claim that the £60 is both damages and debt recovery costs. Can they have it both ways?
Page 24 para (93): they say the debt recovery fee is £70.

Is it £60 or £70 and is it a debt recovery fee or is it damages?

You may want to point how this is "embarrassing" for their case.

...an embarrassing pleading is “one which is ambiguous or unintelligible or which states immaterial matter and raises irrelevant issues which may involve expenses, trouble and delay and thus will prejudice the fair trial of the action, and so is a pleading which contains unnecessary or irrelevant allegations.”

westcoast888

B789 said:

Just a quick note in their WS:

Page 23 para(87): they claim that the £60 is both damages and debt recovery costs. Can they have it both ways?
Page 24 para (93): they say the debt recovery fee is £70.

Is it £60 or £70 and is it a debt recovery fee or is it damages?

You may want to point how this is "embarrassing" for their case.

...an embarrassing pleading is “one which is ambiguous or unintelligible or which states immaterial matter and raises irrelevant issues which may involve expenses, trouble and delay and thus will prejudice the fair trial of the action, and so is a pleading which contains unnecessary or irrelevant allegations.”

Brilliant, many thanks. Can I reference their WS in my WS? 

Mouse007

westcoast888 said:

Brilliant, many thanks. Can I reference their WS in my WS? 

Of course you can, I went through BW Legal's complete WS in our WS refuting it all point by point.

Umkomaas

Brilliant, many thanks. Can I reference their WS in my WS? 

Not quite clear about the meaning above. If you you mean can you use it as a framework for your own, personalising it to match your circumstances, then that's a good idea. But if you mean putting links or copying it to add into your own WS, then that's a 'no'. 

Just so there's no misunderstanding. 

westcoast888

Umkomaas said:

Brilliant, many thanks. Can I reference their WS in my WS? 

Not quite clear about the meaning above. If you you mean can you use it as a framework for your own, personalising it to match your circumstances, then that's a good idea. But if you mean putting links or copying it to add into your own WS, then that's a 'no'. 

Just so there's no misunderstanding. 

I meant can i refer to the claimants WS and dispute their points

Fruitcake

Yes you refer to their WS or specific paragraphs within it in yours.