Spring Parking & DCBL LEGAL - I won in court!!!

Pat_Burger

 Coupon-mad said:

Some changes:

The phrase is as I said "void for impossibility" and don't put it in bold. It's a normal phrase.

Para 10 has an unfinished sentence.

I would remove the paragraph about Mendacity because it's crossing a line you shouldn't cross in small claims.  The signatory works for Spring Parking so there's no suggestion of lies.

And every paragraph needs a number. Loads of them have no number.

Perfect thank you, have updated with all of this!

1505grandad

Para 11  -  "The claimant has failed to prove this car was not permitted to park there by not conducting though due diligence on its own part."

thorough?

Pat_Burger

1505grandad said:

Para 11  -  "The claimant has failed to prove this car was not permitted to park there by not conducting though due diligence on its own part."

thorough?

Thank you!

Le_Kirk

Pat_Burger said:

1.            I have included on a non-redacted version of the Car Park Management agreement (See Exhibit 05) The agreement is not signed by the landowner, nor is it signed by Barsham securities but someone “of Kemsley LLP”. I do not know who Kemsley are and of the what authority they have to sign on behalf of Barsham Securities. It is my belief that the claimant has only included a redacted version of the agreement as they wish to lure the court into believing that authority has been granted, yet an unknown party has signed the agreement. The lack of direct contractual links to either the landowner or Barsham Securities casts doubt on the claimant's standing and the validity of their claim.

Couple of suggestions above.

Pat_Burger

Le_Kirk said:

Pat_Burger said:

1.            I have included on a non-redacted version of the Car Park Management agreement (See Exhibit 05) The agreement is not signed by the landowner, nor is it signed by Barsham securities but someone “of Kemsley LLP”. I do not know who Kemsley are and of the what authority they have to sign on behalf of Barsham Securities. It is my belief that the claimant has only included a redacted version of the agreement as they wish to lure the court into believing that authority has been granted, yet an unknown party has signed the agreement. The lack of direct contractual links to either the landowner or Barsham Securities casts doubt on the claimant's standing and the validity of their claim.

Couple of suggestions above.

Thank you! have amended!

Pat_Burger

Hi all,

Just wanted to see if anyone had any more thoughts or feedback before I submit tommorow? Thank you!

Pat_Burger

All sent off. Received auto reply both from DCBLegal and also the county court, who are working on arrears currently according to their autoreply.

Coupon-mad

Pat_Burger said:

All sent off. Received auto reply both from DCBLegal and also the county court, who are working on arrears currently according to their autoreply.

I hope you didn't email it to the CNBC?

Pat_Burger

Coupon-mad said:

Pat_Burger said:

All sent off. Received auto reply both from DCBLegal and also the county court, who are working on arrears currently according to their autoreply.

I hope you didn't email it to the CNBC?

Nope, definitely the county court

Pat_Burger

Is it normal for DCBL to send me the hearing bundle and ask me to agree to it:

The Court has ordered that both parties agree a Hearing Bundle ahead of the Hearing on 19/11/2024.

Please see attached the proposed Hearing Bundle, which includes both parties documents that we have on file.  

Please confirm by XX on XXXXX that you are happy with the attached so the same can be filed at the Court on behalf of both parties. Should you have any documents that you wish to include, please ensure these are provided by the above mentioned time frame.  

Should we not receive a response from you by XX on XXXX, the attached will be filed at the Court accordingly.  

We look forward to hearing from you.  

They also want to submit this past the deadline for when Witness Statements had to be filed (which is today)

Thank you!