Acknowledge of service

Coupon-mad

Cazzy1964 said:

Would it be ok if I tell you what I’ve put, to see if this is enough?

Of course.  Just don't show us the whole template - spare us please - as I don't need to mark my own homework!

Cazzy1964

The car park is Broughton shopping park.. Broughton near Chester. 

Apparently there were signs there at one point. Stating the 20min limit drop off. They   aren’t there now because we have checked. 

Cazzy1964

The defendant has visited Broughton Shopping park on a regular basis, since moving to broughton a number of years ago. The defendant was authorised to park there as it is a free car park to shoppers. The defendant has never recalled seeing a time limit at the pick up point. The defendant does not recall any letters being sent to him. No information or photo of the alleged contract on the sign has yet been supplied, therefore the defendant is having to defend blind at this point.

Coupon-mad

That'll do.  Just to check:

Has he also changed para 2 to add 'and driver' if he is SURE it was him? If there are other drivers in the family who could have been shopping or dropping off/picking up a parcel or item that day then of course he adds that fact too (without naming them, obvs!).

Cazzy1964

Well his wife is insured to drive the car so it could have been her 

Cazzy1964

Does he add this to paragraph 2 or 3 about it may not have been him 

Coupon-mad

He puts in an extra para 4 and maybe 5 to add a POFA 'no keeper liability' argument* and changes #2 to say that other drivers were insured so the driver is not evidenced and nor is a liability trail.  On the balance of probabilities he was likely not driving because others in the family prefer shopping and he works full time (if true).


* For that wording already done a hundred times and more on here, search the forum for Henry Greenslade POPLA 2015 defence.

KeithP

Cazzy1964 said:

Well his wife is insured to drive the car so it could have been her 

Whilst it's true, I suggest you change "The defendant was authorised to park there..."
to...
The driver was authorised to park there...

Mouse007

Coupon-mad said:

 he was likely not driving because others in the family prefer shopping and he works full time (if true).

If I was writing that I would have ended up with

 he was likely not driving because others in the family prefer shopping and he has to work full time to fund their shopping habits

Was one of my stock jokes, usually when my wife, mother and daughter all went off together

Cazzy1964

Thank you everyone for all your help. 

Its made things a lot clearer