Letter of claim DCBL/UKPC

teddyinwonderland

Le_Kirk said:

teddyinwonderland said:

@Le_Kirk I've looked at other WS on here for an example and I did mine as theirs , just naming them "exhibit 1" "exhibit 2" ... is that wrong to do so? 

If you looked at the WS from @aphex007 you will see that they used XX-01 etc but whatever convention suits you so long as you and the judge can easily go from your narrative to the actual piece of evidence .

@IloveElephants example as their case seemed similar to mine  

in your opinion does it look okay? Apart from proofreading for grammar/spelling mistakes is there anything else I need to add before I submit it 

1505grandad

any help?:-

https://www.britishparking.co.uk/BPA-AOS-Conference

Le_Kirk

Providing it backs up and supports what you put in your defence and you proof read, grammar and spelling check, add paragraph numbers and you have shown all evidence you want to, then go for it.

Castle

The "Landowner's" contract refers to a company called Cardiff Lux SARL with a company reg number of 07192349; however Companies House shows that this number belongs to "Forces Support Limited" which is a charity set up to help the Armed Forces and it certainly doesn't own this retail park.

teddyinwonderland

Castle said:

The "Landowner's" contract refers to a company called Cardiff Lux SARL with a company reg number of 07192349; however Companies House shows that this number belongs to "Forces Support Limited" which is a charity set up to help the Armed Forces and it certainly doesn't own this retail park.

Would I add this as an “exhibit”, the contract and then a screenshot of companies house? 

teddyinwonderland

1505grandad said:

any help?:-

https://www.britishparking.co.uk/BPA-AOS-Conference

Excuse me for my ignorance but I had a look on the link you shared and I can’t see a summary of their conference or anything that says about BPA members complying with new CoP 

teddyinwonderland

I'm sorry I'm a bit confused.I edited my draft a bit : https://docs.google.com/document/d/1ssR5B9NESBsiu74KKYkqA33oehFytveCx7_wO8elDfE/edit?usp=sharing 

however, after digging up a bit more on the forum I saw a comment from @Re@Redx not to mix up the old and the new CoP, so maybe the witness statement by Joel was right and I shouldn't expect them to comply with the new one? 

as most probably my hearing will be decided on papers I don't want to mess it up
The deadline to submit my defence is 24/05/2023

Coupon-mad

Why is your hearing on the papers? That's usually how to lose.  Is this the one where the Court hasn't given you much choice?

maybe the witness statement by Joel was right and I shouldn't expect them to comply with the new one? 

Nope, far from it.  The new Code clauses are not going to change (only the money is being reviewed).  The Template Defence explains this, and says that the fact the statutory Code is temporarily stalled doesn't affect the fact that it has been in the public domain for well over a year and is a clear steer for Judges.

The BPA did say back in 2022 that they expect their members to comply with the new Code (but that was before the two/three Judicial Reviews were thrown in by the more rich/greedy players).

teddyinwonderland

Coupon-mad said:

Why is your hearing on the papers? That's usually how to lose.  Is this the one where the Court hasn't given you much choice?

maybe the witness statement by Joel was right and I shouldn't expect them to comply with the new one? 

Nope, far from it.  The new Code clauses are not going to change (only the money is being reviewed).  The Template Defence explains this, and says that the fact the statutory Code is temporarily stalled doesn't affect the fact that it has been in the public domain for well over a year and is a clear steer for Judges.

The BPA did say back in 2022 that they expect their members to comply with the new Code (but that was before the two/three Judicial Reviews were thrown in by the more rich/greedy players).

It was allocated on papers, I emailed the court saying that I disagree and got this reply “:

(Removed by Forum Team)

I used the template defence, hence his witness statement is as a response to my defence why I expect them to comply with the new Code of Practice. 

Do you have the “article” where BPA said that so I can back myself up?

Coupon-mad

Because the Code was published by the Govt in Feb 2022, I think it will be in the BPA publication 'Parking News' in March or April 2022, if it's anywhere.

One of my thread discussions (found in my posting profile when you click on my username) is a thread linking to all the Parking News editions for the past few years.