Help Needed! Please can I get some feedback on my defence.

Coupon-mad

Yes...but of course add the transcripts too.

Skysurfer69

Coupon-mad said:

Yes...but of course add the transcripts too.

Of course! I'm a fool, done now. 

Skysurfer69

Okay, so, is this WS good for sending, or are there any more changes I should consider?

ETA: re-adding the link to the current draft

https://docs.google.com/document/d/19-hXmg6MQZU7_W1KjAM46xrpEcHjLOkT/edit?usp=share_link&ouid=105462088843519370819&rtpof=true&sd=true

Skysurfer69

Actually, I've just realised that I have a couple of outstanding questions. 

In the Conclusion, point number 37 talks about Costs. Am I leaving this in here? I'm not particularly concerned with receiving or asking for costs to be recovered for myself.

Secondly, on page 22, I've left a picture of the sign so that I can get an opinion from this forum on thoughts about leaving it in or not.

Coupon-mad

I'd remove that photo and also exhibit 8 entirely.

1. In the matter of costs, the Defendant asks:

1. The previously reserved costs of £315, and

1. at the very least, for standard witness costs for attendance at Court, pursuant to CPR 27.14, and

1. for a finding of unreasonable conduct by this Claimant, seeking costs pursuant to CPR 46.5

Does the above actually apply to me?

Not if you don't have any 'reserved costs' from a previous CCJ set aside hearing!  But are you not wanting to claim loss of a day's leave (£95 fixed) for wasting a day attending this upcoming hearing?

1505grandad

Another .doc WS where the word "Judgment" many times has been incorrectly amended to include a middle "e"  -  probably of no consequence  -  just offends against my "pedanticness" as it clearly states the correct word (in this context) on the exemplar and exhibits to be put in front of a Judge.

https://forums.moneysavingexpert.com/discussion/comment/80360818/#Comment_80360818

Skysurfer69

1505grandad said:

Another .doc WS where the word "Judgment" many times has been incorrectly amended to include a middle "e"  -  probably of no consequence  -  just offends against my "pedanticness" as it clearly states the correct word (in this context) on the exemplar and exhibits to be put in front of a Judge.

https://forums.moneysavingexpert.com/discussion/comment/80360818/#Comment_80360818

I'm really sorry, I don't know if I follow what you are trying to say here...

"Pedantry" aside, are you saying it's "judgment" or "judgement"

I may have misunderstood your earlier comment to mean I should correct the spelling to judgement... 

ETA: to err on the side of caution, I think (and hope) this is what you mean @1505grandad

https://docs.google.com/document/d/19-hXmg6MQZU7_W1KjAM46xrpEcHjLOkT/edit?usp=share_link&ouid=105462088843519370819&rtpof=true&sd=true

Coupon-mad

The correct spelling is judgment.

1505grandad

"Suggest you look at the Judgment you are exhibiting as there in middle "e" in this context."

My apologies I see that I put  "in"  instead of  "is no"  after "there"  -  however the "Judgment" document exhibit is as stated. (once again I blame the meds).

Skysurfer69

In going over my WS, I've noticed that unlike the referenced paras in PE v Beavis, there were no such transcripts as referenced for PE v Somerfield (see section 21). 

Please can someone check my work and confirm that what I have added as Exhibit-14 is correct?