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

Coupon-mad

Yes that's correct.

You will probably have to hand deliver a printed version of this bundle to the local court because it's likely over 50 pages with all the transcripts.

In which case - printing costs are not cheap!

You can email the same bundle to the solicitors acting for the claimant.

1505grandad

"In my statement I shall refer to (Exhibits-01-14)....."

A heads-up  -  there are 15?

Skysurfer69

Coupon-mad said:

Yes that's correct.

You will probably have to hand deliver a printed version of this bundle to the local court because it's likely over 50 pages with all the transcripts.

In which case - printing costs are not cheap!

You can email the same bundle to the solicitors acting for the claimant.

Thanks! That's a pain, as yes, it's 52 pages long. 

Are there any specific rules that need to be followed when printing or can I just take the file along to a local printing service?

ETA: I found the problem, the PE v Somerfield wasn't supposed to be 419-428, it was supposed to be 419 & 428. 
With just those two paras the .doc is shortened to 49 pages.

Coupon-mad

No it wasn't! 

It is all those paragraphs but I am sure you can shave 2 pages off somewhere.

Just merge your PDFs and make them smaller, using a PDF editor (free).

Skysurfer69

Coupon-mad said:

No it wasn't! 

It is all those paragraphs but I am sure you can shave 2 pages off somewhere.

Just merge your PDFs and make them smaller, using a PDF editor (free).

Okay, we're getting there. You were correct, I managed to shave of 3 pages by reducing some of the image sizes and cropping the upper and lower margins of the transcripts. I have re-added everything from PE vSomerfield transcripts. (Just as an aside here, the original thread had omitted to add any of the transcripts as Exhibits, so I wonder how that worked out for them?)

I also went back to the car park to get new images for ex-10 & ex-11 as I thought I could be pulled up for showing a completely different setup than those in ex-08 & ex-09. So now they're all images of the same sign from various perspectives.  

One other question I do have is on the use of "I" in some instances and "The Defendant" in others, should I normalise the use of one or the other for consistency?

If you agree and can't find any further issues or omissions etc. I'm almost at the point of submitting then (court date is mid December, so I have time yet, but haven't seen anything inbound from the Claimant. 

Thanks again for all your help. 

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

Coupon-mad

Use "I" in a WS.

Embed the date taken in your photos or exhibit a screenshot of the photo (instead or as well) which does the same job,

Skysurfer69

Coupon-mad said:

Use "I" in a WS.

Embed the date taken in your photos or exhibit a screenshot of the photo (instead or as well) which does the same job,

Some of my images are already date/time stamped. Is it a better idea to insert a caption with date of capture on instead?

1505grandad

Just checking  -  you state in para 31:-

"In the present case, the Claimant has fallen foul of those tests. There are two main issues that render this parking charge to be purely penal (i.e. no legitimate interest saves it) and thus, it is unenforceable:"

yet only appear to state one  -  i.e. "Hidden Terms:"

Skysurfer69

1505grandad said:

Just checking  -  you state in para 31:-

"In the present case, the Claimant has fallen foul of those tests. There are two main issues that render this parking charge to be purely penal (i.e. no legitimate interest saves it) and thus, it is unenforceable:"

yet only appear to state one  -  i.e. "Hidden Terms:"

And it's exactly this type of thing for which we all owe a debt of gratitude to you all in this forum. Great spot, thanks!

Skysurfer69

Okay, seeing that I'm likely at the point of being ready to submit, I've revisited the Notice of Allocation to see what the process is and this has raised a few questions (apologies in advance if these seem like silly questions):

1.  The Claimant has until mid-November to pay the trial fee. Should I wait until then before submitting my WS?
2. The notice states that I am to "deliver a copies of all documents" to both the Court and the Claimant. I don't see anything that says I can email the docs to the court and I don't have an email address, how do i request this or does that mean I need to get it printed and delivered to the Court anyway? 
3. I need to bring original documents to the Trial. Is that just a single printout of everything in my WS as it stands right now or do I need to go back and print out the transcripts from Source? I know this seems like an obvious question but I don't want to make any stupid mistakes should this go all the way.

Thanks in advance