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UKPC/DCBL

24

Comments

  • Coupon-mad
    Coupon-mad Posts: 131,199 Forumite
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    edited 31 March 2023 at 7:20PM
    It is alleged that the defendant left the site, which is denied. The claimant has failed to provide photographic evidence to support the allegation and the claimant is put to strict proof that the defendant left the site and where the site boundaries were defined on the signs
    Don't say this in a DCBLegal case defence, because the POC don't actually say what the allegation or breach was.  The POC is silent on that so do the same as in all the other current UKPC threads this month and be vaguer in para 3, do not plug the gaps in their pleadings and use the extra para 4 - 11 defence by @Johny86
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top of this/any page where it says:
    Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • B789
    B789 Posts: 3,441 Forumite
    First Anniversary First Post Name Dropper Photogenic
    edited 31 March 2023 at 7:30PM
    Jalex59 said:
    Hi all - service acknowledged. l am drafting my defence and intend to use all the paragraphs in the template. With my own words being “ The defendant entered was at the car park of the retail park to visit and browse the numerous shops on the site. and noted the maximum stay

    It is alleged that the defendant driver left the site, which is denied. The claimant has failed to provide photographic evidence to support the allegation and tThe claimant is put to strict proof that the defendant was the driver on an unremarkable day several years ago and left the site and where the site boundaries were defined on the signs”

    My twopennethworth as long as you include all the other template points as advised earlier. Also, if the PCN is not PoFA complaint and the driver has not been identified.
  • Jalex59
    Jalex59 Posts: 17 Forumite
    First Anniversary First Post Name Dropper
    Thanks all for your comments, will adapt accordingly.
  • Jalex59
    Jalex59 Posts: 17 Forumite
    First Anniversary First Post Name Dropper
    It is alleged that the defendant left the site, which is denied. The claimant has failed to provide photographic evidence to support the allegation and the claimant is put to strict proof that the defendant left the site and where the site boundaries were defined on the signs
    Don't say this in a DCBLegal case defence, because the POC don't actually say what the allegation or breach was.  The POC is silent on that so do the same as in all the other current UKPC threads this month and be vaguer in para 3, do not plug the gaps in their pleadings and use the extra para 4 - 11 defence by @Johny86
    As vague as this;

    3. The defendant was at the retail park to visit and browse the numerous shops and facilities on the site.

    Will use 4-11 above.

  • Jalex59
    Jalex59 Posts: 17 Forumite
    First Anniversary First Post Name Dropper
    In P2 of my defence I am admitting being the Registered Keeper and driver, as picked up on a previous thread.
  • Coupon-mad
    Coupon-mad Posts: 131,199 Forumite
    Name Dropper First Post Photogenic First Anniversary
    Yep that's fine so far and of course the rest of the Template Defence, taking it to over 30 paragraphs after copying paras 5 - 11 from Johny's example.

    DO NOT USE HIS PARA 4 AS YOU WERE DRIVING.

    Instead put this:

    4.  No signs were seen and having been back for a look, the Defendant avers that the prominence and legibility of any supposed parking terms is extremely poor at this location, compared with the large and eye-catching retail banners. The Defendant is unsure what the cause of action is, and what he is supposed to have done wrong, given that the Particulars are silent about the precise allegation, supposed breach or indeed any terms of the supposed 'contract'.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top of this/any page where it says:
    Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • B789
    B789 Posts: 3,441 Forumite
    First Anniversary First Post Name Dropper Photogenic
    Jalex59 said:
    In P2 of my defence I am admitting being the Registered Keeper and driver, as picked up on a previous thread.
    Was the PCN PoFA compliant?
  • Jalex59
    Jalex59 Posts: 17 Forumite
    First Anniversary First Post Name Dropper
    Yep that's fine so far and of course the rest of the Template Defence, taking it to over 30 paragraphs after copying paras 5 - 11 from Johny's example.

    DO NOT USE HIS PARA 4 AS YOU WERE DRIVING.

    Instead put this:

    4.  No signs were seen and having been back for a look, the Defendant avers that the prominence and legibility of any supposed parking terms is extremely poor at this location, compared with the large and eye-catching retail banners. The Defendant is unsure what the cause of action is, and what he is supposed to have done wrong, given that the Particulars are silent about the precise allegation, supposed breach or indeed any terms of the supposed 'contract'.
    Thanks new para inserted, total 33!?
  • Jalex59
    Jalex59 Posts: 17 Forumite
    First Anniversary First Post Name Dropper
    B789 said:
    Jalex59 said:
    In P2 of my defence I am admitting being the Registered Keeper and driver, as picked up on a previous thread.
    Was the PCN PoFA compliant?
    Thanks B789, not sure if I know the answer to that, it's almost 4 years ago!
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