County Court Business Centre Claim

Coupon-mad

The example WS in the NEWBIES thread already deal with the added £70.

No you don't counterclaim. The WS in the NEWBIES thread show how to do a 'costs assessment' in some of the linked users' threads.

You don't have these costs:

"previously reserved costs of £315"

member2090

https://1drv.ms/w/c/9237c70e19c4f7e6/EUHx_-VoNRBKqSkEvpaCFZkBLkUSLXCL2Gfg14QDzWbHvA?e=harIln

Can someone tell me if this is okay please?

1505grandad

Para 9  -  "Date and Time of the Incident: Friday, 11th November 2022, at approximately 13:15PM."

Is this the correct date?

Also:-

Para 36  -   "None of this was agreed by me, let alone known or even seen as I attempted to gain entry to the store.."?

Do any of the paras in WS repeat those already in the Defence?

member2090

1505grandad said:

Para 9  -  "Date and Time of the Incident: Friday, 11th November 2022, at approximately 13:15PM."

Is this the correct date?

Also:-

Para 36  -   "None of this was agreed by me, let alone known or even seen as I attempted to gain entry to the store.."?

Do any of the paras in WS repeat those already in the Defence?

yes it is the date of incident.

no it is not in the defense.

is it okay ?

1505grandad

"yes it is the date of incident."

Just wondered why the evidence photos are dated 13th  -  and you state that because sunroof & window opened showed driver in car  -  so how can that be evidence of a parking event 2 days earlier?.

"Exhibit 05 Windows And Sunroof Open"


"On 11th November 2022 the Defendant drove into Silverworks to pick up a vulnerable, elderly relative residing at Gladstone House."  -  just wondered why you would attempt to gain entry to a store?.

member2090

1505grandad said:

"yes it is the date of incident."

Just wondered why the evidence photos are dated 13th  -  and you state that because sunroof & window opened showed driver in car  -  so how can that be evidence of a parking event 2 days earlier?.

"Exhibit 05 Windows And Sunroof Open"


"On 11th November 2022 the Defendant drove into Silverworks to pick up a vulnerable, elderly relative residing at Gladstone House."  -  just wondered why you would attempt to gain entry to a store?.

apologies the date was incorrect it is the 13th.

i have edited para 36 thanks for spotting that  

would it be okay to submit you think?

https://1drv.ms/w/c/9237c70e19c4f7e6/EUHx_-VoNRBKqSkEvpaCFZkBLkUSLXCL2Gfg14QDzWbHvA?e=oGRcK3

Coupon-mad

To save me repeating myself on thread after thread, search the forum for:

don't need exhibits 2 3 4 Chan judgments

And read what others then did to improve their WS recently.  ONE judgments link including Chan and Akande.  There are TWO appeals that support the view that the Claim should be struck out for failure to comply with Part 16.

Bazarius

I would add a “failure in their duty  to mitigate damages” defence .  The Doctrine of Mitigation covers this angle of defence. 

From what the OP says - it appears that the attendant may have hidden round the corner and taken photos from a distance therefore the issuance of the PCN could have been avoided through reasonable efforts by simply showing  their presence in uniform or let the driver know they cannot park there .  

Similar was  mentioned  in VCS v Ibbotson where the attendant just watched the driver walk past him and left the car park thus incurring a PCN. 

member2090

Do i have to fill this part in on every page ?

KeithP

member2090 said:

Do i have to fill this part in on every page ?

No you don't have to do that.

Set it up as a heading in your word processing software so that it will appear at the top of every page.

Remember also that every page needs a page number. That too can be automated.