County Court Business Centre Parking Ticket

LeoBoy

I am going to write my WS Monday as it needs to be sent Tuesday. I will add my previous defense. Is there any tips what to add? Also shall I mention that their WS is mostly completely unreadable as a lot of the text is blurry and pretty much all the pictures of parking signs in their WS are completely too dark to see plus they're not even where my Mum parked. Or shall I wait for the actual hearing to tell the Judge as he must have the same papers?

Coupon-mad

I think cover it in your WS.

At least two people in threads tonight have shown draft WS you can read and copy from.

You don't "add your previous defence".

LeoBoy

Coupon-mad said:

I think cover it in your WS.

At least two people in threads tonight have shown draft WS you can read and copy from.

You don't "add your previous defence".

Sorry. I can't seem to find the draft WS's. Could you send link please.

Le_Kirk

Coupon-mad said:

I think cover it in your WS.
At least two people in threads tonight have shown draft WS you can read and copy from.

LeoBoy said:

Coupon-mad said:

I think cover it in your WS.
At least two people in threads tonight have shown draft WS you can read and copy from.
You don't "add your previous defence".

Sorry. I can't seem to find the draft WS's. Could you send link please.

You need to read through the threads posted today/tonight to find them.

LeoBoy

This is my WS. If anyone wants to add anything please let me know as I have to send it Tue. Thanks.

The Defendant now 78 years old went to do her weekly shop which she has done for many years, the car park is collect ticket on entry and pay for your ticket before returning to your car, you then put the ticket in machine to open the barrier to exit the car park. She entered the car park (as shown on the top picture of page 55 of the claimants witness statement – Although blurry there is no sign about a contract and it just looks like a tariff sign which was obeyed by the defendant as otherwise she wouldn’t have been able to leave the car park)  She parked and displayed her blue badge on the front dashboard as normal and went to do her shop, before returning to her car she went to the ticket machine to pay for the parking, when returning to the car she noticed there was a ticket on her car and discovered her blue badge had fallen on the passenger side floor. She phoned her son in a panic and he told her not to worry and to take a photo of where it dropped and he would appeal on her behalf. Her son appealed stating what had happened and showed them her valid Blue Badge. The appeal was rejected since then several threatening letters have been received. Her son has written to the court on 30th August 2024 via email requesting to attend as the defendant’s litigation friend. I don’t believe that the claimant is actually out of pocket as the defendant paid for her parking on the day so feel a penalty charge should not apply to this case..

 

 

 

 

I shall refer to the Claimants Witness Statement as to their Page numbers.

Page 2 Contract is unreadable.

Pages 3-4 are blurry.

Pages 7-11 is not where the Defendant parked.

Page 12 is unreadable and nowhere near where the defendant parked.

Pages 13-20 Are just printouts of signs with no locations.

Pages 36-39 Never received from the Claimant.

Pages 46-55 Unreadable and nowhere near where the Defendant was parked.

Pages 56-65 are the multistorey covered car park nowhere near where the Defendant parked.

Pages 66-75 Is the service yard which is not even a car Park

 

I would like to add

(Ref 1.A)   A letter which was received from QDR Solicitors Dated 29/06/2023 Which they now say their client is ZZPS Limited stating that a County Court Judgement was entered against the Defendant with a judgment debt of £277 and threatening if not paid the Claimant would either issue an Attachment of Earnings application, Charging Order Application or a Warrant of Control Application. Also a copy of the Defendants Blue Disable Badge (Ref 2.A)

LeoBoy

Also the previous defense is in with it.

Coupon-mad

That's not how other posters present a Witness Statement. You need proper headings and a statement of truth. I can't give links because it simply involves looking at other threads to see WS.

LeoBoy

Coupon-mad said:

That's not how other posters present a Witness Statement. You need proper headings and a statement of truth. I can't give links because it simply involves looking at other threads to see WS.

I have put a statement of truth on the WS.

Le_Kirk

Your witness statement should be written in the first person, so "I am 78 years old and went to do my weekly shop..............."
At the end of your WS you put this: -

(Ref 1.A)   A letter which was received from QDR Solicitors Dated 29/06/2023 Which they now say their client is ZZPS Limited stating that a County Court Judgement was entered against the Defendant with a judgment debt of £277 and threatening if not paid the Claimant would either issue an Attachment of Earnings application, Charging Order Application or a Warrant of Control Application. Also a copy of the Defendants Blue Disable Badge (Ref 2.A)

Is this true?  Are you defending the claim or applying for a set-aside?

Coupon-mad

LeoBoy said:

Coupon-mad said:

That's not how other posters present a Witness Statement. You need proper headings and a statement of truth. I can't give links because it simply involves looking at other threads to see WS.

I have put a statement of truth on the WS.

Is this a WS to accompany a N244 CCJ set aside application? If yes, then it should be FAR more detailed with case law about the wrong address being used.

This is explained in the CCJ set aside section of the second post of the NEWBIES thread, where I advise people to copy & adapt the WS by Zbubuman.

Or are you successfully past CCJ set aside stage and are on the next stage of defending the claim before a second hearing?

Actually, from briefly hopping back and reading your first post from over a year ago, this is your Mum's WS to write from her POV.  She is at all times the Defendant, not you.