PCN from UKCPM Gladstone - URGENT help with witness statment

Brightlinks

Coupon-mad said:

Paragraph 3 needs to add that there are no signs at all on that side of the area, which (beside the building) is believed to fall outside of the enforcement boundary.  This is also supported by the fact that a ticketer for the Claimant stated this; that is why there are no contractual signs on the business side.

Remove para 11 as there are no "signs within".  Not on that side.


Paragraph 31 is wrong to say:

" Adding debt recovery / costs/ damages / fees (however described) onto a parking charge is now banned.

it isn't (yet).  Why do people keep copying this version?  The right wording is in the Template Defence thread.

para 3 updated - 

3.    At the end of March 2020, Government announced the Lockdown in the whole country. We spoke to the manager at Birkdale clinic next to our block of flat, to allow us to park our vehicle during the lockdown. The manager verbally allowed us to park our vehicle during the lockdown period. There are no signs at all on that side of the area, which (beside the building) is believed to fall outside of the enforcement boundary.  This is also supported by the fact that a ticketer for the Claimant stated this; that is why there are no contractual signs on the business side. (Claimants Exhibit – xx)

Para 11 removed

para 31 - can i keep only - 1.    The claim is exaggerated by inclusion of a false, wholly disproportionate and unincurred 'damages' enhancement of £70 upon which the Claimant seems to have also added interest at 8% calculated from the date of parking. Clearly an abuse of the court process.

Coupon-mad

Just replace 'now banned' (which probably apoears twice) with the proper version.

1505grandad

Para 7  -  " The tenant’s contract makes no assertion that a permit must not be displayed to use the bay, nor that a penalty of £100 must be paid in the event of a failure to do so."

Is there a "not" that should not be there?

Brightlinks

1505grandad said:

Para 7  -  " The tenant’s contract makes no assertion that a permit must not be displayed to use the bay, nor that a penalty of £100 must be paid in the event of a failure to do so."

Is there a "not" that should not be there?

Updated now.

Brightlinks

Is better to send a soft copy of WS to court email address ?

Coupon-mad

Yes, to the local court - and copy in the solicitors IN THE SAME EMAIL so they can't deny receiving it.

Brightlinks

Hi All

Just an update, Solicitor is not attending the hearing in mid of july, can i quote and take below judgement copy to the court ?

UKPC v S Masterton fobidding signs

Boat_to_Bolivia

They will send a legal rep!

Brightlinks

ok thanks for heads up.

Can I submit a judgment copy at the time of hearing ?

Coupon-mad

No you can't ambush at the hearing.