Filing a defence following CCJ put aside. PCN dated March 2018. DCB legal!

skoobimum

Their exhibit list shows the PCN (exhibit 4) 
and the NTK (exhibit 5) but no debt collection letters or reminders just the letter of claim from DCB (exhibit 6) 6 exhibits in total with the amended ‘landowner’ agreement & the photos of vehicle on the day. 

I cannot find my wedding certificate & expect it in the loft amongst a load of other wedding paraphernalia so am not including this as my name has only been hyphenated anyway to include my husband’s name before my surname.
thx 

Castle

The only signs, (which appear to be dated 4 Feb 2019, so 11 months after the event), in the claimant's WS refer to free parking, there's no mention of pay & display. 

skoobimum

Yes I have noted the time stamp on 1 of their photos being nearly a year after the alleged contravention 👍🏻 it wasn’t a pay & display car park, a ticket was required to be displayed for 3hrs free parking. 

Coupon-mad

Yep, which my suggested wording covers.

Show us your full draft incorporating my suggested exhibits and paragraphs (remember I did not mean those to be paragraph one onwards, as I explained, other things should be stated first). 

skoobimum

Please find attached a copy of my preliminary witness statement, I still have to add the exhibits relating to various cases but have added your suggestions Coupon Mad (not sure if theyre in correct order as i seem to be going back and forth!) but would love some help/constructive criticism etc. thanks

https://www.dropbox.com/scl/fi/51fx0ywwh8jj447fw399x/Defendant-Witness-Statement-Spring-Parking-1-edited.pdf?rlkey=w69yg4vzsczyj6vsybl44lkoq&dl=0

Coupon-mad

We'll take a look. What's your deadline?

skoobimum

Today at 4pm 🙈

Le_Kirk

In your paragraph #6 you state that there is a persuasive appeal case for "these exact circumstances" but you haven't' said what circumstances.  Are you referring to the CEL v Chan, which you do in paragraph #7?  Just needs a clarification.  IANAL and it is only my opinion but providing it refers to items that you put in your defence and you are backing up and supporting that defence with the evidence you have shown, it should be OK.

Coupon-mad

Yes it looks good - sign, date and email a PDF of the whole bundle soon to the local court and DCB Legal.  Not the CCBC of course.

Merge all your PDF exhibits into one long PDF and then compress it, so it's small enough to email and won't bounce back.

Don't wait.  Do it now as the merge of your PDFs takes a few minutes (find a free tool).  

skoobimum

Thanks everyone, particularly @Coupon-mad. It is done! 😓 I realised (too late) that my formatting had gone a bit squiffy half way through the exhibits on transferring from .docx to PDF,  am hoping this won’t matter? 🤞