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CE - Drafting Defence - Help needed

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  • KeithP
    KeithP Posts: 41,296 Forumite
    Part of the Furniture 10,000 Posts Name Dropper
    I would suggest that paragraphs 18, 20 and 21 should also be removed from your Defence.

    Remember to re-number the whole document before filing.
  • Coupon-mad
    Coupon-mad Posts: 151,354 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Yes, and remove 22, 23, 24 and 25.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Hello again,

    I have a court date for this now, and I'd apreciate help drafting the witness statement. I've had a look at some of the previous examples but I'm not sure which bits I should include.

    WS as it stands



  • LDast
    LDast Posts: 2,496 Forumite
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    If the PPC issued the claim themselves, how can they add the £50 legal fee?
  • Coupon-mad
    Coupon-mad Posts: 151,354 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 26 August 2024 at 2:02AM
    They can if they have an in house legal team.

    In Ladak v DRC Locums Ltd  (UKEAT/0488/13/LA), the Employment Appeal Tribunal upheld the first tier decision that the costs incurred by a party's in-house legal team could be recovered.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Le_Kirk
    Le_Kirk Posts: 24,481 Forumite
    Part of the Furniture 10,000 Posts Photogenic Name Dropper
    You might want to adjust the sentence beginning: -
    "I took a few minutes .................. as there were several other cars ahead which left or found spaces." and
    "I observed the group ahead (around 8 people, with two cars) of me........"
    Sounds like there were two cars in the queue!  Maybe: -
    "I observed the group ahead of me (about eight people from two cars)........"

  • 1505grandad
    1505grandad Posts: 3,781 Forumite
    Part of the Furniture 1,000 Posts Name Dropper
    There are several statements in WS re DRA fees  -  most of the previous posts in this thread relate to the fact that CEL have not charged the fee in this case?
  • Bazarius
    Bazarius Posts: 128 Forumite
    Fourth Anniversary 100 Posts Name Dropper
    LDast said:
    If the PPC issued the claim themselves, how can they add the £50 legal fee?
    Scott Wilson is CEL’s Barrister on their books.   Not a very good one obviously… 
  • Le_Kirk said:
    You might want to adjust the sentence beginning: -
    "I took a few minutes .................. as there were several other cars ahead which left or found spaces." and
    "I observed the group ahead (around 8 people, with two cars) of me........"
    Sounds like there were two cars in the queue!  Maybe: -
    "I observed the group ahead of me (about eight people from two cars)........"


    Thanks, I've made these adjustments
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