DCB Legal Claim form issued - help drafting defence

PartyPops

Coupon-mad said:

I'd wait 3 weeks for the same reason I explained to @cheme7676 just now.

Interesting! Well my defence is drafted and ready.

I’ll set a reminder to check back in the forums on 20th July as I think I have until 31st July to submit my defence.

Hopefully, there will be further points that can be made in favour of fellow motorists like us.

PartyPops

Defence has been submitted as I am coming to the deadline. 

Question: Is there a deadline for the questionnaire that I need to fill out when I receive it and when should I receive the questionnaire by?

KeithP

It takes minutes to file a Defence, but you have filed yours a week before the deadline.
You have now thrown away the opportunity to add any new information that is expected this week.

It will be several weeks before you get a Directions Questionnaire to complete.

1505grandad

"Defence has been submitted as I am coming to the deadline."

Just checking  -  did you receive auto acknowledgement to the early filing of D?

PartyPops

1505grandad said:

"Defence has been submitted as I am coming to the deadline."

Just checking  -  did you receive auto acknowledgement to the early filing of D?

Yes, I received the auto acknowledgement. Thanks for checking.

KeithP said:

It takes minutes to file a Defence, but you have filed yours a week before the deadline.
You have now thrown away the opportunity to add any new information that is expected this week.

It will be several weeks before you get a Directions Questionnaire to complete.

I didn’t want to leave it to the very last minute and there is no guarantee that the new information will come this week. I can however use this information in a new claim that I am expected to receive next month as I’ve got a notice letter for another parking charge from another company which I’ll set up a new thread for. Thank you

KeithP

PartyPops said:

KeithP said:

It takes minutes to file a Defence, but you have filed yours a week before the deadline.
You have now thrown away the opportunity to add any new information that is expected this week.

It will be several weeks before you get a Directions Questionnaire to complete.

I didn’t want to leave it to the very last minute...

No-one said to leave it to the last minute, did they?

But to file a Defence seven days before the deadline is just plain silly when we are expecting good information that you might have wanted to include.

PartyPops

Update after many months....

So I filed my defence as stated and it took pretty much nearly 3 months for a Directions Questionnaire to arrive as the court is coping with a heavy load of cases right now. I rang up to check if the Claimant complied with the 28 days deadline to make their intentions clear if they would like to proceed upon receiving my Defence and looks like they did (same day of receiving it lol).

I received the Directions Questionnaire and have filled it out online and returned it using the guidance on this forum to the email address I filed my defence to and also sent copies to DCB legal email addresses (info/danielle/paul @dcb and also sent one to enquiries@secureaspace and I'm within the timeframe as the deadline is next week. 
(note that I haven't posted any physical copies as I don't think there's any way to track these if not signed for)

So here we are on our way to the main event, waiting to get a hearing date and will be drafting up a Witness Statement to file within 14 days of the hearing date I'm given.
Will use guidance from baz417 upload on Claim form for car parking charges - Page 15 — MoneySavingExpert Forum put into my own words
I've taken some key points in the newbies thread that I intend to rely on, anyone have any additional ones or think some of these are outdated and thrown out?

1. photos proving the scarce/illegible small print signs
2. Car park operates a colour coded bay system dividing bays into five groups (pay and display / 4x types of permits different departments in building), all written in very small printed writing making it confusing for the driver
3. A copy of the Beavis case sign as a comparison to the signs in the car park (I have visited car park and taken pictures how bad it looks shown on page 1 of this thread)
   
4. Exaggerated Claim and 'market failure' currently examined by the Government
   
5. CRA Breaches
   
6. The Beavis case 
   
7. Hidden Terms (high costs buried in small printed terms on awful sign)

Attach exhibits:
1. ParkingEye Limited v Beavis–Paragraphs 98, 193, and 198

2. Parkingeye sign 
3. Fairlie v Fenton (1870) LR 5 Exch 169 Transcript
4. Excel v Mrs S transcript
5. Excel v Wilkinson Case Transcript
6. Photos of terrible signs in car park poorly worded (some of the photos from page 1 in this thread)

Should I be attaching any evidence to support number 5 in my key points list, CRA Breaches? Should I put something in exhibits for this?
If anyone has some DCB Legal cases that I can use that would be even better

Coupon-mad

Why these? Not relevant to most cases:

3. Fairlie v Fenton (1870) LR 5 Exch 169 Transcript
4. Excel v Mrs S transcript

Why not CEL v Chan as seen in every WS now?!

UncleThomasCobley

If you use the CEL v Chan case (which you absolutely must for a DCB Legal filed claim) in your WS, make sure that you change the highlighted "2. The Defendant draws to the attention of the allocating Judge that there is now a persuasive Appeal judgment..." to "2. The Defendant draws to the attention of the Court that there is now a persuasive Appeal judgment..."

PartyPops

Coupon-mad said:

Why these? Not relevant to most cases:

3. Fairlie v Fenton (1870) LR 5 Exch 169 Transcript
4. Excel v Mrs S transcript

Why not CEL v Chan as seen in every WS now?!

I took it from the baz417's template however upon looking into it, the only one I am keeping is the Excel v Mrs S transcript: "Now for the first time, the DLUHC's draft IA exposes that the template 'debt chaser' stage costs less than £9. This shows that HHJ Jackson was right all along in Excel v Wilkinson"
I am thinking of actually removing it as it may not be relevant, thoughts?

I have actually prepared my Witness Statement from now as I want to be ready and don't want this whole case clashing with my work schedule so I thought I'd get it out the way sooner the better.
CEL v Chan has been added.

I've uploaded it censored my bits on:
https://www.dropbox.com/scl/fi/64045l8h1u6cj6iilu529/WS-Censored-DCB.docx?rlkey=y72ozp1kvcmv5at2p3qmimhfv&dl=0

I have highlighted in yellow the parts that I've added to baz417's template and I've also removed quite a bit from his template that wasn't relevant to my case i.e. keypad error on payment machine as no payment was made in my case.

I would appreciate some feedback on the following:
- Overall template
- Did I include too many images of car park and signs? Do you think my images will work in my favour? i.e. lighting not working on all lights, terrible signage etc. referred to in 24/27/28/29/30 
- 19 - 22 CEL v Chan referred
- Do you think my 27/28/29/30 being in the CRA Breaches section is a good structure to put it in there or should i have it in its own section titled something else?