Do I have a defence? - Claim Form Received

Camex3000

Okay thank you @Coupon-mad . I have given this a go. Please see my WS here - https://www.dropbox.com/scl/fi/bzm4laxu79n0aususvjqc/WS.docx?rlkey=vah3dzkfga0fvv9a6jyw5ns1j&st=ns3llwll&dl=0 

I would really appreciate any critique / comments here.  

This has taken me a lot of today (yesterday now I suppose) and I am not very confident in what I have provided myself. I think a number of my points are very similar to what's been included in my defence. Is this okay? 

I have added the Multiple Claims for same Circumstance PCNs section (Paragraphs 18-21). I wasn't sure if this should be a separate section or I should've just included these as extra points to the Facts and Sequence of Events Section? 

This section is also wording taken from my defence with just the evidence of payment adding. Would this be okay? I wasn't sure on how to best put this across in my WS apart from doing this. 

In Paragraph 32, I have highlight '2023'. Should this now be changed to 2024? 

Having also received the claimants WS on morning of the 20th. I have included the 'Observations re this Claimant's Witness Statement Section' (Paragraphs 41 & 42), using some detail I found on here. Is this okay and should I be including anything further here?   

With this is it also okay to take images from their WS to use as exhibits for mine? 

Also with Paragraph 47, is there anything further I need to do or include to claim my costs? 


Apologies for the further questions as well. Any guidance on these would be really helpful too and much appreciated.

Thank you again for the extensive help to date. 

Coupon-mad

Yes that's good!

In 3, 8, 12, 18, 19 and probably more, you have 'The Defendant draws/believes' etc., which should all be changed to the first person: "I".

With this is it also okay to take images from their WS to use as exhibits for mine? 

I would not add to your pages - just refer to their exhibit number if talking about one of their pics.

Try to stay under 50 pages.

1505grandad

Para 40  - is the following applicable?:-

"as I attempted to gain entry to the store."

(The photo in the o/p suggests just housing?) 

KeithP

Are your initials CQ?
If so, your full name is retrievable via Dropbox.

Camex3000

KeithP said:

Are your initials CQ?
If so, your full name is retrievable via Dropbox.

Ah okay, is this still viewable? I have attempted to change the name so this can't be seen. Thank you for letting me know. 

KeithP

Camex3000 said:

KeithP said:

Are your initials CQ?
If so, your full name is retrievable via Dropbox.

Ah okay, is this still viewable? I have attempted to change the name so this can't be seen. Thank you for letting me know. 

You've fixed it. Well done.

Camex3000

In 3, 8, 12, 18, 19 and probably more, you have 'The Defendant draws/believes' etc., which should all be changed to the first person: "I".

Thank you @Coupon-mad, I have updated this to change The Defendant to 'I' where I believe this was applicable. The documents is at 42 pages, or that's what it's displaying as to me at least. 

1505grandad said:

Para 40  - is the following applicable?:-

"as I attempted to gain entry to the store."

(The photo in the o/p suggests just housing?) 

Good spot @1505grandad thank you. I have updated this now. 


Please see my updated WS here - https://www.dropbox.com/scl/fi/rmtjv0my25ofp74mzzp9n/WS2.docx?rlkey=hi1xlhqvjseh611vc5nyjht5q&st=g706heem&dl=0 

Would this now be all okay to send, or is there anything else I should be changing / adding? 

Many thanks.                          

Coupon-mad

You need the date/time metadata showing in your signage pics, but I would not show exhibits 6 or 8 at all.  I'd remove mention of those.  They are too close up and legible IMHO.

Also, where you talk about Chan, add the judgments URL and refer to it (see the NEWBIES thread list of recommended exhibits).  Someone else has done this today already so you could copy what they put about that URL.  I don't recall the username.

Also (unless I missed it) you don't seem to have the Beavis case quotes listed in the a-f list of recommended Exhibits in the NEWBIES thread.

Camex3000

Thank you yet again @Coupon-mad. I have updated the images of signage to include the date/time and removed exhibits 6 and 8. Please see the updated WS here - 
https://www.dropbox.com/scl/fi/0t5vmhzcsb0kucmzjpkxj/WS3.docx?rlkey=fx64aia38r8e59r53xqhtx6td&st=y05l0rxj&dl=0

Does it matter that the images were taken in 2023? 

Where I have taken out the previous Exhibit 08, can I still make the statement in Paragraph 13 about the No Parking on Access Road sign, not having this exhibited anymore and not having further pictures of this sign. It's shown within the Claimants Exhibits, should I refer to that? 

I have also added in the judgments URL for Chan under the section I talk about Chan - Paragraph 5. This is all okay to include here in addition to Exhibit 1, as referred to in Paragraph 4, which is partially the same? 

With the Beavis case quotes, is this not what is shown in exhibit 13, or is that something further? 

I have also seen that you've advised that we are expecting an updated final draft IA from the DLUHC soon and as such recommended that person to keep up to date on this before their hearing. I assume this would be the same for myself? 

Thank you

Coupon-mad

I didn't intend that you remove the "no parking in access road" sign.  There were two close ups (looked like the same sign) shown as exhibits 6 & 8 and only those were to be removed.