My first court defence

1505grandad

JoeN1988 said:

1505grandad said:

"20.This inconsistent approach to signage and lack of informing motorists of various terms and conditions equates to usual predatory tactics used by the Claimant to claim money off motorists looking for somewhere to park. Exaggerated Claims and ‘market failure’ currently examined by the Government


32.The Claimant has not provided any evidence of the additional charges"

There seems to be paras missing between 20 and 32?

That's just poor numbering. I'll get that changed. Thanks for pointing it out

The reason I mentioned "paras missing" is because there are usually headings re "CRA breaches" and "Beavis against this claim" which unless I have missed them do not appear in your WS. However you have included the Beavis sign and the Supreme Court Case paras  -  usually quoted under the headings  -  in your exhibits at the end (no list of exhibits at the top of WS nor mention in WS main body).

It was just a quick look so there may be others  -  and do not know which exemplar WS you used.

JoeN1988

Thanks for pointing that out. should be sorted now.

https://www.dropbox.com/scl/fi/ibludcn8c5imenk2mwpxm/Witness-Statement-JN.docx?rlkey=mudjb89tjb967bkh20bi7yfn6&dl=0

Link should now be working

Coupon-mad

JoeN1988 said:

https://www.dropbox.com/scl/fi/45nju9erzkijlowbvtrn9/SKM_C300i24022213290.pdf?rlkey=p54960f3xbbo3yohjq5e2fm07&dl=0

Please find attached a redacted copy of the Claimants WS

Which does include the Authorised White list at the end.  Was that list all redacted, such that the Judge can't tell if your name & VRM was on there?

No evidence of not paying.

JoeN1988

Coupon-mad said:

JoeN1988 said:

https://www.dropbox.com/scl/fi/45nju9erzkijlowbvtrn9/SKM_C300i24022213290.pdf?rlkey=p54960f3xbbo3yohjq5e2fm07&dl=0

Please find attached a redacted copy of the Claimants WS

Which does include the Authorised White list at the end.  Was that list all redacted, such that the Judge can't tell if your name & VRM was on there?

No evidence of not paying.

Is that the white list?

It's just a repeated list of my name, address and email

DVLA logo at the bottom.

I assumed it was something to do with how they attained my contact details.

I redacted that to withhold my personal details

Coupon-mad

Oh ... really?! 

It looked like a Whitelist of exempted vehicles! Oh that's good news!

I have had a re-think and would advise you to remove the 2 paragraphs that point out that there's no evidence of not paying and no evidence of not having an electronic permit.

Just state something more vague and state that you were both a 'user' and you obtained an 'electronic permit' and you deny any breach.

Hopefully being vaguer on that fundamental point will make it easy for you to point out the missing evidence at the hearing!

Tipping JB off now might see a second WS from them, papering over the cracks.

KeithP

Joe, you have left your full name and address showing on page 55 of that dropbox file.

JoeN1988

Thanks CM, I'll get on that this evening. 

Thanks for the heads up Keith. I can't do much about it until i get home this evening.

I could remove the link if it's not needed any more?

JoeN1988

@Coupon-mad I've replaced the paragraphs you mentioned and finalised the WS. I've sent it to a relative who does proofreading.

Do i have to send it to the local court within business hours similar to the Northampton Court or is it a better system?

Coupon-mad

You can email it at any time and won't get a receipt from the local court.  You must copy in the Claimants. 

JoeN1988

Thanks. Strangely the Claimants WS bundle also copied Elms legal in, despite them having chickened out.

Not sure if this is incompetence on their part. Should i copy them in? My instincts day not to.