Golden nuggets: Put in the Defence or save for the Witness Statement?

themofster

So the muppets that are UKPC and DCB Legal are unaware of a number of golden nuggets, mainly who the landowner actually is (and how the car park is used by multiple entities under one group), how manically confusing their signage is (due to them not understanding/being completely unaware of the landowner's organisational structure), and the fact that the car park was free parking on the day of the supposed contravention (the supposed contravention was permit-related. However, the car park is usually pay-and-display).

So my question - based on the fact that the Defence is more of a tick box exercise (based on my limited knowledge, happy to be corrected) and a court appearance is likely anyway, should I save these important arguments for the WS so the Claimant has little time to blag a response?

Thank you!

Coupon-mad

A court appearance won't happen.

DCBLegal always discontinue well-defended cases at WS stage.

Both the main things you mention (landowner authority and signage) are ALREADY in the Template Defence anyway.  So you don't need to elaborate on those until WS stage when you win.

And if you look at the current template defence you will see to add the paragraphs about CEL v Chan (and the transcript).  By way of details underneath that section you could just vaguely state that parking was free and the Defendant cannot understand why a charge or a claim was raised at all.

themofster

Thank you for the clear and concise feedback as always @Coupon-mad