SUCCESS DCB Legal Claim Form/Spring Parking

paddyposh

1505grandad said:

"Independent Parking Committee"

I was really pointing out that the above name was changed to International Parking Community in 2016  -  so why are they quoting the incorrect ATA name.

Thanks - I have added that part as well to my point.

paddyposh

Question - some great points on this thread here regarding where they accused me of using a template internet defence. Can / should I include some or all of these points on my WS too?

https://forums.moneysavingexpert.com/discussion/6536889/my-ccj-was-set-aside-have-now-received-a-trial-date-for-sept-please-help-me-understand-this-situ/p7

Only difference being it sounds like on that thread the WS was written by their solicitor Gladstones, whereas mine is written by a solicitor of Spring Parking and signed by him. Upon Googling his name it confirms this to be the case. However, he has added DCB Legal info to the part where he signed the statement of truth?

KeithP

1505grandad said:

"Independent Parking Committee"

I was really pointing out that the above name was changed to International Parking Community in 2016  -  so why are they quoting the incorrect ATA name.

Which confirms that it is not only a template, but an eight year old template.   

LDast

paddyposh said:

Question - some great points on this thread here regarding where they accused me of using a template internet defence. Can / should I include some or all of these points on my WS too?

https://forums.moneysavingexpert.com/discussion/6536889/my-ccj-was-set-aside-have-now-received-a-trial-date-for-sept-please-help-me-understand-this-situ/p7

Only difference being it sounds like on that thread the WS was written by their solicitor Gladstones, whereas mine is written by a solicitor of Spring Parking and signed by him. Upon Googling his name it confirms this to be the case. However, he has added DCB Legal info to the part where he signed the statement of truth?

And what was wrong with the suggestion I gave you a couple of posts back regarding their assertions about your defence?

If you insist on just copying and pasting bits of other WS and then adding what has been provided here, you end up with a useless document that is repetitive, out of sequence and likely to cause your case more harm than good thus justifying the claimants assertions that you use a template and have no idea what you are actually talking about.

LDast

In your draft, you have the preliminary matter in the correct place but then go on to the claimants WS rebuttal and only then go on to facts and sequence of events and then go on to rebut some more points in the claimants WS. It is not good.

Also, where is there Akande transcript which should be at the very top of the list of referenced case law.

paddyposh

LDast said:

paddyposh said:

Question - some great points on this thread here regarding where they accused me of using a template internet defence. Can / should I include some or all of these points on my WS too?

https://forums.moneysavingexpert.com/discussion/6536889/my-ccj-was-set-aside-have-now-received-a-trial-date-for-sept-please-help-me-understand-this-situ/p7

Only difference being it sounds like on that thread the WS was written by their solicitor Gladstones, whereas mine is written by a solicitor of Spring Parking and signed by him. Upon Googling his name it confirms this to be the case. However, he has added DCB Legal info to the part where he signed the statement of truth?

And what was wrong with the suggestion I gave you a couple of posts back regarding their assertions about your defence?

Nothing in fact I thought that was fantastic and have included it all in my WS. I just wasn't sure if I should add some extra bits or not from that about it being unprofessional etc.

Link to my WS here again WS Redacted.docx any comments would be greatly appreciated so I can finalise any bits and submit tomorrow afternoon

paddyposh

LDast said:

In your draft, you have the preliminary matter in the correct place but then go on to the claimants WS rebuttal and only then go on to facts and sequence of events and then go on to rebut some more points in the claimants WS. It is not good.

Also, where is there Akande transcript which should be at the very top of the list of referenced case law.

Thank you I will review the ordering.

The Akande (and Chan) are the top two in Exhibit 1, underneath my statement of truth part. Chan is the first one followed by Akande currently.

paddyposh

Agreed and understand what you're saying. This is all very new to me so apologies for any misunderstandings etc. I have made some adjustments to the order so it now shows the prelim matter, Facts and SoE, Response to the Claimant’s Arguments in Their WS (including land contract) then Claimant’s Assertion Regarding My Defence 

I was looking at other threads for advice and ideas as well as has been mentioned to me numerous times in here, but can appreciate how it can be jumbled and hopefully I have rectified.

LDast said:

paddyposh said:

Question - some great points on this thread here regarding where they accused me of using a template internet defence. Can / should I include some or all of these points on my WS too?

https://forums.moneysavingexpert.com/discussion/6536889/my-ccj-was-set-aside-have-now-received-a-trial-date-for-sept-please-help-me-understand-this-situ/p7

Only difference being it sounds like on that thread the WS was written by their solicitor Gladstones, whereas mine is written by a solicitor of Spring Parking and signed by him. Upon Googling his name it confirms this to be the case. However, he has added DCB Legal info to the part where he signed the statement of truth?

And what was wrong with the suggestion I gave you a couple of posts back regarding their assertions about your defence?

If you insist on just copying and pasting bits of other WS and then adding what has been provided here, you end up with a useless document that is repetitive, out of sequence and likely to cause your case more harm than good thus justifying the claimants assertions that you use a template and have no idea what you are actually talking about.

1505grandad

Also:-

"Conclusion

30. The Claimant's PoC........"

there are 54 paras yet a conclusion heading/para is halfway through the WS.

paddyposh

1505grandad said:

Also:-

"Conclusion

30. The Claimant's PoC........"

there are 54 paras yet a conclusion heading/para is halfway through the WS.

Thank you - misheading by me, was meant to sum up the initial points. Will move to the bottom with my main conclusion