Permit at work VCS DCB Legal court claim

1505grandad

"10. The Defendant, at all material times, parked in accordance with the terms granted by the lease. "

Contradicts:-

"8. (added to the end of original paragraph #2) However, the vehicle is recognised and it is admitted that the Defendant was the registered keeper but the claimant cannot confirm who was the driver."

Kitkat8

Thank you so much I will edit to say '10. The Defendant, at all material times, maintains that the vehicle was parked in accordance with the terms granted by the lease. "

Kitkat8

I'm going to submit my defence tomorrow so I don't forget I have made the changes recommended. Thankyou all I will keep you updated (:

KeithP

Kitkat8 said:

Thank you so much I will edit to say '10. The Defendant, at all material times, maintains that the vehicle was parked in accordance with the terms granted by the lease. "

Would that be better written as...
'10. The Defendant maintains that at all material times the vehicle was parked in accordance with the terms granted by the lease'.

Kitkat8

I have changed it now thanks so.much @KeithP

Kitkat8

I have also added this: 

11. The Defendant maintains that a permit was displayed in a tax disc holder on the windscreen by the driver of the vehicle before starting their shift on the day in question.

Kitkat8

Another claim form has come through for the 2nd charge. I will be sending the same defence.

Gr1pr

Kitkat8 said:

Another claim form has come through for the 2nd charge. I will be sending the same defence.

But do add cause of action estoppel and Henderson versus Henderson etc, plus that the claims be combined too

Kitkat8

ive just realised i cant send the same defence as i need to update the dates for the preliminary matter so have requested the information again. I'm not sure if action estoppel or Henderson Vs Henderson would apply here as it was a separate incident. Same car park the next day. I will ask for the claims to be combined though

Gr1pr

If all the core components are the same, they should have issued one claim for ALL outstanding invoices, not piecemeal,   so definitely estoppel applies 

Same parking company, same location, same alleged breach, same £100 charge. ( or less per incident, but typically £100. ) , same vehicle, same solicitors too

Doesn't matter if its one PCN , or two , or twenty