Defence in court
The facts known to the Defendant:
2. The facts in this defence come from the Defendant's own knowledge and honest belief. Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to "state all facts necessary for the purpose of formulating a complete cause of action". The Defendant is unable, on the basis of the POC, to understand with certainty what case, allegation(s) and what heads of cost are being pursued, making it difficult to respond. However, the vehicle is recognised and it is admitted that the Defendant was the registered keeper.
3.1 Communication with Parking Company and Gladstone Solicitors:I communicated to Parking and Property Solutions (PPS) that Defendant was not the driver in both instances. Unfortunately, there was no response from PPS. Subsequently, the case was passed to Gladstone Solicitors, and on 23/06, defendant sent an email providing the details of the actual driver who was collecting him and two toddlers aged 2 and 1 from home address. Despite providing these details on 01/11/23, defendant received no further communication from Gladstone Solicitors.
3.2 Stopping in Parking :
On both days, the driver stopped the car in the parking area to assist in loading me and our toddlers from our home address. As the children needed to be loaded safely, stopping elsewhere on the street was not feasible due to double yellow lines and heavy traffic. The driver briefly stopped by the exit door to the building to facilitate the safe loading of the toddlers into the car. After stopping and loading, our intention was to drive away, and this is precisely what transpired. Additionally, due to a broken lift, it was safer for the driver to come to the flat to assist in taking the two toddlers downstairs.
All points 4-30 as in template
Statement of Truth
I believe that the facts stated in this defence are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
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