At Claim Stage - Would appreciate feedback on defence paragraphs

Jack_Russell45

Hi, new on here and I've submitted AOS and followed Template defence following guidance on the forum and would appreciate feedback on the below bits that I inserted:

"3. The Defendant was driving down xxxxx towards xxxx city centre when he became light-headed. The Defendants son suggested pulling off the road into an abandoned Iceland store as a safe course of action. The abandoned stores car park was empty and there were no visible parking signs that the defendant could see. The Defendant pulled into the abandoned stores car park area as the suggestion was the safest course of action.

 4. The Defendant is a law-abiding citizen that follows the rules and has never knowingly parked in a paid car park without purchasing a ticket. The Defendant would have still pulled into the abandoned store as it was the safest course of action had he have known it was a paid for car park and would have purchased a ticket. This was an honest mistake, the Defendant kept the car running and made no attempt to park in a bay.

 5. The Defendants son went to a local shop for a bottle of water for the Defendant. The Defendants son did not see any parking signs when he exited the car park or on his return to the vehicle. The Defendant exited the car park approximately 3 minutes after entering when the light-headed episode subsided."

KeithP

Hello and welcome.

What is the Issue Date on your Claim Form?

Upon what date did you file an Acknowledgment of Service?
Your MCOL Claim History will have the definitive answer to that.

Jack_Russell45

Hi and thanks for the welcome,

Issue date 26th Feb, AOS done on 2nd March. Probably I completed AOS too quickly but I had the time so went ahead.

troublemaker22

Still plenty of time to draft a good defence without prematurely giving away too much information. To help us guide you please post the front page of the claim form (redacting the CNBC claim reference, the claimant’s reference your name, address, vehicle number and claim password). 

Castle

Jack_Russell45 said:

Hi and thanks for the welcome,

Issue date 26th Feb, AOS done on 2nd March. Probably I completed AOS too quickly but I had the time so went ahead.

2nd March was a Saturday and therefore, your AOS will deemed to have been received on 4th March. Deadline for filing your defence will be Tuesday 2nd April 2024.

Jack_Russell45

Here is the front page of the claim form, thanks for any inputs

Jack_Russell45

Here is the front page of the claim form, thanks for any inputs

Coupon-mad

OK. Standard DCBLegal generic roboclaim rubbish.  The Template Defence will do. 

Jack_Russell45

Coupon-mad said:

OK. Standard DCBLegal generic roboclaim rubbish.  The Template Defence will do. 

Thank you, is there anything in my 3 bullet points at the start of the thread that I should leave out or in your experience is it good enough to go?

Coupon-mad

Remove the repetition: 'abandoned' (3 times!).