Excel Parking vs MrGrumpy

callmeMrGrumpy

Hi, first time poster here, let me say thanks. I’ve been following and using the advice from these boards for a while when the need arises, just I’m at a stage now I’m not 100% on what to write in a Witness Statement for a parking charge I’m challenging against Excel Parking Services Ltd.

 

TL:DR – I paid for the parking on the website which took ages to go through as it was having problems. The problems were not with my phone or connection. Excel say didn’t pay, then in witness statement admit I did pay before exit, but slower than the 5 minutes they allow to complete payment. Took 16 minutes after entering carpark trying pay station, then website, then spoke to staff onsite, called helpline and got no answer whilst continuing to queue on the phone I completed via the website.

As Excel took payment after their 5 minute 'consideration' period - when they knew what time my car entered and time to complete transaction - could them accepting payment constitute a contract? if the 5 minutes was so precious, despite my efforts to pay - why did they knowingly accept payment? 

Since the date in question, the contract at landowner has been renewed, all signage and pay machines have been replaced. Witness statement I have received from Excel have all the current layout and tariffs that are in place now, not which were in place on the date in question, this is confirmed from staff onsite that they have all been updated in the last couple of months.

In my witness statement can I challenge their witness statement as most of the evidence they have provided were not present at the time and as such their evidence is mostly meaningless.

They argue in witness statement that I paid to slowly, when in POC they said I failed to pay.

I have screen shots of payment, phone call log for date, time and duration.

I argue that there was no loss of money anywhere, I paid for 2 hours of parking before 16 minutes after arriving on site and left site 26 mins after arriving. The condition on contract for paying within 5 minutes is an unfair condition given that their equipment onsite, website and service desk were all playing up.

 

The long detail.

Timeline of events on the day are (I’ve removed as much detail to make it identifiable to the PPC in this forum, whilst still trying to maintain the details);

1.1.    I confirm that I am the registered keeper of the vehicle XXXX XXX and was the sole driver of that vehicle on the XX June 2023.

1.2.    My 8-year-old son was attending a birthday party XXXTrampoline CentreXXX Derby.

1.3.    I entered the carpark from the XSideX entrance on ??? Road, in the north east of the site at HH.MM.ss, Drove anticlockwise around the building following the one-way arrows looking for a suitable parking space and parked on the East side of the carpark.

1.4.    Once parked, I approached Pay Station on the corner of the east side of the building. There were several people already present trying to pay without success as the coins were falling through to the rejected coins receptacle. I waited several minutes for my turn and eventually got to the front of the queue.

1.5.    I tried several different coins that I had with me and was having no success, coins just kept falling through to the coin reject receptable.

1.6.    I do not recall there being any facility to pay by card at the machine. The machines on site have been replaced and updated since the 18th June 2023 as well as the parking tariffs and signage.

1.7.    Signage near the Pay Station displayed an online payment option via website that could be used, I don’t recall there being details about an App being available.

1.8.    I navigated to the website on my smart phone. I had a good signal no connection problems. I was presented with the website appearing in a foreign language. I reload the website several times and encountered application timeout (API timeout of the Database connection – I’m an IT professional with over 2 decades experience, online payment processes was part of my day to day work for the last 5 years and it amused me). I close down all open safari browsers on my device attempt to the website again.

1.9.    I completed the above actions in step 1.8 whilst walking round the east and north sides of the building and entered XXXTrampoline CentreXXX  to collect my son, concerned the Party was due to have finished, he would be waiting on his own and be worried.

1.10.                     I enter the building still struggling with the website to load correctly. I approach the staff on reception in XXXTrampoline CentreXXX and advise them I’ve been unable to pay present due to the payment machine not accepting coins and the website not working correctly.

1.11.                     Staff at XXXTrampoline CentreXXX said they were unable to help as the carpark was operated by ‘another company’ they suggested moving the car quickly to the road before it registers properly as I ‘may get away with it’. I stated that I’ve already been trying a few minutes so probably missed the grace period.

1.12.                     XXXTrampoline CentreXXX provided me a phone number for the parking company (Excel Parking Services) which I called and continued to retry the web page.

1.13.                     I was placed in a queue for the phone line.

1.14.                     Exhibit SA1 – Screenshot of phone call log.

1.15.                     I continued to try the website reloading and changing the detected language from Bulgarian to English. The website failed to detect and calculate my location correctly so I was then required to enter the site code for the car park which I noted when near faulty pay machine.

1.16.                     I was still ringing the helpline number, I have a pair of headphones with me, so calling a phone number and listening to it ring constantly whilst browsing a website was entirely possible. I still had a good strong signal.

1.17.                     After several more minutes I managed to navigate the website, register an account, select the correct car park and car details, pay for the parking. All this time the helpline was still ringing and no answer of an actual human to explain the difficulties.

1.18.                     Payment of £1.70 was completed at entry time +16minutes, I believe this was £1.50 for two hours of parking and a 20p online charge, as the Claimants own records account for. (Excel Parking Services Witness Statement – Page 8 Paragraph 16) This was the cost of parking for the minimum term of 2 hours that was available at the time in question. As stated above the tariffs, signs and pay machines have all been updated since the 18th June 2023.

1.19.                     I collected my son from the party area, thanked the parents of child who birthday it was and proceeded back to my car, by walking along the north edge of the building and down the east edge. Entered my car and proceeded to exit the car park back onto Siddals Road to journey home at entry time+26minutes

1.20.                     Total Duration of Stay 26 minutes 25 seconds. Time Paid for prior to leaving the carpark. 120 minutes.

 

 

Particulars of Claim

I’ve taken this directly from the claim form that was submitted to the CNBC in November 2023. I’ve since had the case allocated to the small claims court local to myself. Details omitted as usual.

 

“The claim is for a breach of contract for breaching the terms and conditions set on private land. The defendant’s vehicle, XXXX XXX, was identified in the XXXXX XXXXX car park on the DD/06/2023 in the breach of the advertised terms and conditions; namely Parked without purchasing a valid Pay and Display ticket for VRM. At all material times the Defendant was the registered keeper and / or driver. The terms and conditions upon entering the private land were clearly displayed at the entrance and in prominent locations. The sign was the offer and the act of entering private land was the acceptance of the offer hereby entering into a contract by conduct. The signs specifically details the terms and conditions and consequences of failure o comply, namely a parking charge notice will be issued, and he defendant has failed to settle the outstanding liability. The Claimant seeks the recovery of the parking charge notice, contractual costs and interest.”

 

Amount Claimed                      £170

Cour Fee                                       £35

Legal Representatives Costs £50

Total amount                             £255

 

 

I’ve got the witness statement that Excel have submitted and the notice of allocation to the small claims court. The Judge has set out some additional directions which are all ‘The evidence which the Claimant must file at court and sent to the defendant must include;

a.       A copy of any written terms of the contract between the parties

b.       A copy of the agreement by which the claimant is authorised by the landowner to conduct parking operations.

c.       Details of the location where the contract was made

d.       If Photographic evidence is relied upon, each image must be clear in colour A4

e.       Detailed allegations of any breach of contract relied upon by the claimant

f.        An explanation of how the amount of the alleged debt is calculated under the agreement’

Question – Can I challenge in my witness statement the content of Excels statement? It seems to be just a standard printout of a contract argument. The evidence submitted, has an image – not a photo, so just some computer generated design of what the CURRENT sign at the car park displays and not the sign or wording that was present at the time in question.

A lot of my argument against their witness statement is based on the ‘at time in question’. Their own documents say they had a contract in place and it in effect until November 2023 (5 months after incident) – it was renewed and with that renewal came replacement of the signs and upgrades to parking payment machines and new tariffs. I’ve spoken to people who work the trampoline site and they recall that new signs were put in before Christmas which aligns with my idea.

Page 6 paragraph 3 say there is a paginated bundle marked XX1-2 and goes on to say ‘The evidence tenered in the exhibits is taken from the Claimants company records.’

I’ve got the document and the page numbers and only count upto page 11. After that is a series of images printed and other documents just stuck in at the end. No refence in any of the document directly relates to any of the images or pictures or adds any explanation to what they are. Also these are the company records for the site – then with any document management system dates are available, shouldn’t these be included as the details of the documents and have an awareness of what was in place at which date?

Page 8 Paragraph 14 – ‘The claimant submits that it does not take 16 minutes to pay for parking on an app. If the app was slow then this would be due to the Defendants phone signal or internet which the Claimant cannot be held accountable for.’

                This seems strange – it’s just wild speculation on behalf of Excel – they have not evidenced any fault with their systems and just guess I must have been having a problem with my phone or signal. Are they allowed to just add wild speculation and guesswork and present it as evidence? Also amusing that they say they can’t be held responsible for connectivity problems as it’s outside of their control, but they but that entirely on within my area of control.

Page 8 Paragraph 15 ‘Whilst there is a 5 minute consideration period, the claimant does review each contravention in whereby a ticket has been purchased aftr the consideration period and a view would be taken to either pursue the PCN or no depending on the circumstances.”

Page 8 Paragraph 16 ‘ IN this case, the PCN was pursued as it was deemed by the claimant that purchasing a ticket 16 minutes after entry was not reasonable. The Claimant submits that it does not take a user that long to pay for parking.’

Page 8 Paragraph 17 ‘the claimant avers that there were 2 machines on site at location 1 and a further 2 machines at location 2…’

                I recall there only being 1 machine at the location I paid and there may have been 2 on the other side of the building, but as they have all been replaced since then – how do I evidence or challenge it?

                This seems to be the crux of their action. they haven’t taken into account the circumstances and the efforts I went to complete the payment. The whole ‘you were to slow’ seems to be just a automatic process, originally saying that I hadn’t paid in the POC then changing the case in the witness statement to be ‘you paid to slowly’ whilst taking any accountable to their faulty equipment and services. I paid – took a great deal to pay and completed the transaction paying for 2 hours of parking at a site I only used for 26 minutes and that transaction was completed prior to leaving site. At no point have I tried to evade the parking fee, and this whole claim seem to be just a opportunistic attempt to extort more money for an unreasonable condition.

Page 12 of Excels  witness statement is an aerial image, probably taken from google, of the site with colour pins denoting signs on site, lines for protected area and entrance locations.

This is the current ‘as is’ configuration and has no dates as to indicate when the plan was made. I don’t’ think this was the arrangement that was present at the time in question.

Page 13 is a mock up of the welcome sign that is currently displayed at the site on one of the two entrances. It’s not a photo of the sign, just a design of what it should say. I think they are intending this to be them fulfilling part A of the Judges additional directions.

Page 14 is a photo of half of a sign from one of the two entrances. I was clearly taken in landscape and printed on A4 in portrait so literally half the large sign and maybe 1/3 (left most) of the Caution in wintery times attached underneath on the pole. Even amusing, the tariffs displayed on this sign which are visible do not align with the charges they indicate on page 12. Nor are they the tariffs that you can read from the sign on google Streetview of the carpark taken 3 weeks before my parking issue. This half picture in the statement is a lower price, so I suggest an even older image.

Page 15 is a picture of the sign and pay station that currently in place and was installed just prior to Christmas, months after my issue. Large print can be read, but the detailed T&C’s are not readable in this image. No indication of when the photo was taken or where on the aerial view this is located.

Page 16 – Leaseholder witness statement. This I think is Excel trying fulfil of part B of the Judges directions. This is only a one party signature signed by Alun Cockcroft (commercial Director of Excel Parking Services Ltd) dated August 2020 and states they are the lease holder, and as the lawful occupier of the site, Excel are able to exercise the same rights as the landown (with limited exceptions).

There are no details of who the landowner is, or any additional signatures on the paper. Would this be an example of Excel marking their own homework? They have not provided as the judge requested in part B “A copy of the agreement by which the claimant is authorised by the landowner to conduct parking operations.”

callmeMrGrumpy

continued from above due to post length.

So do I challenge their witness statement in my witness statement or keep them to myself and wait for the court date to challenge them? They seem to have changed their stance from the POC to now claiming no payment then slow payment.

I made all reasonable attempts to pay, and did pay for the parking. Their condition of transaction complete within 5 minutes of entering the site doesn’t seem a fair condition given it was their paystation at fault, their helpline which so busy no one answered after more than 6 minutes and their website that was struggling and having problems.

I’ve got

screen shots of the call I made to their helpline.  

Bank statement saying that the money was taken from my bank.

The actual electronic receipt didn’t arrive in my email – that’s why I took the screenshot of call and got the statement as I suspected that the website was working so badly that they might claim I hadn’t paid at the time.

Streetview with dates of the signs present on site taken 3 weeks before my incident.

Aerial view of site, where I have noted the entrance I used and the route round the carpark I took approximate location of where I parked. Location of the faulty pay machine and route I walked into the venue. (with approximate distances) in meters.         

nopcns

Did you use the template defence? If so, what did you add/edit with your defence?

callmeMrGrumpy

I didn't use a template defence. Wrong of me I know. My Defence is / was - I paid for the ticket that they claimed I hadn't paid for that was detailed in the POC. Here is the evidence of proof of purchase.

nopcns

Ca you show us exactly, the wording used in your defence?

Coupon-mad

We do need to see your defence verbatim.

YES challenge all their dodgy evidence in your WS.  And this is Jumpin' Fun isn't it? Loads of threads about WS written to beat Excel claims there.  Search the forum.

callmeMrGrumpy

Yes it’s  Jumpin fun. Had been searching for Excel parking Derby, hadn’t thought there would be so many people in the same situation with such an exacting search phrase. 

Parenthood roll takes top billing at the moment as I sit watching the swimming lessons. I’ll be able to get infront of my computer in a few hours and respond with the defence. 

I don’t think anyone will be impressed with it - I was foolishly believing that keeping it simple to the point would. Give anyone with any common sense a clear understanding of what happened without all the legal references. Truth and honesty. At some point I assumed someone real would actually take note of this at EPS and apply a human brain rather than robotically servicing the litigation machine. 

callmeMrGrumpy

Like I said - me trying to explain the silliness of this and thinking that someone at EPS would see sense and stop pursuing the matter. defence argument below.

"I paid the £1.70 parking charge via the website on the day when I parked on the carpark. The website was being very slow and it took several attempts for the payment to process successfully.

I supplied a copy of my bank statement to Excel Parking when the original Invoice arrived, showing that payment was made on the day in question and stating the above about frequent interruptions and timeouts I received whilst trying to complete the payment. Ultimately payment was made and proof of payment on my part was supplied to Excel Parking.

This was rejected (I suspect automatically without any human looking at the submission). I then instructed via their appeals process that I wished this to be passed to the independent ombudsman for their review and judgement. I also stated in the response that I as the data subject do not agree with Excel passing these detailed on to any collection agency or party acting in that manner as is my right under GDPR until the outcome of the Ombudsman / Independent review has completed. This is another error in Excel Parting in failure to follow instructions and breaching GDPR.

At no point has excel given an explanation to the why my evidence as insufficient or acknowledged limitations and faults with their online tool on the day in question and have just proceeded to automatically issue claims and waste everyone's times, both mine and the courts.

I will be counter claiming for my time and expenses in defending this abuse of process."

Coupon-mad

Not bad actually.

The main crux is that you paid and you certainly defended that position.

You need to evidence that in your WS along with the usual a-f typical other exhibits seen in the NEWBIES thread.  There are also 5 linked exemplar WS there (not the CCJ set aside ones) but in the other recent Jumpin'Fun threads you will slmost certainly find a pretty much bespoke WS already written for this site.

callmeMrGrumpy

I can't post links yet as account hasn't been active long enough.

text of it in the next few posts.

_________________________

Witness Statement by MX XXXXXXX

Exhibits XXXXXXXXX

 

In the County Court at Derby                                                                                       Claim No: XXXXXXX

 

BETWEEN

Excel Parking Services Limited Claimant

and

Mr XXXXXXXXX Defendant

Table of contents removed as forum says it's a link

 

Witness Statement of Mr XXXXXXX

1.       I, XXXXXXX, of XXXXXXaddressXXXXXX, the defendant against whom this claim is made. The facts below are true to the best of my belief and my account has been prepared based upon my own knowledge.

 

2.       In my statement I shall refer to (Exhibits 1-12) within the evidence supplied with this statement, referring to page and reference numbers where appropriate. My defence is repeated and I will say as follows:

 

Defence argument.

3.    I paid the £1.70 parking charge via the app on the day when I parked on the carpark. The website was being very slow and it took several attempts for the payment to process successfully

 

4.    I supplied a copy of my bank statement to Excel Parking when the original Invoice arrived, showing that payment was made on the day in question and stating the above about frequent interruptions and timeouts I received whilst trying to complete the payment. Ultimately payment was made and proof of payment on my part was supplied to Excel Parking.

 

 

5.    This was rejected (I suspect automatically without any human looking at the submission). I then instructed via their appeals process that I wished this to be passed to the independent ombudsman for their review and judgement. I also stated in the response that I as the data subject do not agree with Excel passing these detailed on to any collection agency or party acting in that manner as is my right under GDPR until the outcome of the Ombudsman / Independent review has completed. This is another error in Excel Parting in failure to follow instructions and breaching GDPR.

 

6.    At no point has excel given an explanation to the why my evidence as insufficient or acknowledged limitations and faults with their online tool on the day in question and have just proceeded to automatically issue claims and waste everyone's times, both mine and the courts.

 

 

7.    I will be counter claiming for my time and expenses in defending this abuse of process.

 

Preliminary matter: The claim should be struck out

 

8.       The Defendant draws to the attention of the court that there is now a persuasive Appeal judgment to support striking out the claim (in these exact circumstances of typically poorly pleaded private parking claims, and the extant PoC seen here are far worse than the one seen on Appeal). The Defendant believes that dismissing this meritless claim is the correct course, with the Overriding Objective in mind. Bulk litigators (legal firms) should know better than to make little or no attempt to comply with the Practice Direction. By continuing to plead cases with generic auto-fill unspecific wording, private parking firms should not be surprised when courts strike out their claims based in the following persuasive authority.

 

9.       A recent persuasive appeal judgment in Civil Enforcement Limited v Chan (Ref. E7GM9W44) would indicate the POC fails to comply with Civil Procedure Rule 16.4 and Practice Direction Part 16. On the 15th August 2023, in the cited case, HHJ Murch held that 'the particulars of the claim as filed and served did not set out the conduct which amounted to the breach in reliance upon which the claimant would be able to bring a claim for breach of contract'. The same is true in this case and in view of the Chan judgment, the Court should strike out the claim, using its powers pursuant to CPR 3.4 (See Exhibit 01).

 

10.   Similarly, at the Wakefield County Court on 8th September 2023, District Judge Robinson considered mirror image POC in claim K3GF9183 (Parallel Parking v anon) and struck the Claim out without a hearing. (See Exhibit 02).

 

11.   Likewise, in January 2023 (also without a hearing) District Judge Sprague, sitting at the County Court at Luton, struck out a similarly badly-pleaded parking claim with a full explanation of his reasoning. (See Exhibit 03).

 

12.   Furthermore, at Manchester District Judge McMurtrie and District Judge Ranson also struck out a claim (again without a hearing) on the grounds of POC’s lacking clarity, detail, and precision. As stated in the final image below, the Claimant’s solicitors confirmed they would not file an amended POC, demonstrating again the reliance of a number of firms on robo-letters and illegitimate practices. (See Exhibit 04).

 

13.   The Defendant believes the Claim should be struck out and should not have been accepted by the CNBC due to a represented parking firm Claimant knowingly breaching basic CPRs. The specifics of this case lack clarity, as no explicit statement has been provided to indicate which specific term of the alleged contract was purportedly breached.

 

14.   POC, copy of text below and Claimants Witness statement (Excel Parking Witness Statement Page 7 paragraph 11) states nonpayment of fees due. Whilst Claimants Witness statement, on the very next page goes on to detail that payment was accepted, Excel Parking Witness Statement Page 7 paragraphs 15 – 16.

 

15.   All fees due were paid by Defendant at the soonest opportunity and completed prior to exiting the parking site despite the Claimants Pay machine being out of order, Claimants website was experiencing technical difficulties and Claimants telephone system was either understaffed or overwhelmed by volume of calls and not answering.

 

16.   Contrary to the POC, EPS seem to be attempting to pursue this parking charge as a breach of contract condition, namely paying within 5 minutes of entry. Defendants that this condition was arduous and unfair which doesn’t take into account the Claimants own failings.

 

 

Particulars of Claim

 

17.   This is a copy of the text taken this directly from the claim form that was submitted to the CNBC in November 2023. 

 

18.   “The claim is for a breach of contract for breaching the terms and conditions set on private land. The defendant’s vehicle, XXXX XXX, was identified in the XXXXX XXXXX car park on the DD/06/2023 in the breach of the advertised terms and conditions; namely Parked without purchasing a valid Pay and Display ticket for VRM. At all material times the Defendant was the registered keeper and / or driver. The terms and conditions upon entering the private land were clearly displayed at the entrance and in prominent locations. The sign was the offer and the act of entering private land was the acceptance of the offer hereby entering into a contract by conduct. The signs specifically details the terms and conditions and consequences of failure o comply, namely a parking charge notice will be issued, and he defendant has failed to settle the outstanding liability. The Claimant seeks the recovery of the parking charge notice, contractual costs and interest.”

callmeMrGrumpy

The timeline of events on the 18th June 2023

 

1.       Timeline for events on the 18th June 2023 are as follows;

1.1.    I Confirm that I am the registered keeper of the vehicle XXXX XXX and was the sole driver of that vehicle on the 18th June 2023.

1.2.    My 8-year-old son was attending a birthday party Jumpin Fun Inflatable Park, Derby. 8 Siddals Road, Derby DE1 2PY.

1.3.    I entered the carpark from the Siddals Road entrance, in the north east of the site at 14.09.22, Drove anticlockwise around the building following the one-way arrows looking for a suitable parking space and parked on the East side of the carpark as indicated in Exhibit 05.

1.4.    Once parked, I approached Pay Station on the corner of the east side of the building. Indicated on Exhibit 05. There were several people already present trying to pay without success as the coins were falling through to the rejected coins receptacle. I waited several minutes for my turn and eventually got to the front of the queue.

1.5.    I tried several different coins that I had with me and was having no success, coins just kept falling through to the coin reject receptable.

1.6.    I do not recall there being any facility to pay by card at the machine. The machines on site have been replaced and updated since the 18th June 2023 as well as the parking tariffs and signage, this was confirmed by Staff working at Jumpin’ Fun as having taken place during the last ‘couple of months’ when I discussed the parking on site with them on 20th March 2024.

1.7.    Signage near the Pay Station displayed an online payment option via website that could be used, I don’t recall there being details about an App being available.

1.8.    I navigated to the website on my smart phone. I had a good signal no connection problems. I was presented with the website appearing in a foreign language. I reload the website several times and encountered application timeout (API timeout of the Database connection – I’m an IT professional with over 2 decades experience, online payment processes was part of my day to day work and it amused me). I close down all open browsers on my device attempt to the website again.

1.9.    I completed the above actions in step 8 whilst walking round the east and north sides of the building and entered Jumpin Fun to collect my son as Indicated on Exhibit 05, concerned the Party was due to have finished, he would be waiting on his own and be worried.

1.10.                     I enter the building still struggling with the website to load correctly. I approach the staff on reception in Jumpin Fun and advise them I’ve been unable to pay present due to the payment machine not accepting coins and the website not working correctly.

1.11.                     Staff at Jumpin Fun said they were unable to help as the carpark was operated by ‘another company’ they suggested moving the car quickly to the road before it registers properly as I ‘may get away with it’. I stated that I’ve already been trying a few minutes so probably missed the grace period.

1.12.                     Jumpin Fun provided me a phone number for the parking company (Excel Parking Services) which I called and continued to retry the web page. Exhibit 06. Please take note of the length of time I was queuing with no answer, could this suggest wider issues with payments increasing caller volume or just mismanaged staffing.

1.13.                     I was placed in a queue for the phone line with no human answering to explain my situation.

1.14.                     I continued to try the website reloading and changing the detected language from Bulgarian to English. The website failed to detect and calculate my location correctly so I was then required to enter the site code for the car park.

1.15.                     I was still ringing the helpline number, I had a pair of headphones with me, so calling a phone number and listening to it ring constantly whilst browsing a website was entirely possible. I still had a good strong signal.

1.16.                     After several more minutes I managed to navigate the website, register an account, select the correct car park and pay for the parking. All this time the helpline was still ringing and no answer of an actual human to explain the difficulties.

1.17.                     Payment of £1.70 was completed at 14.25 as the Claimant own records account for. Excel Parking Witness Statement Page 7 paragraph 16,  This was the cost of parking for the minimum term of 2 hours that was available at the time in question, Exhibit 07 and confirmed in Excel Parking Witness Statement Page 7 paragraph 16. As stated above the tariffs, signs and pay machines have all been updated since the 18th June 2023.

1.18.                     I collected my son from the party area, thanked the parents of child who birthday it was and proceeded back to my car, by walking along the north edge of the building and down the east edge. Entered my car and proceeded to exit the car park back onto Siddals Road to journey home at 14.35.47

1.19.                     Total Duration of Stay 26 minutes 25 seconds. Time Paid for prior to leaving the carpark. 120 minutes.

1.20.                     At no point have I the Defendant denied using the carpark facilities or tried to evade the charges, and I believe I went above and beyond reasonable steps to provide payment.