Help needed with two claims froms

Coupon-mad

Sceptical, utilise and authorise don't have k's or z's and a lot of para 8 onwards reads like ChatGPT wrote it...shudder...!  Also PCM can (probably) hold you liable as registered keeper so much of that isn't correct.

seaside_pillow

Thank you @Coupon-mad, your points are noted.

Overall is there anything else that needs to be removed/added/improved? Do you think this defence is good enough?

Coupon-mad

Show us the next draft (only your added section, not the whole template) minus the Chat GPT over-complicated English and minus the bits that say PCM can't hold the keeper liable. And with no US spellings.

seaside_pillow

I have updated the draft accordingly (to my best), feedback is welcome: 


8.0      The Defendant has another family member who resides in the same residential area mentioned in the claim(s) (B%a%r%k%i%n%g R%i%v%e%r%s%i%d%e – I%G%11), and the drivers used the vehicle to visit the said family member. However, since the defendant was neither present nor a passenger during the instances leading to the alleged PCNs, and because they had not agreed to any ‘contract’ nor there was any consent from the defendant to form or enter into any agreements with the Claimant beforehand. Concerns arise on whether these ‘contract(s)’ are legitimate or legally binding, and on what grounds.


9.0      P%C%M U%K's Particulars of Claim(s) fails to outline the terms and conditions of the alleged ‘contract(s)’ or subsequentially provide any evidence about the identity of the driver during the alleged incidents as the vehicles have two authorised drivers. Hence, the Claimant's incoherent Particulars of Claim(s) violate CPR 16.4, warranting the dismissal of the claim(s).

10.0    Given PCM-UK's history of questionable practices and ill-treatment towards motorists, which was exposed by BBC Watchdog previously, Defendant views P%C%M U%K's claim(s) with scepticism due to their lack of integrity and deceit. And knowing the Claimant was previously involved in similar claims when District Judge Cross of St Albans County Court on 20/09/16 struck out a claim without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and 'providing no facts that could give rise to any apparent claim in law'. The Defendant invites the court to strike out these claim(s) as well.

11.0    The Defendant, who is reliant on this vehicle as their main mode of transport due to their disability, denies P%C%M U%K's exaggerated claim(s) of harm or damage, whether intentional or unintentional, viewing them as mere scare tactics to manipulate and exploit people by undermining one of the country institutions, the judiciary, for unlawful gains and claims. These claim(s) are grounded in a business model characterised by extortionate practices aimed at targeting hardworking individuals, and the disabled. Thus, the defendant invites the court to dismiss these claim(s) based on these grounds, and they adamantly refuse to agree to any of P%C%M U%K's demands.

12.0    The Defendant seeks to bring to the court's attention the following matter regarding the failure of both P%C%M U%K's, and B%R%L, the landowner responsible for unit development, to provide adequate parking for disabled Blue Badge (BB) holders. Despite not being the driver of the alleged offences, the Defendant, who is disabled, faces significant barriers in accessing the area due to the lack of suitable parking spaces for non-residential BB holders, which also prevents the defendant from exercising their fundamental rights of visiting and interacting with their family member who lives in this vicinity. The existence of only one designated non-residential disabled parking space constitutes a clear violation of the London Plan 2021 Policy T6.5.


13.0    With an expansive development area spanning 7.7 hectares and comprising more than 1600 units, the provision for disabled parking spaces is grossly inadequate. Such disregard for accessibility raises concerns of discrimination, and contradicts the Claimant's alleged affiliation with the disabled charity organization "Disabled Motoring UK." These actions and violations underscore the urgent need for P%C%M U%K's, and the landowner to rectify the situation and uphold their obligations to provide adequate parking for disabled individuals.

seaside_pillow

Hey, any feedback regarding this version of the draft? @Coupon-mad

Le_Kirk

Is there some reason why you (I assume it is not a keyboard fault) insert % signs randomly?

Coupon-mad

None of this is relevant if you weren't in the car:

11.0    The Defendant, who is reliant on this vehicle as their main mode of transport due to their disability, denies P%C%M U%K's exaggerated claim(s) of harm or damage, whether intentional or unintentional, viewing them as mere scare tactics to manipulate and exploit people by undermining one of the country institutions, the judiciary, for unlawful gains and claims. These claim(s) are grounded in a business model characterised by extortionate practices aimed at targeting hardworking individuals, and the disabled. Thus, the defendant invites the court to dismiss these claim(s) based on these grounds, and they adamantly refuse to agree to any of P%C%M U%K's demands.

12.0    The Defendant seeks to bring to the court's attention the following matter regarding the failure of both P%C%M U%K's, and B%R%L, the landowner responsible for unit development, to provide adequate parking for disabled Blue Badge (BB) holders. Despite not being the driver of the alleged offences, the Defendant, who is disabled, faces significant barriers in accessing the area due to the lack of suitable parking spaces for non-residential BB holders, which also prevents the defendant from exercising their fundamental rights of visiting and interacting with their family member who lives in this vicinity. The existence of only one designated non-residential disabled parking space constitutes a clear violation of the London Plan 2021 Policy T6.5.


13.0    With an expansive development area spanning 7.7 hectares and comprising more than 1600 units, the provision for disabled parking spaces is grossly inadequate. Such disregard for accessibility raises concerns of discrimination, and contradicts the Claimant's alleged affiliation with the disabled charity organization "Disabled Motoring UK." These actions and violations underscore the urgent need for P%C%M U%K's, and the landowner to rectify the situation and uphold their obligations to provide adequate parking for disabled individuals.

seaside_pillow

@Le_Kirk good point. But I have done this because I heard somewhere that PPCs and their solicitors are lurking around here. So trying to minimise that. Not sure if it is effective but just an extra precaution so they don't expect what the defence will be based on even before filing it.

seaside_pillow

@Coupon-mad thanks you again for the feedback

None of this is relevant if you weren't in the car:

I see, so you suggest not including it in the defence. What about the rest of the defence, is it good?

Coupon-mad

I almost never have time to look back!

Show us the new more concise draft of your added bit (please don't show us the rest of the template defence).