CLAIM DISMISSED - CLERKENWELL COURT 10.02.25

skintbutwantstosave

1.        I am xxxx, of xxxx and I am 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 and honest belief. 

 

2.        In my statement, I shall refer to Exhibits SA1-7 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:

 

3.        I deny that the Claimant is entitled to relief in the sum claimed, or at all. It is denied that any conduct by the driver was in breach of any term.  Further, it is denied that this Claimant (understood to have a bare licence as agents) has standing to sue or form contracts in their own name. Liability is denied, whether or not the Claimant is claiming 'keeper liability'.

 

PRELIMINARY MATTER - The Claim should be struck out

4.        I respectfully submit that, before proceeding with the hearing, the Court should consider a Preliminary Matter: striking out the claim due to the Claimant's failure to comply with CPR 16.4. The Particulars of Claim (PoC) do not meet the requirements under CPR 16.4(1)(a) and (1)(b), and thus also fail to satisfy the requirements under CPR 16.4(2). The Claimant’s Witness Statement (WS) attempts to justify the deficiencies by referring to Practice Direction 7C and CPR 1, but this does not remedy the fundamental inadequacies in the original PoC.

Non-Compliance with CPR 16.4

5.        Failure to Comply with CPR 16.4(1)(a): The PoC do not provide a concise statement of the facts on which the Claimant relies. The vague allegation of breaching terms and conditions does not specify the facts constituting the alleged breach, nor does it detail how or when the breach occurred, or the specific terms allegedly breached. There is no explanation of how the amount claimed was calculated. This fails to meet the requirement for a concise statement of facts that enables the Defendant to understand the case.

 

6.        Failure to Comply with CPR 16.4(1)(b) and (2): The Claimant seeks interest under section 69 of the County Courts Act 1984 but does not comply with CPR 16.4(1)(b) and (2), which require the details of the interest sought. While the PoC state the interest rate (8% per annum) and daily rate (£0.02), they do not indicate the date from which interest is claimed, the date to which it is calculated, or the total amount of interest claimed up to that date.

 

7.        Failure to Comply with CPR PD 16(7.5): The claim is for an alleged breach of contract that was supposedly entered into by conduct. CPR PD 16(7.5) specifically states:

8.        “7.5 Where a claim is based upon an agreement by conduct, the particulars of claim must specify the conduct relied on and state by whom, when and where the acts constituting the conduct were done.”

 

9.        The PoC do not adhere to this requirement. They fail to specify the exact conduct relied upon to establish the contract, as well as the time, location, and party responsible for the acts constituting the alleged conduct. The omission of these essential details renders the PoC inadequate for a claim based on an alleged agreement by conduct.

Response to the Claimant’s Arguments in Their WS

10.    The Claimant’s WS argues that the claim was issued via the County Court Business Centre, and that Practice Direction 7 are only permitted to insert brief details on the Claim Form. However, this does not override the fundamental requirement under CPR 16.4 for the PoC to set out a clear and concise statement of facts. It cannot be right that the fundamental basic rule that Particulars of Claim must set out the case which a defendant has to meet can somehow be swept away by the character limit imposed by the MCOL system. If the Claimant really cannot fit that into the 1080 character limit, then the remedy is to serve detailed Particulars of Claim.

11.    The reference to Practice Direction 7C section 5.2A does not excuse the Claimant’s failure to meet the requirements of CPR 16.4. While it may be true that attaching documents is not mandatory under Practice Direction 7C, the PoC still must satisfy the standard for adequately pleaded claims. The Claimant’s argument effectively suggests that the rules allow for a lower standard in online claims, which is not supported by the CPR or relevant case law.

12.    Furthermore, the Claimant may argue that they have subsequently addressed the deficiencies in their WS. However, this does not retrospectively cure the original non-compliance. The Civil Procedure Rules clearly require the PoC to include sufficient detail from the outset, and not to be supplemented later in an attempt to remedy shortcomings. The purpose of the PoC is to give me adequate notice of the case they need to answer and to enable the preparation of a defence at the earliest opportunity. Allowing the Claimant to rely on their WS to fill in gaps would undermine this purpose and the principles of fairness, procedural justice and the Overriding Objective.

 

Misapplication of CPR 1

13.    The Claimant’s reference to CPR 1, which outlines the Overriding Objective to deal with cases justly and at proportionate cost, does not excuse non-compliance with CPR 16.4 and CPR PD 16(7.5). Ensuring proportionality does not allow for inadequate particulars that compromise my ability to understand the claim. The Overriding Objective requires fairness to both parties, and the failure to provide properly pleaded PoC undermines this principle.

14.    The Claimant's PoC were deficient from the outset, failing to comply with CPR 16.4 and CPR PD 16(7.5), thereby placing the Defendant at a disadvantage by not providing sufficient detail. The subsequent attempt to address these shortcomings in the WS does not retrospectively cure the original non-compliance. Given these deficiencies, I respectfully submit that the Court should strike out the claim.

 

Facts and Sequence of events

15.    Date and Time of the Incident: It is admitted that on the material date, I was the registered keeper of the vehicle VRN. It is unknown who the driver of the vehicle was on the dates of the claimed PCN, given the PCN dates back to 2019.

 

16.    Multiple users of the vehicle: Multiple family members were authorised by me to use the vehicle at the times of the alleged contraventions via their own comprehensive insurance policies, which allowed them to use another private vehicle for which they were covered on a third party only basis.

 

17.    No authority to issue Parking Notice: The claimant pursues a claim for  the vehicle not parking fully within a marked parking bay. I do recognise the location of the alleged parking violation as being at Lions Court in Northampton as I have walked via adjacent streets across the Wathen Wigg Bridge as a shortcut. It is denied the Claimant has authority to issue a parking notice as described in the Claimant’s WS at paragraphs 4-8.

 

18.    The Claimant relies upon the authority granted to them under the terms of a Landowner Agreement as alleged at paragraph 5 of the WS and that the Claimant is authorised by the Landowner to manage and enforce parking on the land. The Claimant exhibits a copy of the said “Landowner Agreement” at GS1.

 

19.    Exhibit GS1 is not a “Landowner Agreement between the Landowner and the Claimant, but it is titled a “Parking Scheme Agreement between Nene Riverside MCL (RMG) a management company and the Claimant. At paragraph 7 of the said “Landowner Agreement, it is stated:

 

“The Client must notify NPM immediately in writing of any change of landowner”

 

20.    This makes the agreement presented not factually correct with the claimants statement that the agreement is between the Landowner and the Claimant; the Claimant’s standing and rights to manage and enforce the regulations in situ at the site, are simply hearsay without evidence that they have the Landowners authority. I have seen no such evidence of this legal authority or a contractual arrangement between the Claimant and the Landowner as alleged at paragraph 5 of the WS.

 

21.    Furthermore at Exhibit GS3 a site map has been provided which sets out the Claimant’s parking boundary and areas where signage is to be erected for which parking is to be enforced.

 

22.    Photographs provided within the statement at GS4, quite clearly show that the vehicle was observed to be outside the parking boundary as provided within the site map and outside the confines of the alleged agreement that was in place between the Claimant and the Landowner. Google street view screengrab coloured in yellow and GS3 coloured in yellow are provided at Exhibit [SA1] for ease of reference to show where the vehicle was parked.

 

23.    The Claimant therefore has no contractual basis whatsoever to state a contract was formed between the Claimant and the Defendant, as the Claimant had no legal standing. Further the Claimant has no contractual authority to issue or charge any parking charge notices as it outside the bounds of the Landowner Agreement between the Claimant and the Landowner.

 

24.    While the claimant references One Parking Solution Ltd v Wilshaw [2021] to argue that proving the landowner’s authority is not necessary, this case does not absolve them from demonstrating that they have the right to pursue legal action based on an agreement that does not involve the landowner. The agreement with Nene Riverside MCL (RMG) does not, in itself, establish the claimant's standing to issue Parking Charge Notices or pursue litigation, as Nene Riverside MCL (RMG) is not the landowner. There is no evidence within the agreement that Nene Riverside MCL (RMG) has been expressly authorised by the landowner to delegate the rights claimed by the claimant. Without such evidence, the agreement presented does not substantiate the claimant's claim to enforce parking charges on the land.

Furthermore, the claimant’s assertion that privity of contract applies is flawed. As the agreement is not directly with the landowner, I am entitled to challenge whether the claimant has the requisite rights to enforce parking terms. The claimant cannot simply assert authority through Nene Riverside MCL (RMG) without demonstrating that the landowner expressly authorised this arrangement. In the absence of such evidence, the agreement presented by the claimant is insufficient to demonstrate their standing.

 

25.    Inadequate Signage: I have observed a lack of clear and visible signage regarding parking regulations. The signs that are present are placed in obscure locations, making them difficult to notice, including one that was positioned on an erected fence/ enclosure far from a typical line of sight. The sign does not stipulate where this alleged contract is enforced. Additionally, the signage featured very small text, making the terms and conditions impossible to read from a reasonable distance. The poor placement and legibility of these signs made it extremely difficult for anybody to be aware of or comply with the parking rules which can be seen in the photographs exhibited in the Claimant’s WS at Exhibt GS4.

 

26.    Regarding the contractual element of the sign, the claimant contends that a contract was formed between the driver and the claimant based on the terms displayed on the sign. For a contract to be formed, there must be a clear and unequivocal offer capable of being accepted by conduct.

 

27.    In light of these issues, the Claimant has failed to establish that a valid and enforceable contract was formed between the driver and the claimant, and the authority to issue the Parking Charge Notice is questionable. The prohibitive nature of the sign and the lack of a direct agreement with the landowner significantly undermine the Claimant's position, and the claim should be dismissed accordingly.

 

28.    The Claimant refers to a letter (Claimants WS Exhibit GS6) titled Notice to Registered Keeper they claim to have sent to my address in March 2019 where they cited the reason for the parking charge notice was that the vehicle was “Parked in a no Parking Area” which is completely different to the Claimant’s WS where they allege the vehicle was not parked fully in a marked bay.

 

29.    No authority to obtain KADOE details from DVLA given that the vehicle was not parked within the parking boundary within which the Claimant was entitled to enforce, the Claimant had no authority to obtain the Registered Keeper’s details from the DVLA.  Under paragraph B2.3 of the KADO contract:

 

Before making each request for Data, the Customer shall gather evidence to demonstrate that it has Reasonable Cause to request that Data. This evidence may include scans, images, photographs, correspondence and any other evidence that the Customer may rely on to show its compliance with the requirements of this Contract and of the relevant Accredited Trade Association’s Code of Practice.

 

30.    The Claimant has failed to gather evidence which demonstrates that it had Reasonable Cause to request Data from the DVLA.

 

skintbutwantstosave

Primacy of existing residential parking rights

1.        Notwithstanding the above, I assert that the Claimant’s signs cannot (i) override the existing rights enjoyed by residents and their visitors and (ii) that parking easements cannot retrospectively and unilaterally be restricted where provided for within a lease. I will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services Ltd (2016) and of Sir Christopher Slade in K-Sultana Saeed v Plustrade Ltd [2001] EWCA Civ 2011. (Exhibit SA2 and SA03)

 

2.        This position is supported by the recent Court of Appeal decision in Duchess of Bedford House RTM Company Limited & Ors V Campden Hill Gate Ltd (2023) ECWA Civ 1470 which reaffirms residential parking rights using not only a fair interpretation of the lease but also Section 62 of the Law of Property Act 1925 (Exhibit SA04)

 

Particulars of Claim (POC) in breach of Procedure Rules

 

3.        I draw to the attention of the allocating Judge that there are now two persuasive Appeal judgments 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).  I believe 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.

 

4.        The appeal judgments in Civil Enforcement Limited v Chan [2023] (Ref. E7GM9W44) (CEL v Chan) and CPMS v Akande (Exhibit SA06) would indicate the POC fails to comply with Civil Procedure Rule 16.4(1)(e) and Practice Direction Part 16.7.5. 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 (Exhibit 04) the Court should strike out the claim, using its powers pursuant to CPR 3.4.

 

5.        The claim appears to be using generic wording which has obstructed any semblance of clarity.  I trust that the court will agree that a claim pleaded in such generic terms lacks the required details and would have required proper particularisation in a detailed document I respectfully submit that the claimant’s continued reliance on these deficient POCs should result in the court giving no weight to their justification, and I once again refer the court to the persuasive appeal case above, CEL v Chan [2023], which I have included as evidence. 

 

6.        Furthermore, these additional costs appear to be arbitrary and penal in nature. Under established law principles, such as ParkingEye Ltd v Beavis [2015], parking charges must either be a genuine pre-estimate of loss or commercially justified. In this case, the additional £70 is neither justified nor explained. (Exhibit 06)

 

7.        The claimant has provided no breakdown or explanation of how this amount was calculated or why it is appropriate. It can only be viewed as a punitive charge designed to penalise the defendant, which is contrary to established legal principles that prohibit excessive and unfair contractual penalties.

 

8.        The claimant’s demand for additional costs of £70 per PCN is entirely baseless. It is not supported by any clear contractual term, it violates the CRA's requirements for fairness and transparency, and it constitutes an unlawful penalty charge. The court should strike out this portion of the claim as unenforceable.

 

Claimant’s Assertion Regarding My Defence

9.        The Claimant alleges in their Witness Statement that I have filed a "generic Defence downloaded from the internet" and suggests that my Defence lacks substance or is disingenuous. I respectfully submit that this assertion is unfounded and overlooks the procedural and legal context in which my Defence was prepared. The validity of a Defence is determined by its legal basis, not by whether it addresses procedural issues or raises common legal points.

10.   Firstly, the Claimant's assertion that I did not engage with their appeals process does not affect the substance or merit of my Defence. There is no requirement under the Civil Procedure Rules to pursue an internal appeal before defending a claim in court. My right to challenge the claim remains intact regardless of whether I engaged with the Claimant's appeals process, and this has no bearing on the validity of my Defence. The court is concerned with the merits of the legal arguments, not the extent of my prior engagement with the Claimant’s appeals procedures.

11.   Secondly, the primary basis of my Defence is that the Particulars of Claim (PoC) provided by the Claimant were woefully deficient and failed to comply with CPR 16.4. The PoC did not include a concise statement of the facts or sufficient detail about the basis of the claim, leaving me unable to understand the case I was required to answer. This is a legitimate and substantive challenge to the adequacy of the claim. The Claimant's failure to provide compliant PoC is a procedural issue that directly affects the fairness of the proceedings and my ability to prepare a detailed response.

12.   The Claimant’s suggestion that my Defence is a "template" does not diminish its validity. Legal arguments addressing procedural deficiencies, such as the non-compliance with CPR 16.4, are entirely appropriate and can be raised in any Defence, whether they resemble arguments used in other similar cases or not. The hypocrisy in the Claimant's assertion is evident, as their PoC themselves are a "template," albeit a particularly deficient one, commonly seen in bulk litigation claims. The fact that the Claimant's PoC contain deficiencies shared across many cases only underscores the legitimacy of my challenge. It is ironic for the Claimant to criticise my Defence as a "template" when their own PoC consist of generic, auto-filled wording that fails to comply with procedural requirements. A Defence that addresses relevant procedural issues is not rendered insubstantial simply because similar procedural failings are encountered frequently.

13.   Moreover, the Claimant's contention that I did not raise challenges at earlier stages, such as during the debt collection process or in response to a Letter of Claim, is irrelevant to the merits of my Defence. The timing or lack of previous objections does not preclude me from challenging the claim now. The Claimant’s failure to provide sufficient detail in the PoC prejudiced my ability to engage meaningfully with any earlier correspondence and does not negate my right to a fair hearing on the issues now raised.

14.   The substance of a Defence lies in the legal grounds it presents. In this case, my Defence is based on the Claimant's failure to provide adequate PoC, which is a significant procedural deficiency under CPR 16.4. The Claimant’s dismissal of this as "disingenuous" or a "waste of time" does not change the fact that the PoC must comply with the rules to ensure a fair and just legal process. The court has a duty to consider whether the Claimant’s PoC adequately set out the case, and the procedural fairness owed to defendants who must understand and respond to the allegations against them.

15.   In conclusion, the Claimant's assertion that my Defence lacks substance is without merit. The focus on procedural deficiencies is a direct response to the Claimant's failure to comply with the rules governing litigation, which has impacted my ability to prepare a more detailed Defence. The issues raised in my Defence are therefore legitimate and warrant the Court's consideration.

 

Hearsay evidence

16.    The Claimant’s 'witness' is a paralegal employed by the Claimant’s solicitors and has no direct knowledge of the actual events that form the basis of the claim. Any evidence provided by this individual is second-hand, supposedly relying entirely on information supplied by the Claimant, and thus cannot carry the same weight as testimony from someone who witnessed or was directly involved in the incident. 

 

17.    While the Civil Evidence Act 1995 allows hearsay evidence in civil proceedings, it is required to be given less weight, especially when it comes from someone with no firsthand knowledge. Furthermore, under CPR 32.2, the court has the discretion to exclude hearsay evidence when it is of limited probative value. In this case, the witness provides only second-hand information from the claimant and cannot be considered reliable or probative.

 

18.    The Claimant's WS fails to comply with CPR Practice Direction 32, paragraph 18.2, as it does not clearly distinguish between what the witness knows firsthand and what has been provided to them by others. It is evident that the individual providing the statement, being a paralegal with no direct involvement in the events, relies on information provided by their client and lacks personal knowledge of the facts. As a result, this statement amounts to hearsay, which weakens its credibility.

 

19.    In response to the Claimant's assertion at paragraph 27 that all reminders would also have been passed to me by family members and therefore would have been in receipt of the PCN, I would like to clarify that there is no evidence the support this assertion.

 

20.    I would like to formally state that I have never received the Notice to the Registered Keeper, nor have I been made aware of any such parking charge notice until the Claimant issued court proceedings. The Claimant has no knowledge of my personal circumstances and whether I was on good terms with family members or not. I moved out of the address as stated within the PoC as the relationship with family members was not amicable a first page extract of my lease is exhibited at SA08. As I did not receive any of the letters I was not able to as alleged at paragraph 20 of the Claimant’s WS to pay the PCN, provide details of the driver or appeal the PCN. The paralegal is merely speculating and making assumptions which are not grounded in fact.

 

Statement of Truth

I believe that the facts stated in this witness statement 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. 

Signature:

Date: 

 

 

 

 

EXHIBITS

 

 

Links to judgements included within witness statement

Exhibit SA01 – confirmation of vehicle parked outside of boundary

[insert photo here]

Exhibit SA02

Jopson v Homeguard Services Ltd (2016)

https://www.parkingcowboys.co.uk/wp-content/uploads/2016/12/JOPSON-V-HOMEGUARD-2906J-Approved.pdf

 

Exhibit SA02

Duchess of Bedford House RTM Company Limited & Ors V Campden Hill Gate Ltd (2023) ECWA Civ 1470

https://www.casemine.com/judgement/uk/6576d76952aae60ac079d0bd?utm_source=amp&target=amp_jtext

 

Exhibit SA03

K-Sultana Saeed v Plustrade Ltd [2001]

https://www.casemine.com/judgement/uk/5a8ff71460d03e7f57ea734b

 

Exhibit SA04

Civil Enforcement Limited v Chan (Ref E7GM9W44)

https://www.scribd.com/document/676990676/Civil-Enforcement-Limited-v-Ming-Tak-Chan-CC-Luton?doc_id=676990676&order=652107815

 

Exhibit SA05

CPMS v Akande

https://www.dropbox.com/scl/fi/2jef4c7bljyp6dse24p70/Judgments.pdf?rlkey=jsgusx180wzjz2f6er0436xw2&st=03x4tsbq&dl=0

 

Exhibit SA06

ParkingEye Ltd v Beavis [2015]

Cavendish Square Holding BV / Beavis (Appellants) v Talal El Makdessi / ParkingEye Limited (Respondents)

 

 

skintbutwantstosave

@Coupon-mad is there anything else missing before i email the court and c sols?

1505grandad

An observation:-

"15.    Date and Time of the Incident: It is admitted that on the material date, I was the registered keeper of the vehicle VRN. It is unknown who the driver of the vehicle was on the dates of the claimed PCN, given the PCN dates back to 2019."

Therefore should this be "driver":-

"23.    The Claimant therefore has no contractual basis whatsoever to state a contract was formed between the Claimant and the Defendant,"

No doubt the filed and served copy will have the paras numbered sequentially.

skintbutwantstosave

1505grandad said:

An observation:-

"15.    Date and Time of the Incident: It is admitted that on the material date, I was the registered keeper of the vehicle VRN. It is unknown who the driver of the vehicle was on the dates of the claimed PCN, given the PCN dates back to 2019."

Therefore should this be "driver":-

"23.    The Claimant therefore has no contractual basis whatsoever to state a contract was formed between the Claimant and the Defendant,"

No doubt the filed and served copy will have the paras numbered sequentially.

thanks this has been updated, and e-signed.

I will convert to pdf and e-file, if there are no further observations. I will keep referring back until 3.30pm.

Coupon-mad

This looks wrong or not enough and/or in the wrong place:

"a first page extract of my lease is exhibited at SA08"

Firstly a 'first page extract' (only) is of no use. Secondly, this reads like you are proving where you lived (i.e. some other lease)?  That's not what you need to do.

The lease agreement you need in evidence is the one for the location you parked at. No other. You need to show you were a resident and that the lease (or tenancy agreement there?) gave you rights of way by vehicle and did not prevent short stops in the communal approach layby area for unloading or picking up/setting down passengers.

Do you not have any way to prove that right? Don't have that lease agreement?

If not, just add to para 20 that this was your relatives' home address (Flat X) and as an authorised visitor you had a right to stop and deliver/collect an item, and loading/unloading or picking up/setting down passengers is not parking.

skintbutwantstosave

Coupon-mad said:

This looks wrong or not enough and/or in the wrong place:

"a first page extract of my lease is exhibited at SA08"

Firstly a 'first page extract' (only) is of no use. Secondly, this reads like you are proving where you lived (i.e. some other lease)?  That's not what you need to do.

The lease agreement you need in evidence is the one for the location you parked at. No other. You need to show you were a resident and that the lease (or tenancy agreement there?) gave you rights of way by vehicle and did not prevent short stops in the communal approach layby area for unloading or picking up/setting down passengers.

Do you not have any way to prove that right? Don't have that lease agreement?

If not, just add to para 20 that this was your relatives' home address (Flat X) and as an authorised visitor you had a right to stop and deliver/collect an item, and loading/unloading or picking up/setting down passengers is not parking.

I do not have a copy of the lease, so have amended the paragraph. 

skintbutwantstosave

1505grandad said:

An observation:-

"15.    Date and Time of the Incident: It is admitted that on the material date, I was the registered keeper of the vehicle VRN. It is unknown who the driver of the vehicle was on the dates of the claimed PCN, given the PCN dates back to 2019."

Therefore should this be "driver":-

"23.    The Claimant therefore has no contractual basis whatsoever to state a contract was formed between the Claimant and the Defendant,"

No doubt the filed and served copy will have the paras numbered sequentially.

I have added a costs assessment  is this sufficient?

1.        Given the significant time and effort required to Defend against this unjust claim, I respectfully request that the court consider awarding costs under CPR 27.14(2)(g). I have spent considerable time researching, preparing and drafting the Defence, considerable time applying to set aside judgement due to incorrect service of documents, preparing and drafting this witness statement and potentially attending the hearing. My estimate time incurred is as follows:

a.      Research and preparation of defence: 6 hours

b.      Telephone calls, research and setting aside CCJ: 4 hours

c.      Research and preparation of witness statement: 6 hours

d.      Time away from work as currently self employed : 7 hours (@ £50/hour)

e.      Travel expenses (return journey to hearing): either 45p/mile and parking costs / public transport costs

f.        I request that the court considers the above time incurred at the reasonable rate in its Judgment, given the Claimant’s unreasonable behaviour in pursuing this claim. 

Coupon-mad

Yes if you sign & date that, too.

skintbutwantstosave

Coupon-mad said:

Yes if you sign & date that, too.

Thank you so much for all your help so far in getting to this stage. Also thank you helping me get the initial CCJ set aside on this matter back in April. I will keep this thread posted on progress.