Civil National Business centre claim form

Coupon-mad

Very good point. That will sound better than talking about the driver and guessing what happened.

bertiewill

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. The driver parked the car for the purpose of an evening out with friends. The claimant alleges that the  r car was parked at 20.03 and left the car park at 14.29 on the same day, this is impossible. 

4. The defendant puts the Claimant to strict proof that this was not two separate visits, which is a typical ANPR flaw whereby 'first in last out' images taken across a 24 hour period are wrongly taken to suggest a single period of parking with no real evidence.

bertiewill

OK, thanks all. Email sent. 

What can I expect next? A letter back or an email? Am hoping it will be dropped.

Gr1pr

bertiewill said:

OK, thanks all. Email sent. 

What can I expect next? A letter back or an email? Am hoping it will be dropped.

All covered in the newbies sticky thread and also in the defence template thread, both by coupon mad 

And study the finished cases in the discontinued thread by Umkomaas too, you can read the other few hundred cases in that thread too to gain more knowledge on the process 

Le_Kirk

Trainerman said:

bertiewill said:

3. The driver parked their car for the purpose of an evening out with friends at 20.03. Can the claimant supply strict proof that the departure at 14.49 the next day was the same visit or was it a separate visit? 

To my mind. the PoC state that on the 14th October the vehicle entered at 20.03 and left at 14.29 on the same day. This is clearly impossible and in itself shows up the PoC as deficient. A good point of defence perhaps.

Surely, you should be writing: -

Can the The claimant supply is put to strict proof that the departure at 14.49 the next day was the same visit or was it and not a separate visit?