Private PCN

Lakoko

Exhibit 10 - DEFENDANT’S SCHEDULE OF COST

Ordinary Costs

Loss of earnings through attendance at court hearing: £95.00.

 

Further costs for Claimant’s misconduct

In pursuant to Civil Procedure Rule 44.11 in conducting research, preparation, postage, and drafting of documents (15 hours at Litigant in Person rate of £19 per hour): £285.00.

 

TOTAL COSTS CLAIMED: £380.00.

 

 

Signature:

 

Date:

 

 

 

 

 

KeithP

The last few words of paragraph 18 state "...as detailed in paragraph 19", yet paragraph 19 doesn't contain those details.

Coupon-mad

Remove the second use of the word "against" at the end of the first sentence.

Change 'the driver' to "I" in para 9.

Remove the criminal offence accusing word "defraud" because a Judge never wants to hear that.  It has no place in a civil matter defence and could be deemed that you have crossed over the line into unreasonableness because UKPC will say it was one or two rogue ticketers and was years ago and there was no intention to defraud. You can't say (because there's no evidence) that there was deliberate and endemic (normal) bad conduct by the company itself.   You have to be a bit careful with your words.

paragraphs 46 and 47 repeat the same sentence. Remove the second use of that sentence. No repetition.

All looking good though. Well prepared.

Lakoko

Thank you very much for all your advice. I have revised the WS based on your suggestions. Just waiting for about 3 days before the 14days kick in before sending it to the court and the claimant.

1505grandad

Para 31  -  ".....has confirmed that BPA Approved Operator Code of Practice 2012 Version 8, January 2020  will be referred to in relation to any issues of non-compliance....

I don't think this date should be in there?

Lakoko

@1505grandad I am confused. Please could you be more clearer why that date cannot be there. The non compliance occurred last year June 2023. The new BPA code comes to effect this year June 2024. Are you saying there was another BPA code of practice between the 2020 and 2024 code of practice? If yes can provide a link to it?

1505grandad

As you can see I highlighted this and 2012  -  the numbers 2012 I believe have nothing to do with the BPA CoP referred to in that sentence.

Coupon-mad

He's just saying remove '2012'!

Lakoko

Thanks @1505grandad and Coupon-mad. Much clearer now. I have removed 2012. I do not know how it got there must have been typo error.  Kind regards

Lakoko

Hi all, I am now ready to submit the revised WS following all your recommendations. However, I have some questions and need your advice again. The court handling my hearing is the county court at Willesden in London but the actual hearing will take place at Royal Court of Justice, Strand London. Questions are:
1. Which of these courts should I send my witness statement to?

2. If I should send to both courts, I do not have the email address of the Royal Court of Justice, Strand London. So do anybody have the email address for Royal Court of Justice, Strand London. I have tried Dr Google, but cannot find any meaningful email address on the internet.