Name driver ?

Gr1pr

Stick to the template, just add a short concise sentence about the app problem and payment systems were not working etc, no big stories, save those for later on when your witness statement is due, the other WS can also be added then, as can those from the venue too

You can always write your sentence here so people can check it and make suggestions 

Coupon-mad

And add the paragraph given to you by @LDast as well.

Then show us the first 10 paragraphs for critique (NOT the entire template here, please, even though in reality you are using it).

thechud

Yes I already put that in it’s excellent, also may add this due to mentioning app failure 

Consumer Rights Act 2015 and parking apps

You are entering into a digital content contract by using a parking app. Your statutory rights under a digital content contract are enshrined under the Consumer Rights Act 2015.

S34 – Digital content to be of satisfactory quality

S35 – Digital content to be fit for particular purpose

S36 – Digital content to be as described

Coupon-mad

That's a very good point. Not seen that used before.

LDast

The paragraph numbering is from the first paragraph. So, para #1 then the subheading "Preliminary Matter" which is the PoFA 4(5) failure (x 1 para) and, if appropriate, the CEL v Chan (x 2 paras) and the embedded transcript images, followed sub heading "The facts as known to the Defendant which include all of your paragraphs and then the rest of the Template Defence.

Every para is numbered sequentially.

KeithP

thechud said:

Ok as well shown here on steps it’s going as stated . However the 28 days past after sending my defence and nothing heard back then on 17th July on mcol it stated case stay lifted and dq filed by claimant and sent. I received no form so downloaded and sent off had confirmation email yet still not showing on case ( weekly report shows they are 16 days behind on DQ ) 
it’s now 16th August, I have had no reply from claimant on my defence, no copy of their n180 , nothing on stay lifted reason . Since court claim form there has been nothing, shouldn’t I have been informed of stay lifted or be getting copy’s of claimants reply to defence & dq ? I’m supposed to send my form but to who they are charging me solicitors cost but like my POC I have to guess 😂😂

What was CNBC's response - telephone number on your Claim Form - when you put those questions to them?

LDast

You must get a copy of the application to lift the stay. If you did not ever receive the claimants response or acknowledgement of the defence, then there is an abuse of process going on and you need to raise a complaint with the CNBC and get them to clearly explain how the claimant was able to lift the stay without following the required Court Procedure Rules.

Highlight that you are very aware of this abuse of process and you require answers.

Coupon-mad

There was no application to lift the stay.   You don't need to email or phone.  Your case is continuing normally after a blip caused by the CNBC overlooking something as usual.

Go back to the NEWBIES thread 2nd post and read about Witness Statement stage.

Coupon-mad

Nope, none of the above are relevant and they won't supply them except what they exhibit with their WS. Don't ask them.

GoogleStreetview will show you images, usually once a year going back many years.

Coupon-mad

Yep that's a POFA-worded NTK.

Remind us: who made the claim, CEL themselves or DCB Legal?