PCN as a visitor of a private car park

zeusxav

https://1drv.ms/b/c/cd360057fac5b7e9/EaJMV6wnTdlBnc2ExmaOZg4Brv1uZ5dybjCYUzNGIKg4ew?e=UJsmeg

zeusxav

Hi, that's a blanked out version .... how does it look please?  

1505grandad

Is these dates correct?:-

"4. On 30 October 2023 XXX asked one of the concierge staff if they could allocate a visitor space for 30th September 2024 until 2 October 2024."

Para 6  -  "I was never provided a parking permit as requested by the claimant."  -  not sure what that means.

"17. Vehicle Control Services advertise they are a member of the Independent Parking Community and yet failed to follow the code of practice set down in this by failing to display any signage in relation to parking."

The above is not the correct name of the ATA.

The SoT is not correct.

There does not appear to be the usual WS items included.

Coupon-mad

You need to read recent WS examples from this Summer.  For example the threads by:

@Defendant911

@Harry77

zeusxav

1505grandad said:

Is these dates correct?:-

"4. On 30 October 2023 XXX asked one of the concierge staff if they could allocate a visitor space for 30th September 2024 until 2 October 2024."

Para 6  -  "I was never provided a parking permit as requested by the claimant."  -  not sure what that means.

"17. Vehicle Control Services advertise they are a member of the Independent Parking Community and yet failed to follow the code of practice set down in this by failing to display any signage in relation to parking."

The above is not the correct name of the ATA.

The SoT is not correct.

There does not appear to be the usual WS items included.

Thank you for the feedback.  

I've amended the dates to read correctly.
6 - amended to reference exhibit 1
17 - VCS website state they are a an accredited operator of IPC which is where i got the code of conduct from.  That who I was to appeal to.
I copied the SoT para fro Harry77 WS

zeusxav

Coupon-mad said:

You need to read recent WS examples from this Summer.  For example the threads by:

@Defendant911

@Harry77

Hiya, 
I've read through these but not sure which relates to my case so I haven't added any particulars in.  I understand the POFA part and I tried to get the case transcription for a Linked Parking v Mr L 2016 but couldn't find it even through the national archives etc.

Coupon-mad

zeusxav said:.

I copied the SoT para fro Harry77 WS

Surely not from his final draft?

I suggest those examples purely to show you the headings. Introduction, the bits about the DLUHC draft IA, the importance of the Consumer Rights Act 2015 and the conclusion, costs & statement of truth.

Only ever read their final draft.

This then gives you the WS structure and you put your facts and specific other exhibits at the start/middle, as your story.  

Don't go looking for unreported county court cases.  They are pointless.  I already provide a comprehensive a-f list of recommended exhibits in the NEWBIES thread anyway.  You've seen that?

zeusxav

Coupon-mad said:

zeusxav said:.

I copied the SoT para fro Harry77 WS

Surely not from his final draft?

I suggest those examples purely to show you the headings. Introduction, the bits about the DLUHC draft IA, the importance of the Consumer Rights Act 2015 and the conclusion, costs & statement of truth.

Only ever read their final draft.

This then gives you the WS structure and you put your facts and specific other exhibits at the start/middle, as your story.  

Don't go looking for unreported county court cases.  They are pointless.  I already provide a comprehensive a-f list of recommended exhibits in the NEWBIES thread anyway.  You've seen that?

SoT : This bit? 

I believe that the facts stated in this 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 and honest belief in its truth.

Sorry that's from defendant 911

I don't want costs.  I haven't incurred anything and VCS have threatened to ask for solicitor fees and travel costs.

I've seen the list in the newbies thread - from the witness statement section?!

a) I've got the beavis sign

b) I've got my photos of zero signage.

c) the claim form specified the breach.

d) I was the driver and keeper

e) I'm not the tenant for lease - a visitor

f) I'm a visitor

g) I've added in the IPC code of practice

I'll go over it and reorder the paragraphs

Thank you

Coupon-mad

Yes that's the right SoT.

You don't have to ask for costs but are entitled to ask for £95 to attend a hearing at least, plus travel costs if any.

Glad to hear you have got the appropriate exhibits for your case.

zeusxav

I need the £95 to pay to get my now grey hair dyed!!!! 
I'd just be happy with this over.  My little brain is ready to explode....