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dfergzz

I have just successfully completed AOS as per the amazing guide instructions.

Le_Kirk

dfergzz said:

I have just successfully completed AOS as per the amazing guide instructions.

Excellent, given the POC you've shown us, just use the standard template defence and ONLY show us your amended paragraphs #2 & #3 (and any that you add) but we don't need to see it all; you do, of course send it all to CNBC.

dfergzz

OK the time has come to file my defence so i have just had a good read over the guide again and put something together from the defence template. I put the truth in my northern english so any last minute advice if needed would be much appreciated.

Here are my paragraphs 2 + 3.

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 and driver.  

3.The defendant vaguely recalls that on the day in question he had intended to pick up an elderly friend who had an appointment at XXXX but first went to visit somebody at theXXX and had parked in the car park outside. As the elderly friend's dental appointment went on for longer than expected it was simply overlooked by the defendant that the maximum stay may now have exceeded and therefore to enter his car registration details into the computer system. 

Coupon-mad

Nope.  You do not admit to fault.

dfergzz

I'll  scrap the last paragraph In #3

dfergzz

Is this any better? Its a bit sparse so to spk and reading up on some other posts on the forum shall i add anything about not knowing blue badge procedure due to unclear sinage or anything?

3.The defendant vaguely recalls that on the day in question he was accompanying an elderly friend, a blue badge holder, who had an appointment at XXXXX. The additional time taken was necessary as the elderly friend's dental appointment went on for longer than expected due to frequent breaks being required due to health. 

Coupon-mad

Add that there were no t&cs signs near the accessible bays.

dfergzz

Coupon-mad said:

Add that there were no t&cs signs near the accessible bays.

Ok done!! Shall I delete that 'liability is denied part' from #1 as I see you mention in other posts? 
And then finally email this as instructed in the template post?

3.The defendant vaguely recalls that on the day in question he was accompanying an elderly friend, a blue badge holder, who had an appointment at xxxxxxx situated on xxxxxxxx. The additional time taken was necessary as the elderly friend's dental appointment went on for longer than expected due to frequent breaks being required due to poor health. Furthermore, there were no clear and obvious signage located near to the accessibility parking bays detailing the full terms and conditions of using the car park, especially for blue badge holders and as a patron of one of the outlets / shops / establishments.  

Coupon-mad

Put accessible bays not 'accessibility' bays.

Nothing needs deleting from the Template.

dfergzz

Coupon-mad said:

Put accessible bays not 'accessibility' bays.

Nothing needs deleting from the Template.

Ok thank you so much for your help. I will change it and then sign & date and email