N1SDT claim form- Euro carparks

Count2tentwice

I am rubbish at this sort of thing and it has taken me ages to find the template hopefully it is the correct one, but here is the adjusted section 2 and my written section 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 (hire car)is recognised and it is admitted that the Defendant was the registered driver.

3. The defendant arrived at the Euro Car Parks Walsall Waterfront to complete health and safety related works at the TGI Fridays restaurant.  The defendant parked and purchased a parking ticket for the time required that day from the machine paying the correct fee.  After checking 1st with the TGI Fridays staff that there was no alternative staff parking or a way to issue the registration number of the vehicle to park as a contractor at no or a reduced cost.  The defendant left the car park upon completion of works and loading of tools, ladders and equipment back into the vehicle and queueing to exit the busy car park.  This was some 4 plus years ago (February 2020) and there has been no recent correspondence prior to the claim form issued dated 3rd September 2024.

Thank you all who have commented and helped.

Gr1pr

You can now edit your posts 

The template defence is in the template defence thread by coupon mad in announcements, easy to find, pinned to the top of the forum, just read the first few posts in it, ignoring the rest

There is no such thing as a registered driver 

In 2) You are the hirer, you may be the driver too, in which case remove the word registered , changing to hirer and driver. ( If true. )

Count2tentwice

even if the company i was working for were the hirer, and I was the driver.  I will alter. thank you

Gr1pr

In that case admit that the vehicle is recognised and you were the driver, dont complicate it with incorrect words 

Coupon-mad

Your defence looks fine for the above.

DCB Legal will discontinue in 2025, as always.

Count2tentwice

Hello 
A little update.
I have received a  "Notice of Proposed Allocation to the small claims Track"

N180 from the Civil National Business Centre as well as a completed form from the Euro Car Parks.

KeithP

Count2tentwice said:

Hello 
A little update.
I have received a  "Notice of Proposed Allocation to the small claims Track"

N180 from the Civil National Business Centre as well as a completed form from the Euro Car Parks.

Just continue to follow the guidance in that checklist you were following when you filed a Defence.