Save As To Costs

1505grandad

"But that document is entitled - DEFENCE "

"I believe that the facts stated in this defence are true. "

Just checking  -  the SoT will be amended?

maclean7265

@Coupon-mad - Brill, thanks! I will add that section in also and amend accordingly (will update the draft later).

@1505grandad - I missed this one, thank you! I've searched the doc and fixed any errors now so it should be all correct (hopefully).

maclean7265

maclean7265 said:

Thanks again everyone!

My WS draft can be found here: WS

I'd welcome any comments and suggestions. Any questions or, please let me know!

Hi everyone -

Just checking to see if there were any other issues / comments on this one before sending?

Thanks!

Johnersh

Not read the statement, but just to clarify/expand on the @Coupon-mad point…

1. PoFA operates to get the keeper where the driver is unknown. There are strict limits to its application and the sums claimable;

2. Not being the driver is a defence to the alleged breach of contract, but it is only a defence to keeper liability under PoFA where the name of the driver and an address is provided *before* the claim form was issued (see the date on its face). While ppc’s would like it to say this, PoFA does not stipulate that the named driver must have a residential address in E&W;

3. If the defendant was not the driver and has supplied the address, then that is a complete defence and should come out very clearly in the witness evidence - dont shroud the key arguments amongst a sea of more generic ones.

maclean7265

Just wanted to say a massive thanks to everyone for commenting and to the wider forum for support.

Submitted the WS earlier this week and I have just had a notice of discontinuation from Parkingeye! 

I'll share my final version of the WS next week when I am back from holiday 👍

Coupon-mad

Very good news!  The WPSATC offer was just chancing their arm.

ANOTHER PARKINGEYE ONE BITES THE DUST!