Euro Car Parks - Claim Form received (from DCB Legal) 2

Coupon-mad

Motty2014 said:

I updated the paragraphs as follows:

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.

3. As the alleged breach of contract took place almost six years ago, the defendant cannot recall the exact time specifics surrounding the allegation.  Claiming 8% interest for six years of sitting on their hands is a clear abuse and hugely disproportionate reward for doing nothing to bring this case to court. The POC is extremely vague in detail but the Defendant firmly believes that the driver did purchase a pay and display permit. The Claimant is put to strict proof of all their assertions, including paragraph 4 of the POC that suggests they complied with the POFA 2012 Schedule 4 . In 2019, Euro Car Parks did not use/comply with that Act so the POC falsely states a level of liability that cannot apply.

I'd suggest the above.

Please delete the post earlier with the full template defence as it is an unnecessary post which is making your thread too long.  I started to read it and sighed! We don't need to see it.