Single Claim Multiple PCNs using PoC Defence

HardDaysNight27

I have a claim from DCB/CEL stating 8 dates and a single location.
The claim form is their standard template for one PCN and they just added 7 more dates to it.
The LBC states 4 PCN's at the stated location and 4 at other locations.
I am using the CEL vs. Chan in my defence to try to kill this off at allocation.
I want to know should I include evidence of the LBC in my defence?
If so extract or full?

Gr1pr

No evidence is submitted with the textual defence 

Post the issue date and AOS date please, plus a redacted picture of the POC too, hiding the VRM details first 

HardDaysNight27

Issued: 7/11/24
AOS: 13/11/24

PoC: 
Particulars of Claim 1. The Defendant (D) is indebted to the Claimant (C) for a Parking Charge issued to vehicle XXXXXXX at XXXXXX Car Park.

2. The PCN(s) were issued on XX/XX/2022, XX/XX/2022, XX/XX/2022, XX/XX/2022,  XX/XX/2022, XX/XX/2022, XX/XX/2023, XX/XX/2023.

3. The defendant is pursued as the driver of the vehicle for breach of the terms on the signs (the contract). Reason: Authorised Vehicles Only
4. In the alternative the defendant is pursued as the keeper pursuant to POFA 2012, Schedule  4.
AND THE CLAIMANT CLAIMS
1. £1360 being the total of the PCN(s) and damages.
2. Interest at a rate of 8% per annum pursuant to s.69 of the County Courts Act 1984 from the date hereof at a daily rate of £.25 until judgment or sooner payment.

3. Costs and court fees 

Gr1pr

Looks like your deadline is 4pm tomorrow 

HardDaysNight27

Gr1pr said:

Looks like your deadline is 4pm tomorrow 

Yep that's what I make it.

HardDaysNight27

The LBC contradicts the PoC for locations and Reasons of Issue
So you can see why I was thinking including the LBC or extract of it might strengthen the argument for the PoC defence - This question has probably been asked before but I could not find it in the forum.
Actually even the issued dates aren't correct, they are the dates of the alleged infringements not when the PCN's are issued, something judges appear to overlook.

Grizebeck

Don't worry if you a bit late.

Gr1pr

HardDaysNight27 said:

The LBC contradicts the PoC for locations and Reasons of Issue

So you can see why I was thinking including the LBC or extract of it might strengthen the argument for the PoC defence - This question has probably been asked before but I could not find it in the forum.

Actually even the issued dates aren't correct, they are the dates of the alleged infringements not when the PCN's are issued, something judges appear to overlook.

There are some replies in other recent cases with a precise basic defence for the POC details, especially where the dates don't natch

HardDaysNight27

Grizebeck said:

Don't worry if you a bit late.

I'll try to get it done today
But knowing me it will be last minute, 3:59pm tomorrow.
It was a judge that suggested this type of defence.
I did one like this already but I put the judgment as an exhibit at the end of the document.

HardDaysNight27

From what I understand...
The Chan Judgment goes at the top of the defence to give it prominence for the allocating judge.
The supporting judgments are included with it.
Then the regular defence points are included after that.
My PCN's are double dips which I have evidence to rebut them.
I'll mention that near the end.

Have I got this correct? 

Coupon-mad

I wouldn't use Chan (the breach is stated).

I would also keep this killer error under your hat for now, if you know for a fact that the LBC was right, that 4 of them weren't issued regarding the single location now wrongly stated in the POC:

I have a claim from DCB/CEL stating 8 dates and a single location.
The claim form is their standard template for one PCN and they just added 7 more dates to it.
The LBC stated 4 PCN's at the stated location and 4 at other locations.

Just use the normal template defence and add brief info about the circumstances or putting them to proof that the vehicle was unauthorised and actually parked where the POC states, but also deny the POC paragraphs one by one.

As seen in every thread like this. There are loads of multiple PCN claim threads. We win 99% of the time!

I hate providing links to threads because it stops people seeing how to hop around and finding & reading threads for themselves. But in the spirit of the Season, here's one showing what to put for paragraph 3:

https://forums.moneysavingexpert.com/discussion/comment/81139187/#Comment_81139187

That shows you some 'deny the POC' wording to include in your para 3.

And of course use the Template Defence but we don't want to be shown it ... please...!

Then follow the first 12 steps in the Template Defence thread so that you don't need to ask about the DQ questions or the laughable Mediation phone call.

We hope that we are only needed again by Defendants at WS & evidence stage next year. The 'first 12 steps' advice saves us all time.

Question:

What's the relevance of telling us that these are double dips?  How can that be relevant to unauthorised parking?