County court euro car parks

cotswold989

Hi there , new to this and new to court, I have a court date set and need to tackle how to put together my defence/witness statement. I have 3 PNCs against my name, I was not the driver on 2 of the occasions and can prove i was at work of the time of the events. The other time I was dropping off an individual with a disability and I could not get her mobility scooter working , as the signage terms and conditions were unreadable and didn't state I couldn't drop somebody off , I left without paying on that occasion. 

Times of events
PNC1: 14 minutes, not the driver
PNC2: 19 minutes issues with mobility scooter
PNC3: 22 minutes , not the driver , 
On PNC 1 and 3 i did send euro car parks a letter of appeal to say I wasnt the driver. However they have hounded me for all 3  since 2022 with debt collection because I am the registered keeper. 
Is there anyway to fight this or any laws that could help me 
Thankyou 

Gr1pr

If you have a court date then your defence has already been filed,  you wont be changing it,  post a redacted copy below 

I assume that this claim is by DCB Legal on behalf of ECP for all 3 pcns,  so 3 invoices,  only one court claim for an inflated sum 

Post the deadline date for submitting your WS + Exhibits bundle to the court and claimant   ( which court   ?  )

cotswold989

My defence 

Pnc1 14 minutes 8th April 2022

Even though I am the registered keeper of the vehicle in question. I was not the driver on this occasion and I sent a letter within the 28 day period stated by euro car parks in the pnc letter that I was not the driver. I did not recieve a reply from the claimant on this matter. I did however have lots of debt collection letters sent to me and a notice to keeper letter. 

Pnc 2 25.08.2022

On this occasion I was dropping off an individual with a disability so I could assist her with her mobility scooter. I was having issues starting the scooter and couldn't leave her until I got it working. The signage itself did not state I couldn't drop somebody off.

Pnc 3 21.12.2022

On this date I was not the driver of the vehicle and was at work. 

Additionally I did not receive a letter before action, I believe this to have been an important document that the claimant should of sent.

The claim is by QDR solicitors on behalf of ECP and the case is being held at the county court at Dudley 

My defence isn't great at all because I thought it was just a quick summary of why I dispute their claim. I have no experience with this. 

Gr1pr

Presumably you did not name the driver,  so they are trying to invoke keeper liability using POFA 2012

So QDR Legal , not the typical DCB Legal 

You need to work on making your WS bundle as good as possible 

cotswold989

I named the driver on the first letter of appeal to euro car parks on the last one I did not because they ignored my first letter for the first PNC , I'm working on my ws bundle but am needing help to see if there is any way to fight this or anything I may not know about law wise/ past cases that may aid me 

Gr1pr

The fact that you named the driver under POFA early doors should definitely be mentioned in the WS bundle,  as should the no Letter of Claim either 

Your picture of the court order 6 months ago said to send a copy of your defence to Dudley court,  did you do that back then  ?

As I asked you earlier,  when is your WS deadline   ?

cotswold989

Yes I have sent dudley court a defense and counter claim form that I filled out. The WS deadline in Tuesday 4th February. Court is on the 18th February 

Coupon-mad

cotswold989 said:

Yes I have sent dudley court a defense and counter claim form that I filled out. The WS deadline in Tuesday 4th February. Court is on the 18th February 

The NEWBIES thread gives you a full a-f list of exhibits and info on how to find recent WS, so you can read a few over the weekend and copy the format.