Gladstones 2 Claim forms in 2 months. First was DISCONTINUED & 2nd is just crazy and unfair charges!

Coupon-mad

Forget about the earlier claim. They must have had a new staff member that month, as a whole batch went out like that by mistake.

We just laughed. Forget that blip! Unimportant.

However, I do think your facts paragraph 6 should state that:

6.  It is denied that the PCN was compliant with the POFA 2012 (because Horizon Parking did not use compliant 'keeper liability' clause 9(2)f wording in that year), so the registered keeper Defendant cannot be held liable for any sum at all. Further, the first PCN was never served and the 'Notice to Keeper/reminder' failed to offer the mandatory 40% discount and was for £70, not £80 as stated in the POC. Moreover, a keeper cannot be pursued for any sum above the 'maximum sum' set by Schedule 4 of the POFA 2012. The alleged breach (the 'relevant obligation') is unspecified and the Claim does not even state whether they are relying upon the POFA in any event. The court is invited to strike out the claim without a hearing.

Stitch25

Hi, Coupon-mad, and everyone helping with your comments. Very grateful for paragraph 6 (as above). I will follow the defendent  template , copy and paste as explained. Really want this done today. Thanks

Stitch25

Hi again, I've just finished my first draft following the template, added paragraph 6. as above/ coupan-mad,suggested. 33 paragraphs total. I've just (copy/paste) everything, changed the numbers needed. Do I need to change any paragraph words? IF NOT, shall I just fallow the next steps? I'm very grateful to Coupan, as it would take me many more hours to write down paragraph 6. Thank you !

Coupon-mad

The only thing to remove is the template stuff about the DLUHC as that is old news. I will be amending the template to remove it within days.

Stitch25

Hi, I've delete, first part of paragraph 12, but kept "The Ministerial Foreward ..."
Deleted paragraph 14. And rearranged paragraph numbers.  
Now I'm going to follow those 12 next steps, read &understand  before sending/filing. 
Thank you very much 

Stitch25

Hi, how to find  gladstones solicitors email adress,? I've got untill Monday  to file the  defence. Looked for their email online but can't find it. Thanks 

Coupon-mad

Stitch25 said:

Hi, how to find  gladstones solicitors email adress,? I've got untill Monday  to file the  defence. Looked for their email online but can't find it. Thanks 

But you don't send a Defence to Gladstones.

And I've just simplified the Template Defence to stop people emailing it. Advice has changed.

Stitch25

Thanks! I'm glad I've asked! I will have a look at the template again before sending it.

Le_Kirk

You don't "send" it, it is done online via MCOL; as @Coupon-mad wrote, the advice has changed.

Stitch25

I've got this today.