Template defence from newbies thread not worked?

sammyb1996

ChirpyChicken said:

Remove point 2 
Make point 3 more succinct.  Less waffle.

Thanks i will remove and have changed point 3 to the following.

(I removed the fact that there was other signage. Because I guess that can just be stated in the WS?)

This okay?

“3. The defendant denies a breach of "the terms on the signs (the contract). Reason: Permit Holders Only". 

The denial is based on inadequate entry signage at "Car Park At DaisyField Pools Daisy Lane Blackburn BB1 5HB".

The entrance signage provided by the claimant (CEL) is not visible for any customer entering the car park driving from the North side of Daisy Lane. 

Also, the entrance signage provided by the claimant does not state where the terms and conditions can be found regarding the contract between visitor and claimant. 

The facts outlined by the defendant put the claimant in violation of the BPA Code Of practice version 8 2020. 

Therefore the defendant could not agree to the contract or be deemed to agree set out by the claimant.” 

Coupon-mad

I think other signage is important to mention. 

You should also challenge landowner authority and CEL's standing to sue. There appears to be an identified principal -  Half Fish - whose own sign offers parking for patrons and doesn't mention CEL nor is their offer subject to any relevant obligation to have or display a permit.

Coupon-mad

Please show us these different signs.

sammyb1996

This other images are on my comment from 2nd July 7:33pm. If it’s pulling through for you? Last 2 images of disabled sign and half fish sign.

the HF sign doesn’t mention anything to do with a parking permit or fine etc. 

When I first got the PCN’s I did speak to the manager who said was nothing really to do with them and fobbed me off. They left shortly after that and I stopped going after being spoken to like that. 

Since then pool closed down in aug 2023. And the CEL signs have been taken down in car park.