Horizon parking (TESCO) court documents arrived.

Dan_Barns

Is there an online copy of the DQ? I've only received a paper one and I note that it needs to be emailed? 

Coupon-mad

Yes: the Template Defence thread explains.

Dan_Barns

Hi guys, onto the witness statement part now and need to submit it tonight as the deadline is today. I'm not going to lie I actually cant remember what happened here, it was almost 2 years ago, so tricky to do a witness statement ? what shall i include in the witness statement? my defence was mainly around abuse of process and signs etc. Are there any links to how the witness statement should be set out again?

Gr1pr

Study the 2nd post in the newbies sticky thread in announcements near the top of the forum by coupon mad

Dan_Barns

thanks done that thats great. Doesnt say too much about what to write when i can barely remember what happened. Do i just state that fact straight away and say i cannot recall the events?

Gr1pr

We dont tell you what to write because its your bespoke Witness Statement

We suggest that you study several recent WS and add certain Exhibits to back up your defence, especially Chan and Akande because the alleged breach was not specified

Nobody is expecting you to have total recall about an unremarkable day long ago where you may not have even been present

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/81920649#Comment_81920649

Yes but not just that.

There's obviously the important point you made that you cannot be sure who was driving. Unlikely to have been you at this retail park, which means you have a POFA point of 'no keeper liability' and you need the exhibits that I list in the NEWBIES thread of course, including the transcripts for:

CEL v Chan

CPMS v Akande

EXCEL v Smith

VCS v Edward

Excel v Wilkinson

Horizon didn't use POFA worded NTKs so they couldn't hold keepers liable in 2024.

This is important but it's nothing new and you don't have to write it from scratch, it's been done many times in WS before.

So, search the forum for one of those cases and the words 'witness statement'.

My notes tell me that the thread by @Kpmp54 in 2025 has Chan & Akande and also Smith, Edward & Wilkinson. Adapt that one and show us your draft tonight first.

Which solicitors, Gladstones? Moorside?

Have you had their WS bundle to pick apart?