Help needed please - Parking Ticket N1SDT

Coupon-mad

Gr1pr said:

That's correct,  adapt that one,  although you might prefer to email it at the moment due to the subsequent feedback in that thread about MCOL 

Absolutely not unless we want everyone to lose due to emailing unsigned defences.

I cannot understand why this has been suggested to people. 

tobypixie

It took a while to fill in the defence as like others, on saving, it kept coming up with an error "This field has invalid character. You cannot use < >"  I took away various characters like "   :  - '  I finally got it to save.

Can someone please cast their eye over my wording on paragraph 3 and 3.1 ( I have copied  3 as directed but added 3.1 with my own wording). Does this look ok or do I need to add anything else?  Do I mention that I have pics of the ticket and broken keypad or do I send this in my witness statement?

Many thanks for your help.

3. Referring to the POC: paragraph 1 is denied. The Defendant is 

not indebted to the Claimant. Paragraph 2 is denied. The Defendant 

does not accept that a contravention occurred on 12/05/2021, as 

alleged.  Whilst the Defendants company is the registered keeper, 

paragraphs 3 and 4 are denied. The Defendant is not liable and has 

seen no evidence of a breach of prominent terms.  The quantum is 

hugely exaggerated (no PCN can be £170 on private land) and there 

were no damages incurred whatsoever.

 

3.1 The vehicle is recognised and it is admitted that the 

Defendants Ltd company is the registered keeper and the defendant 

was not the driver.  The defendant is aware that a parking ticket 

was purchased but due to the ticket machine having a keypad that 

was illegible, letters and numbers faded, worn out and sticking it 

was extremely difficult to input the vehicle registration. Also all

correspondence received has failed to recognise the 

registered keepers full title. 

Gr1pr

You are correct about banned characters, but you can use ' instead of " , so the template has been re edited today to take account of the useful feedback 

Your Exhibits  ( evidence   ) etc go with the WS, not at this defence stage,  which is text only 

I think that your paragraphs are good enough as they are,  or mention that pictures of the faulty machine will be provided in the Witness Statement 

But dont go over the 122 lines limit

Ps, coupon mad is correct to say that it cannot be emailed without additional headers and footers,  plus it needs to be signed too, if email was to be used,  so getting the new template into MCOL should be the best way to record the defence,  so on MCOL,  preferably not by email 

cw_2377

Good luck, sounds like a very valid case to me!

tobypixie

Thank you all. ...

Gr1pr yes it took me a while to get MCOL to save the template. Good advice I will add in the line that you suggest about the pictures I have.

cw_2377 it's reassuring to know someone else thinks we have a valid case. I was unsure at first.

 Coupon-mad said:

Gr1pr said:

That's correct,  adapt that one,  although you might prefer to email it at the moment due to the subsequent feedback in that thread about MCOL 

Absolutely not unless we want everyone to lose due to emailing unsigned defences.

I cannot understand why this has been suggested to people. 

Coupon-mad...Thank you I will not use the email route. 

Coupon-mad

Don't forget to SUBMIT the defence!

tobypixie

Coupon-mad said:

Don't forget to SUBMIT the defence!

Submitted online, thanks for all your help.