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Secure Parking solutions

124

Comments

  • Milliered
    Milliered Posts: 133 Forumite
    100 Posts Second Anniversary
    edited 28 February at 8:16AM

    Okay,here's another go.

    Have put my wording over two paragraphs 3 and 4 and then renumbered to 10 as suits or remove 10 if needed.

    3. Reference to Particulars of Claim, 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 30th August 2025 as alleged.

    Paragraphs (3 and 4) are also denied as there was no breach of the terms on the signs( the contract) therefore, there was no Unauthorised Vehicle .

    4. The Defendant disputes that the vehicle was even parked within the car park boundary and did not even enter or exit the car park. Therefore, a contract could not possibly have been entered and agreed or indeed even broken.

    The vehicle was parked for a total of less than ten minutes on the side within the junction off the main rd that then enters into the car park once clear of the junction approx another 20 feet. The Defendant never went past the first sign which is located high up on the side of the residential building. On further inspection, there is another sign further into the car park that was obscured by a white van, which is shown in the photos taken by the attendant who had been hidden in his car to operate covertly..

    Rest to follow as template. Renumbered as needed. I assume this is going to look long winded so really need some advice please as to what to do as short on time.

    Many thanks

  • Milliered
    Milliered Posts: 133 Forumite
    100 Posts Second Anniversary

    Having just re read para 2 and 4 on the template defence, they seem to be at odds with what I have written myself in my paragraph. Would you agree?

    Obviously I want to use the template defence in whole so please advice what to do as struggling. Have to fit in around work and has to be submitted tomorrow.

    TThanks

  • Gr1pr
    Gr1pr Posts: 13,013 Forumite
    10,000 Posts First Anniversary Photogenic Name Dropper

    A defence is written in the 3rd person

  • Milliered
    Milliered Posts: 133 Forumite
    100 Posts Second Anniversary
    edited 27 February at 8:54PM

    TThanks for your reply

    I have changed the comments of ' I' to 'the Defendant ' to rectify the couple of errors if that's what you meant? I have also rejigged a couple of the lines that were repeated

    Is it all about right or still way off ? Would very much appreciate some guidance as to where I am with it please.

  • Milliered
    Milliered Posts: 133 Forumite
    100 Posts Second Anniversary

    Hi all.

    Would appreciate it if someone could look over my new draft please before I submit it shortly.

    Many thanks

  • Coupon-mad
    Coupon-mad Posts: 160,905 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic

    carpark is incorrect, it's 2 words: car park

    Otherwise, I'd remove this unnecessary narrative and keep it for WS stage later:

    "When the Defendant questioned him about the carpark boundary, he didn't know and just waved his hand across the front of the vehicle to indicate an imaginary boundary line.

    Photos that the Defendant took myself at the alleged breach prove the distance between the vehicle and the carpark, also the distance to the first sign that indicates the carpark boundary."

    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
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  • Milliered
    Milliered Posts: 133 Forumite
    100 Posts Second Anniversary

    Hi Coupon-mad

    Thank you for your reply.

    Have altered my draft again .

    Would it be worth putting it in just as number 3 rather than split over numbers 3 and 4 or is it too much wording for one paragraph.

    Would you be kind enough to have a look over it again for me to see if all ok and then I can get submitted today?

    Many thanks

  • Le_Kirk
    Le_Kirk Posts: 26,182 Forumite
    Part of the Furniture 10,000 Posts Photogenic Name Dropper

    3. Reference With reference to Particulars of Claim, 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 30th August 2025 as alleged. Paragraphs (3 and 4) are also denied as there was no breach of the terms on the signs( the contract) therefore, there was no Unauthorised Vehicle .

    4. The Defendant disputes that the vehicle was even parked within the car park boundary and did not even enter or exit the car park. Therefore, a contract could not possibly have been entered and agreed or indeed even broken. The vehicle was parked for a total of less than ten minutes on the side within the junction off the main rd that then enters into the car park once clear of the junction approx another 20 feet. The Defendant never went past the first sign which is located high up on the side of the residential building. On further inspection, there is another sign further into the car park that was obscured by a white van, which is shown in the photos taken by the attendant who had been hidden in his car to operate covertly..

    Change your #3 as shown. Every paragraph requires a number so adjust as above.

  • Milliered
    Milliered Posts: 133 Forumite
    100 Posts Second Anniversary

    HI Le_Kirk

    Thanks for the reply.

    So when i rectify the couple of grammar issues and number as you advise, it will be good to go with then?

    Many thanks

  • Gr1pr
    Gr1pr Posts: 13,013 Forumite
    10,000 Posts First Anniversary Photogenic Name Dropper

    IMHO, yes, do those few corrections, copy, paste, save, submit

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