National Parking Control and DCB Legal

bigbadbri79 · 28 October at 1:42PM

Gr1pr said:

Who is the defendant ? You ir your daughter ? Is she both keeper and driver ? If she is both then you are a personal assistant, helping her, but you cannot take over if she is the defendant

I think you need to be clearer in who is what here

I thought it was clear. All daughter - driver, keeper, defendant. And if you want to call a PA then yes.

bigbadbri79 · 28 October at 1:44PM

The PA draft as below:

2. The allegation(s) and heads of cost are vague and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. This also makes retrieving material documents/evidence difficult, which is highly prejudicial. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant has little recollection of events, save as set out below and to admit that they were the registered keeper and the driver of the vehicle.

3. The Defendant is a longstanding member of the David Lloyd Colchester health club, which provides on-site parking facilities exclusively for its members and authorised visitors. As part of the club’s membership benefits, members are granted permission to use the car park while attending the premises for fitness or leisure purposes. On the material date, the Defendant attended the club as a paying member for legitimate use of the facilities and was therefore fully entitled to park on site.