ANOTHER ONE BITES THE DUST!

Neo14

Recieved the court heairng date, will wait for Gladstones to submit the court fees first. Any general advice? any idea what happens normally in such situations?

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ChirpyChicken

https://forums.moneysavingexpert.com/discussion/comment/82074640#Comment_82074640

Yes you submit your witness statement as per the order. If no date for the WS get it in 14 days before hearing

Coupon-mad

This is explained in detail in the NEWBIES thread post 2. There are also loads of WS examples on the forum this year, if you want to search a bit & copy one.

Neo14

https://forums.moneysavingexpert.com/discussion/6637641/advice-needed-private-parking-ticket-mediation-appointment-euro-parking-gladstones-solicitors

Thansk again. I have prepared my witness statement as below and would really appreciate your valuable comments pls.

IN THE COUNTY COURT

Claim No: [CLAIM NUMBER]

Between

(Claimant)

-and-

(Defendant)

WITNESS STATEMENT OF

I, , of [current address], am the Defendant in these proceedings. I make this witness statement in support of my Defence. The facts contained in this statement are within my own knowledge unless otherwise stated and are true to the best of my knowledge and belief.

Background

1. I am the registered keeper of the motor vehicle referred to in these proceedings.

2. I deny that I am liable to the Claimant for the parking charge or any additional sums claimed.

3. This claim concerns an alleged parking event said to have occurred on 23 July 2024 at land serving Stack Shack and the Ali Hajveri Mosque.

4. The Claimant's case relies primarily upon Automatic Number Plate Recognition ("ANPR") images recording the vehicle entering the site at approximately 17:48 and exiting at approximately 17:55, a total recorded duration of approximately seven minutes (Exhibit WJ-01).

5. I understand that the Claimant alleges that a parking charge became payable because the driver failed to comply with the parking terms displayed on signage at the site.

6. I respectfully submit that the Claimant has failed to establish, on the balance of probabilities, that any enforceable parking contract was formed or that I am legally liable for the charge.

Procedural History

7. This matter has already been considered by the Court at an earlier stage of the proceedings.

8. By Order dated 11 March 2026 (Exhibit WJ-02), the Court determined that the original Particulars of Claim failed to comply with CPR 16.4(1)(a) and directed the Claimant to file amended Particulars clarifying the legal basis of its claim.

9. The Court specifically directed the Claimant to identify whether liability was alleged under Schedule 4 of the Protection of Freedoms Act 2012 ("POFA"), whether the alleged relevant obligation arose under contract or otherwise, and the basis upon which liability against the Defendant was asserted.

10. Having carefully reviewed the amended Particulars of Claim (Exhibit WJ-03), I remain unable to identify with certainty whether the Claimant alleges that I am liable:

a. as the driver;

b. as the registered keeper pursuant to Schedule 4 POFA; or

c. upon some alternative legal basis.

11. The amended Particulars continue to refer to reliance upon POFA only "where applicable", whilst also advancing an alternative basis of liability where POFA is not relied upon. In my respectful submission, this does not provide the clarity that the Court expressly directed.

12. Whilst I appreciate that the burden of proving the claim rests entirely upon the Claimant, I have nevertheless sought to understand the legal basis of the claim from the amended pleading. Despite doing so, I remain uncertain as to the precise case I am required to answer.

Keeper Liability

13. I am the registered keeper of the vehicle. I do not accept that this fact alone gives rise to liability for the parking charge.

14. If the Claimant seeks to hold me liable as keeper rather than as driver, it must establish full compliance with the mandatory requirements of Schedule 4 of the Protection of Freedoms Act 2012.

15. Parliament enacted Schedule 4 as a limited statutory exception to the ordinary legal principle that liability rests with the driver who is alleged to have entered into the contract. It follows that the burden rests squarely upon the Claimant to demonstrate compliance with every condition necessary to transfer liability from driver to keeper.

16. The amended Particulars do not clearly state that the Claimant relies upon keeper liability under POFA, nor do they identify how the statutory requirements are said to have been satisfied.

17. Furthermore, the evidence presently before me does not include a copy of the Notice to Keeper upon which any alleged compliance with Schedule 4 would necessarily depend. In the absence of that document, I am unable to assess whether the statutory requirements have been met. The burden of proving such compliance rests entirely upon the Claimant.

18. If, alternatively, the Claimant seeks to pursue me as the driver, the burden remains upon it to prove, on the balance of probabilities, that I was the driver at the material time. I respectfully submit that the Claimant has produced no evidence capable of establishing that fact.

19. In either event, whether the Claimant relies upon keeper liability or driver liability, it bears the burden of proving its case. I respectfully submit that the evidence presently before the Court does not discharge that burden.

ANPR Evidence

20. The principal evidence relied upon by the Claimant consists of ANPR images recording the vehicle entering and leaving the site.

21. ANPR technology records only the times at which a vehicle passes cameras positioned at the perimeter of the site. It does not record what occurs after entry or before exit.

22. The Claimant's evidence therefore does not establish:

a. whether the vehicle was parked at all;

b. when any alleged period of parking began;

c. when any alleged period of parking ended;

d. whether a parking bay was occupied;

e. whether the driver remained inside the vehicle;

f. whether the driver left the vehicle; or

g. whether any contractual terms were accepted.

23. The Claimant's own evidence records a total site presence of approximately seven minutes.

24. That period necessarily includes driving into the site, slowing or manoeuvring within the car park, locating any available parking space, observing the surroundings, reading any signs, deciding whether to remain, turning the vehicle if necessary, and exiting through the site.

25. In my respectful submission, the Claimant's own evidence is entirely consistent with a motorist entering private land, attempting to understand the parking restrictions, deciding not to accept the terms offered, and leaving shortly afterwards.

26. The ANPR evidence does not distinguish between a motorist who accepts contractual terms and parks, and one who simply enters, considers those terms and departs. It therefore cannot, without more, establish that any enforceable parking contract came into existence.

27. The burden remains upon the Claimant to prove that a contract was formed and subsequently breached. In my respectful submission, the ANPR evidence alone is insufficient to establish either proposition.

Formation of any Contract

28. The Claimant alleges that a legally binding contract was formed between the driver and the Claimant by virtue of the driver's presence on the site. I do not accept that the evidence relied upon establishes that proposition.

29. A contract cannot arise merely because a vehicle passes an ANPR camera. The Claimant must establish that the driver had a reasonable opportunity to become aware of the contractual terms and accepted those terms by conduct.

30. The Claimant has produced no evidence demonstrating what the driver actually did during the seven-minute period recorded by the ANPR system.

31. In particular, there is no evidence that the driver:

a. parked the vehicle in a designated parking bay;

b. left the vehicle unattended;

c. entered either Stack Shack or the Ali Hajveri Mosque;

d. attempted to use the vehicle registration keypad;

e. remained on the land after deciding to accept the alleged contractual terms.

32. The Claimant's evidence therefore falls short of establishing that any contract was concluded between the driver and the Claimant.

Signage and the Keypad System

33. The Claimant relies upon photographs of signs which appear to have been produced for the purposes of these proceedings (Exhibit WJ-05).

34. I do not dispute that signs may have been present on the site. However, the burden rests upon the Claimant to prove that the signs relied upon accurately represent the signage in place on the material date, including their wording, positioning, prominence and visibility.

35. From the material produced, it appears that genuine customers and authorised visitors were required to enter their vehicle registration number into a keypad or terminal.

36. However, the Claimant has produced no evidence that the driver entered either premises, saw the keypad, had a realistic opportunity to use it, or failed to comply with any clearly communicated requirement.

37. Equally, the Claimant has produced no evidence demonstrating that the entrance signage clearly warned motorists that a parking charge could arise within such a short period if the registration process had not been completed.

Fairness and Transparency

38. The Consumer Rights Act 2015 requires consumer contract terms to be fair and transparent.

39. In my respectful submission, a reasonable consumer must first be afforded a genuine opportunity to enter the site, locate the relevant signage, understand the parking arrangements, consider whether to accept those arrangements and, if they choose not to do so, leave without penalty.

40. The Claimant's own evidence records only approximately seven minutes on site.

41. On the evidence before the Court, I do not consider that the Claimant has demonstrated that a reasonable consideration period was afforded before enforcement action arose.

Landowner Authority

42. I have not seen any evidence establishing that the Claimant possessed authority from the landowner to enter into contracts with motorists or to pursue legal proceedings in its own name.

43. I respectfully put the Claimant to strict proof that it held such authority on the material date by producing the relevant contemporaneous agreement.

ParkingEye Ltd v Beavis

44. The Claimant relies upon the decision of the Supreme Court in ParkingEye Ltd v Beavis [2015] UKSC 67.

45. I respectfully submit that the present claim is materially distinguishable from Beavis.

46. In Beavis, there was no dispute that the motorist had parked, accepted the parking terms and remained beyond the permitted free period. The issues before the Supreme Court concerned the enforceability of the parking charge in those circumstances.

47. In the present case, the principal issues are fundamentally different. The Claimant has not established that any contract was formed, that any period of parking occurred, or that any statutory keeper liability has arisen.

48. I therefore respectfully submit that Beavis does not relieve the Claimant of its obligation to prove the essential elements of its claim on the facts of this case.

Additional £60

49. The Claimant seeks to recover an additional sum of £60 described as contractual or debt recovery costs.

50. The Claimant has not demonstrated that this additional amount formed part of any contract with the motorist, that it was prominently communicated on the signage, or that it represents a genuine loss or expense incurred.

51. I respectfully submit that the Court should decline to award this additional sum.

Conclusion

52. Having considered the Claimant's evidence in its entirety, I respectfully submit that it has failed to establish, on the balance of probabilities:

a. the legal basis upon which I am said to be liable;

b. compliance with Schedule 4 of the Protection of Freedoms Act 2012, if keeper liability is alleged;

c. the identity of the driver, if driver liability is alleged;

d. any actual period of parking;

e. that an enforceable contract was formed;

f. that the signage and keypad system were sufficiently clear and prominent;

g. that it possessed the necessary authority from the landowner; or

h. that the additional £60 is recoverable.

53. For all of the reasons set out above, and those contained within my Defence, I respectfully invite the Court to dismiss the Claimant's claim.

Statement of Truth

I believe that the facts stated in this witness statement are true.

Signed: ______________________

XYZ

Dated: ______________________

DEFENDANT'S SKELETON ARGUMENT

IN THE COUNTY COURT

Claim No: [CLAIM NUMBER]

Between

Claimant

-and-

Defendant

A. Overview

1. The Defendant respectfully submits that the Claimant has failed to discharge the burden of proving its claim on the balance of probabilities.
2. The Claimant relies principally upon ANPR images recording approximately seven minutes between entry and exit from the site.
3. Those images do not establish a period of parking, acceptance of contractual terms or any breach of contract.

B. Issues for Determination

The principal issues before the Court are:

1. Has the Claimant identified the correct legal basis of the claim following the Court's Order of 11 March 2026?
2. If keeper liability is alleged, has the Claimant demonstrated compliance with Schedule 4 of the Protection of Freedoms Act 2012?
3. If driver liability is alleged, has the Claimant proved the identity of the driver?
4. Has the Claimant proved that a parking contract was formed?
5. Does the ANPR evidence establish any actionable period of parking?
6. Has the Claimant proved adequate signage and a fair opportunity to consider the contractual terms?
7. Is the additional £60 recoverable?

C. Defendant's Submissions

1. Uncertain Cause of Action

The amended Particulars continue to refer to POFA only "where applicable" whilst advancing alternative bases of liability. The Defendant respectfully submits that the Claimant has not clearly identified the legal route upon which it relies.

2. Keeper Liability

If keeper liability is alleged, strict compliance with Schedule 4 POFA is required. The burden rests entirely upon the Claimant.

3. Driver Liability

If the Claimant instead alleges driver liability, it must prove, on the balance of probabilities, that the Defendant was the driver. The Claimant has produced no evidence establishing that fact.

4. ANPR Evidence

ANPR records entry and exit only.

It does not prove:

• parking,
• duration of parking,
• acceptance of contractual terms,
• or breach.

A recorded duration of seven minutes is equally consistent with a motorist entering, considering the terms and leaving without accepting them.

5. Contract Formation

The Claimant has produced no evidence demonstrating that the driver:

• parked;
• entered either premises;
• used the keypad;
• or otherwise accepted the contractual terms.

6. Additional £60

The Defendant respectfully submits that the Claimant has not demonstrated any contractual entitlement to the additional £60.

D. Relief Sought

The Defendant respectfully invites the Court to:

1. dismiss the claim; and
2. award the Defendant such costs as are recoverable under CPR 27.14.

Gr1pr

I will never understand why people keep using the old WS statement of truth that was retired over 5 years ago, in favour of the newer 3 sentence WS that has applied since !

It worries me that people have used AI or looked at years old WS , instead of using a recent WS by members like JackR1, preferably from within the last 12 months

Castle

OP

Given that the Hearing Fee was due on Friday 31st July, have you rang the Court to confirm if it has been paid.

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/82090132#Comment_82090132

Well worth checking!

Apart from correcting the 5 year out of date SoT, the OP needs to add:

• the usual words about HHJ Moloney and the transcript link (as seen in recent WS this year, e.g. @JackR1 )
• some quotes about consideration periods from the CMA's July 2026 Open Letter to the parking sector, plus link it for the judge to read.

Neo14

Thanks once again for the comments. I did confirm from the court after the deadline and the fees is been submitted. I have revised the witness statement based on the advise/comments and hoping to post it tonight. Please let me know if any final changes I should be making (sorry had to post it in 2 sections as otherwise it exceed post length). IN THE COUNTY COURT

Claim No: [CLAIM NUMBER]

Between

EURO PARKING SERVICES LIMITED (Claimant)

-and-

XYZ (Defendant)

WITNESS STATEMENT OF

I, XYZ, of [current address], am the Defendant in these proceedings. The facts stated in this witness statement are true to the best of my knowledge and belief unless otherwise stated.

1. This witness statement is made in support of my Defence. Where I refer to documents, these are exhibited as WJ-01 onwards. I am a litigant in person with no formal legal training. I have prepared this statement to the best of my ability and respectfully ask the Court to take that into account. My Defence is repeated where relevant.

Background

2. I am the registered keeper of the vehicle referred to in these proceedings.

3. I deny that I am liable to the Claimant for the parking charge or any additional sums claimed.

4. The claim concerns an alleged parking event on 23 July 2024 at land serving Stack Shack and the Ali Hajveri Mosque.

5. The Claimant relies principally upon Automatic Number Plate Recognition ("ANPR") images recording the vehicle entering the site at approximately 17:48 and exiting at approximately 17:55, a total recorded duration of approximately seven minutes (Exhibit WJ-01).

6. The Claimant alleges that a parking charge became payable because the driver failed to comply with the terms displayed on signage at the site.

7. I respectfully submit that the Claimant has failed to establish, on the balance of probabilities, that an enforceable parking contract was formed or that I am legally liable for the charge.

Procedural History

8. The Court has already considered the adequacy of the Claimant's pleadings during these proceedings.

9. By Order dated 11 March 2026 (Exhibit WJ-02), the Court found that the original Particulars of Claim did not comply with CPR 16.4(1)(a) and directed the Claimant to file amended Particulars clarifying the legal basis of the claim.

10. The Court specifically directed the Claimant to identify whether liability was alleged under Schedule 4 of the Protection of Freedoms Act 2012 ("POFA"), whether the alleged obligation arose under contract or otherwise, and the basis upon which liability was asserted against the Defendant.

11. Having carefully reviewed the amended Particulars of Claim (Exhibit WJ-03), I remain unable to identify with certainty whether the Claimant alleges liability:

a. as the driver;

b. as the registered keeper pursuant to Schedule 4 POFA; or

c. upon some alternative legal basis.

12. The amended Particulars continue to refer to reliance upon POFA only "where applicable", whilst simultaneously advancing an alternative basis of liability where POFA is not relied upon. In my respectful submission, this still fails to provide the clarity that the Court expressly required.

Keeper Liability

13. I am the registered keeper of the vehicle. I do not accept that this fact alone gives rise to liability.

14. If the Claimant seeks to recover the parking charge from me as keeper, it must demonstrate full compliance with the mandatory requirements of Schedule 4 of the Protection of Freedoms Act 2012.

15. Parliament enacted Schedule 4 as a limited statutory exception to the general rule that liability rests with the driver who is alleged to have entered into the parking contract. It follows that the burden rests entirely upon the Claimant to demonstrate compliance with every condition required to transfer liability from the unknown driver to the registered keeper.

16. The amended Particulars do not clearly state that keeper liability is relied upon, nor do they explain how the statutory conditions are said to have been satisfied.

17. At the time of preparing this witness statement, the Claimant has not exhibited or otherwise disclosed any Notice to Keeper within its evidence bundle. In the absence of that document, neither I nor the Court can assess whether the mandatory requirements of Schedule 4 of the Protection of Freedoms Act 2012 have been satisfied. The burden of proving compliance rests entirely upon the Claimant.

18. If, alternatively, the Claimant seeks to pursue me as the driver, the burden remains upon it to establish, on the balance of probabilities, that I was driving at the material time.

19. The Defendant has never admitted to being the driver. There is no legal presumption that a registered keeper was driving, and the burden of proving that fact rests entirely upon the Claimant.

Burden of Proof

20. Throughout these proceedings the burden of proof remains with the Claimant. It is not for me to speculate as to what may have occurred during the recorded seven-minute period. If the Claimant asks the Court to conclude that an enforceable parking contract was formed and subsequently breached, it must establish those matters by evidence. In my respectful submission, it has not done so.

ANPR Evidence

21. The principal evidence relied upon by the Claimant consists of ANPR images recording the vehicle entering and leaving the site.

22. ANPR cameras record only the times at which a vehicle passes the cameras positioned at the perimeter of the site. They do not record what occurs after entry or before exit.

23. Accordingly, the Claimant's evidence does not establish:

a. that the vehicle was parked;

b. when any alleged period of parking began;

c. when any alleged period of parking ended;

d. that a parking bay was occupied;

e. that the driver left the vehicle;

f. that the driver entered either premises;

g. that the driver used, or had an opportunity to use, any keypad registration system; or

h. that the driver accepted any contractual terms.

24. The Claimant's own evidence records only approximately seven minutes on site.

25. That period necessarily includes driving into the site, manoeuvring within the car park, identifying any available space, locating and reading any signs, deciding whether to remain, and leaving the site.

26. In my respectful submission, the evidence is entirely consistent with a motorist entering private land for the purpose of considering the terms offered, deciding not to accept those terms and leaving shortly afterwards.

27. A motorist is entitled to enter private land for the purpose of considering contractual terms and deciding whether to accept them. If those terms are rejected, the motorist is entitled to leave. Mere entry onto land for the purpose of reading signage does not, of itself, amount to acceptance of a contract..

Consideration Period and Fairness

28. The Claimant's own evidence records only a seven-minute site presence.

29. The Competition and Markets Authority, in its Open Letter to the Private Parking Sector (July 2026), reminded parking operators that consumers must be afforded a genuine opportunity to read, understand and decide whether to accept contractual terms before enforcement action is taken (Exhibit WJ-04).

30. Those principles reflect the requirements of the Consumer Rights Act 2015, which requires consumer terms and notices to be fair, transparent and brought properly to the attention of consumers.

31A. The Claimant has produced no evidence that enforcement action was delayed until the driver had been afforded a reasonable opportunity to consider the alleged contractual terms and decide whether to remain or leave. In my respectful submission, the evidence instead suggests that liability is said to arise almost immediately upon entry, which is inconsistent with ordinary contractual principles and the fairness requirements of the Consumer Rights Act 2015.

31. On the evidence before the Court, I do not consider the Claimant has demonstrated that the driver was afforded a reasonable opportunity to identify, understand and either accept or reject the alleged contractual terms before liability was said to arise.

Formation of any Contract

32. The Claimant alleges that a legally binding contract was formed between the driver and the Claimant by virtue of the driver's presence on the site. I do not accept that the evidence establishes that proposition.

33. A contract cannot arise merely because a vehicle passes an ANPR camera. The Claimant must prove that the driver had a reasonable opportunity to become aware of the contractual terms and accepted those terms by conduct.

34. The Claimant has produced no evidence demonstrating what the driver actually did during the seven-minute period recorded by the ANPR system.

35. In particular, there is no evidence that the driver:

a. parked the vehicle in a designated parking bay;

b. left the vehicle unattended;

c. entered either Stack Shack or the Ali Hajveri Mosque;

d. located or used the vehicle registration keypad;

e. remained on the land after deciding to accept the alleged contractual terms.

36. In my respectful submission, the Claimant has therefore failed to prove that any contract was concluded between the driver and the Claimant.

Neo14

https://forums.moneysavingexpert.com/discussion/6637641/advice-needed-private-parking-ticket-mediation-appointment-euro-parking-gladstones-solicitors

Signage

37. The Claimant relies upon photographs of signage and a generic image of the parking terms (Exhibit WJ-05).

38. However, the burden rests upon the Claimant to prove that the signs relied upon accurately represent the signage in place on the material date, including their wording, prominence, positioning and visibility.

39. The Claimant has produced no contemporaneous evidence demonstrating that the signage relied upon was sufficiently prominent or that the driver had a fair opportunity to read and understand the alleged contractual terms before any liability arose.

40. From the evidence served, it appears that authorised users of the site were expected to enter their vehicle registration into a keypad or terminal.

41. However, there is no evidence that the driver entered either premises, had a realistic opportunity to locate the keypad, understood how the system operated, or failed to comply with any clearly communicated requirement.

42. Given that the entire site presence relied upon by the Claimant is approximately seven minutes, I respectfully submit that the Claimant has not established that a reasonable consumer would have been afforded sufficient time to identify the parking arrangements, understand them and either accept or reject them before enforcement action was triggered.

Landowner Authority

43. I have seen no evidence demonstrating that the Claimant possessed authority from the landowner to offer parking contracts or to pursue legal proceedings in its own name.

44. As an agent, the Claimant is put to strict proof of a contemporaneous written agreement with the landowner, including any schedules defining the site boundary and confirming the Claimant's authority to issue parking charges and commence legal proceedings.

ParkingEye Ltd v Beavis

45. The Claimant relies upon the decision of the Supreme Court in ParkingEye Ltd v Beavis [2015] UKSC 67.

46. I respectfully submit that the present case is materially distinguishable.

47. In Beavis, there was no dispute that the motorist had parked, accepted the contractual terms and remained beyond the permitted free parking period. The principal issue before the Supreme Court was whether the parking charge was unenforceable as a penalty.

48. By contrast, the principal issues in the present claim are whether any parking contract was formed at all, whether there was any proven period of parking, and whether the Claimant has established liability against the Defendant.

49. The Supreme Court did not decide that every parking charge is automatically enforceable. Each claim remains dependent upon the Claimant proving that an enforceable contract was formed on the particular facts.

50. Whilst the first-instance judgment is not binding authority, I respectfully rely upon HHJ Moloney QC's explanation of the commercial basis of the parking charge, namely that the charge itself was intended to fund the operation of the parking scheme. That reasoning is consistent with the Supreme Court's conclusion that the parking charge was commercially justified, and does not support the routine addition of further debt recovery sums.

Additional Recovery Sum

51. The Claimant seeks to recover an additional sum described as debt recovery or contractual costs.

52. The Claimant has not demonstrated that this additional amount formed part of any parking contract, that it was prominently communicated to motorists, or that it represents any genuine contractual entitlement.

53. In my respectful submission, the parking charge itself was intended to cover the ordinary costs of operating the parking scheme. The Claimant has produced no evidence demonstrating any contractual basis for recovering an additional sum beyond the original parking charge.

Overall Assessment of the Evidence

54. Having considered the Claimant's evidence as a whole, I respectfully submit that it establishes only that a vehicle entered and left the site over a period of approximately seven minutes.

55. It does not establish:

a. that the vehicle was parked;

b. that the driver accepted any contractual terms;

c. that the driver failed to comply with any clearly communicated contractual obligation;

d. that the statutory requirements for keeper liability have been satisfied, if those provisions are relied upon;

e. or that I am legally liable for the parking charge.

Conclusion

56. The burden of proof has remained throughout upon the Claimant. It is for the Claimant to establish, on the balance of probabilities, every element of its claim.

57. In my respectful submission, the Claimant has failed to establish:

a. the legal basis upon which I am pursued;

b. that an enforceable parking contract was formed;

c. that there was any proven period of parking;

d. that the signage and keypad arrangements were sufficiently clear and prominent;

e. that the requirements for keeper liability have been satisfied, if relied upon;

f. that it possessed the necessary landowner authority; or

g. that the additional recovery sum is recoverable.

58. Having regard to the evidence as a whole, I respectfully submit that the Claimant has failed to discharge the burden of proving its claim on the balance of probabilities.

59. For all of the reasons set out above, together with those contained within my Defence, I respectfully invite the Court to dismiss the Claimant's claim.

Statement of Truth

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed: ___________________________

XYZ

Dated: ___________________________

Coupon-mad

Nearly done!

• Is it true that their bundle doesn't have a copy of the landowner agreement? Again, thst would be very rare. Or don't you have Gladstones' WS yet?

EDIT:

even though there seems to be no bundle yet, yes they did include the landowner agreement in the re-pleaded POC:

…so remove this section:

Landowner Authority

"43. I have seen no evidence demonstrating that the Claimant possessed authority from the landowner to offer parking contracts or to pursue legal proceedings in its own name.

44. As an agent, the Claimant is put to strict proof of a contemporaneous written agreement with the landowner, including any schedules defining the site boundary and confirming the Claimant's authority to issue parking charges and commence legal proceedings."

Finally, unless I missed it, you haven't exhibited HHJ Moloney's judgment nor quoted para 3.4 of his findings in your section 'Additional Recovery Sum'.

Copy JackR1's section on that.