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Horizon Parking Court claim form

Hi everyone, last year I received a Horizon Parking fine by mail after my car was parked in a Tesco Express car park, as I wasn't the driver on that day I ignored the letters until yesterday when I received a Court Claim Form.
Today I've done the acknowledge service of claim fallowing the newbie steps and now I'm preparing my defence.   
I will upload a picture with the Claim Form so you can have a look and a Defence template modified for my case, it would be more than helpful if you can have a look over it and give me some indications on what to modify next. 
Thank you.

«13

Comments

  • Gr1pr
    Gr1pr Posts: 10,858 Forumite
    10,000 Posts First Anniversary Photogenic Name Dropper
    There are 10 paragraphs in the defence template,  not 7

    The statement of truth is about 4 or 5 years out of date, plus isn't required when using MCOL 

    Too many sub paragraphs,  get rid of them and make it concise too

    The alleged breach is not pleaded in the POC 
  • patient_dream
    patient_dream Posts: 4,083 Forumite
    1,000 Posts Fourth Anniversary Photogenic Name Dropper
    YET ANOTHER MISLEADING CLAIM BY DCBL.   VERY MISLEADING TO A JUDGE

    The fake £70 is indeed a FAKE ADD-ON .

    This is a new wheeze by DCBL.  Previous claims on here uses the word DAMAGES and now they clain the fake is CONTRACTUAL COSTS which even more rubbish than DAMAGES

    DCBL keep ignoring what the Supreme Court said in the ParkingEye v Beavis case.
    They said that cost of the parking ticket was set to operate the scheme ?   

    County Court judges know what the Supreme court said and therefore they know that the fake add-on of £70 is just trying to mislead them.

    Eceryone knows that DCBL uses words to cover up the real meaning ... DEBT RECOVERY COSTS.   The majority of judges will not allow this, nor will they allow the 8% interest.  Compared to interest rates today, it is highly inflated.

    As said DCBL are misleading you and the court. DCBL needs to get a grip
  • ThankGr1pr said:
    There are 10 paragraphs in the defence template,  not 7

    The statement of truth is about 4 or 5 years out of date, plus isn't required when using MCOL 

    Too many sub paragraphs,  get rid of them and make it concise too

    The alleged breach is not pleaded in the POC 
    Thank you for suggestions, I modified the template and I will upload it for an opinion as well.
  • Gr1pr
    Gr1pr Posts: 10,858 Forumite
    10,000 Posts First Anniversary Photogenic Name Dropper
    edited 10 November at 12:45PM
    3 almost repeats the ending of 2, add some of 3 into 2 instead, so then lose 3, renumbering 3.1 as 3

    You can delete the last lines at the end if you are submitting it on MCOL,  when completed
  • Gr1pr said:
    3 almost repeats the ending of 2, add some of 3 into 2 instead, so then lose 3, renumbering 3.1 as 3

    You can delete the last lines at the end if you are submitting it on MCOL,  when completed
    Just modified point 2 and 3 and deleted the last lines.
  • Gr1pr
    Gr1pr Posts: 10,858 Forumite
    10,000 Posts First Anniversary Photogenic Name Dropper
    edited 10 November at 1:03PM
    Delete everything before paragraph 1

    In 2, add not before the driver 

    You need all 10 paragraphs,  nothing before or after though
  • RealMadrid19
    RealMadrid19 Posts: 13 Forumite
    10 Posts
    Gr1pr said:
    Delete everything before paragraph 1

    In 2, add not before the driver 

    You need all 10 paragraphs,  nothing before or after though
    Just done it
  • 1505grandad
    1505grandad Posts: 4,114 Forumite
    Part of the Furniture 1,000 Posts Name Dropper
    There are duplicate paras.
  • RealMadrid19
    RealMadrid19 Posts: 13 Forumite
    10 Posts
    There are duplicate paras.
    Hi, sorry can you be more specific?
  • Gr1pr
    Gr1pr Posts: 10,858 Forumite
    10,000 Posts First Anniversary Photogenic Name Dropper
    There are duplicate paras.
    Hi, sorry can you be more specific?
    7 , 8 & 9 are showing in both pictures,  so duplicated 

    I assume that you cannot add the full defence to one post  ?  All 10 , so in doing the reply you overlapped,  so perhaps do 5 + 5
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