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Back again to win again. Need some advice. Thanks.

I'm back again for a second time. First time they pulled out last minute before court date. A win!
Thanks again for all the help from this forum.

Re this new one, I've acknowledged on MCOL so I have a little time to get my defence in order.
Just want to check a couple of things. It's Gladstones (representing for Horizon Parking Ltd) this time. So as I understand it I am to copy the relevant Gladstones specific paragraph 3 into my 10 point defence, the paragraph below that starts: 

3. With regards to the POC in question, two recent persuasive appeal judgments in Civil Enforcement Limited v Chan (Ref. E7GM9W44) and Car Park Management Service Ltd v Akande (Ref. K0DP5J30) would indicate the POC fails to comply with Civil Procedure Rule 16.4(1)(e) and Practice Direction Part 16.7.5.

Is this correct:

Am I to put my defence at the end of this paragraph 3 with the 10 point defence template?

My defence is that I was helping my pregnant wife with a young child and also a disabled woman and her husband, with bad knees, from a separate vehicle into a hotel lobby and rooms with all luggage and I went 2 mins over the allotted drop off time. Plenty of witnesses etc. (I tried to complain to the hotel but they weren't at all helpful/ interested.)

I can formulate the above neatly but just wish to know where it goes.

Hopefully I'm barking up the right tree.

Thanks in advance.

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