Smart parking Ltd defence

1505grandad

"The Defendant recalls visiting Everards Meadows as a genuine customer but has no recollection of any signage being clear, prominent, or capable of forming a contract, and the Claimant is put to strict proof that adequate notices existed at the time."

You are only defending against the PoC (Reason: Insufficient Paid Time) -  the signage/contract is only applicable to a driver and as you have only stated "Defendant" in the sentence it would indicate "Defendant" is driver  -  which you do not want to convey.

If you use the case kindly provided by link you would be stating the following (and then para 4 re the untruth can be added):-

"3. Referring to the Particulars of Claim, paragraph 1 is denied. The Defendant is not indebted to the Claimant. Although the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has been provided with no evidence of any breach of clear or prominent terms. The Defendant denies the claim in its entirety. Any stay at Milton Keynes Central Station Everards Meadows was either within paid time or covered by a reasonable extension, including mandatory grace periods under the relevant Code of Practice. Given the passage of more than four five years and the lack of detail in the inadequate Particulars of Claim, it is impossible for the Defendant to provide a full response. Signage at the material time may also have been unclear or insufficient. The claimed sum is grossly inflated, as no private parking charge can lawfully amount to £170, and no loss or damages were incurred."

Obviously the strike outs will not be included  -  I only showed what needed to be amended (my bold) from the linked case.

Add the para 4 and amend numbers so there will be 11 paras.

Coupon-mad

But you only admitted driver to the retailer didn't you? So it doesn't matter & obviously you use the POFA paragraph.

Just copy - verbatim - ANY Smart defence.

coconut_ice_cream

Thank you @1505grandad, appreciate it so much!

@Coupon-mad I genuinely don’t remember if it was only retailer or appeal as well

Coupon-mad

Doesn't matter. All defended cases are discontinued.