Halfords Chatham total parking

Gr1pr

Your defence must be truthful, you know the truth of the matter (or have no idea )

We won't suggest what the truth might be, so we wont coach you ( but we will check your amended paragraphs after you post them below )

Proof of contract flowing from the landowner is always a feature in any case, plus signage etc, standard stuff

All 10 paragraphs are used ( sometimes it maybe more, 11 or 12. , but normally its all 10, if they all fit into the 122 lines on MCOL )

If the actual breach is pleaded in the POC, do not use Chan & Akande, regardless of which solicitors are used, so rare in DCB LEGAL cases, In your case its in point 3 in the POC ( its TPS via DCB LEGAL )

The facts of the matter arrive with their WS in several months time, not at this early stage

Coupon-mad

Why do you want to remove the standard defence para 10 that applies to all cases?

Car1980

Remember the onus is on them to make their claim. I'd put something brief in paragraph 3, such as:

"The defendant was a legitimate customer of Halfords and purchased a new battery, with help from the sales assistant. It is denied an overstay occurred and the claimant has failed to state what this even amounts to in their inadequate particulars."

meiyaonline

I shall write again to Halfords quoting the above sentence and see if the claim is stopped . Meantime I will work on my defence and post it when done

meiyaonline

I thought para 10 was about making a counterclaim and lots of people don’t so maybe I misunderstood but I do not have any evidence of signage as last week while I was dealing with the court papers and AFTER I went to the store with those papers to see what it was all about and ask for some help regarding the claim ( if it could be stopped)

ALL the original signage was removed and new signage put up whereby the time has been changed from 30 minutes stay to 60 minutes .

New signage is now dotted about on the exterior of the store building unless I just use the new signs

so I can’t include signage in my defence.

Can one upload images on the mcol website ?

Gr1pr

Paragraph 10 is about claiming your costs, like Parking, petrol, time off work, to attend the hearing etc

Nothing to do with a counter claim ! You are not counter claiming !

You could add a sentence stating that the signage was inadequate and has since been replaced

No exhibits or evidence or pictures etc are included or uploaded with the concise defence

The defence is copied, pasted, saved, submitted ( and is only textual characters only. ) into MCOL

Your future Witness Statement in several months time can go into more details, with pictures etc

Coupon-mad

Para 10 isn't about a counterclaim. Read it!

meiyaonline

i’m sorry I clearly misunderstood. I actually read the posts and comments as it suggested doing to get some for my template and I read amongst those comments that many people do not use paragraph 10 so thank you for clearing that up. I obviously misunderstood from that point..

I get tired very quickly especially when I’m reading due to the disability that I have as reading mimics REM which makes me feel very sleepy as I don’t have enough adrenaline as other people do to help me throughout the day with energy I think as well I panicked and I stress and I probably tried to take too much information one been really helpful that has been so kind and so helpful with me and has taken the time out to guide me through this which is exactly what I needed helped to calm me down because the more stressed I get the more tired I feel but just being on this forum and having this support from everybody has been so beneficial and I can’t thank you all enough. I think what you’re doing is absolutely amazing and I would definitely be lost without you guys.

Gr1pr

No problem

Please Post your proposed paragraphs 2 & 3 below, because your defence deadline is due in a week and nothing is more important

meiyaonline

Ok but I have one more question please? … my defence must be truthful .

I truthfully did not see or have knowledge of any notices or letters relating to this until I got the court papers .

According to my messages on my phone relating to this time period I went to purchase a battery for my mums car .

According to the text messages on my phone relating to that date at 2.15 I asked my friend if I should get a yuasa battery 50,000 @£95 or a Halfords battery 20,000 @£73 and at 2.51 I got a reply. I bought the Halfords and paid cash that my mums car gave me for her battery .
That is all I can say with certainty at this moment .
is it better to state this? Word for word

and admit to be being the driver and the keeper or neither confirm or deny ?