I've got a County Court Claim for a 2yr old PCN

2nd draft taking onboard advice seen here and in other threads (sorry the cut and paste is rubbish, the word document is formatted correctly):-

In the County Court Business Centre
Between:
Civil Enforcement Limited V xxxx

Claim Number: xxxx

I am xxxx, the defendant in this matter and the registered keeper of vehicle xxxx.
I deny I am liable for the entirety of the claim for each of the following reasons:
1) The Claim Form issued on the 12th March 2018 by Civil Enforcement Ltd was not correctly filed under The Practice Direction as it was not signed by a legal person but signed by !!!8220;Civil Enforcement Limited!!!8221; (Claimant!!!8217;s Legal Representative)!!!8221;.
2) This Claimant has not complied with pre-court protocol (as outlined in the new Pre Action Protocol for Debt Claims, 1 October 2017).
a) There was no compliant !!!8220;Letter before County Court Claim!!!8221;, under the Practice Direction.
b) This is a speculative serial litigant, issuing a large number of !!!8220;draft particulars!!!8221;.
c) The Claim Form Particulars did not contain any evidence of contravention or photographs. These documents and the !!!8220;Letter before County Court Claim!!!8221; should have been produced, pursuant to paragraph 6 of the Practice Direction !!!8211; Pre Action Conduct. This constitutes a deliberate attempt to thwart any efforts to defend the claim or to !!!8220;take stock!!!8221;, pursuant to paragraph 12 of the Practice Direction. Again, this totally contradicts the guidance outlined in the new Pre-Action Protocol for Debt Claims (2017), the aims of which are:
i) Early engagement and communication between the parties, including early exchange of sufficient information about the matter to help clarify whether there are any issues in dispute.
ii) Enable the parties to resolve the matter without the need to start court proceedings, including agreeing a reasonable repayment plan or considering using an Alternative Dispute Resolution (ADR) procedure.
iii) Encourage the parties to act in a reasonable and proportionate manner in all dealings with one another (for example, avoiding running up costs which do not bear a reasonable relationship to the sums in issue).
iv) Support the efficient management of proceedings that cannot be avoided!!!8221;.
d) The Defence therefore asks the Court to strike out the claim as disclosing no cause of action and having no reasonable prospect of success as currently drafted.
3) The Claimant failed to meet the Notice to Keeper obligations of Schedule 4 of the Protection of Freedoms Act 2012. Absent such a notice served within 14 days of the parking event and with fully compliant statutory wording, this Claimant is unable to hold me liable under the strict !!!8220;keeper liability!!!8221; provisions.
a) Schedule 4 also states that the only sum a keeper can be pursued for (if Schedule 4 is fully complied with, which it was not, and if there was a !!!8220;relevant obligation!!!8221; and !!!8220;relevant contract!!!8221;, fairly and adequately communicated, which there was not) is the sum on the Notice to Keeper.
b) The Claimant did not comply with POFA 2012 and give the registered keeper opportunity, at any point, to identify the driver. A Notice to Keeper can be served by ordinary post and the Protection of Freedoms Act requires that the Notice, to be valid, must be delivered no later than 14 days after the vehicle was parked. No ticket was left on the windscreen and no notice to keeper was sent within the 14 days required to comply with POFA 2012, only a speculative invoice entitled Parking Charge Notice which was sent outside of the 14 day period, which did not comply with POFA 2012. This would exclude the registered keeper being liable for any charges.

Henry Greenslade, lead adjudicator of POPLA in 2015 and an eminent barrister and parking law expert, stated that !!!8220;However keeper information is obtained, there is no !!!8216;reasonable presumption!!!8217; in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort.!!!8221; Schedule 4 also states that the only sum a keeper can be pursued for (if Schedule 4 is fully complied with, which it was not, and if there was a 'relevant obligation' and !!!8216;relevant contract' fairly and adequately communicated, which there was not) is the sum on the Notice to Keeper. They cannot pluck another sum from thin air and bolt that on as well when neither the signs, nor the NTK mentioned a possible £346.54 for outstanding debt and damages. The additional costs, which the defendant contests have not been incurred, are none of its concern.
4) The Claimant has added unrecoverable sums to the original parking charge. It is believed that the employee who drew up the paperwork is remunerated, and the particulars of claim are templates, so it is simply not credible that £50 legal representative!!!8217;s costs were incurred. The Defendant believes that Civil Enforcement Ltd has artificially inflated this claim. They are claiming legal costs when not only is this not permitted (CPR 27.14) but the Defendant believes that they have not incurred legal costs. According to Ladak v DRC Locums UKEAT/0488/13/LA the claimant can only recover the direct and provable costs of the time spent on preparing the claim in a legal capacity, not any administration cost. The Defendant denies that the Claimant is entitled to any interest whatsoever. The claimant has not explained how the claim has increased from the original parking notice to £346.54. If the Claimant alleges that they claim the cost of its in-house administration, these cannot be recovered - they are staff performing the task that they have been employed for and essential to the Claimant's business plan.
5) This case can be distinguished from ParkingEye v Beavis [2015] UKSC 67 (the Beavis case) which was dependent upon an undenied contract, formed by unusually prominent signage forming a clear offer and which turned on unique facts regarding the location and the interests of the landowner. Strict compliance with the BPA Code of Practice (CoP) was paramount and Mr Beavis was the driver who saw the signs and entered into a contract to pay £85 after exceeding a licence to park free. As far as I can ascertain, based upon the particulars of this claim and complete lack of evidence and photographs, and without having been furnished with the alleged signage !!!8220;contract!!!8221;, none of this applies in this material case.
6) It is denied that the Defendant or lawful users of his/her vehicle were in breach of any parking conditions or were not permitted to park in circumstances where an express permission to park had been granted. All Sports Club Members are allowed use of the car park. The Defendant avers that there was an absolute entitlement to park, which cannot be fettered by any alleged parking terms. The club allowed members the right to park a vehicle, without limitation as to type of vehicle, ownership of vehicle, the user of the vehicle or the requirement to display a parking permit.
a) The Defendant avers that the operator!!!8217;s signs cannot (i) override the existing rights enjoyed by club members.
b) Accordingly it is denied that:
i) there was any agreement as between the Defendant or driver of the vehicle and the Claimant.
ii) there was any obligation (at all) to display a permit; and
iii) the Claimant has suffered loss or damage or that there is a lawful basis to pursue a claim for loss.
7) In the POPLA Annual Report 2015 by parking expert barrister and Lead Adjudicator, Henry Greenslade, he clarified the fact that a registered keeper can only be held liable under the POFA Schedule 4 and not by presumption or any other legal argument.
The Defendant denies any liability whatsoever to the Claimant in any matter and asks the Court to note that the Claimant has:
a. Failed to disclose any cause of action in the incorrectly filed Claim Form issued on 11th October 2017.
b. Sent a template, well-known to be generic cut and paste !!!8220;Particulars!!!8221; of claim relying on irrelevant case law (Beavis) which ignores the fact that this Claimant cannot hold registered keepers liable in law, due to their own choice of non-POFA documentation.
The insufficient Particulars of Claim disclose no clear cause of action. The court is invited to strike out the claim of its own volition as having no merit and no reasonable prospects of success.

Alternative Defence - Failure to set out clearly parking terms
In the alternative, the Defendant relies upon ParkingEye Ltd v Barry Beavis (2015) UKSC 67 insofar as the Court were willing to consider the imposition of a penalty in the context of a site of commercial value and where the signage regarding the penalties imposed for any breach of parking terms were clear - both upon entry to the site and throughout.
a. The Defendant avers that the parking signage in this matter was, without prejudice to his/her primary defence above, inadequate.
b. At the time of the material events the signage was deficient in number, distribution, wording and lighting to reasonably convey a contractual obligation;
c. The signage did not comply with the requirements of the Code of Practice of the Independent Parking Committee!!!8217;s ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory; and
d. The signage contained particularly onerous terms not sufficiently drawn to the attention of the visitor as set out in the leading judgment of Denning MR in J Spurling v Bradshaw [1956] EWCA Civ 3
e. The Defendant avers that the site that is the subject of these proceedings is not a site where there is a commercial value to be protected. The Claimant has not suffered loss or pecuniary disadvantage. The penalty charge is, accordingly, unconscionable in this context, with ParkingEye distinguished.

I confirm that the above facts and statements are true to the best of my knowledge and recollection.

Thanks very much for your help.

Claim acknowledged & Defence emailed.

How long does it normally take for the next stage?