claim form from CEL he;p needed on how to play it

i have done the acknowledgement today and spent a lot of the day looking threw other peoples defences and copied some bits and pieces that are relevant to me.
I then went on to read a section on the newbie thread of what to argue and what not to. I feel that this has pretty much wiped out any argument i had.
If i post a copy of my defence is there anyone i can ask to have a look to see if it holds up?
many thanks

right so just a quick refresher...
my car was parked on a car park that was free for 3hrs but overstayed by approx half an hour. They have anpr cameras and have sent me letters with pictures on showing mey car coming and going and the times. I am a member of the gym that offers this car park to their members for use (would this somehow help my defense?). I have an email i found from when i received the 1st penalty charge where i wrote to them and told them i would not pay and that i wanted proof that they held a contract for that land - they did not provide this.I have also emailed the landowner a few months back asking if they could intervene with this matter and they replied that because it was over a year ago that it happened they could not but they were aware of CEL causing many people a problem and were looking into finding a new car parking company as they were having so many complaints about this one (could i somehow use this in my defense?)
right so here is what i have so far.....
Defence is as follows:

In the County Court Business Centre
Claim Number:

---

Between:

Civil Enforcement Limited v

---

I am

---

, the defendant in this matter and registered keeper of vehicle

---

.

I deny I am liable for the entirety of the claim for each of the following reasons:

1. The Claim Form issued on 01/10/2018 by Civil Enforcement Limited was not(is this supposed to be the original date of fine or the date I got the claim form?)
correctly filed under The Practice Direction as it was not signed by a legal person but signed by “Civil Enforcement Limited” (Claimant’s Legal Representative).

2. This Claimant has not complied with pre-court protocol. And as an example as to why this prevents a full defence being filed at this time, a parking charge can be for trespass, breach of contract or a contractual charge. All these are treated differently in law and require a different defence. The wording of any contract will naturally be a key element in this matter, and a copy of the alleged contract has never been provided to the Defendant.

a) There was no compliant “Letter before County Court Claim” under the Practice Direction.

b) This is a speculative serial litigant, issuing a large number of identical 'draft particulars'. The badly mail-merged documents contain very little information.

c) The Schedule of information is sparse of detailed information.

d) The Claim form Particulars were extremely sparse and divulged no cause of action nor sufficient detail. The Defendant has no idea what the claim is about - why the charge arose, what the alleged contract was; nothing that could be considered a fair exchange of information.(can I say this if I have a letter with pictures of my car entering and leaving the car park?)
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 keeper liability provisions.
4. The Particulars of Claim state that the Defendant was the registered keeper and/or the driver of the vehicle. These assertions indicate that the Claimant has failed to identify a Cause of Action, and is simply offering a menu of choices. As such, the Claim fails to comply with Civil Procedure Rule 16.4, or with Civil Practice Direction 16, paras. 7.3 to 7.5. Further, the particulars of the claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached.

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 ‘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 £276.76 for outstanding debt and damages.
Due to the sparseness of the particulars, it is unclear as to what legal basis the claim is brought, whether for breach of contract, contractual liability, or trespass. However, it is denied that the Defendant, or any driver of the vehicle, entered into any contractual agreement with the Claimant, whether express, implied, or by conduct.
5. 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’s (or even admin) costs” were incurred. I deny the Claimant is entitled to any interest whatsoever.

6. In the absence of any proof of adequate signage that contractually bound the Defendant then there can have been no contract and the Claimant has no case.

a) The Claimant is put to strict proof that at the time of the alleged event they had both advertisement consent and the permission from the site owner to display the signs.

b) In the absence of strict proof I submit that the Claimant was committing an offence by displaying their signs and therefore no contract could have been entered into between the driver and the Claimant.

c) Inadequate signs incapable of binding the driver - this distinguishes this case from the Beavis case:

(i) Sporadic and illegible (charge not prominent nor large lettering) of site/entrance signage - breach of the POFA 2012 Schedule 4 and the BPA Code of Practice and no contract formed to pay any clearly stated sum.
(ii) Non existent ANPR 'data use' signage - breach of ICO rules and the BPA Code of Practice.(I need to double check that this is true)
(iii) It is believed the signage and any terms were not transparent or legible; this is an unfair contract, not agreed by the driver and contrary to the Consumer Rights Act 2015 in requiring a huge inflated sum as 'compensation' from an authorised party using the premises as intended.
(iv) No promise was made by the driver that could constitute consideration because there was no offer known nor accepted. No consideration flowed from the Claimant.
(v) The signs are believed to have no mention of any debt collection additional charge, which cannot form part of any alleged contract.
The terms on the Claimant's signage are also displayed in a font which is too small to be read from a passing vehicle, and is in such a position that anyone attempting to read the tiny font would be unable to do so easily. It is, therefore, denied that the Claimant's signage is capable of creating a legally binding contract.
d) CEL CoP breaches - this distinguishes this case from the Beavis case:
(i) the signs were not compliant in terms of the font size, lighting or positioning.
(ii) the sum pursued exceeds £100.
(iii) there is / was no compliant landowner contract.

7. No standing - this distinguishes this case from the Beavis case:
It is believed Civil Enforcement do not hold a legitimate contract at this car park. As an agent, the Claimant has no legal right to bring such a claim in their name which should be in the name of the landowner.

8. No legitimate interest - this distinguishes this case from the Beavis case:
This Claimant files serial claims regarding sites where they have lost the contract, known as revenge claims and it believed this is one such case. This is not a legitimate reason to pursue a charge out of proportion with any loss or damages the true landowner could pursue.

9. The charge is an unenforceable penalty based upon a lack of commercial justification. The Beavis case confirmed that the penalty rule is certainly engaged in any case of a private parking charge and was only disengaged due to the unique circumstances of that case, which do not resemble this claim.
(Can I say this for my case?)
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 1st October 2018.

(b) Sent a template, well-known to be generic cut and paste 'Particulars' 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.(can I say this in my case?)

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


ANY GOOD?
DO I NEED TO ADD OR AMEND ANYTHING?
i am eternally grateful for any help you can provide

thanks for your advice up to yet
just trying to edit my defense....

can i argue point number 2 on my defense (see above) if my letters say i am being fined for breach of terms and conditions?

can i argue point 2a if i have a letter from CEL saying "in accordance with pre action conduct and protocol for debt claims, we wish to give you a final opportunity to settle your debt"

can i argue point 2d if they have sent photos?

point 3... i have a letter from CEL saying that there is no legal requirement for them to send out a PCN within 14 days of the incident as there is no reference to POFA on the ticket. Is this true/correct? should i remove this?

the 3 points listed under CEL cop breaches = do they make sense? shall i delete that bit, am i duplicating things?
should i leave point 9 out?
also should i add a bit about them actually proving i was parked over the allotted time and say i could of been looking for a space or queuing to get off the car park or would i be better concentrating just on the points already made?
i also aim to add this ...
On contacting the landowner the defendant was informed that the landowner was trying to terminate their current parking control contract due to numerous problems with complaints from customers regarding unfair and unjust fines. The defendant feels that this proves that the charge is predatory and not based on any legitimate interest or commercial justification. Thus said the defendant is a long standing customer of the site in question as they hold a gym membership for a business on this site. The defendant is not aware if Civil Enforcement Ltd still hold a parking control contract for this site or ever had one as no proof of the matter has been provided.

hope this makes sense and very grateful for your guidance