going to court vs VCS

HI Kieth, issue date 24 June.
I replied to the Court AOS and have untill the 27th of July to send them my defence.
Any tips or corrections would be welcome.
My Defence.
1. It is admitted that the defendant was the registered keeper of the vehicle in question.
2. As this PCN was issued in July 2015 I have no idea if I was driving the van on the day in question. I will make all the following points in the first party for the sake of expediency.
3. The location of the said offence is a gated shared delivery yard for Iceland and at the time 99p stores (now Poundland).
4. My company had delivered to this 99p store on many occasions before and after the PCN was issued and is still delivering to the Poundland store to date.
5. The delivery yard has a gate which must be opened by a member of staff from one of the stores. We always get permission from the store manager to use the yard to make our delivery as you must sign into the store each time.
6. The reason for this parking company`s presence on this site can only be for the sole purpose of deterring parking from uninvited persons, for the benefit of drivers authorised by the leaseholder businesses.
7. The driver was allowed the right to unload by the leasehold business, relying on an express verbal agreement with the stores management. This permission created the prevailing and overriding contract –the only contract-and the business was concluded as agreed, at no cost or penalty.
8. Loading with the permission of the landowner/leaseholder is not `parking` and signs cannot override existing rights enjoyed landowners and their visitors, as was found in the appeal case decided by His Honour judge Harris QC at Oxford County Court. In case number B9GF0A9E: Jopson V Home Guard Services.
8i In the Jopson appeal it was also held as a finding of fact, that stopping to unload is not `parking`.
8ii In the Jopson appeal it was also held that signs added later by a third party parking firm are of no consequence to authorised visitors to premises where other rights prevail and supersede any alleged new `parking contract.`
9. The right of the onsite businesses to allow authorised vehicles to load/unload pre-dates the arrival of this claimant.
10. In any event, the signs make no offer to authorised visitors engaged in permitted loading/unloading for which no parking permit was ever required.
11. Furthermore, the signage in the yard was and still is, unclear as there are two parking companies with signs on display. In fact the other company`s board is displayed on the wall of the 99p store which I was parked adjacent to.
12. This charge represents a breach of the well-known and well-established principle of promissory estoppel i.e. that a promise is enforceable by law, even if made without formal consideration, when party A has made a promise to party B, who then relies on that promise to his subsequent detriment.
13. This charge represents a breach of the well-known and well-established principle that ‘a grantor shall not derogate from his grant’. This rule embodies a general legal principle that, On the on hand the security/reception staff verbally allowed access and opened the gate, to enable loading/unloading on more than one occasion (the vehicle could not have entered without such express permission and this is proved by the very fact that the gate was opened to allow entry of the vehicle.). Landholders cannot allow or promise this on the one hand, then on the other hand, take away this permission or promise, in allowing a third party to disallow and/or seek or charge for the permitted action by a driver.
14. if A agrees to confer a benefit on B then A should not do anything that substantially deprives B of the enjoyment of that benefit.

Hi, thanks for your reply to my post.
I have read a shed load of the posts and replys on this subject.
I have put my defence on my thread if you could have a read of it and give me any advice or pointers I would very much appreciate it.
many thanks in advance.