wrong registration number on PCN, please help

Hi
I have study some NEWBIES forum and found some threads apply to my defense, please check and rate my draft, many thanks.


CLAIM No: xxxxxxxxxx
BETWEEN:
UK CAR PARK MANAGEMENT LTD (Claimant)
-and-
xxxxxxxxxxx (Defendant)
1. The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all.
2. The Particulars of Claim state that the Defendant was the registered keeper and/or the driver of the vehicle(s). 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.
3. 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.
4. 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.
5. Registration mark on the summons (PCN) did not relate to Defendant vehicle or any vehicle that Defendant had ever own.
6. Parking charge notice (PCN) shows different Vehicle registration number and do not match details of the car. Formal Demand (NTK) contain incorrect the Vehicle registration number do not match data from original Notice (number xxxxx) Notice To Driver (NTD) do not mirror the details on the Notice To Keeper (NTK) and therefore does not meet the strict requirements of the POFA 2012 and should be cancelled.
7. Vehicle was parked before the gate entrance of residential estate (few meters before information board) Information board suggest the controlled zone applies beyond the gates. There are no any signs and information (from the main road to the gate) the parking is forbidden, there are also no others marks like yellow or red lines or information boards.
8. The Protection of Freedoms Act 2012, Schedule 4, at Section 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper, in this case £100. The claim includes an additional £60, for which no calculation or explanation is given, and which appears to be an attempt at double recovery.
9. In summary, it is the Defendant's position that the claim discloses no cause of action, is without merit, and has no real prospect of success. Accordingly, the Court is invited to strike out the claim of its own initiative, using its case management powers pursuant to CPR 3.4.
I believe the facts contained in this Defence are true.
Name
Signature
Date

hi
Could you help me with this draft defence?
Any sugestions?


Thanks

Hi

I have received letter from Gladstons with attached filled N180 form with "paper only request"
And form N159 Notice of Allocation to the small claims Track.
Should I replay to the court or wait for court action following court letter I have received.
Court should send to me form N159 "Directiond questionare (Small Claims Track)?
Thank you.

Thank you.
Yes, I have read post 2 from newbies, but form N159 has point B: I do not agree that the claim Should be dealt with on the papers alone.
That point made me confused.
So, no action needed and wait for N180 from the court.