Need My Witness Statement Checking Over

You have:

Independent Parking Committee

...six times, and that is NOT the name of the IPC. 2 out of 3 words are wrong!

I didn't see (may have missed it) that you have adduced Henry Greenslade's words 'Understanding Keeper Liability' from the POPLA Report 2015 as evidence to support your point that, under the POFA, a keeper cannot be held liable if the statute is not complied with, nor can any adverse inference be drawn by that keeper choosing not to name the driver. you are perfectly at liberty to defend as keeper and have no such obligation in law, nor can any presumption be made.

You need that POPLA 2015 Annual Report page in evidence.

You have referred to 9(2)f but para 9 does not relate to your case at all.

Para 8 does, so go and read and cite para #8 of the POFA Schedule 4 and show that the operator has not issued a NTK in compliance with the 'keeper liability' statutory warning required as mandatory wording in 8(2)f.

Then point out that in #16 of his WS, Brian Hargreaves has perjured himself by saying they did issue a NTK in accordance with paragraph 8. They didn't, that is what's known as a non-POFA NTK, clear as day, even the wording says they are merely 'assuming the keeper was the driver' which is NOT what Schedule 4 is about (quite the opposite, say so!). Any parking firm knows the difference between a non-POFA NTK and a POFA one. No excuse for that lie.

Also adduce some case transcripts that support the fact that a keeper can't be held liable outwith the POFA. Several like that in the second page of he Parking Prankster's case law. Easy to include, and very useful for a clueless Judge to steer them to see what's in front of their face.

Not the driver = not liable. It's your main defence, in a non-POFA case.

Good, what evidence are you filing then, list it?

You can't change your defence, it's already long past submission!