Small Claims date received

Hello again,
Work and home life have distracted me for a while but I am back for more help please.
I need help with my skeleton argument (this is for a residential space) I know Coupon-Mad has posted one on this site somewhere but I'm struggling to find it??
I am going to use as evidence: Tenancy agreement, Transcripts of Jopson v Homeguard, Link V Ms P, Pace V Mr N, and Saeed V Plustrade. Also going to include Transcript of House of commons debate on the Parking Bill (all of it or salient points??). Photo of parking sign and my witness statement. Do I need anything else??

Here is my witness statement: (As you can tell 'stolen' and amended from this forum :rotfl:)
Witness Statement
In the matter of

Link Parking (Claimant)
v
Mrs xxxxxx (defendant)

Claim no:

Witness statement of Mrs xxxxxx, defendant

I am the Defendant in this matter, I am unrepresented, with no experience of Court procedures. If I do not set out documents in the way that the Claimant may do, I trust the Court will excuse my inexperience.
In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.


1. I am not the Registered Keeper of the vehicles concerned, there is no evidence from Link Parking of the driver and as this event involved two vehicles, it is impossible to say who might have been driving each vehicle.

2. The Defendant neither admits or denies being the driver at the time of the supposed event, and therefore puts Link Parking to strict proof that any contract can exist between the Claimant and themselves.

3. As neither vehicle stated in the claim are owned by the Defendant, I have no obligation to name the driver to a private parking firm. It remains the burden of the Claimant to prove their case.



4. No adverse inference can be drawn from my lawful decision to ignore the yellow Parking Charge Notice, impersonating a parking ticket yet with no basis in law.

5. Link Parking have offered no evidence of either vehicle being illegally parked at xxxxxx despite them claiming photographs are available to view on their website. I have been unable to find any photographs as these can only be viewed prior to an internet payment being made, as shown on the parking charge notice

6. The agreement for parking at the property lies with the landlord and not Link Parking as stated in the tenancy agreement

7. I will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services Ltd (2016) and of Sir Christopher Slade in K-Sultana Saeed v Plustrade Ltd [2001] EWCA Civ 2011.Also in Pace v Mr N [2016] C6GF14F0 [2016] it was found that the parking company could not override the tenant's right to park by requiring a permit to park furthermore In Link Parking v Ms P C7GF50J7 [2016] it was also found that the parking company could not override the tenant's right to park by requiring a permit to park.


8. The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action.

9. A publically televised debate held in the House of Commons (Parking Code of Practice Bill– in the House of Commons at 12:43 pm on 2nd February 2018.) discussed the unreasonable circumstances of repeated issuing of fines to individuals parking in their own parking space outside their property with the Claimant’s solicitors Gladstones being involved in many such cases.

I believe that the facts stated in this Witness Statement are true.

Also should I get a witness statement from an 'independent' person (my daughters flatmate) who was there at the time of the alleged parking breach??