Vehicle Control Services County Court Claim - Am I stuffed?

I have (finally) drafted my defence after reading through all of the documents. I have just used a template from another forum that seemed very similar to mine and tailored it to fit my case better.

Apologies if I've gotten the wrong end of the stick with what to do, I'm very new to all of this and have no legal background!

I appreciate any help you can offer. Here goes:

Claim Number: ____
Vehicle Control Services Ltd (Claimant) vs. Me (Defendant)
I am ___, the defendant in this matter and registered keeper of vehicle ___.

Statement of Defence

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

1. It is admitted that at all material times the Defendant was the owner of a ___ vehicle variously with registration marks___ as permitted by the Driver and Vehicle Licensing Authority ("the DVLA")

2. It is neither admitted nor denied that to which the Claimant are permitted to undertake parking enforcement. The Claimant is put to strict proof.

3. It is admitted that the Defendant parked her vehicle on the dates stated whilst working at MY COMPANY. The premises are operated by MY COMPANY with whom the Defendant works and is permitted parking free of charge. The Defendant denies any separate contract with the Claimant in respect of parking arrangements.

4. It is not admitted that the Claimant has contractual or other lawful authority to bring proceedings against the Defendant. The Claimant is put to strict proof. Further, and in the alternative, the Defendant avers that the Claimant requires the permission of MY COMPANY or the owner of the relevant land, if different, to commence proceedings.

5. The Defendant works at the premises and as such is entitled to parking, which was agreed with MY COMPANY. The Defendant has continued to abide by the contract in place between the land owner and MY COMPANY which does not mention a permit or subsequent charges if this is not displayed. In the premises, it is denied that there was any breach of contract or of parking terms. The Claimant's claim is wholly misconceived.

6. The claim against the defendant is for breach of contract. The defendant argues there was no contract in place. The defendant can evidence poor signage at the premises. There are three different signs on the premises. One indicates MY COMPANY employees and visitors are welcome to park in the spaces provided. The defendant argues this sign does not mention any permits required to park on the premises. The text is very prominent compared to the small printed sign issued by the claimant. The defendant avers that theirs would be one of several contract the defendant could have entered into by their own logic.

8. The Defendant avers that the Claimant has issued proceedings inappropriately, prematurely and without complying with the practice directions on pre-action conduct.

9. The defendant contacted the claimant to appeal twice and did not receive notice of the outcome of the claim. The claimant continued to send two notices of intended court proceedings. The claimant failed to respond to the defendant’s appeal. The claimant failed to provide the defendant with the opportunity to appeal with the relevant independent body.

9. The Defendant avers that the Claimant's claim has no reasonable prospect of success. The defendant asks the court to eliminate the claim as having no reasonable prospect of success as it stands.

STATEMENT OF TRUTH
The Defendant believes that the facts set out in the Defence are true.

The key points I'm trying to make here are that the signs are very unclear, there was already a contract in place with my company that doesn't mention anything about permits and they failed to reply to my appeal letters.

Thanks for everyone's help so far

Sorry - I meant licensed to.

I have the Licence For Car Parking Space agreement from work. I'm going to upload it in its entirety now - hold on.

Argh - as a new user it won't let me post a link

imgur.com/a/pifw1

edit: that might have worked. Let me know if it hasnt!


There - no mention of charges or of Vehicle Control Services

So I've (finally) been asked to provide my supporting documents to my claim.

After looking on the newbie thread, I've got my case law documents printed and will include these as well as some pictures on the confusing signs and my parking contract.

As I've put myself down as the only witness I've gathered (from the newbie thread) I have to now provide a statement. Is this different to my defence or do I just put a copy of my defence in?

If it's different, I'm not sure what I need to add as my defence pretty much has everything in it that I want to say.

I think I have all the relevant documents to send after I've cleared this up, please also let me know if you think there's something I may have missed.

Any help would be much appreciated.

Thanks!