IMPORTANT: Please make sure your posts do not contain any personally identifiable information (both your own and that of others). When uploading images, please take care that you have redacted all personal information including QR codes, number plates and reference numbers.
My Witness Statement is due
Options
ElParque
Posts: 74 Forumite
and my skeleton defence if I have to send that to the court with the WS.
This was my defence (sent to the court earlier)
1. It is acknowledged that the defendant, xxxxxxxxxxxxxxxxxxxx is the registered keeper of the vehicle.
2. I deny any liability in this claim, and any debt is denied in its entirety. The date of the alleged incident is [pre Oct] /2012 which is nearly 5 years ago. How can anyone be expected to remember where they may have parked a car or if they were driving on one random day five years ago? I certainly do not remember getting a 'ticket' and had I have done I certainly would remember. Further the car in question is one on which, according to my insurance policy, I was not the main driver and indeed, with access to another car, I very rarely drove this car.
3 It is extremely unreasonable for the claimant to store DVLA data for 5 years then pounce with a claim with no due diligence nor evidence, in the hope that I do not have any paperwork relating to this alleged debt (which I don't). It is even more unreasonable that, having made no attempt whatsoever to contact me for years -and knowing that keepers could not be held liable for parking charges in early 2012 anyway - the Claimant has the audacity to try to ask the court for the right to claim statutory interest at 8% from date of incident (£35.70). The long delay is clearly the fault of the Claimant and should not be used as an excuse to effectively try double recovery.
4. The claimant may seek to rely on the case of Elliot v Loake and seek to persuade the court that this case created a precedent which amounts to a presumption that the registered keeper is the driver, with no evidence or admission to prove its allegations. In the Elliot v Loake case the finding that the keeper was the driver was based on the provision of forensic and other evidence, none of which has been presented here. Elliot v Loake was also a criminal case, which has no bearing on a civil matter.
I would bring to the courts attention two recent cases where the Judges ruled Elliott v Loake as not relevant or applicable, (Excel v Mr C C8DP37F1 Stockport 31/10/2016) and (Excel v Mr B C7DP8F83 at Sheffield 14/12/2016)
Furthermore The Protection of Freedoms Act 2012 (PoFA 2012) which came into force in October 2012 is the only legislation currently available allowing a private parking firm to hold a registered keeper liable. It can be seen the date of the alleged contravention is 20/01/2012 which predates the enactment of PoFA 2012. This being the case, the claimant cannot surely hold the registered keeper liable, only the driver, of which no evidence has been produced.
PATAS and POPLA Lead Adjudicator and barrister, Henry Michael Greenslade, clarified that with regards to keeper liability, "There is no ‘reasonable presumption’ in law that the registered keeper of a vehicle is the driver and operators should never suggest anything of the sort" (POPLA report 2015). It seems Excel Parking Services Ltd think they know better.
5. The claim form itself also gives no indication of on what basis the claim is brought, for example whether this charge is founded upon an allegation of trespass or 'breach of contract' or contractual 'unpaid fees'. Because of this, I have had to cover all eventualities in defending such a 'cut & paste' claim which has caused significant distress and has denied me a fair chance to defend this claim in an informed way. Therefore, as an unrepresented litigant-in-person I respectfully ask that I be permitted to amend and or supplement this interim defence as may be required following a fuller disclosure of the Claimant's case.
In the pre court stage the Claimant’s solicitor did not send me a Letter before Action so I have
a) No summary of facts on which the claim is based.
b) No list of the relevant documents on which the claimant intends to rely and
c) I wasn't offered any form of possible negotiation.
6. 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. HMCTS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA. I believe the term for such conduct is ‘robo-claims’ which is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers. I have reason to believe that this is a claim that will proceed without any facts or evidence supplied until the last possible minute, to my significant detriment as an unrepresented Defendant.
7. I am yet to have knowledge of all documents provided to the court in support of the application, despite sending a Part 18 request to the claimant's solicitors on xxxxxx. Accordingly, it is denied that the Claimant has authority to bring this claim. The proper Claimant (if any debt exists, which is denied) would be the landowner. Strict proof is required that there is a chain of contracts leading from the landowner to Excel Parking Services Ltd, and no proof has been provided.
8. The alleged debt as described in the claim are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.
9. It is submitted that (apart from properly incurred court fees) the added 'contractual costs' of £54 and the £50 legal representative's costs are simply numbers made up out of thin air, and are an attempt at double recovery by the Claimant. I have not been shown any evidence that the deliberately indistinct, almost illegible and unlit signs in the car park refer to these amounts.
10. It is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event. The signs were insufficient in terms of their distribution, wording and lighting hence incapable of binding the driver, which distinguishes this case from the ParkingEye Ltd v. Beavis case:
a) Sporadic and illegible (charge not prominent nor large lettering) site/entrance signage - breach of the BPA Code of Practice and no contract formed to pay any clearly stated sum.
b) The signs are believed to have no mention of any debt collection additional charge, which cannot form part of any alleged contract.
c) The signage was not lit and any terms were not transparent or legible; this is an unfair contract, not agreed by the driver and contrary to the Unfair Terms in Consumer Contracts Regulations 1999.
d) No promise was made by the driver that could constitute consideration because there was no offer known nor accepted. No consideration flowed from the Claimant.
e) Absent the elements of a contract, there can be no breach of contract.
Further, this claimant is known for incoherent and sparse signage, incapable of forming a contract. In Excel Parking Services Ltd v M R Cutts at Stockport County Court in 2011, claim 1SE02795, DDJ Lateef dismissed the claim by Excel and ordered the company to pay Mr Cutts' £53.50 costs. The Judge personally visited the site to view the signs in situ and found that the key issue was that Excel had not taken reasonable steps to draw to Mr Cutts’ attention to the terms and conditions of using the car park. I will include in my evidence, Mr Cutts' own published article '‘Phoney fines and dodgy signs take drivers for a ride'' which is specifically about Excel's signs.
11. It is expected that this Claimant may try to counter that article about their signs but it is worth noting that the Judge agreed with Mr Cutts, who is something of an expert on clear terms as he manages the Plain Language Commission and is the author of Lucid Law, the Plain English Lexicon and the Oxford Guide to Plain English.
12. It is also worth noting that Simon Renshaw-Smith (previously known as 'Captain Clampit') who runs Excel Parking Services, is in the public domain as having attacked the Judge’s integrity in the Cutts case. The Plain Language Commission's article states that Mr Renshaw-Smith wrote to Stockport MP Andrew Gwynne: ‘The recent decision by Deputy District Judge Lateef, is an embarrassment to the judicial system. Such an off the wall judgment leads one to question if there was indeed an ulterior motive. DJ Lateef is not fit to serve the Civil Courts'.
13. I am aware that the only ticket-machine at this site is prone to be faulty. I therefore ask that the claimant produce evidence that no payment was made that day in relation to the incident and indeed that the ticket machine was working at the time the parking notice was issued.
14. Excel Parking Services Ltd are not the lawful occupier of the land. Absent a contract with the lawful occupier of the land being produced by the claimant, or a chain of contracts showing authorisation stemming from the lawful occupier of the land, I have the reasonable belief that they do not have the authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.
15. The defendant denies the claim in its entirety voiding any liability to the claimant for all amounts claimed due to the aforementioned reasons and I request the court strike out this claim for the reasons stated above.
Statement of Truth: I confirm that the contents of this statement are true to the best of my knowledge and belief.
Since I posted my defence I have received their 'evidence' which consists of some slightly contradictory statements and partly illegible photos.
A letter to me says that the parking attendant wasn't able to fix the ticket to the car because the driver drove away but the parking ticket itself says that the driver handed back the ticket to the attendant.
The letter says that the ticket was issued at 11:05 but the photos of my car show the time as 11:06. If the ticket was issued at 11:05 then the attendant took photos, why wasn't he/she able to fix the ticket to the car? Did they make up the part about handing the ticket to the driver? Is it worth pursuing this line of defence?
The ticket itself identifies the driver as a male so I know that the driver must have been one of my three sons (all qualified to drive) because it wasn't me (Now that they have told me what happened that day, I'd have remembered this incident). The main driver according to the insurance doc is female though I haven't been able to get a copy of the insurance.
They claim that the driver stayed 50 minutes after the expiry of his ticket although the photo evidence they have of the displayed ticket is completely illegible.
Anyway, all that being said... I have no evidence of the signage at the time and the car park is now run by another firm. I think my main defence is that the case is pre-2012.
In my defence I refer to some case law. Do I have to print out transcripts/judgements in those cases as part of my WS or evidence or just state the relevant part of the case?
Parts of my defence seem no longer relevant.
Any advice as to how to proceed from here?
This was my defence (sent to the court earlier)
1. It is acknowledged that the defendant, xxxxxxxxxxxxxxxxxxxx is the registered keeper of the vehicle.
2. I deny any liability in this claim, and any debt is denied in its entirety. The date of the alleged incident is [pre Oct] /2012 which is nearly 5 years ago. How can anyone be expected to remember where they may have parked a car or if they were driving on one random day five years ago? I certainly do not remember getting a 'ticket' and had I have done I certainly would remember. Further the car in question is one on which, according to my insurance policy, I was not the main driver and indeed, with access to another car, I very rarely drove this car.
3 It is extremely unreasonable for the claimant to store DVLA data for 5 years then pounce with a claim with no due diligence nor evidence, in the hope that I do not have any paperwork relating to this alleged debt (which I don't). It is even more unreasonable that, having made no attempt whatsoever to contact me for years -and knowing that keepers could not be held liable for parking charges in early 2012 anyway - the Claimant has the audacity to try to ask the court for the right to claim statutory interest at 8% from date of incident (£35.70). The long delay is clearly the fault of the Claimant and should not be used as an excuse to effectively try double recovery.
4. The claimant may seek to rely on the case of Elliot v Loake and seek to persuade the court that this case created a precedent which amounts to a presumption that the registered keeper is the driver, with no evidence or admission to prove its allegations. In the Elliot v Loake case the finding that the keeper was the driver was based on the provision of forensic and other evidence, none of which has been presented here. Elliot v Loake was also a criminal case, which has no bearing on a civil matter.
I would bring to the courts attention two recent cases where the Judges ruled Elliott v Loake as not relevant or applicable, (Excel v Mr C C8DP37F1 Stockport 31/10/2016) and (Excel v Mr B C7DP8F83 at Sheffield 14/12/2016)
Furthermore The Protection of Freedoms Act 2012 (PoFA 2012) which came into force in October 2012 is the only legislation currently available allowing a private parking firm to hold a registered keeper liable. It can be seen the date of the alleged contravention is 20/01/2012 which predates the enactment of PoFA 2012. This being the case, the claimant cannot surely hold the registered keeper liable, only the driver, of which no evidence has been produced.
PATAS and POPLA Lead Adjudicator and barrister, Henry Michael Greenslade, clarified that with regards to keeper liability, "There is no ‘reasonable presumption’ in law that the registered keeper of a vehicle is the driver and operators should never suggest anything of the sort" (POPLA report 2015). It seems Excel Parking Services Ltd think they know better.
5. The claim form itself also gives no indication of on what basis the claim is brought, for example whether this charge is founded upon an allegation of trespass or 'breach of contract' or contractual 'unpaid fees'. Because of this, I have had to cover all eventualities in defending such a 'cut & paste' claim which has caused significant distress and has denied me a fair chance to defend this claim in an informed way. Therefore, as an unrepresented litigant-in-person I respectfully ask that I be permitted to amend and or supplement this interim defence as may be required following a fuller disclosure of the Claimant's case.
In the pre court stage the Claimant’s solicitor did not send me a Letter before Action so I have
a) No summary of facts on which the claim is based.
b) No list of the relevant documents on which the claimant intends to rely and
c) I wasn't offered any form of possible negotiation.
6. 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. HMCTS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA. I believe the term for such conduct is ‘robo-claims’ which is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers. I have reason to believe that this is a claim that will proceed without any facts or evidence supplied until the last possible minute, to my significant detriment as an unrepresented Defendant.
7. I am yet to have knowledge of all documents provided to the court in support of the application, despite sending a Part 18 request to the claimant's solicitors on xxxxxx. Accordingly, it is denied that the Claimant has authority to bring this claim. The proper Claimant (if any debt exists, which is denied) would be the landowner. Strict proof is required that there is a chain of contracts leading from the landowner to Excel Parking Services Ltd, and no proof has been provided.
8. The alleged debt as described in the claim are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.
9. It is submitted that (apart from properly incurred court fees) the added 'contractual costs' of £54 and the £50 legal representative's costs are simply numbers made up out of thin air, and are an attempt at double recovery by the Claimant. I have not been shown any evidence that the deliberately indistinct, almost illegible and unlit signs in the car park refer to these amounts.
10. It is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event. The signs were insufficient in terms of their distribution, wording and lighting hence incapable of binding the driver, which distinguishes this case from the ParkingEye Ltd v. Beavis case:
a) Sporadic and illegible (charge not prominent nor large lettering) site/entrance signage - breach of the BPA Code of Practice and no contract formed to pay any clearly stated sum.
b) The signs are believed to have no mention of any debt collection additional charge, which cannot form part of any alleged contract.
c) The signage was not lit and any terms were not transparent or legible; this is an unfair contract, not agreed by the driver and contrary to the Unfair Terms in Consumer Contracts Regulations 1999.
d) No promise was made by the driver that could constitute consideration because there was no offer known nor accepted. No consideration flowed from the Claimant.
e) Absent the elements of a contract, there can be no breach of contract.
Further, this claimant is known for incoherent and sparse signage, incapable of forming a contract. In Excel Parking Services Ltd v M R Cutts at Stockport County Court in 2011, claim 1SE02795, DDJ Lateef dismissed the claim by Excel and ordered the company to pay Mr Cutts' £53.50 costs. The Judge personally visited the site to view the signs in situ and found that the key issue was that Excel had not taken reasonable steps to draw to Mr Cutts’ attention to the terms and conditions of using the car park. I will include in my evidence, Mr Cutts' own published article '‘Phoney fines and dodgy signs take drivers for a ride'' which is specifically about Excel's signs.
11. It is expected that this Claimant may try to counter that article about their signs but it is worth noting that the Judge agreed with Mr Cutts, who is something of an expert on clear terms as he manages the Plain Language Commission and is the author of Lucid Law, the Plain English Lexicon and the Oxford Guide to Plain English.
12. It is also worth noting that Simon Renshaw-Smith (previously known as 'Captain Clampit') who runs Excel Parking Services, is in the public domain as having attacked the Judge’s integrity in the Cutts case. The Plain Language Commission's article states that Mr Renshaw-Smith wrote to Stockport MP Andrew Gwynne: ‘The recent decision by Deputy District Judge Lateef, is an embarrassment to the judicial system. Such an off the wall judgment leads one to question if there was indeed an ulterior motive. DJ Lateef is not fit to serve the Civil Courts'.
13. I am aware that the only ticket-machine at this site is prone to be faulty. I therefore ask that the claimant produce evidence that no payment was made that day in relation to the incident and indeed that the ticket machine was working at the time the parking notice was issued.
14. Excel Parking Services Ltd are not the lawful occupier of the land. Absent a contract with the lawful occupier of the land being produced by the claimant, or a chain of contracts showing authorisation stemming from the lawful occupier of the land, I have the reasonable belief that they do not have the authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.
15. The defendant denies the claim in its entirety voiding any liability to the claimant for all amounts claimed due to the aforementioned reasons and I request the court strike out this claim for the reasons stated above.
Statement of Truth: I confirm that the contents of this statement are true to the best of my knowledge and belief.
Since I posted my defence I have received their 'evidence' which consists of some slightly contradictory statements and partly illegible photos.
A letter to me says that the parking attendant wasn't able to fix the ticket to the car because the driver drove away but the parking ticket itself says that the driver handed back the ticket to the attendant.
The letter says that the ticket was issued at 11:05 but the photos of my car show the time as 11:06. If the ticket was issued at 11:05 then the attendant took photos, why wasn't he/she able to fix the ticket to the car? Did they make up the part about handing the ticket to the driver? Is it worth pursuing this line of defence?
The ticket itself identifies the driver as a male so I know that the driver must have been one of my three sons (all qualified to drive) because it wasn't me (Now that they have told me what happened that day, I'd have remembered this incident). The main driver according to the insurance doc is female though I haven't been able to get a copy of the insurance.
They claim that the driver stayed 50 minutes after the expiry of his ticket although the photo evidence they have of the displayed ticket is completely illegible.
Anyway, all that being said... I have no evidence of the signage at the time and the car park is now run by another firm. I think my main defence is that the case is pre-2012.
In my defence I refer to some case law. Do I have to print out transcripts/judgements in those cases as part of my WS or evidence or just state the relevant part of the case?
Parts of my defence seem no longer relevant.
Any advice as to how to proceed from here?
0
Comments
-
Yes, agreed. You should show as evidence, proof that the POFA was enacted on 1.10.2012.Anyway, all that being said... I have no evidence of the signage at the time and the car park is now run by another firm. I think my main defence is that the case is pre-2012.
Print them as evidence for the court (you can get away with emailing the other side's solicitors, no printing needed, but copy in one of your OWN email addresses and print out the proof it was received & when and who the recipients were, and put that proof of emailing in your court bundle to bring with you on the day.In my defence I refer to some case law. Do I have to print out transcripts/judgements in those cases as part of my WS or evidence or just state the relevant part of the case?
Which bits?Parts of my defence seem no longer relevant.
Any advice as to how to proceed from here?PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
The bits that are not relevant are;
The machine wasn't broken on the day (if the ticket in my car was from that day)
I can't get hold of an insurance document for the year in question.
I have found a photo of the signage but from 2015. Should I use it? It's 3 years after my case. (Can't link it)
Should I just go all out on the pre-POFA argument? Is that a winning tactic if I can convince the judge of its legitimacy (all things being equal)?0 -
Yes, that and attacking THEIR evidence on the day, because they have to file their evidence and WS too and it will include signs (maybe they will only have photos from the wrong year, too).Should I just go all out on the pre-POFA argument? Is that a winning tactic if I can convince the judge of its legitimacy (all things being equal)?PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
You wrote
"The date of the alleged incident is [pre Oct] /2012 which is nearly 5 years ago. How can anyone be expected to remember where they may have parked a car or if they were driving on one random day five years ago? I certainly do not remember getting a 'ticket' and had I have done I certainly would remember."
If their side says they do remember and you don't , then that does you no good at all.
All you needed to say was that they identified the driver as male. You are female and were not driving on the day. This was before POFA and it could have been one of 3 or 4 regular male drivers, but none of them can recall the events of 5 years ago.
Pre-POFA, keeper liability did not exist and if the attendant had a camera, he was in a position to photograph the driver to aid identity.
But you can not be held liable.0 -
You wrote
[/I]If their side says they do remember and you don't , then that does you no good at all.
All you needed to say was that they identified the driver as male. You are female and were not driving on the day. This was before POFA and it could have been one of 3 or 4 regular male drivers, but none of them can recall the events of 5 years ago.
Pre-POFA, keeper liability did not exist and if the attendant had a camera, he was in a position to photograph the driver to aid identity.
But you can not be held liable.
I'm all for being able to decide on one's own gender but still I'm not sure anyone would necessarily believe I was female. The point is that one of my kids must have been driving the car that day. If the evidence from the attendant can be believed then my wife was not the driver. That's all we know.0 -
Sorry - wrong conclusion drawn from paragraph "The ticket itself identifies the driver as a male"0
-
Or where do I find them?
I'm trying to find judgements or transcripts from Excel v Mr C C8DP37F1 and Excel v Mr B C7DP8F83 to use as evidence in my case. (I referenced them in my defence).0 -
Do I need any more than this?
WITNESS STATEMENT
1. I, xxxx, xxxxxam the defendant in this claim. The facts in this statement come from my personal knowledge.
2.As the keeper of the car at the centre of this claim, in early August 2016 I received a letter from BW Legal threatening to pursue me for a £100 PCN and an additional £54 for legal costs which they claimed are detailed in the car park terms and conditions. Because this correspondence and subsequent claim came many years after the date of the alleged incident and because Excel Parking Services (EPS) have now been kicked off the car park in question I am unable to produce anything other than a photo of the signage at the car park from 2015 (see exhibit 5) but, unless the signs were clearer in 2012 than they were in 2015 it can be seen from my evidence that no such reference to £54 legal costs is made on the signs in the car park. I think it unlikely that EPS changed their signage between 2012 and 2015 to remove the reference to the £54 costs.
3. The incident occurred more than five years ago. There were 5 people in my family who could have been driving the car on the day in question. Anyone with a car insurance policy could have driven the car with my permission. My evidence (exhibit 1 and 2) shows that according to the insurance policy I was not the main driver of the car and indeed I very rarely did drive the car. I cannot remember the incident. I have no idea who was driving.
I believe that the facts stated in this Witness Statement, are true.
Signed: Date: 11/04/170 -
(EPS) have now been kicked off the car park
Not 'kicked off' in a legal submission - no slang! Also having 'exhibit 5' followed by exhibit 1 and 2, makes no sense? This is your chance to file your evidence in your favour, so there is MORE to throw at this.
I would use Excel v Cutts (a case scrutinising the typically awful Excel signs in 2011) and Excel v Lamoureux (proving that Excel cannot hold a keeper liable outwith the POFA). Both transcripts are available by Googling 'Parking Prankster case law'.I'm trying to find judgements or transcripts from Excel v Mr C C8DP37F1 and Excel v Mr B C7DP8F83 to use as evidence in my case. (I referenced them in my defence).
I would also have as evidence, Henry Greenslade's wording 'Understanding Keeper Liability' easily found by Googling 'Annual Report 2015 POPLA'.
And I would have as evidence, Martin Cutts' own article 'Dodgy signs and phoney fines take drivers for a ride' (all about Excel's signage and written for the Plain Language Commission).
And I would have as evidence, the FOI request on 'whatdotheyknow' - the response from the DVLA which confirms that Excel were banned in 2012 from getting data, for a 'serious breach' of the BPA Code of Practice in suggesting that:
(a) the keeper can be assumed responsible
and
(b) the keeper is liable for a charge (pre-POFA)
both of which were not true and not allowed. Excel have just waited a few years and are now suing people using the same allegations, in the hope that people and courts don't know that they were temporarily sanctioned/banned for 3 months in 2012 by the DVLA, for saying exactly that!
All of this is covered in other pre-POFA witness statements I am sure, with links because I've posted them before, several times. Try searching 'Excel Martin Cutts DVLA 2012 banned keeper responsible' or similar.
Always change to 'SHOW POSTS' when searching this forum.PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0 -
Just to add, read through Matthew87's WS and evidence he has just posted about:
http://forums.moneysavingexpert.com/showthread.php?t=5573407&page=2
Remember the Judge won't do this for you. The evidence is what you file now and bring with you, so add more!PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
CLICK at the top of this/any page where it says:
Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0
This discussion has been closed.
Categories
- All Categories
- 343.2K Banking & Borrowing
- 250.1K Reduce Debt & Boost Income
- 449.7K Spending & Discounts
- 235.3K Work, Benefits & Business
- 608.1K Mortgages, Homes & Bills
- 173.1K Life & Family
- 247.9K Travel & Transport
- 1.5M Hobbies & Leisure
- 15.9K Discuss & Feedback
- 15.1K Coronavirus Support Boards