Your browser isn't supported
It looks like you're using an old web browser. To get the most out of the site and to ensure guides display correctly, we suggest upgrading your browser now. Download the latest:

Welcome to the MSE Forums

We're home to a fantastic community of MoneySavers but anyone can post. Please exercise caution & report spam, illegal, offensive or libellous posts/messages: click "report" or email forumteam@.

Search
  • FIRST POST
    • RM_2007
    • By RM_2007 23rd Sep 17, 1:52 AM
    • 92Posts
    • 44Thanks
    RM_2007
    At Small Claims stage - PCM and Gladstones
    • #1
    • 23rd Sep 17, 1:52 AM
    At Small Claims stage - PCM and Gladstones 23rd Sep 17 at 1:52 AM
    Hi All,


    Cross posting from the pepipoo forum to get as much help as possible.


    Long story short - Got a NTK from PCM for parking on double yellow lines on a private estate. Went through the motions with Gladstones and cort papers were recieved (dated 06/09).


    Followed the Newbie sticky and acknoledged the AOS and hav started to draft the defence.


    The Pepipoo thread is here
    http://forums.pepipoo.com/index.php?showtopic=112701&st=60&gopid=1318034&#en try1318034


    I can cross post all the deatils if it is easier. I've found it a aunting task to compile the defence but have been helped by all the advice on the sticky - Thanks Coupo-Mad and all the others who have contributed.


    Main arguments are:


    prohibitive 'forbidding parking' signs
    signage being inadequate
    No Standing


    I've also thrown in not POFA compliant and unreasonable and vexatious claim. I still need to go through it and possible remove anything that is considered to be an irrelevant defence, so in the interest of time, Putting the current draft up for review.


    Your help and guidence would be very appriciated.








Page 2
    • Coupon-mad
    • By Coupon-mad 5th Mar 18, 9:36 PM
    • 58,576 Posts
    • 72,079 Thanks
    Coupon-mad
    On this occasion it is on a double yellow and I take your point that should have been a warning to the driver. However please do correct me if I have misunderstood, DYL's on private land are not the same as on the public roads (appreciate it still should have been a indicator to the driver).
    Look up what double yellows actually mean (and all the exemptions which allow a car to stop/be left) on Public Highway, because - in case you are one of lots of drivers who think so - they are not an indicator of 'no stopping' at all.

    1: I'll hand deliver the bundle to the court on Friday, but will need to post to Gladstones - is next day signed for/recorded required - would need to send by Thursday.
    The 'bundle' is what you physically take to court. You mean you will hand deliver a ring binder file with a contents page and WS and appendices all nicely numbered and easy to follow? Hand delivery to the court (BEFORE NOON on a Friday on case they shut the manned clerk's desk early) is good.

    You never send anything signed for to Gladstones or a parking firm, guess why not? Think about what 'signed for' requires...

    Just post it ordinary 1st class (free cert of posting from the PO counter, and KEEP THAT PROOF, don't just pop it in a postbox) and email it as well, to G's a few attachments at a time on Thursday.

    Gladstones email is easy to find by searching this forum.



    2: I'm drafting the witness statement tonight, from your post on pepipoo, is should be a statement from a witness (me in this case) that supports what is in my original defence. In terms of exhibits that I want to include - how should you reference them and do you then include them in an appendix?
    Have a look at the examples shown in post #2 of the NEWBIES thread, they show WS with numbered evidence being referred to, throughout.


    3: When referring to exhibits in the witness statement, to you include the exhibit reference?
    Yes.

    4: I plan on including some video as suggested in the newbie tread - are there any recommendations on what format to use? Create a DVD or just include a mpeg etc?
    Memory stick maybe, hand delivered to the Court, and in the posted version to Gladstones, and have a copy with you in your bundle and a method of showing the video if the Judge lets you - needs to be short and on point.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • RM_2007
    • By RM_2007 5th Mar 18, 9:47 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Thank you Coupon-mad.

    Yes I intend hand deliver a lever arch file with a contents page and WS and appendices all nicely numbered and hopefully easy to follow.

    On my last pint of confusion - do I need to send a full copy of everything to Gladstones as well? From your answer on the postage, I assume I do?
    • Coupon-mad
    • By Coupon-mad 5th Mar 18, 11:23 PM
    • 58,576 Posts
    • 72,079 Thanks
    Coupon-mad
    Yes you must. But not tons of attachments on a single email, and post it too (with free proof).
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • RM_2007
    • By RM_2007 6th Mar 18, 11:15 AM
    • 92 Posts
    • 44 Thanks
    RM_2007
    1st draft of the witness statement below (I need to do a bit more digging on the DYL rules). Would appreciate a review. I'll also draft a skeleton argument doc and include the evidence refs.

    1. I, xxx, of xxx, am the Defendant in this matter, and will say as follows

    2. 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.

    3. In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.

    4. Whilst I was the Registered Keeper of the vehicle concerned, there is no evidence of the driver and as this event has been resurrected from over 1 year ago, it is impossible to expect a keeper to recall who might have been driving.

    5. The Defendant denies being the driver at the time of the supposed event, and therefore puts PARKING CONTROL MANAGEMENT (UK) LIMITED to strict proof that any contract can exist between the Claimant and themselves.

    6. At the time in November 2016, the insurance covered more than one family member, who I have no obligation to name to a private parking firm. It remains the burden of the Claimant to prove their case.

    7. There was no requirement upon me as keeper to respond to what appeared to be junk mail. No adverse inference can be drawn from my lawful decision to ignore the colourful letter, impersonating a parking ticket yet with no basis in law.

    8. In May 2017 I received a Letter before Claim from the claimants solicitors for an inflated amount of £160. I have researched this and discovered that the claimants solicitors, Gladstones, have history of issuing robo-claims for 'parking charges' in their thousands.

    9. The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160. I submit the added costs have not actually been incurred by the Claimant; these are figures plucked out of thin air and applied regardless of facts, as part of their robo-claim litigation model, in an attempt at double recovery, circumventing the Small Claims costs rules. Further, Gladstones appear to be in contravention of the Solicitors’ Regulation Authority Code of Conduct by knowingly demanding more monies than they know they can recover.

    10. The Defendant also disputes that the Claimant has incurred £50 solicitor costs.

    11. The Defendant has the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt.

    12. Notwithstanding the Defendant's belief, the costs are in any case not recoverable.

    13. The Claimant described the charge of £50.00 "legal representative’s costs" not "contractual costs". CPR 27.14 does not permit these to be recovered in the Small Claims Court.

    14. I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress, such that I intend to report PARKING CONTROL MANAGEMENT (UK) LIMITED to the Information Commissioner for misuse of my data, obtained from the DVLA.

    15. My DVLA data was supplied for the single strict purpose of enquiring who was driving, not for storing for a prolonged period then suing me as if I can now be held liable, in the hope I will not defend/will have lost the paperwork/will have moved house, or even better, that I will be so scared that I will pay over £244, for what was apparently an unproven £100 charge, allegedly incurred by another party, if incurred at all.

    16. The claimant has failed to properly respond to my request made on 12/05/2017 & 09/06/2017 by royal mail postal service, requesting any documentation and relevant contracts with the land owners that allow the claimant to issue claims upon the landowner’s behalf. My request was not actioned appropriately (I received copies of two PCN’s, one of which states the time as 15:25 and the other as 15:58 and also 7 poor quality prints of photographs, one of which does not look like any siganage in the direct vicinity of where the car was located and of such low quality that the timestamp cannot read).

    CLAIMANTS CORRESPONDENCE APPENDED AS EVIDENCE: E.XX

    17. No windscreen ticked was attached to the vehicle at the time. The claimant took photographs but did not place a ticket on the car. Additionally, as far I am aware, there are no uniformed wardens patrolling the site – photographs are taken in a secretive manner. I believe this is because the claimant is deliberately targeting motorist for their financial gain.

    18. I did not receive a copy of the contract with the landowner or an answer on whether the charges were based on damages for breach of contract or trespass, nor did I receive a full explanation on how the additional £60 on an £100 charge was calculated, only that it was incurred in facilitating the recovery. This appears to be an added cost with apparently no qualification and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.


    19. Para. 4(5) Schedule 4 Protection of Freedoms Act 2012 which sets out that the maximum amount recoverable from the registered keeper, where the keeper liability provisions have been properly invoked (which is expressly denied in this case) is that amount specified in the Notice to Keeper (whether issued in accordance with paras 8(2)c; 8(2)d, 9(2)c or 9(2)d of the Act).

    POFA APPENDED AS EVIDENCE: E.xx

    20. The claimants photographs show the car is parked on a section with double yellow lines. However there are no upright signs or markings on the kerb on that side of the road indicating any restrictions. The car was not causing any obstructions and the driver would have only stopped there to pickup or drop off something from the school office on that side of the road. Additionally as this is not a public road, I do not believe double yellow lines have the same legal basis as they do on a public road.

    LOCATION PHOTOGRAPHS APPENDED AS EVIDENCE: E.XX

    21. I believe the signage on entrance to the site and in the surrounding area parking signage in this matter was, without prejudice to my defence, woefully inadequate and incapable of forming the basis of a contract.

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: E.Xx
    SIGNAGE VIDEO APPENDED AS EVIDENCE: E.Xx

    22. The signage at the site entrance measures 450mm wide by 610mm high containing over 300 words in varying font size and at heights over two meters from the ground, some at first story height did not comply with the requirements of the Code of Practice of the Independent Parking Committee’s ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory.

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: E.Xx
    IPC CODE OF PRACTICE 2016 APPENDED AS EVIDENCE: E.XX
    IPC CODE OF PRACTICE 2017 APPENDED AS EVIDENCE: E.XX

    23. The signage opposite the area where the vehicle was photographed is on the opposite side of the road, approximately 4 meters above ground with very small writing, making it illegible and does not mention what restrictions apply to the section of the road with the double yellow markings

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: E.Xx

    24. The claimant has not supplied to me any part of the contract with the landholder or any other document that demonstrated that PARKING CONTROL MANAGEMENT (UK) LIMITED had their authority to make a claim.

    25. I did not receive a fully completed directions questionnaire from the claimant, they only sent a blank form with additional paperwork that did not answer the questions set out in the DQ.

    CLAIMANTS DQ APPENDED AS EVIDENCE: E.XX

    26. I have yet to receive any documents that the claimant intends to rely upon at the hearing other than what I have already mentioned.

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



    Signed xxxxxxxxxxxxxxxx


    Dated xxxxxxxxxxx
    • nosferatu1001
    • By nosferatu1001 6th Mar 18, 11:35 AM
    • 2,765 Posts
    • 3,443 Thanks
    nosferatu1001
    2 isnt needed
    4 and 5 arent great when read together; you say you cant recall who drov, then categorically state you were not hte driver. the last element of 5 is an ARGUMENT and not a statement of fact.


    6) I would roll that into 4. not only was it more than 1 year ago, but the insurance covers more than one driver AND ADD IN that ANYONe with DOV cover could have driven your vehicle with your permission . State that you were not the driver as a lead in to 4


    9) why is this in a WS? Its more argument. Just state the amount had bene inflated iwhtout any explanation as to the lawful basis for this incresae.


    10) Is this the filing fee? If so the proper place for disputing that was in the defence. You could state to back up your defence disputing of their filing fee something like "this poorly worded partiuclar of cliam, that disclosed no cause of action and had ni significant detail, appears to be identical to the thousands of automatically generated particulars you have seen while researching your defence. It only used X of the 180 characters available, and could not had taken more than 5 miniutes to prepare. You require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced AND PAID.


    12) and 13) the FILING costs ARE recoverable. Are you sure you have not picked this from a BW legal case, where they DO describe costs as "initial legal costs" and to the amount of £64, which is then easily distinguishable from the filing fee


    14) Who cares what you INTEND to do?


    15) you now say £244, not £160... I also dont think it belongs here unles syou are counterclaiming for DPA breach - their breach of KADOE isnt your concern as a defence.


    16) If youre going to mention 2 PCNs - are they different numbers? You need t state exactly what the relevance i of two pcn, and of course, REFERENCE THEM AS EVIDENCE with your initials and a unique reference INLINE to your argument - so two pcn (ref INITIALS/001) and 7 photos (ref INITIALS/002) if you wish to include them. For example, if there are 2 pcn for the same reference but differnet times, state that both cannot be true. etc.


    17) Your conclusion isnt really relevant?


    18) POFA does not disallow double recovery. Thats the job of courts to not allow them to double recover.
    19) What you need to say that, EVEN IF they had met the requirements of POFA to make the Keeper liable - and I notice youve not addressed the validity of the NTK in your WS at all yet, whether they were received in time etc - POFA does not allow them to recover more than the value of the NTK, with no additional charges. You need to deny POFA compliance here, you havent done so yet - obv only if POFA wasnt met!


    POFA is NOT evidence I wouold suggest - its an Act. Take a copy on the day, dont supply them with copies now. See what others such as Jonersh think


    20) there is no "belief" here. DYL on privtae land have NO inherent meaning, and in addition, even IF they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting (to use the TMA2004 verbage) is NOT parking, and IS allowed on public roads covered by DYL so again, IF the driver was boarding /alighting,there would still nbe no breach of any supposed contract, which is denied.


    24) Does this not repeat what you said earlier?


    26) You likely wont, as they will send them on the deadline.


    Just my initials thoughts. See what others suggest.
    • RM_2007
    • By RM_2007 6th Mar 18, 4:20 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Thanks nosferatu1001. Responses below
    2 isnt needed
    Will remove

    4 and 5 arent great when read together; you say you cant recall who drov, then categorically state you were not hte driver. the last element of 5 is an ARGUMENT and not a statement of fact.
    I’ll amend and also remove last element of 5.

    6) I would roll that into 4. not only was it more than 1 year ago, but the insurance covers more than one driver AND ADD IN that ANYONe with DOV cover could have driven your vehicle with your permission . State that you were not the driver as a lead in to 4
    I was not the driver so will stick with that and amend to (rolling 4, 5 and 6 together):
    “Whilst I was the Registered Keeper of the vehicle concerned, there is no evidence of the driver. I deny being the driver at the time of the supposed event. At the time in November 2016, the insurance covered more than one driver, who I have no obligation to name to a private parking firm. Additionally, anyone with Driving other Vehicles cover could have driven the vehicle with my permission. It remains the burden of the Claimant to prove their case.”



    9) why is this in a WS? Its more argument. Just state the amount had bene inflated iwhtout any explanation as to the lawful basis for this incresae.
    Will amend to:
    “The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160”

    10) Is this the filing fee? If so the proper place for disputing that was in the defence. You could state to back up your defence disputing of their filing fee something like "this poorly worded partiuclar of cliam, that disclosed no cause of action and had ni significant detail, appears to be identical to the thousands of automatically generated particulars you have seen while researching your defence. It only used X of the 180 characters available, and could not had taken more than 5 miniutes to prepare. You require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced AND PAID.
    In the POC, it states:
    £160 for the parking charges + interest = £169.76
    £25 court fees
    £50 “Legal representative’s costs”
    Total £244.76

    I did dispute this in my defence and will bring it up in the skeleton defence as well. There seems to be more than 180 characters so I’ll reword to:
    “The Defendant also disputes that the Claimant has incurred £50 solicitor costs. The poorly worded particular of claim, that disclosed no cause of action and had no significant detail, appears to be identical to the thousands of automatically generated particulars I have seen while researching my defence. It only used 80 words, and could not had taken more than 5 minutes to prepare. I require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced and paid”


    12) and 13) the FILING costs ARE recoverable. Are you sure you have not picked this from a BW legal case, where they DO describe costs as "initial legal costs" and to the amount of £64, which is then easily distinguishable from the filing fee
    As listed above, the £50 looks to be on top of the hearing fee – is that the same as the filing fee? If so I will remove points 11, 12 and 13.


    14) Who cares what you INTEND to do?
    Fair point, will reword to:
    “I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress”


    15) you now say £244, not £160... I also dont think it belongs here unles syou are counterclaiming for DPA breach - their breach of KADOE isnt your concern as a defence.
    Amount breakdown listed earlier but will remove the point

    16) If youre going to mention 2 PCNs - are they different numbers? You need t state exactly what the relevance i of two pcn, and of course, REFERENCE THEM AS EVIDENCE with your initials and a unique reference INLINE to your argument - so two pcn (ref INITIALS/001) and 7 photos (ref INITIALS/002) if you wish to include them. For example, if there are 2 pcn for the same reference but differnet times, state that both cannot be true. etc.
    Sorry that should have said two NTK’s. Both with the same reference but have different times (same date).
    “The claimant has failed to properly respond to my request made on 12/05/2017 & 09/06/2017 by royal mail postal service, requesting any documentation and relevant contracts with the land owners that allow the claimant to issue claims upon the landowner’s behalf. My request was not actioned appropriately. I received copies of two NTK’s (Ref xx/E.xx), one of which states the time as 15:25 and the other as 15:58. Both of the NTK’s cannot be true as they state different times. The claimant also included 7 poor quality prints of photographs (Ref xx/E.xx), one of which does not look like any signage in the direct vicinity of where the car was located and of such low quality that the timestamp cannot read.”

    BTW, on the evidence itself, where should I write the unique reference? Along the top or bottom of the documents and as they are multiple pages, should I have a different ref per page?

    17) Your conclusion isnt really relevant?
    I’ll remove the last sentence and leave as:
    “No windscreen ticked was attached to the vehicle at the time. The claimant took photographs but did not place a ticket on the car. Additionally, as far I am aware, there are no uniformed wardens patrolling the site – photographs are taken in a secretive manner.”

    18) POFA does not disallow double recovery. Thats the job of courts to not allow them to double recover.
    I’ll remove part of the sentence and leave as:
    “I did not receive a copy of the contract with the landowner or an answer on whether the charges were based on damages for breach of contract or trespass, nor did I receive a full explanation on how the additional £60 on an £100 charge was calculated, only that it was incurred in facilitating the recovery. This appears to be an added cost with apparently no qualification and an attempt at double recovery”
    19) What you need to say that, EVEN IF they had met the requirements of POFA to make the Keeper liable - and I notice youve not addressed the validity of the NTK in your WS at all yet, whether they were received in time etc - POFA does not allow them to recover more than the value of the NTK, with no additional charges. You need to deny POFA compliance here, you havent done so yet - obv only if POFA wasnt met!


    POFA is NOT evidence I wouold suggest - its an Act. Take a copy on the day, dont supply them with copies now. See what others such as Jonersh think
    I’ll add a para about POFA. In my defence I pointed out that the NTK does not meet all of the requirements – it does not state the duration the vehicle was parked. Other than that I didn’t spot anything else.
    I included POFA in the evidence as it was suggested that the judge may not have a copy of it at hand and it may be useful to include.
    I’ll reword para to:
    “It is denied that the Defendant was the driver of the vehicle and the Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. If the claimant is perusing me as keeper under POFA, then the NTK’s must be fully compliant with POFA schedule 4, which in this case it is expressly denied that both the NTKs are fully compliant as they do not state the duration the vehicle was parked. Additionally each NTK states a different time and both cant be true. Even if the NTK’s had met the requirements of POFA to make the keeper liable, POFA does not allow the claimant to recover more than the value of the NTK, no additional charges are allowed.

    20) there is no "belief" here. DYL on privtae land have NO inherent meaning, and in addition, even IF they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting (to use the TMA2004 verbage) is NOT parking, and IS allowed on public roads covered by DYL so again, IF the driver was boarding /alighting,there would still nbe no breach of any supposed contract, which is denied.
    Last sentence amended to say:
    “Additionally as this is not a public road, double yellow lines on private land have no inherent meaning and in addition, even if they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting is not parking, and is allowed on public roads covered by DYL therefore, if the driver was boarding /alighting, there would still be no breach of any supposed contract, which is denied.”

    24) Does this not repeat what you said earlier?
    I’ll merge with 18

    26) You likely wont, as they will send them on the deadline.
    Amended to:

    “I have yet to receive any documents that the claimant intends to rely upon at the hearing other than what I have already mentioned. I am therefore unable to present a full and proper defence for the claim”
    • RM_2007
    • By RM_2007 6th Mar 18, 10:40 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Updated Witness Statement - new para added (#15, #6 and #23)

    1. I, xxx, of xxx, am the Defendant in this matter, and will say as follows

    2. In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.

    3. Whilst I was the Registered Keeper of the vehicle concerned, there is no evidence of the driver. I deny being the driver at the time of the supposed event. At the time in November 2016, the insurance covered more than one driver, who I have no obligation to name to a private parking firm. Additionally, anyone with Driving other Vehicles cover could have driven the vehicle with my permission. It remains the burden of the Claimant to prove their case.

    4. There was no requirement upon me as keeper to respond to what appeared to be junk mail. No adverse inference can be drawn from my lawful decision to ignore the colourful letter, impersonating a parking ticket yet with no basis in law.

    5. In May 2017 I received a Letter before Claim from the claimant’s solicitors for an inflated amount of £160. I have researched this and discovered that the claimant’s solicitors, Gladstones, have history of issuing robo-claims for 'parking charges' in their thousands.

    6. The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160.


    7. The Defendant also disputes that the Claimant has incurred £50 solicitor costs. The poorly worded particular of claim, that disclosed no cause of action and had no significant detail, appears to be identical to the thousands of automatically generated particulars I have seen while researching my defence. It only used 80 words, and could not had taken more than 5 minutes to prepare. I require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced and paid.

    8. The Defendant has the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt.

    9. Notwithstanding the Defendant's belief, the costs are in any case not recoverable.

    10. The Claimant described the charge of £50.00 "legal representative’s costs" not "contractual costs". CPR 27.14 does not permit these to be recovered in the Small Claims Court.

    11. I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress.

    12. The claimant has failed to properly respond to my request made on 12/05/2017 & 09/06/2017 by royal mail postal service, requesting any documentation and relevant contracts with the land owners that allow the claimant to issue claims upon the landowner’s behalf. My request was not actioned appropriately. I received copies of two NTK’s (Ref RM/E.xx), one of which states the time as 15:25 and the other as 15:58. Both of the NTK’s cannot be true as they state different times. The claimant also included 7 poor quality prints of photographs (Ref RM/E.xx), one of which does not look like any signage in the direct vicinity of where the car was located and of such low quality that the timestamp cannot read.

    CLAIMANTS CORRESPONDENCE APPENDED AS EVIDENCE: RM/E.XX and RM/E.XX

    13. No windscreen ticked was attached to the vehicle at the time. The claimant took photographs but did not place a ticket on the car. Additionally, as far I am aware, there are no uniformed wardens patrolling the site – photographs are taken in a secretive manner.

    14. The claimant has not supplied to me any part of the contract with the landholder or any other document that demonstrated that PARKING CONTROL MANAGEMENT (UK) LIMITED had their authority to make a claim or an answer on whether the charges were based on damages for breach of contract or trespass, nor did I receive a full explanation on how the additional £60 on an £100 charge was calculated, only that it was incurred in facilitating the recovery. This appears to be an added cost with apparently no qualification and an attempt at double recovery.

    15. The claimant did not send me a Letter before Action that complied with the Practice direction on pre-action conduct. The Letter before Action can be seen to miss the following information
    a. A clear summary of facts on which the claim is based.
    b. A list of the relevant documents on which their client intends to rely.
    c. How the “charge amount” of 160 pounds has been calculated and justified.
    d. Any form of possible negotiation or ADR offered

    16. The claim form itself is vague and lacks pertinent information as to the grounds for the claimant’s case. The particulars of claim fail to meet CPR16.4 and PD16 7.3-7.5 and merely provide a date, location, and an "amount" consisting of a completely unsubstantiated and inflated three-figure sum, vaguely and incoherently adduced by the claimant's solicitors and demands payment within 14 days. The claim also states "parking charge " which 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'.


    17. It is denied that the Defendant was the driver of the vehicle and the Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. If the claimant is perusing me as keeper under POFA, then the NTK’s must be fully compliant with POFA schedule 4, which in this case it is expressly denied that both the NTKs are fully compliant as they do not state the duration the vehicle was parked. Additionally each NTK states a different time and both cant be true. Even if the NTK’s had met the requirements of POFA to make the keeper liable, POFA does not allow the claimant to recover more than the value of the NTK, no additional charges are allowed

    POFA APPENDED AS EVIDENCE: RM/E.XX

    18. The claimant’s photographs show the car is parked on a section with double yellow lines. However, there are no upright signs or markings on the kerb on that side of the road indicating any restrictions. The car was not causing any obstructions and the driver would have only stopped there to pick up or drop off something from the school office on that side of the road. Additionally, as this is not a public road, double yellow lines on private land have no inherent meaning and in addition, even if they were to indicate "no parking", there would need to be signs indicating that in the immediate vicinity, and in addition boarding / alighting is not parking, and is allowed on public roads covered by DYL therefore, if the driver was boarding /alighting, there would still be no breach of any supposed contract, which is denied

    LOCATION PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX

    19. I believe the signage on entrance to the site and in the surrounding area parking signage in this matter was, without prejudice to my defence, woefully inadequate and incapable of forming the basis of a contract.

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX
    SIGNAGE VIDEO APPENDED AS EVIDENCE: RM/E.XX

    20. The signage at the site entrance measures 450mm wide by 610mm high containing over 300 words in varying font size and at heights over two meters from the ground, some at first story height did not comply with the requirements of the Code of Practice of the Independent Parking Committee’s ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory.

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX
    IPC CODE OF PRACTICE 2016 APPENDED AS EVIDENCE: RM/E.XX
    IPC CODE OF PRACTICE 2017 APPENDED AS EVIDENCE: RM/E.XX

    21. The signage opposite the area where the vehicle was photographed is on the opposite side of the road, approximately 4 meters above ground with very small writing, making it illegible and does not mention what restrictions apply to the section of the road with the double yellow markings

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/E.XX

    22. I did not receive a fully completed directions questionnaire from the claimant, they only sent a blank form with additional paperwork that did not answer the questions set out in the DQ.

    CLAIMANTS DQ APPENDED AS EVIDENCE: RM/E.XX

    23. The Claimant has sent threatening and misleading demands which stated that further debt recovery action would be taken to recover what is owed by passing the debt to a recovery agent (which suggested to the Defendant they would be calling round like bailiffs) adding further unexplained charges with no evidence of how these extra charges have been calculated.

    CLAIMANTS CORRESPONDENCE APPENDED AS EVIDENCE: RM/E.XX


    24. I have yet to receive any documents that the claimant intends to rely upon at the hearing other than what I have already mentioned. I am therefore unable to present a full and proper defence for the claim.

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


    Dated xxxxxxxxxxx
    • Coupon-mad
    • By Coupon-mad 6th Mar 18, 11:01 PM
    • 58,576 Posts
    • 72,079 Thanks
    Coupon-mad
    Independent Parking Committee ("IPC")
    Nope, they are the International Parking Community nowadays.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • RM_2007
    • By RM_2007 6th Mar 18, 11:30 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Thanks Coupon-Mad. I'll correct. Does everything else look ok now?

    Question on the documents to be sent to Gladstones by post. I have purchased folder separators for the court and my copy of the documents - whilst Gladstones version will be a copy of what I will send to the court, paginated etc, do I need to include separators or can I put their copy (in the correct order) but just loose inside an envelope?
    • Coupon-mad
    • By Coupon-mad 7th Mar 18, 12:29 AM
    • 58,576 Posts
    • 72,079 Thanks
    Coupon-mad
    can I put their copy (in the correct order) but just loose inside an envelope?
    Yes, I would!

    Typo here:
    If the claimant is perusing
    I have only skim read it, so wait for more comments.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • RM_2007
    • By RM_2007 7th Mar 18, 12:42 AM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Thanks again Coupon-mad. I'll amend.

    Nosferatu1001 mentioned and I've just seen a post from Bargepole that said dont include pofa as evidence but have a printed copy at hand should the judge want to see a copy, so I'll remove those references as well.

    Question on Skeleton argument - does that need to be sent in with the Witness statement and evidence (including a copy to Gladstones) or is that submitted later?
    • RM_2007
    • By RM_2007 7th Mar 18, 12:56 AM
    • 92 Posts
    • 44 Thanks
    RM_2007
    First draft of the Skeleton Argument. Went through the defense and pulled out main arguments. I mention J Spurling v Bradshaw [1956] EWCA Civ 3 in the defence - do I need to include that as evidence?

    SKELETON ARGUMENT FOR THE CLAIMANT (Litigant in person)

    The defendant will rely on the following submissions:

    Failure to set out clear parking terms:


    1. The signs erected on site are incapable of forming the basis of a contract and indeed make it clear that that is not the case. Further it is trite law that a term that is forbidding cannot also constitute an offer.

    2. The Defendant avers that the parking signage in this matter was, without prejudice to his/her primary defence above, woefully inadequate. The signage at the site entrance measures 450mm wide by 610mm high containing over 300 words in varying font size and at heights over two meters from the ground, some at first story height.

    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/xxx to RM/xxx.

    3. The Defendant relies upon ParkingEye Ltd v Barry Beavis (2015) UKSC 67 insofar as the Court were willing to impose a penalty in the context of a site of commercial value and where the signage regarding the penalties imposed for any breach of parking terms were clear - both upon entry to the site and throughout. Should the claimant rely on the case of ParkingEye v Beavis, I wish to point out that there is a test of good faith which in this case was not one of fair and open dealings.

    4. My case can be distinguished from the Beavis case, which was dependent upon Mr Beavis being the driver who accepted a clear contract, formed by unusually prominent signage. Strict compliance with the BPA Code of Practice and the clear, prominent terms on brief signs was held to be paramount. None of this applies in this material case.

    PARKINGEYE LTD V BARRY BEAVIS SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/XXX

    5. The signage did not comply with the requirements of the Code of Practice of the International Parking Community’s ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory; and contained particularly onerous terms not sufficiently drawn to the attention of the visitor.
    IPC doc APPENDED AS EVIDENCE: RM/XXX
    J Spurling v Bradshaw [1956] EWCA Civ 3 appended as evidence

    6. The claimant are not the landowners, merely an agent and cannot pursue the defendant for trespass
    PCM vs Bull appended as evidence

    7. The signage does not mention the double yellow lines, where the vehicle was photographed. Additionally there are no signs on the side of the road the car was located to indicate any yellow line restrictions.
    SIGNAGE PHOTOGRAPHS APPENDED AS EVIDENCE: RM/xxx

    Failure to be compliant with POFA

    8. It is denied that the Defendant was the driver of the vehicle and the Claimant is put to strict proof.

    9. The Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. The Defendant avers that the Claimant is therefore limited to pursuing the keeper in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 ("POFA")

    10. Before seeking to rely on the keeper liability provisions of Schedule 4 POFA the Claimant must demonstrate that there was a ‘relevant obligation’ either by way of a breach of contract, trespass or other tort; and that it has followed the required deadlines and wording as described in the Act to transfer liability from the driver to the registered keeper. It is not admitted that the Claimant has complied with the relevant statutory requirements.


    11. The Claimant or the Claimant’s representatives, Gladstones, have artificially inflated the value of the Claim from £100 to £160. This appears to be an added cost with apparently no qualification and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.

    12. The original NTK (ref RM/xxx) posted by this Claimant states a Full Charge of £100.00 (£60.00 discounted). The second NTK (Ref RM/xxx) states a full charge of £100 however the Claimant's legal firm now inflates these sums, in a deliberate or negligent attempt at more than double recovery:
    a. £160.00 Principal debt
    b. Interest £9.76
    c. Legal representative’s costs £50
    d. Outstanding balance to pay now £244.76

    13. The driver did not enter into any 'agreement on the charge', no consideration flowed between the parties and no contract was established.

    14. The Defendant denies that the driver would have agreed to pay the original demand of £100 to agree to the alleged contract had the terms and conditions of the contract been properly displayed and accessible.

    15. The claimant has failed to serve a fully compliant NTK. The NTK’s sent to the defendant do not contain the duration the vehicle is stated to have been parked, which POFA requires. Furthermore, the two NTK’s state different timings, 31 minutes apart, again demonstrating the claimant’s failure to comply with POFA schedule 4, Paragraph 9 (2) (a) which states that the NTK must “specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates”. Furthermore both NTK’s cannot be true if they specify different timings.

    NTK’s APPENDED AS EVIDENCE: RM/xxx
    16. The claimant cannot to rely on Elliot v Loake ('EvL') to claim that the driver and the keeper can be 'assumed' to be the same, however that was a criminal case and referred to the owner, not the keeper. In any event, in EvL there was overwhelming forensic evidence from other sources that the defendant was the driver at the time. By contrast, in my case this Claimant has not offered any evidence to the driver's identity and cannot make any lawful assumption.

    17. The vital matter of 'keeper liability' regarding the law when parking on private land was confirmed by parking law expert barrister, Henry Greenslade, the previous POPLA Lead Adjudicator, in 2015 in the Annual Report where he stated:

    18. “There is no reasonable presumption in law that the registered keeper of a vehicle is the driver. Operators should never suggest anything of the sort. Further, a failure by the recipient of a notice issued under Schedule 4 to name the driver, does not of itself mean that the recipient has accepted that they were the driver at the material time. Unlike, for example, a Notice of Intended Prosecution where details of the driver of a vehicle must be supplied when requested by the police, pursuant to Section 172 of the Road Traffic Act 1988, a keeper sent a Schedule 4 notice has no legal obligation to name the driver. [...] If... {POFA 2012 Schedule 4 is}... not complied with then keeper liability does not generally pass."

    POPLA ANNUAL REPORT 2015 APPENDED AS EVIDENCE: RM/xxx

    19. Therefore, no lawful right exists to pursue unpaid parking charges from myself as keeper of the vehicle, where an operator is unable to transfer the liability for the charge using the POFA.

    No Standing

    20. The claimant is not the not the lawful occupier of the land. I have the reasonable belief that the Claimant has no locus standi at the time of this parking event and at best, were contractors of a principal, the landowner. They have failed to show a cause for action by way of sight of a copy of the contract they have with the landowner to assign the right to enter into contracts with the public and to make claims and take civil action against drivers in their own name.

    Wholly unreasonable and vexatious claim

    21. It is submitted that the conduct of the Claimant in pursuing this claim is wholly unreasonable and vexatious. The Court is invited to take Judicial Notice of the fact that the Claimant's solicitors, Gladstones, is engaged in a course of conduct which involves issuing tens of thousands of totally meritless Claims, which are routinely dismissed by District Judges sitting in this Court, and other County Court hearing centres in all parts of England & Wales.

    22. It is noted that in view of all of the above, the Court could decide of its own volition to strike this claim out under CPR 16.4 and as an unrepresented Defendant I ask the presiding Judge to use their case management powers and relieve me of the burden of having to appear to defend myself as registered keeper, in view of the Claimant having supplied no evidence of any basis for a claim against me in law.


    I believe that the facts stated in this Skeleton Defence are true.



    Signed xxxxxxxxxxxxxxxx


    Dated xxxxxxxxxxx
    • nosferatu1001
    • By nosferatu1001 7th Mar 18, 8:43 AM
    • 2,765 Posts
    • 3,443 Thanks
    nosferatu1001
    Look back at your claim form

    Does it state £50 cost to file the claim IN ADDITION TO the £50 mentioned in the PoC? The cost to file a claim is based on amount, and is set by the court. This is payable to the court. In addition, IF you use a solicitor to prepare the claim filing, you can claim UP TO £50 for the solicitor to do so.

    Correction on my part 0- i think it allows 1080 char. So count how many - i think they tend to use about 500 max. What this does is set them up to struggle to rebut your assertion they cant have spent £50 on it NOR provided a cause of action because - in their terms - the box on MCOL isnt very big. You state that while space is limited, they didnt even use all the space they had, AND there was nothing stopping them serving separate particulars of claim IF that was necessary to demonstrate a clear cause of action. They took neither action.
    • RM_2007
    • By RM_2007 7th Mar 18, 10:09 AM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Good morning nosferatu1001

    Looking at the front of the claim form, the PoC section only mentions £160 for "parking charges/damages and indemnity if applicable and interest of £9.76"

    The important notes section lists as follows:

    Amount claimed: £169.76
    Court Fee: £25
    Legal Representative's costs: £50
    Total amount £244.76

    I cant see any other mention for filing a claim. pages 2, 3 and 4 are for responding but checked those as well.

    Correction on my part 0- i think it allows 1080 char. So count how many - i think they tend to use about 500 max. What this does is set them up to struggle to rebut your assertion they cant have spent £50 on it NOR provided a cause of action because - in their terms - the box on MCOL isnt very big. You state that while space is limited, they didnt even use all the space they had, AND there was nothing stopping them serving separate particulars of claim IF that was necessary to demonstrate a clear cause of action. They took neither action.
    its 502 words so I'll amend my para to say:

    "7. The Defendant also disputes that the Claimant has incurred £50 solicitor costs. The poorly worded particular of claim, that disclosed no cause of action and had no significant detail, appears to be identical to the thousands of automatically generated particulars I have seen while researching my defence. It only used 502 characters of the 1080 characters available, and could not had taken more than 5 minutes to prepare. I require an explanation as to how £50 of actual solicitor time was spent, and require proof it was invoiced and paid."
    • nosferatu1001
    • By nosferatu1001 7th Mar 18, 11:59 AM
    • 2,765 Posts
    • 3,443 Thanks
    nosferatu1001
    That £50 is the fee for filing the claim> So you cannot include anything about the £50 not being claimable - it IS claimable. However it is only for provable time spent on filing the claim, and there is no way they spent more than 5 monutes doing tha t- its standard wording (you can find multiple examples) with about 4 details changed.
    • RM_2007
    • By RM_2007 7th Mar 18, 2:33 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    "According to Ladak v DRC Locums UKEAT/0488/13/LA the claimant can only recover the direct and!provable!costs of the!time!spent!on preparing the claim in a legal capacity, not any administration cost"

    Is this what you meant nosferatu1001?
    • nosferatu1001
    • By nosferatu1001 7th Mar 18, 2:58 PM
    • 2,765 Posts
    • 3,443 Thanks
    nosferatu1001
    Yes, minus the weird formatting
    So you put them to strict proof thayt the £50 ewqas invoiced and paid, and a breakdown of the actual logged solicitor time. Then you ask them to prove how many claims they file a day, and how many staff they have....
    • RM_2007
    • By RM_2007 7th Mar 18, 4:21 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Thank you.

    Witness statement reworded para 7 and will leave in para 8:

    "7. The Defendant also disputes that the Claimant has incurred £50 solicitor costs. The poorly worded particular of claim, that disclosed no cause of action and had no significant detail, appears to be identical to the thousands of automatically generated particulars I have seen while researching my defence. It only used 502 characters of the 1080 characters available, and could not had taken more than 5 minutes to prepare. According to Ladak v DRC Locums UKEAT/0488/13/LA the claimant can only recover the direct and provable costs of the time spent on preparing the claim in a legal capacity, not any administration cost. I require an explanation as to how £50 of actual solicitor time was spent, and the claimant is put to the strictest proof that it was invoiced and paid.

    8. The Defendant has the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt."

    Will remove para 9 and 10

    "9. Notwithstanding the Defendant's belief, the costs are in any case not recoverable.

    10. The Claimant described the charge of £50.00 "legal representative’s costs" not "contractual costs". CPR 27.14 does not permit these to be recovered in the Small Claims Court."

    Hopefully I got this right.

    Does this mean I need to include "Ladak v DRC Locums UKEAT/0488/13/LA " in the evidence?

    A few more questions -

    1: Do I include the skeleton argument in this pack to Galdstones and the court now or is that sent later?
    2: My cost/expenses schedule - do I need to include that as well?
    • RM_2007
    • By RM_2007 7th Mar 18, 8:08 PM
    • 92 Posts
    • 44 Thanks
    RM_2007
    Copy of what I have in my pack to send to the court and Gladstones (Once Witness Statement is finalised).

    Do I need to include the defence statement since the court will already have that?
    Do I need to include any other court doc - such as the notice of allocation?
    I've included an extract of the POPLA report rather than the full 44 pages - is that acceptable?
    IF i need to include the skeleton argument and my cost schedule now, would that go into section 2?

    Pack details below:

    Section 1
    • Claim form (Inc Particulars of Claim)
    • Defence Statement


    Section 2
    • Witness Statement


    Section 3
    • NTK 1 (10th November 2016) Exhibit RM/E.01
    • NTK 2 (16th December 2016) Exhibit RM/E.02
    • DEBT COLLECTION LETTER 1 (16th January 207) Exhibit RM/E.03
    • DEBT COLLECTION LETTER 2 (6th February 2017) Exhibit RM/E.04
    • GLADSTONES FINAL REMINDER (10TH April 2017) Exhibit RM/E.05
    • GLADSTONES LBC (2ND May 2017) Exhibit RM/E.06
    • DEFENDANTS RESPONSE TO LBC (12TH May 2017) Exhibit RM/E.07
    • GLADSTONES RESPONSE TO DEFENDANT (2nd June 2017) Exhibit RM/E.08
    • DEFENDANTS RESPONSE TO GLADSTONE (9th June 2017) Exhibit RM/E.09
    • GLADSTONES RESPONSE TO DEFENDANT (15th August 2017) Exhibit RM/E.10
    • GLADSTONES RESPONSE TO DEFENDANT (15th August 2017) - COPY OF NTK!!!8217;S Exhibit RM/E.11
    • GLADSTONES RESPONSE TO DEFENDANT (15th August 2017) - PHOTOS Exhibit RM/E.12
    • GLADSTONE COPY OF DIRECTIONS QUESTIONNAIRE (24TH OCTOBER 2017) Exhibit RM/E.13
    • DEFENDANTS COPY OF DIRECTIONS QUESTIONNAIRE (11TH November 2017) Exhibit RM/E.14
    • PCM vs BULL Exhibit RM/E.15
    • IPC CODE OF PRACRICE 2016 Exhibit RM/E.16
    • PARKINGEYE LTD V BARRY BEAVIS SIGNAGE PHOTOGRAPHS Exhibit RM/E.17
    • POPLA ANNUAL REPORT 2015 EXTRACT Exhibit RM/E.18
    • DEFENDANTS PHOTOGRPHS OF THE SITE Exhibit RM/E.19
    • DEFENDANTS VIDEO AND ELECTRONIC PHOTOGRAPHS OF THE SITE Exhibit RM/E.20
    Last edited by RM_2007; 07-03-2018 at 8:20 PM.
    • RM_2007
    • By RM_2007 8th Mar 18, 8:40 AM
    • 92 Posts
    • 44 Thanks
    RM_2007
    updated contents..hopefully this the right things to include

    Section 1
    • Claim form (Inc Particulars of Claim)
    • Skeleton Arguments
    • Defence Statement

    Section 2
    • Witness Statement

    Section 3
    • NTK 1 (10th November 2016) Exhibit RM/E.01
    • NTK 2 (16th December 2016) Exhibit RM/E.02
    • DEBT COLLECTION LETTER 1 (16th January 207) Exhibit RM/E.03
    • DEBT COLLECTION LETTER 2 (6th February 2017) Exhibit RM/E.04
    • GLADSTONES FINAL REMINDER (10TH April 2017) Exhibit RM/E.05
    • GLADSTONES LBC (2ND May 2017) Exhibit RM/E.06
    • DEFENDANTS RESPONSE TO LBC (12TH May 2017) Exhibit RM/E.07
    • GLADSTONES RESPONSE TO DEFENDANT (2nd June 2017) Exhibit RM/E.08
    • DEFENDANTS RESPONSE TO GLADSTONE (9th June 2017) Exhibit RM/E.09
    • GLADSTONES RESPONSE TO DEFENDANT (15th August 2017) Exhibit RM/E.10
    • GLADSTONES RESPONSE TO DEFENDANT (15th August 2017) - COPY OF NTK’S Exhibit RM/E.11
    • GLADSTONES RESPONSE TO DEFENDANT (15th August 2017) - PHOTOS Exhibit RM/E.12
    • GLADSTONE COPY OF DIRECTIONS QUESTIONNAIRE (24TH OCTOBER 2017) Exhibit RM/E.13
    • DEFENDANTS COPY OF DIRECTIONS QUESTIONNAIRE (11TH November 2017) Exhibit RM/E.14
    • PCM vs BULL Exhibit RM/E.15
    • IPC CODE OF PRACRICE 2016 Exhibit RM/E.16
    • PARKINGEYE LTD V BARRY BEAVIS SIGNAGE PHOTOGRAPHS Exhibit RM/E.17
    • POPLA ANNUAL REPORT 2015 EXTRACT Exhibit RM/E.18
    • DEFENDANTS PHOTOGRPHS OF THE SITE Exhibit RM/E.19
    • DEFENDANTS VIDEO AND ELECTONIC PHOTOGRAPHS OF THE SITE Exhibit RM/E.20
    • J SPURLING V BRADSHAW [1956] EWCA CIV 3 Exhibit RM/E.21
Welcome to our new Forum!

Our aim is to save you money quickly and easily. We hope you like it!

Forum Team Contact us

Live Stats

178Posts Today

1,629Users online

Martin's Twitter
  • Ah these care free days of watching #ENG score 5 goals in the first half of a World Cup match. It reminds me of... Never.

  • Then it should be. It's not some accident. It's deliberate grappling https://t.co/UxVTuUSNio

  • Penalty yes but time someone was sent off for these wrestling moves #WorldCup

  • Follow Martin