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  • FIRST POST
    • Inapickle01
    • By Inapickle01 23rd Oct 17, 1:06 PM
    • 18Posts
    • 3Thanks
    Inapickle01
    County court claim..defence?
    • #1
    • 23rd Oct 17, 1:06 PM
    County court claim..defence? 23rd Oct 17 at 1:06 PM
    Am I able to defend a county court claim against Horizon Parking or should I just pay?
    There are 6 charges on this claim form! Stupid I know.
    I don’t have any of the original letters as they’re from 2014/early2015 and I listened to the ‘just ignore’ advice. I vaguely remember receiving the first ones but have had absolutely no correspondence recently.
    Do I stand a chance with a defence when it’s multiple charges ?
Page 2
    • Inapickle01
    • By Inapickle01 17th Jun 18, 10:28 PM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    I,(name) of (address) WILL SAY AS FOLLOWS:


    It is acknowledged that the defendant, (name) was the registered keeper of the vehicle. 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.

    The claim is denied in its entirety. I assert that I am not liable to the Claimant for the sum claimed, or any amount at all, for the following reasons and this is my Witness Statement in support of my defence as already filed.

    Presumption of the Registered Keeper as the Driver

    1. It is admitted that I was the authorised registered keeper of the vehicle in
    question at the time of the alleged incident. I was not the driver of the vehicle
    so have no knowledge of the events, or signage terms on the date in
    question and the Claimant did not identify the driver.

    2. The Claimant states that they are pursuing me as the driver. They presume I am the driver because I was the registered keeper of the vehicle.

    i. As quoted on pages 12 & 13 in the POPLA annual report 2015 by PATAS and POPLA Lead Adjudicator and Barrister Henry Michael Greenslade;
    Exhibit 1 – page 14.



    “Keeper Liability
    The person who may be liable for a charge arising out of the presence of a vehicle on private land is the person who last caused the vehicle to be at rest in that position, that is the ‘driver’.
    There is no ‘reasonable presumption’ in law that the registered keeper is the driver.”

    3. Protection of Freedoms Act 2012, Schedule 4, Paragraph 6, Exhibit 2 – page 15, states;
    6 (1) The second condition is that the creditor (or a person acting for or on behalf of the creditor)—
    (a) has given a notice to driver in accordance with paragraph 7, followed by a notice to keeper in accordance with paragraph 8; or
    (b) has given a notice to keeper in accordance with paragraph 9.
    This only allows the Claimant to pursue the registered keeper for parking charges where they serve a Notice to Driver AND Notice to Keeper.


    Signage and Contracts

    4. The signs are unclear and unreadable from inside a vehicle. They are also placed too high to be able to read the small print. The parking charge is hidden within the small print, it is not a clear and prominent charge.

    i. The claimant has provided photographic evidence of the signage in their bundle on pages 12, 13, 14 & 15. These photographs have been resized which gives false illusions.
    Exhibit’s 3-13 - pages 16-26 are full, unsized versions of the signage.

    ii. No prominent signage is displayed at the entrance of the area.
    Please see Exhibit’s 3 & 4 - pages 16 & 17.

    iii. Although there are numerous signs present they are mounted too high and are difficult to read from a vehicle or standing height due to their height and text size.
    Exhibit 5 - page 18 is a photograph of a sign taken from sitting in the driver’s seat.
    Exhibit 6 - page 19 is a photograph of a sign taken after exiting the vehicle.

    iv. The claimant relies on the case of Parking Eye -v- Beavis [2015] stating it was accepted as an established principle that a valid contract can be made by an offer in the form of the terms and conditions set out on the sign and accepted by the driver’s actions as prescribed therein.
    The Defendant argues that;
    A. Parking Eye and Horizon have very different signage.
    Exhibit 14 - page 27 is a copy of the sign Parking Eye submitted to the Supreme Court regarding the Beavis case.
    Part E, Schedule 1 of the Code of Practise of the Independent Parking Committee, Exhibit 18 – pages 31-33, clearly states that;
    “Text should be of such a size and in a font that can easily be read by a motorist having regard to the likely position of the motorist in relation to the sign.”
    I have included three more Parking Eye signs from various sites, Exhibit 15 - page 28, for comparison.

    B. As outlined in points i-iii clear signage was not displayed for any driver to view and agree to and therefore a contract has not been formed.

    v. The Consumer Rights Act 2015.
    A. Section 68 outlines a requirement for transparency for contracts. Exhibit 19 – pages 34-35.
    68 Requirement for transparency
    (1)A trader must ensure that a written term of a consumer contract, or a consumer notice in writing, is transparent.
    (2)A consumer notice is transparent for the purposes of subsection (1) if it is expressed in plain and intelligible language and it is legible.

    B. Section 62, Exhibit 20 – pages 35-36, states;
    62 Requirement for contract terms and notices to be fair
    (1) An unfair term of a consumer contract is not binding on the consumer.
    (2) An unfair consumer notice is not binding on the consumer.
    The defendant argues that as the signs are too high and text too small, they are not adequate nor legible. Therefore, they do not meet the Consumer Rights Act 2015 requirements for transparency and as such are an unfair consumer notice.
    vi. The claimant states that in the unlikely event the Defendant did not see the signs they ought to have done so. The Claimant uses the case Vine v London Borough of Waltham Forrest 2000 to assert that once it is established that sufficient and adequate warning notices were in place, a car driver cannot be heard to say that he or she did not see the notice.
    The Defendant argues that;
    A. The Defendant has not been established as the driver, so it is irrelevant whether the Claimant feels the defendant has seen the signs or not.
    B. The Defendant has already demonstrated in points i-v that sufficient and adequate warning notices were not in place. Therefore, the observation that Lord Justice Roch made in the case of Vine v London Borough of Waltham Forrest 2000 supports the Defendant’s Case that the driver may not have seen the signage.
    As the claimant has not displayed clear signage no contract can be formed with the driver of the vehicle.
    5. In relation to charges; xx,xx,xx&xx the Claimant has stated that their signs have made it clear that a valid permit must be displayed. As shown in Exhibit 17 – page 30 this area is predominantly controlled by Euro Car Parks who also issue permits.
    The Defendant argues that the signage is ambiguous and does not clarify whether it is a permit bay for the land controlled by Horizon or the land controlled by Euro Car Parks.
    This sign can be seen in Exhibit 13 - page 26.

    6. Page 17 of the claimant’s bundle is a birds-eye view of the whole car park. Exhibits 16 – page 29.
    Page 18 is a clearer birds-eye view of the car park indicating the section that is not controlled by Horizon themselves but is controlled by Euro Car Parks.
    Exhibits 17 – page 30.
    The Defendant argues that the Claimant has not provided any evidence of where, specifically, in the car park the vehicle was parked at the times of the alleged incidents.

    Excessive Charges

    7. The Claimant states that as the Defendant has not paid the charge within 28 days they have breached the contract. They state that the breach of contract entitles the innocent party to damages in addition to the charges.
    The Defendant argues that;
    i. The Defendant has no contract with the Claimant as they are not the driver.
    ii. The Defendant has shown how no contract could have been formed with the driver due to inadequate and improper signage.
    iii. As no contract has been breached the Claimant cannot be due damages for breaching a contract.

    8. It does not state on any sign, PCN or Reminder Notice that the charge will increase to £120. It is suggested that this is nothing but a means of artificially inflating the value of the claim.

    9. The Claimant argues that the charge sought is in line with the British Parking Association’s Code of Practise who prescribe a maximum charge of £100. The Claimant then states that the company’s charges are within this level and are therefore not excessive.
    The Defendant argues that;
    i. The charge sought here is £120 per invoice which is higher than the ATA prescription.
    ii. The charge of £120 per invoice is excessive and has not been ruled otherwise in any case including Parking Eye -v- Beavis 2015 and therefore should not be allowed.

    Statement of Truth
    I believe that the facts stated in this Witness Statement are true.
    Dated; Tuesday 19th June 2018
    To the court and
    to the Claimant
    ..........................
    (name)
    Defendant
    • KeithP
    • By KeithP 17th Jun 18, 10:34 PM
    • 10,600 Posts
    • 10,983 Thanks
    KeithP
    I!!!8217;ve just tried to upload a photo via tiny pic. I have the web address but I am unable to post here as I am new.
    I changed the h t t p to h x x p and it still won!!!8217;t allow me to post.
    It would be great if you could see the pic. Especially the ones of the way they have squished the signs.
    Originally posted by Inapickle01
    What's needed is a little bit of initiative.

    I just used the forum search facility and searched for tinypic.

    Within the first dozen or so posts returned I found this one, posted just last Wednesday:

    Does that help you at all?
    Last edited by KeithP; 17-06-2018 at 10:56 PM.
    .
    • Coupon-mad
    • By Coupon-mad 17th Jun 18, 10:46 PM
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    Coupon-mad
    Don't refer to 'excessive charges' in a heading, makes it open to the Claimant to refer to the Supreme Court decision in ParkingEye v Beavis, and kill any such argument.

    Don't have 'the Defendant this, the Defendant that'. Your WS should be your story of what happened, so ''I''. And remove the swathes of quotes from things like the Consumer Rights Act...that isn't the sort of thing to have in a WS.

    And it needs evidence, such as photos and case transcripts that support your case.

    6 (1) The second condition is that the creditor (or a person acting for or on behalf of the creditor):
    (a) has given a notice to driver in accordance with paragraph 7, followed by a notice to keeper in accordance with paragraph 8; or
    (b) has given a notice to keeper in accordance with paragraph 9.
    This only allows the Claimant to pursue the registered keeper for parking charges where they serve a Notice to Driver AND Notice to Keeper.
    The above in blue is not true; under para 9 there is no NTD.

    What are these PCNs even about? Overstay? No permit? Where, retail park?

    Was there a NTD, or just a postal PCN (NTK)? Was the NTK on EACH and EVERY case received by day 14 and was it worded so as to hold the keeper liable every time?
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
    Main site>>Forums>Household & Travel>Motoring>Parking Tickets Fines & Parking - read the NEWBIES THREAD
    • Inapickle01
    • By Inapickle01 18th Jun 18, 8:13 AM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    Thank you Keith. I will do that when I get home.

    Thank you coupon, will amend and repost.

    It is a supermarket car park that is next to a hospital. A small section of the car park is leased to the hospital which is controlled by ECP and not Horizon (will attach map).
    6 PCNs
    1 - no ticket displayed
    1 - ticket expired
    4 - no permit.
    Within the ECP controlled area there is 1 row that belongs to the supermarket. It does say permit holders but it doesn't say whether it is permits for ECP or supermarket.

    Each ticket has, copy of the PCN that was on the window, a reminder notice and photographs of the vehicle. It states that if I was not the keeper/driver at the time they ask to inform them of their details.

    I was hoping my partner could speak on my behalf, easier at things like this than I am. Does the lay rep document go with the bundle or on the day? I have read mixed answers.
    Thank you
    • Inapickle01
    • By Inapickle01 18th Jun 18, 9:27 AM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    http://i63.tinypic.com/bgww93.jpg
    • Inapickle01
    • By Inapickle01 18th Jun 18, 9:52 AM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    Brilliant. That worked.

    I'll upload them now. These are all my photos except the maps which are the claimants. I have taken more than one photo of the signs - I'll post one of each example here. They are all included in my WS. I can upload them all if you require?

    The above link ( http://i63.tinypic.com/bgww93.jpg ) is the birds eye view of the whole car park.

    http://i63.tinypic.com/k3t2ww.jpg - closer view of the top area covered by ECP

    http://i64.tinypic.com/20qezxx.jpg - permit sign

    http://i64.tinypic.com/2ppihb8.jpg - entrance sign photo. There are two entrances, both signs are the same as this and I have included both in my WS. Claimant has not included any entrance signs.

    http://i66.tinypic.com/300rv4y.jpg - close view of the sign. I had to take this holding my phone up at an angle

    http://i67.tinypic.com/23k3f9l.jpg - sign

    http://i65.tinypic.com/15ceuye.jpg - sign

    http://i66.tinypic.com/ehc9lh.jpg - claimants version of the same sign
    • Coupon-mad
    • By Coupon-mad 18th Jun 18, 12:15 PM
    • 63,839 Posts
    • 76,487 Thanks
    Coupon-mad
    Does the lay rep document go with the bundle or on the day?
    You just take a copy of the Lay Reps Right of Audience Order, on the day:

    http://www.legislation.gov.uk/uksi/1999/1225/made

    Tell the court clerk you are there as a lay rep, and say ''no'' if they assume McKenzie friend (the latter cannot speak for the Defendant, whereas a lay rep has that right, as long as the D is also there with them).
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
    Main site>>Forums>Household & Travel>Motoring>Parking Tickets Fines & Parking - read the NEWBIES THREAD
    • Inapickle01
    • By Inapickle01 18th Jun 18, 9:59 PM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    I (name) of (address) WILL SAY AS FOLLOWS:


    It is acknowledged that I, (name) was the registered keeper of the vehicle. 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.

    The claim is denied in its entirety. I assert that I am not liable to the Claimant for the sum claimed, or any amount at all, for the following reasons and this is my Witness Statement in support of my defence as already filed.

    Presumption of the Registered Keeper as the Driver

    1. It is admitted that I was the authorised registered keeper of the vehicle in question at the time of the alleged incident. I was not the driver of the vehicle so have no knowledge of the events, or signage terms on the date in
    question and the Claimant did not identify the driver.

    2. The Claimant states that they are pursuing me as the driver. They presume I am the driver because I was the registered keeper of the vehicle.

    i. As quoted on pages 12 & 13 in the POPLA annual report 2015 by PATAS and POPLA Lead Adjudicator and Barrister Henry Michael Greenslade;
    Exhibit 1 !!!8211; page 14.



    !!!8220;Keeper Liability
    The person who may be liable for a charge arising out of the presence of a vehicle on private land is the person who last caused the vehicle to be at rest in that position, that is the !!!8216;driver!!!8217;.
    There is no !!!8216;reasonable presumption!!!8217; in law that the registered keeper is the driver.!!!8221;

    3. Protection of Freedoms Act 2012, Schedule 4, Paragraph 6, Exhibit 2 !!!8211; page 15, states;
    6 (1) The second condition is that the creditor (or a person acting for or on behalf of the creditor)!!!8212;
    (a) has given a notice to driver in accordance with paragraph 7, followed by a notice to keeper in accordance with paragraph 8; or
    (b) has given a notice to keeper in accordance with paragraph 9.


    Signage and Contracts

    4. The signs are unclear and unreadable from inside a vehicle. They are also placed too high to be able to read the small print. The parking charge is hidden within the small print, it is not a clear and prominent charge.

    i. The claimant has provided photographic evidence of the signage in their bundle on pages 12, 13, 14 & 15. These photographs have been resized which gives false illusions.
    Exhibit!!!8217;s 3-13 - pages 16-26 are full, unsized versions of the signage.

    ii. No prominent signage is displayed at the entrance of the area.
    Please see Exhibit!!!8217;s 3 & 4 - pages 16 & 17.

    iii. Although there are numerous signs present they are mounted too high and are difficult to read from a vehicle or standing height due to their height and text size.
    Exhibit 5 - page 18 is a photograph of a sign taken from sitting in the driver!!!8217;s seat.
    Exhibit 6 - page 19 is a photograph of a sign taken after exiting the vehicle.

    iv. The claimant relies on the case of Parking Eye -v- Beavis [2015] stating it was accepted as an established principle that a valid contract can be made by an offer in the form of the terms and conditions set out on the sign and accepted by the driver!!!8217;s actions as prescribed therein.
    I argue that;
    A. Parking Eye and Horizon have very different signage.
    Exhibit 14 - page 27 is a copy of the sign Parking Eye submitted to the Supreme Court regarding the Beavis case.
    Part E, Schedule 1 of the Code of Practise of the Independent Parking Committee, Exhibit 18 !!!8211; pages 31-33, clearly states that;
    !!!8220;Text should be of such a size and in a font that can easily be read by a motorist having regard to the likely position of the motorist in relation to the sign.!!!8221;
    I have included three more Parking Eye signs from various sites, Exhibit 15 - page 28, for comparison.

    B. As outlined in points 4.i-4.iii clear signage was not displayed for any driver to view and agree to and therefore a contract has not been formed.

    v. The claimant states that in the unlikely event that I did not see the signs I ought to have done so. The Claimant uses the case Vine v London Borough of Waltham Forrest 2000 to assert that once it is established that sufficient and adequate warning notices were in place, a car driver cannot be heard to say that he or she did not see the notice.
    I argue that;
    A. I have not been established as the driver, so it is irrelevant whether the Claimant feels I have seen the signs or not.
    B. I have demonstrated in points i-v that sufficient and adequate warning notices were not in place. Therefore, the observation that Lord Justice Roch made in the case of Vine v London Borough of Waltham Forrest 2000 supports my case that the driver may not have seen the signage.
    As the Claimant has not displayed clear signage no contract can be formed with the driver of the vehicle.
    5. In relation to charges; xx xx xx & xx the Claimant has stated that their signs have made it clear that a valid permit must be displayed. As shown in Exhibit 17 !!!8211; page 30 this area is predominantly controlled by Euro Car Parks who also issue permits.
    I argue that the signage is ambiguous and does not clarify whether it is a permit bay for the land controlled by Horizon or the land controlled by Euro Car Parks.
    This sign can be seen in Exhibit 13 - page 26.

    6. Page 17 of the claimant!!!8217;s bundle is a birds-eye view of the whole car park. Exhibits 16 !!!8211; page 29.
    Page 18 is a clearer birds-eye view of the car park indicating the section that is not controlled by Horizon themselves but is controlled by Euro Car Parks.
    Exhibits 17 !!!8211; page 30.
    I argue that the Claimant has not provided any evidence of where, specifically, in the car park the vehicle was parked at the times of the alleged incidents.

    Charges

    7. The Claimant states that as I have not paid the charge within 28 days I have breached the contract. They state that the breach of contract entitles the innocent party to damages in addition to the charges.

    I argue that;
    i. I have no contract with the Claimant as I was not the driver.
    ii. I have shown how no contract could have been formed with the driver due to inadequate and improper signage.
    iii. As no contract has been breached the Claimant cannot be due damages for breaching a contract.

    8. It does not state on any sign, PCN or Reminder Notice that the charge will increase to £120. It is suggested that this is nothing but a means of artificially inflating the value of the claim.

    9. The Claimant argues that the charge sought is in line with the British Parking Association!!!8217;s Code of Practise who prescribe a maximum charge of £100.
    Exhibit 19 !!!8211; page 33, point 19.5
    The Claimant then states that the company!!!8217;s charges are within this level and are therefore not excessive.
    I argue that;
    i. The charge sought here is £120 per invoice which is higher than the BPA prescription.
    ii. The charge of £120 per invoice is excessive and has not been ruled otherwise in any case including Parking Eye -v- Beavis 2015 and therefore should not be allowed.



    Statement of Truth



    In regards to "excessive charges" would I be better completely removing point 9ii?

    I have included sections of relevant documents.
    For example; BPA Code of Practise. The whole document is 46 pages long. Would I enter the whole document as my exhibit and specify the page/point or just the section I am referring to? At present I have included just the extract I am referring to.

    Thank you
    • Inapickle01
    • By Inapickle01 18th Jun 18, 10:00 PM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    I have switched off smart punctuation I don't know why it's still doing that. I apologise
    • Inapickle01
    • By Inapickle01 19th Jun 18, 12:52 PM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    Re reading it I noticed I left out a vital part. I only individually argued 4/6 tickets.
    I merged point 5&6 together and have come up with the below;

    5. Page 17 of the claimant!!!8217;s bundle is a birds-eye view of the whole car park. Exhibits 16 !!!8211; page 29.
    Page 18 is a clearer birds-eye view of the car park indicating the section that is not controlled by Horizon themselves but is controlled by Euro Car Parks.
    Exhibits 17 !!!8211; page 30.
    i. In relation to charge; xx the Claimant doesn!!!8217;t dispute the fact the driver may have paid for parking.
    I argue that the Claimant has not provided clear evidence of the ticket displayed in the window of the vehicle nor have they provided clear evidence of where, specifically, in the car park the vehicle was parked at the time of the alleged incident.
    ii. In relation to charge; xx the Claimant doesn!!!8217;t dispute the fact the driver may have paid for parking.
    I argue that the Claimant has not provided clear evidence of where specifically, in the car park the vehicle was parked at the times of the alleged incidents.
    iii. In relation to charges; xx xx xx & xx the Claimant has stated that their signs have made it clear that a valid permit must be displayed. As shown in Exhibit 17 !!!8211; page 30 this area is predominantly controlled by Euro Car Parks who also issue permits.
    I argue that the signage in Exhibit 13 - page 26 is ambiguous and does not clarify whether it is a permit bay for the land controlled by Horizon or the land controlled by Euro Car Parks.
    The Claimant has not provided any evidence of where, specifically, in the car park the vehicle was parked at the times of the alleged incidents.



    Is it best to convert to PDF emailing the court and claimant solicitor AND post recorded delivery. Or just post recorded?
    • Coupon-mad
    • By Coupon-mad 19th Jun 18, 1:31 PM
    • 63,839 Posts
    • 76,487 Thanks
    Coupon-mad
    You can't expect the court to print stuff.

    Take a file in person, with a contents page, your WS, your defence, then ordered, numbered evidence printed out, all in a nice ring binder. How often do we have to type this, you want the Judge to have in his/her hands an easy to follow defence file, all paginated and organised like a little book of info.

    As for the Claimant/solicitor, email theirs in several emails, let them lump it.

    No 'signed for' post, please.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
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    • Inapickle01
    • By Inapickle01 5th Jul 18, 5:57 PM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    So tomorrow is the day!

    Hand delivered to court. Emailed claimants solicitors, CCing the court and myself. (2 weeks ago)

    Have my bundle ready. Have a spare for the judge, not sure why I done this just being super prepared I guess.
    Also have a copy of the lay rep doc to hand to court clerk.

    One thing I forgot to ask. Do I ask the claimants solicitor if they have the rights of audience? Or is it worded differently to that?
    • Coupon-mad
    • By Coupon-mad 5th Jul 18, 6:10 PM
    • 63,839 Posts
    • 76,487 Thanks
    Coupon-mad
    No, if you want to try that first, you hand over the paperwork about RoA to the Usher on arrival and say you wish to raise a preliminary matter with the Judge.

    Then once in the room you ask the Judge to read the Preliminary papers and to question whether the rep has Rights of Audience (regardless of whether the Judge has seen him/her before).

    Lamilad has a pre-prepared link to a Preliminary Matters document about RoA.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
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    • Inapickle01
    • By Inapickle01 6th Jul 18, 9:59 AM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    Thank you for all your help.

    We got the date wrong. Hearing was Wednesday. In bold the claim form states 6 June 2018. This is for the trial fee not the hearing.
    My own fault for misreading.
    I assume it's a default loss. Court didn't know the outcome all they said was it's a 10 day wait.
    Absolutely gutted. Thanks for all your time and input guys.
    • Inapickle01
    • By Inapickle01 6th Jul 18, 11:03 AM
    • 18 Posts
    • 3 Thanks
    Inapickle01
    Just out of curiosity; if you inform the parking company of the driver and they admit liability can they still pursue the registered keeper or can they only pursue the driver?
    • Coupon-mad
    • By Coupon-mad 6th Jul 18, 1:24 PM
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    • 76,487 Thanks
    Coupon-mad
    They can only pursue the driver if they have their name and address.

    Gutted you got the date wrong.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT UNLESS IN SCOTLAND OR NI
    TWO Clicks needed Look up, top of the page:
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    • IamEmanresu
    • By IamEmanresu 7th Jul 18, 6:25 AM
    • 3,769 Posts
    • 6,179 Thanks
    IamEmanresu
    I assume it's a default loss.
    No. The judge will look at the facts and judge accordingly. After all this is a Gladstone's pack.

    Let us know when you hear back.
    If you want to win - avoid losing first. Here are a few examples
    1. Failing to Acknowledge or Defend https://forums.moneysavingexpert.com/showthread.php?t=5760415
    2. Template defences that say nothing https://forums.moneysavingexpert.com/showthread.php?t=5818671&page=5#86
    3. Forgetting about the Witness Statement
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