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  • FIRST POST
    • madmidwife
    • By madmidwife 11th Feb 18, 2:45 PM
    • 40Posts
    • 8Thanks
    madmidwife
    Small Claims date received
    • #1
    • 11th Feb 18, 2:45 PM
    Small Claims date received 11th Feb 18 at 2:45 PM
    Hello
    I have been given a date to attend small claims court in Winchester due to Link parking issuing an invoice and Gladstones pursuing it.
    I didnt read the help on here before I responded with my defence
    Date has been set for 26th March.
    Hoping someone can help with my witness statement which I have copied from the examples posted on here.
    Thanks
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
Page 1
    • KeithP
    • By KeithP 11th Feb 18, 3:01 PM
    • 7,240 Posts
    • 6,770 Thanks
    KeithP
    • #2
    • 11th Feb 18, 3:01 PM
    • #2
    • 11th Feb 18, 3:01 PM
    Please post the defence you have submitted and your draft witness statement here.

    Have you now read post #2 of the NEWBIES FAQ sticky/pinned thread?
    .
    • madmidwife
    • By madmidwife 11th Feb 18, 3:43 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    • #3
    • 11th Feb 18, 3:43 PM
    • #3
    • 11th Feb 18, 3:43 PM
    Please post the defence you have submitted and your draft witness statement here.

    Have you now read post #2 of the NEWBIES FAQ sticky/pinned thread?
    Originally posted by KeithP

    Ok so here is where I have messed up big time, I received a LBC in October, and I didnt do anything about it
    A) Because I was just about to move out of my house
    B) I did not know what the letter was, I thought it was another attempt to get me to pay
    So this is probably why i'm in this mess
    What would you suggest I do?
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • The Deep
    • By The Deep 11th Feb 18, 3:49 PM
    • 9,209 Posts
    • 8,980 Thanks
    The Deep
    • #4
    • 11th Feb 18, 3:49 PM
    • #4
    • 11th Feb 18, 3:49 PM
    Gladstones were rhoroughly discredited in the House of Commons last week, watch this.

    http://parliamentlive.tv/event/index/2f0384f2-eba5-4fff-ab07-cf24b6a22918?in=12:49:41

    and while you are waiting for the court case complain to your MP and, if he supports you against these scammers, show his/her reply to the judge.
    You never know how far you can go until you go too far.
    • Coupon-mad
    • By Coupon-mad 11th Feb 18, 3:50 PM
    • 57,564 Posts
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    Coupon-mad
    • #5
    • 11th Feb 18, 3:50 PM
    • #5
    • 11th Feb 18, 3:50 PM
    Never mind the LBC. What did you put in the defence box on that actual court papers?

    PLEASE REPLY ON YOUR ORIGINAL THREAD:

    http://forums.moneysavingexpert.com/showthread.php?t=5760414

    Or is this a different one? How many claims do you have then?

    Show us what your defence said. You MUST have kept a copy, as anyone would?
    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.

    • madmidwife
    • By madmidwife 11th Feb 18, 4:14 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    • #6
    • 11th Feb 18, 4:14 PM
    • #6
    • 11th Feb 18, 4:14 PM
    coupon-mad, this is a different invoice/fine
    Long and short of it is: parked in a residential (block of flats) area as moving my daughter into her first rental. Had my (lease) car and a hire van, parked one in the allocated bay and the other next to it. Got a ticket on car which I then moved and then at 21.43 got a ticket on the van! note in window which said moving in today and no permit issued yet and also challenged the chap the second time telling him the exact same thing.
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • madmidwife
    • By madmidwife 11th Feb 18, 4:32 PM
    • 40 Posts
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    madmidwife
    • #7
    • 11th Feb 18, 4:32 PM
    • #7
    • 11th Feb 18, 4:32 PM
    As a complete numpty I didn't look on here first before I started this whole process so defence is shocking as well:

    On 24/6/17 both vehicles entered ......Flats Bristol to unload the belongings of the tenants of number 42 .......Flats. Car Reg xxxxxx was pared in the allocated space for number 42 with vehicle registration xx1xx1 parked to the side. Both vehicles displayed a note stating the purpose of the vehicles presence in the car park as a permit was yet to be issued. At 15.02 a parking charge notice was issued of xx1xx1 whilst it was still parked next to xxxxxx. A parking charge notice was not issued for xxxxxx despite being parked together at the time. The photographic evidence that Link Parking took at the time will show this. The vehicles continued to be unloaded and xx1xx1 was removed from the car park.
    At 21.43 some six hours later an attendant was witnessed issuing a parking charge for xxxxxx. An independent witness called out to the attendant to inform him that they were moving into the property and were unloading. He continued to take photos on his mobile phone, these photos will show the note displayed in the windscreen explaining lack of permit.
    I believe both charges to be unfair as outline above as proof of tenancy and an independent witness can verify.
    A fair and reasonable service would not have needed to ticket a vehicle at 21.43 that was parked in the allocated space for the flat
    The parking charge notice was left on the windscreen of both cars, however I am not the registered keeper of either vehicle and Link Parking are unable to prove that I was driver at the time of the parking charge notice being issued.
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • Coupon-mad
    • By Coupon-mad 11th Feb 18, 4:41 PM
    • 57,564 Posts
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    Coupon-mad
    • #8
    • 11th Feb 18, 4:41 PM
    • #8
    • 11th Feb 18, 4:41 PM
    You need to read & use, with your Witness Statement and photo evidence of lack of signs, and proof of tenancy agreement, and other evidence:

    Jopson v Homeguard

    from the Parking Prankster's case law page.

    You also need to watch this. Link were named by MPs, and the scam of residential PCNS was condemned:

    http://parliamentlive.tv/event/index/2f0384f2-eba5-4fff-ab07-cf24b6a22918?in=12:49:41

    http://forums.moneysavingexpert.com/showthread.php?t=5787731

    that debate is transcribed here, which will also form part of your evidence that this was unjustified, unfair and fining people moving their things into their flat is not saved by any 'legitimate interest', and so ParkingEye v Beavis is distinguished:

    https://www.theyworkforyou.com/debates/?id=2018-02-02b.1149.0

    Watch the full debate, and use the MPs words to your advantage. Use Jopson v Homeguard!

    What does the tenancy agreement say about obligations and parking fines - nothing? Thought not.
    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.

    • madmidwife
    • By madmidwife 11th Feb 18, 6:10 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    • #9
    • 11th Feb 18, 6:10 PM
    • #9
    • 11th Feb 18, 6:10 PM
    Ok, so I've copied and pasted from various bits suggested on the sticky thread. Its all over the place but is this the sort of thing I should be using in my WS? (I have also tagged on to the bottom the bits taken from the parliamentary bill discussion, not sure where to put it )
    Thanks for your help


    It is admitted that on [date] the Defendant's vehicle was parked at [location]

    It is denied that the Defendant was the driver of the vehicle. The Claimant is put to strict proof.
    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 Defendant in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 ("POFA")
    . 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.
    To the extent that the Claimant may seek to allege that any such presumption exist, the Defendant expressly denies that there is any presumption in law (whether in statute or otherwise) that the keeper is the driver. Further, the Defendant denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of parliament, they would have made such requirements part of POFA, which makes no such provision. In the alternative, an amendment could have been made to s.172 of the Road Traffic Act 1988. The 1988 Act continues to oblige the identification of drivers only in strictly limited circumstances, where a criminal offence has been committed. Those provisions do not apply to this matter.
    Authority to Park and Primacy of Contract
    It is denied that the Defendant or lawful users of his/her vehicle were in breach of any parking conditions or were not permitted to park in circumstances where an express permission to park had been granted to the Defendant permitting the above mentioned vehicle to be parked by the current occupier and leaseholder of [address], whose tenancy agreement permits the parking of vehicle(s) on land. The Defendant avers that there was an absolute entitlement to park deriving from the terms of the lease, which cannot be fettered by any alleged parking terms. The lease terms provide the right to park a vehicle in the relevant allocated bay, without limitation as to type of vehicle, ownership of vehicle, the user of the vehicle or the requirement to display a parking permit. A copy of the lease will be provided to the Court, together with witness evidence that prior permission to park had been given.
    The Defendant avers that the operator’s signs cannot (i) override the existing rights enjoyed by residents and their visitors and (ii) that parking easements cannot retrospectively and unilaterally be restricted where provided for within the lease. The Defendant will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services Ltd (2016) and of Sir Christopher Slade in K-Sultana Saeed v Plustrade Ltd [2001] EWCA Civ 2011. In Pace v Mr N [2016] C6GF14F0 [2016] it was found that the parking company could not override the tenant's right to park by requiring a permit to park furthermore In Link Parking v Ms P C7GF50J7 [2016] it was also found that the parking company could not override the tenant's right to park by requiring a permit to park.
    Accordingly it is denied that:
    there was any agreement as between the Defendant or driver of the vehicle and the Claimant
    . there was any obligation (at all) to display a permit; and
    the Claimant has suffered loss or damage or that there is a lawful basis to pursue a claim for loss.
    The Defendant avers that the residential site that is the subject of these proceedings is not a site where there is a commercial value to be protected. The Claimant has not suffered loss or pecuniary disadvantage. The penalty charge is, accordingly, unconscionable in this context, with ParkingEye distinguished.

    It is denied that the Claimant has standing to bring any claim in the absence of a contract that expressly permits the Claimant to do so, in addition to merely undertaking parking management. The Claimant has provided no proof of any such entitlement.

    It is denied that the Claimant has any entitlement to the sums sought.

    It is admitted that interest may be applicable, subject to the discretion of the Court on any sum (if awarded), but it is denied that interest is applicable on the total sums claimed by the Claimant.

    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. HMCS 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.
    I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.

    This claim and the other very similar one merely states: ''parking charges and indemnity costs if applicable'' which does not give any 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'. Nor are any clear times/dates or coherent grounds for any lawful claim particularised, nor were any details provided to evidence any contract created nor any copy of this contract, nor explanation for the vague description 'parking charges' and 'indemnity costs'.


    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.
    Parking terms cannot be re-offered by a third party contractor on a day-to-day basis (on far more onerous and potentially, completely variable terms) because these were never incorporated into the permission to park as granted by the landowner, which was a stand-alone contract, concluded at the point in time of the provision of a permit which carried very few terms of use and no 'parking charges' nor 'indemnity costs'.

    In the event that the court finds a contract based on signage can supersede the permit terms already agreed and the lease, I put the claimant to strict proof of a chain of contracts leading from the landowner to this claimant which enable these charges to be pursued in court by this contractor, for these alleged contravention(s), whatever they may be.

    The alleged debt(s) as described in the two claims are unenforceable penalties, being just the sort of unconscionable charges exposed as offending against the penalty rule, in ParkingEye Ltd v Beavis.

    It is not believed that the Claimant has incurred additional costs - be it legal or debt collector costs or even their unlawful, fixed sum card surcharge for payments - and they are put to strict proof that they have actually incurred and can lawfully add an extra sums and that those sums formed part of the permit/parking contract formed with the resident in the first instance.

    This case can be easily distinguished from ParkingEye v Beavis which the Judges held was 'entirely different' from most ordinary economic contract disputes. Charges cannot exist merely to punish drivers. This claimant has failed to show any comparable 'legitimate interest' to save their charge from Lord Dunedin's four tests for a penalty, which the Supreme Court Judges found was still adequate in less complex cases, such as this allegation.
    I request the court strike out both claims xxxxxxxx and xxxxxxxxx for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.

    Statement of Truth: I confirm that the contents of this statement are true to the best of my knowledge and belief.

    Parking (Code of Practice) Bill– in the House of Commons at 12:43 pm on 2nd February 2018.
    Sir Greg Knight
    Motorists should have the certainty that when they enter a car park on private land, they are entering into a contract that is reasonable, transparent and involves a consistent process. Poor signage, unreasonable terms, exorbitant fines, aggressive demands for payment and an opaque appeals process, together with some motorists being hit with a fine for just driving in and out of a car park without stopping, have no place in 21st-century Britain.
    Stephen Doughty Labour/Co-operative, Cardiff South and Penarth
    I completely support the right hon. Gentleman’s Bill., but I wonder if he will add to his list of unreasonable circumstances the repeated issuing of fines to individuals parking in their own parking space outside their property, which has affected me and many of the residents in the block where I live in Cardiff.
    Gladstones Solicitors of Knutsford is involved in many such cases—to be clear, I am talking about the firm in Knutsford; This week, I raised concerns about such firms with the Solicitors Regulation Authority, and I am hopeful that it will take a close look at the matter and consider whether the firms are complying with the regulatory environment for solicitors, and with best practice.
    Names highlighted in the debate include Premier Parking Solutions, Premier Park Ltd, Link Parking, New Generation Parking, UK Parking Control and ParkingEye,
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • Coupon-mad
    • By Coupon-mad 11th Feb 18, 6:17 PM
    • 57,564 Posts
    • 71,120 Thanks
    Coupon-mad
    That looks like a defence, not a WS. A WS does not have 'legal argument' but could refer to Jopson.

    Start again, copying a WS. It's written in the first person 'I did this' and refers to evidence by number, and has a statement of truth at the end. Examples in the NEWBIES thread or by searching the forum for Witness Statement.
    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.

    • madmidwife
    • By madmidwife 11th Feb 18, 8:54 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    Thanks Coupon-mad, is this more like it?

    Witness Statement
    In the matter of

    Link Parking (Claimant)
    v
    ******** (defendant)

    Claim no:

    Witness statement of Mrs *******, defendant


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


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




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

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

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

    3. Link Parking have offered no evidence of either vehicle being illegally parked at xxxx xxxx flats, despite them claiming photographs are available to view on their website. I have been unable to find any photographs as these can only be viewed prior to an internet payment being made, as shown on the parking charge notice (Evidence 1)

    4. The agreement for parking at the property lies with the landlord and not Link Parking as stated in the tenancy agreement (Evidence 2)



    5. I will rely upon the judgments on appeal of HHJ Harris QC in Jopson v Homeguard Services Ltd (2016) and of Sir Christopher Slade in K-Sultana Saeed v Plustrade Ltd [2001] EWCA Civ 2011. In Pace v Mr N [2016] C6GF14F0 [2016] it was found that the parking company could not override the tenant's right to park by requiring a permit to park furthermore In Link Parking v Ms P C7GF50J7 [2016] it was also found that the parking company could not override the tenant's right to park by requiring a permit to park. (Evidence 3)

    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.

    7. A publically televised debate held in the House of Commons (Parking Code of Practice Bill– in the House of Commons at 12:43 pm on 2nd February 2018.) discussed the unreasonable circumstances of repeated issuing of fines to individuals parking in their own parking space outside their property with the Claimant’s solicitors Gladstones being involved in many such cases. (Evidence 4)

    I believe that the facts stated in this Witness Statement are true.
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • KeithP
    • By KeithP 11th Feb 18, 9:41 PM
    • 7,240 Posts
    • 6,770 Thanks
    KeithP
    Paragraph 4. ( the first one, you have two paras 3 and 4).
    I would suggest the words 'colourful' and 'impersonating' are inappropriate.
    .
    • madmidwife
    • By madmidwife 12th Feb 18, 6:27 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    Do I also need to put together my skeleton argument and send copies of everything to the court and Gladstones? And if so how close to the deadline? Court date is 23rd March?
    Thanks everyone so far for your help
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • logician
    • By logician 12th Feb 18, 9:27 PM
    • 194 Posts
    • 76 Thanks
    logician
    Court date is 23rd March?
    Thanks everyone so far for your help
    Originally posted by madmidwife

    What does your court order state about filing evidence?
    and Witness Statements etc.

    The dates will be on there.

    Some courts are now getting twitchy if Skeletons are not served in good time to both parties, so best to err on the side of caution.


    You mention Bristol, this wouldn't happen to be at Lakeshore would it??
    • Coupon-mad
    • By Coupon-mad 12th Feb 18, 10:20 PM
    • 57,564 Posts
    • 71,120 Thanks
    Coupon-mad
    Do I also need to put together my skeleton argument and send copies of everything to the court and Gladstones? And if so how close to the deadline? Court date is 23rd March?
    Thanks everyone so far for your help
    Originally posted by madmidwife
    Beware offers to help by private message. DO NOT reply if you get such contact.

    Be aware that parking firms/BPA members post and look at this forum and that a pm may not be from a person whose agenda is the same as mine, for example.

    Please keep this all on this forum, and show us your planned Witness Statement, well before the date the Court letter says your WS and evidence must be exchanged.
    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.

    • madmidwife
    • By madmidwife 25th Feb 18, 5:58 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    Hello again,
    Work and home life have distracted me for a while but I am back for more help please.
    I need help with my skeleton argument (this is for a residential space) I know Coupon-Mad has posted one on this site somewhere but I'm struggling to find it??
    I am going to use as evidence: Tenancy agreement, Transcripts of Jopson v Homeguard, Link V Ms P, Pace V Mr N, and Saeed V Plustrade. Also going to include Transcript of House of commons debate on the Parking Bill (all of it or salient points??). Photo of parking sign and my witness statement. Do I need anything else??

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

    Link Parking (Claimant)
    v
    Mrs xxxxxx (defendant)

    Claim no:

    Witness statement of Mrs xxxxxx, defendant

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


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

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

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



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

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

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

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


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

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

    I believe that the facts stated in this Witness Statement are true.
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • madmidwife
    • By madmidwife 26th Feb 18, 4:23 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    Followed this link http://forums.moneysavingexpert.com/showthread.php?t=5591251&page=5
    But cant find the skeleton?? am i just being stupid?
    Also as I am not the registered keeper of either car (one is lease hire other one was from a hire company for the day) and as far as I'm aware they didn't name me as driver, how can I use this to my advantage?
    Was hoping that Gladstones wouldnt pay the fees and the case would be struck out but no such luck
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • madmidwife
    • By madmidwife 26th Feb 18, 6:46 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    Also should I get a witness statement from an 'independent' person (my daughters flatmate) who was there at the time of the alleged parking breach??
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • madmidwife
    • By madmidwife 27th Feb 18, 10:39 PM
    • 40 Posts
    • 8 Thanks
    madmidwife
    Worried now, received an email from Gladstones with their 'witness statement' which in fact was photos of the vehicles involved, some 'contract' with the managing agents and various correspondence from them and me sent over the last few months

    Going to need some help and a strong argument
    Total debt: £27,000
    3 credit cards, 2 loans, 2 large overdrafts,1 catalogue,
    • nosferatu1001
    • By nosferatu1001 27th Feb 18, 11:43 PM
    • 2,516 Posts
    • 3,081 Thanks
    nosferatu1001
    Your defence should already have included lack of keeper (not registered keeper, keeper) liability - you can!!!8217;t add it now.

    Your witness statement is what needs to be in - skeleton can wait 7ntil a couple days befire. It!!!8217;s a bullet list

    As for the gs ws - I bet if you READ it it!!!8217;s complete template baloney, yes? If in doubt post pics of it.
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