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  • FIRST POST
    • Djdamo
    • By Djdamo 17th Mar 18, 10:47 AM
    • 53Posts
    • 29Thanks
    Djdamo
    BW Legal for VCS county court claim
    • #1
    • 17th Mar 18, 10:47 AM
    BW Legal for VCS county court claim 17th Mar 18 at 10:47 AM
    Hi,


    Back in 2016 the keeper received a NTK through the post dated 06/08/2016 for a PCN that Vehicle Control Services claim was issued to the car registration for breaching the terms and conditions of a privately owned car park on 05/06/2016. The reason for the breach was parked in a restricted area of the car park. The keeper nor the driver have never parked in the car park.

    The keeper sent an appeal letter using a template obtained from these forums via email to VCS on 17/06/2016.


    VCS replied via a letter dated 20/09/2016 acknowledging the appeal and stated they were evaluating the correspondence and were unable to give a decision at the present time however they expected to have their reply by 10/12/2016. They never answered any of the points raised in the appeal nor provided any evidence of the keepers car in their car park.

    The keeper then received another letter from VCS dated 08/02/2017 where they said they were unable to process the appeal as it was not submitted in time.


    There was no further correspondence by either party until the keeper received a claim form from a county court from BW Legal dated 13/03/2018 for 247.88 giving 14 days to respond.

    The keeper was not the driver on that day and the car was not parked in their car at all on that day.


    The keeper intends to defend this claim, what is the best method to do so?




    Thanks
    Last edited by Djdamo; 17-03-2018 at 2:23 PM.
Page 2
    • Djdamo
    • By Djdamo 20th Mar 18, 11:54 AM
    • 53 Posts
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    Djdamo
    Would the email address vcs@bwlegal.co.uk be correct to send the SAR to?
    • Djdamo
    • By Djdamo 20th Mar 18, 1:55 PM
    • 53 Posts
    • 29 Thanks
    Djdamo
    Just staring to put the defence together, how's this so far? Any help appreciated.




    In the County Court Business Centre
    Claim Number: xxxx
    BETWEEN:
    Vehicle Control Services Ltd (Claimant)
    vs
    DJDAMO (Defendant)

    __________________________________________________ _________________________
    Statement of Defence
    I am DJDAMO of Address, Postcode defendant in this matter.
    It is admitted that the defendant was the registered keeper of the vehicle noted at the date of alleged breaches. However, the claimant has no cause of action against the defendant on the following grounds: -




    1. Notwithstanding that the claimant claims no right to pursue the defendant as the registered keeper under The Protection of Freedoms Act 2012 (PoFA 2012); the Claimant has failed to meet the conditions of the Act and has never acquired any right to pursue the Defendant in this capacity if they cannot identify the driver.



    2. It is denied that the Claimant served the required documents with statutory wording as prescribed under the POFA and as such, there can be no keeper liability in any event.


    3. The Claimant alleges that parking charges notices were given for !!!8220;breaching the car park terms and conditions!!!8221; but no terms are given nor is any valid breach established.


    4. The place of the alleged breach is given as !!!8220;restricted area in a car privately owned car park at Sa1!!!8221; which contains many registered parcels of land as well as registered leaseholds on parts of these parcels of land, therefore strict proof is required as to the exact site of the breach.


    5. Vehicle Control Services Ltd are not the lawful occupier of any land around the SA1 development. Absent a contract with the lawful occupier of the land being produced by the claimant, or a chain of contracts showing authorisation stemming from the lawful occupier, I have reasonable belief that they do not have authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.


    6. The Defendant was parked on Langdon road which is under Swansea City Control according to the Swansea SA1 Waterfront Traffic Regulation Order Scheme which came into effect on Friday 19th May 2014.


    7. No attempt was made by the claimant to provide suitable information or evidence of this breach despite the Defendant!!!8217;s direct request on appeal dated 17/06/2016 and acknowledged by the claimant on 20/09/2016


    8. PoFA 2012 only allows the recovery of the parking charge stated on the Notice to Keeper and not court fees, damages, indemnity costs or legal representative!!!8217;s costs.


    9. No contract, terms and conditions or sum payable were never accepted by any driver.


    10. The claimant!!!8217;s notices attempt to make a forbidding offer, which isn!!!8217;t an offer at all, therefore no contract exists.


    11. The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed, the particulars of the claim are not clear and concise as is required by CPR 16.4 1(a).


    12. The claimant failed to include a copy of their written contract as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice A7.1 which says that if you do not own the land on which you are carrying out parking management, you must have the written authorisation of the landowner (or their appointed agent). The written confirmation must be given before you can start operating on the land in question and give you the authority to carry out all the aspects of car park management for the site that you are responsible for. In particular, it must say that the landowner (or their appointed agent) requires you to keep to the Code of Practice and that you have the authority to pursue outstanding parking charges.


    13. The Defendant believes that his personal details have been obtained unlawfully by the Claimant and asks that the Court does not to assist the Claimant to benefit from a wrongdoing. (Ex turpi causa non oritur actio).
    The facts stated in this defence are true, to the best of my knowledge and belief.
    Signed,
    DJDAMO
    • nosferatu1001
    • By nosferatu1001 20th Mar 18, 3:36 PM
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    nosferatu1001
    I would use their normal contact page for the SAR. Is one absolutely needed?

    6) contrains your strongest point, yet its buried behind less relevant ones

    The vehicle WAS NOT PARKED where they claim according to your OP, so why isnt that fact front and centre? They allege it was parked at X, but it was at Y. FUrther more, Y isnt relevant land - its under stat reg - meaning your first point about POFA ist relevant; not ony dont they use the right wording, theyc annot claim Keeper liability anyway as this isnt relevant land (where the car was actually parked) . So the claimant is not only NOT the landholder, tehy cannot havea contract for the location the vehicle was parked as this is under council control and isnt private land.
    • Djdamo
    • By Djdamo 20th Mar 18, 4:14 PM
    • 53 Posts
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    Djdamo
    I suppose a SAR isn't really needed, I was looking to highlight they wouldn't have any photographic evidence of the car being parked in their car park as claimed.



    I'll remove point 1 regarding POFA and place point 6 as the first point as below.

    1. The Defendant was parked on Langdon directly opposite the entrance to the car park at SA1. Langdon road is under Swansea City Control according to the Swansea SA1 Waterfront Traffic Regulation Order Scheme which came into effect on Friday 19th May 2014. This land isn't relevant and therefore keeper liability cannot be claimed. The claimant is not the landowner nor have a contract for the location the vehicle was parked.


    Are the other points still relevant?
    • Lamilad
    • By Lamilad 20th Mar 18, 10:11 PM
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    Lamilad
    I am DJDAMO of Address, Postcode defendant in this matter.

    The fact that they have ticketed you on public land needs to be main focus of your defence. This needs to be stated in the first paragraphs and linked to your point about no cause of action. The claimant has no basis or authority to issue a claim against the defendant, therefore no cause of action. Go on to say that where the vehicle was parked is council controlled land and evidence of this will be provided in due course.

    You DO need to send the SAR. You need to see what evidence they have of where the car was parked. If their own evidence proves it was council land then you have them over a barrel.

    Could someone else - a passenger, perhaps, provide a second witness statement to state where the car was parked?
    • Coupon-mad
    • By Coupon-mad 21st Mar 18, 12:07 AM
    • 63,872 Posts
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    Coupon-mad
    Would the email address vcs@bwlegal.co.uk be correct to send the SAR to?
    Originally posted by Djdamo
    If you do a SAR, you don't send it to the solicitors, you send it to the company direct.

    LoadsofChildren123 has posted to say before, that she is from Swansea and knows the car parks.
    Last edited by Coupon-mad; 21-03-2018 at 12:10 AM.
    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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    • Djdamo
    • By Djdamo 21st Mar 18, 9:52 AM
    • 53 Posts
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    Djdamo
    I can obtain a witness statement from the person the driver was meeting on the day, the car was parked in its location outside the carpark for roughly 5 minutes whilst the driver picking an item up from a friend.

    Ive now sent the SAR to both the info and litigation addresses for VCS.

    Ive had a redraft, is this any better?

    It is admitted that the defendant was the registered keeper of the vehicle noted at the date of alleged breaches. However, the claimant has no cause of action against the defendant on the following grounds: -

    1. The claimant has no basis or authority to issue a claim against the defendant, therefore no cause of action. The Defendant's vehicle was parked on Langdon Road directly opposite the entrance to the car park at SA1. Langdon road is under Swansea City Control according to the Swansea SA1 Waterfront Traffic Regulation Order Scheme which came into effect on Friday 19th May 2014. This land isn't relevant and therefore keeper liability cannot be claimed. The claimant is not the landowner nor have a contract for the location the vehicle was parked.

    2. It is denied that the Claimant served the required documents with statutory wording as prescribed under the POFA and as such, there can be no keeper liability in any event.

    3. The Claimant alleges that parking charges notices were given for !!!8220;breaching the car park terms and conditions!!!8221; but no terms are given nor is any valid breach established.

    4. The place of the alleged breach is given as !!!8220;restricted area in a car privately owned car park at Sa1!!!8221; which contains many registered parcels of land as well as registered leaseholds on parts of these parcels of land, therefore strict proof is required as to the exact site of the breach.

    5. Vehicle Control Services Ltd are not the lawful occupier of any land around the SA1 development. Absent a contract with the lawful occupier of the land being produced by the claimant, or a chain of contracts showing authorisation stemming from the lawful occupier, I have reasonable belief that they do not have authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.

    6. No attempt was made by the claimant to provide suitable information or evidence of this breach despite the Defendant!!!8217;s direct request on appeal dated 17/06/2016 and acknowledged by the claimant on 20/09/2016

    7. PoFA 2012 only allows the recovery of the parking charge stated on the Notice to Keeper and not court fees, damages, indemnity costs or legal representative!!!8217;s costs.

    8. No contract, terms and conditions or sum payable were never accepted by any driver.

    9. The claimant!!!8217;s notices attempt to make a forbidding offer, which isn!!!8217;t an offer at all, therefore no contract exists.

    10. The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed, the particulars of the claim are not clear and concise as is required by CPR 16.4 1(a).

    11. The claimant failed to include a copy of their written contract as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice A7.1 which says that if you do not own the land on which you are carrying out parking management, you must have the written authorisation of the landowner (or their appointed agent). The written confirmation must be given before you can start operating on the land in question and give you the authority to carry out all the aspects of car park management for the site that you are responsible for. In particular, it must say that the landowner (or their appointed agent) requires you to keep to the Code of Practice and that you have the authority to pursue outstanding parking charges.

    12. The Defendant believes that his personal details have been obtained unlawfully by the Claimant and asks that the Court does not to assist the Claimant to benefit from a wrongdoing. (Ex turpi causa non oritur actio).
    The facts stated in this defence are true, to the best of my knowledge and belief.
    Signed,
    • nosferatu1001
    • By nosferatu1001 21st Mar 18, 10:17 AM
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    nosferatu1001
    How about:

    1. The Defendants vehicle was never parked at the location claimed by the Claimant, and therefore the Claimant has no cause of action. Furthermore, where the Defendants vehicle was parked is public land, over whcich the Claimant is unable to demonstrate any standing as the land is controlled by a public order. Evidence of this will be provided at hearing.

    The Defendant's vehicle was parked on Langdon Road directly opposite the entrance to the car park at SA1 where the claimant claims the vheicle was parked. Langdon road is under Swansea City Control according to the Swansea SA1 Waterfront Traffic Regulation Order Scheme which came into effect on Friday 19th May 2014.
    • Coupon-mad
    • By Coupon-mad 21st Mar 18, 6:48 PM
    • 63,872 Posts
    • 76,517 Thanks
    Coupon-mad
    This land isn't relevant and therefore keeper liability cannot be claimed.
    should be (always staying formal and avoiding slang like ''isn't''):

    This land is not ''relevant land'' as defined in Schedule 4 of the Protection of Freedoms Act 2012 and therefore 'keeper liability' cannot be claimed.
    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
    • IamEmanresu
    • By IamEmanresu 22nd Mar 18, 5:58 AM
    • 3,769 Posts
    • 6,181 Thanks
    IamEmanresu
    I've also been given evidence that the road the car was parked on is adopted highway and therefore under the control of the local council.
    Have you been in touch with SCC Highways about this. They have a duty to investigate and stop this so their opinion will be persuasive if you can get it rather than relying on a TRO.

    AFAIR VCS (not Excel) had put up a number of their signs on this road a few years back which then disappeared so SCC will be able to advise about this too. If VCS knew about the TRO (if it is still live) then so did Excel.
    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
    • Djdamo
    • By Djdamo 22nd Mar 18, 6:57 AM
    • 53 Posts
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    Djdamo
    I!!!8217;m getting confused with what I think is conflicting information at the moment.

    According to highway management the road is privately owned by the Welsh Government and not yet adopted highway. I!!!8217;ve not contacted them yet to see what provisions they have in place for managing Langdon road, will do that today. However the person I!!!8217;ve been dealing with at highway management confirmed that presently the civil enforcement officers patrol Langdon road. I!!!8217;m just waiting to hear back if that was also the case in 2016.

    I remember the signs being there a long time ago then sudenly disappearing. I!!!8217;ve also not noticed their wardens walking the road any more.
    Last edited by Djdamo; 22-03-2018 at 9:06 AM.
    • nosferatu1001
    • By nosferatu1001 22nd Mar 18, 10:22 AM
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    nosferatu1001
    If it is a road accessible to the public, then the RTE apply and so the land is still not relevant land. Ditto if owned by a governement - that si NOT private ownership but PUBLIC!
    • Djdamo
    • By Djdamo 7th Apr 18, 5:18 PM
    • 53 Posts
    • 29 Thanks
    Djdamo
    There is a week left to file defence. I've spoken with someone at Welsh Government but as of yet not had confirmation if they contracted out to VCS to control parking on the road after the TRO came into effect in 2014.

    I had no reply from the SAR I sent to either of the VCS email addresses however I had also sent one to the VCS address at BW legal which did get an initial response on the 8th day. They replied asking to confirm name and PCN number before they could give any information. I sent what they requested as it was nothing additional to what they already have. That was over a week ago and not had anything from them since.

    As I currently don't know if VCS held a contract with Welsh Government to ticket the road is the best line of defence still the fact that the car was not parked where they claim?
    Last edited by Djdamo; 07-04-2018 at 7:29 PM.
    • Quentin
    • By Quentin 7th Apr 18, 5:22 PM
    • 37,942 Posts
    • 22,051 Thanks
    Quentin
    Please see this advice which applies to your posts:



    Also, please switch of the Smart Punctuation function of your iPhone/iPad to avoid littering your posts with !!!8251; (and similar) gobbledegook. Every punctuation you use comes out as rubbish now - a forum glitch.
    Go to 'General' > 'Keyboard' > 'Smart Punctuation' and flick the switch off.
    Switching off seems to have no detrimental affect on any other use of the keyboard.
    Originally posted by Umkomaas
    • Coupon-mad
    • By Coupon-mad 8th Apr 18, 12:08 AM
    • 63,872 Posts
    • 76,517 Thanks
    Coupon-mad
    As I currently don't know if VCS held a contract with Welsh Government to ticket the road is the best line of defence still the fact that the car was not parked where they claim?
    Originally posted by Djdamo
    No, you MUST include both points as they both have merit, along with 'unclear signs' (always!).

    You DO know that VCS cannot issue 'parking' charge notices in a road covered by a TRO.

    That's because it's not possible under the TMA 2004. Where there is a TRO, the roads in question can only be enforced by penalty notices complying with the TMA (i.e. proper Council penalties). Now, Councils can use contractors to issue them (e.g. NSL do this for some Councils) but that have to issue proper, Council penalty notices.

    Not 'parking charge notices'.

    Public highway cannot lawfully be enforced as if it were private land and/or under contract law.

    So, you do know that the roads within the TRO are not places that VCS can enforce, and that they cannot have a contract with the local Council/Welsh Govt. VCS never act for Councils, this is a fact.

    Last edited by Coupon-mad; 08-04-2018 at 12:11 AM.
    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
    • Djdamo
    • By Djdamo 9th Apr 18, 11:45 AM
    • 53 Posts
    • 29 Thanks
    Djdamo
    Ok so this is my final draft of my defence unless anyone suggests further changes?

    Defence

    In the County Court Business Centre
    Claim Number: E8DP25C4
    BETWEEN:
    Vehicle Control Services Ltd (Claimant)
    vs
    Djdamo (Defendant)

    It is admitted that the defendant was the registered keeper of the vehicle noted at the date of alleged breaches. However, the claimant has no cause of action against the defendant on the following grounds: -

    1. The Defendants vehicle was never parked at the location claimed by the Claimant, and therefore the Claimant has no cause of action. Furthermore, where the Defendants vehicle was parked is public land, over which the Claimant is unable to demonstrate any standing as the land is controlled by a public order. Evidence of this will be provided at hearing.

    The Defendant's vehicle was parked on Langdon Road directly opposite the entrance to the car park at SA1 where the claimant claims the vehicle was parked. Langdon road is under Swansea City Control according to the Swansea SA1 Waterfront Traffic Regulation Order Scheme which came into effect on Friday 19th May 2014.

    2. It is denied that the Claimant served the required documents with statutory wording as prescribed under the POFA and as such, there can be no keeper liability in any event.

    3. The Claimant alleges that parking charges notices were given for "breaching the car park terms and conditions" but no terms are given nor is any valid breach established.

    4. The place of the alleged breach is given as "restricted area in a privately owned car park at SA1 "which contains many registered parcels of land as well as registered leaseholds on parts of these parcels of land, therefore strict proof is required as to the exact site of the breach.

    5. Vehicle Control Services Ltd are not the lawful occupier of any land around the SA1 development. Absent a contract with the lawful occupier of the land being produced by the claimant, or a chain of contracts showing authorisation stemming from the lawful occupier, I have reasonable belief that they do not have authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.

    6. No attempt was made by the claimant to provide suitable information or evidence of this breach despite the Defendant's direct request on appeal dated 17/06/2016 and acknowledged by the claimant on 20/09/2016.

    7. PoFA 2012 only allows the recovery of the parking charge stated on the Notice to Keeper and not court fees, damages, indemnity costs or legal representative's costs.

    8. No contract, terms and conditions or sum payable were never accepted by any driver.

    9. The claimant's notices attempt to make a forbidding offer, which isn not an offer at all, therefore no contract exists.

    10. The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed, the particulars of the claim are not clear and concise as is required by CPR 16.4 1(a).

    11. The claimant failed to include a copy of their written contract as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice A7.1 which says that if you do not own the land on which you are carrying out parking management, you must have the written authorisation of the landowner (or their appointed agent). The written confirmation must be given before you can start operating on the land in question and give you the authority to carry out all the aspects of car park management for the site that you are responsible for. In particular, it must say that the landowner (or their appointed agent) requires you to keep to the Code of Practice and that you have the authority to pursue outstanding parking charges.

    12. The Defendant believes that his personal details have been obtained unlawfully by the Claimant and asks that the Court does not to assist the Claimant to benefit from a wrongdoing. (Ex turpi causa non oritur actio).
    The facts stated in this defence are true, to the best of my knowledge and belief.
    Signed,
    Last edited by Djdamo; 09-04-2018 at 1:08 PM.
    • Coupon-mad
    • By Coupon-mad 9th Apr 18, 7:54 PM
    • 63,872 Posts
    • 76,517 Thanks
    Coupon-mad
    Needs the heading: DEFENCE

    ...and the date as well as signature at the end.

    And this is wrong:

    controlled by a public order
    should be:

    controlled by a Traffic Regulation Order
    Apart from that, this defence looks good if you are certain that the place is under a TRO.

    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
    • Djdamo
    • By Djdamo 10th Apr 18, 8:20 AM
    • 53 Posts
    • 29 Thanks
    Djdamo
    Thanks Coupon-mad, I'm fairly certain I understand the TRO I have, I guess I'll find out soon enough.

    I'll pop the document in the post this afternoon recorded delivery, and then get to work on the witness statements.

    I have spoke with the person the driver was meeting and they have agreed to supply a witness statement. So would that mean I have 3 witness statements, he drivers, the keepers and the person being met?
    • Johnersh
    • By Johnersh 10th Apr 18, 9:17 AM
    • 1,183 Posts
    • 2,249 Thanks
    Johnersh
    @Djadamo do, please, be careful - this (below) looks distinctly like the TRO applies to most, but does not apply to all of the road. The critical issue is exactly where the car was parked. The last thing you want to do is to get this to a hearing and discover that you were within the curtillage of some private land.

    In principle, though, you seem to be in a reasonable position (more likely than not that it was public land/subject to council enforcement not a PPC) at least on balance of probabilities. At para 5 of the Defence, stuff your reasonable beliefs and issue an outright denial that there is a right to ticket if you believe your documents prove they cannot or put them to strict proof. Either way, you need to make clear that this is for them to prove, not merely a refusal to pay because you don't like it. Para 12 probably won't wash. At Para 10 PD 16 7.3(1) is the section that requires the terms of the contract to be set out. PD 16 7.5 requires the Claimant to specify the conduct that you took to complete your acceptance of the contract (they probably haven't done that adequately either). If there was no signage, it is not clear how para 9 can be maintained. It may need to be reworked.

    - Langdon Road / Heol Langdon (from its junction with the north eastern
    kerbline of King's Road / Heol Y Brenin to a point 990 metres north east
    thereof
    - Langdon Road / Heol Langdon (from a point 44 metres south of its junction
    with the southern kerbline of Fabian Way to the northern kerbline of Langdon
    Road / Heol Langdon, for clarification where the roundabout on Langdon
    Road / Heol Langdon is situated, a distance of 49 metres)
    "The best advice I ever got was that knowledge is power and to keep reading."
    DISCLAIMER: I post thoughts as & when they occur. I don't advise. You are your own person and decision-maker. I'm unlikely to respond to DMs seeking personal advice. It's ill-advised & you lose the benefit of a group "take" on events.
    • Djdamo
    • By Djdamo 10th Apr 18, 1:32 PM
    • 53 Posts
    • 29 Thanks
    Djdamo
    Thanks Johnersh, The part of the road that is not covered by the TRO is a gated section currently privately owned by Allied British Port. This is approximately 900 meters away from where the vehicle was parked. The vehicle was parked roughly between 80 to 100 meters north east away from the junction of Kings Road.

    I can remove Para 12.

    Im a little confused with your other recomendations, do i have the PD's the wrong way around?

    There was signage up at one time all along Langdon Road however I'm unsure as to when this was removed, its not there now.

    Para 5 reworded

    5. Vehicle Control Services Ltd are not the lawful occupier of any land around the SA1 development and therefore do not have authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.
    Last edited by Djdamo; 10-04-2018 at 5:38 PM.
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