VCS 'Parking Outside Designated Bay' defence helpppp needed!

Thank you for all your help so far @coupon-mad and @keithp !
Here is my second draft, using the bargepole example too.

Vehicle Control Services Ltd (Claimant)

-and-

Miss ---- (Defendant)

____________
DEFENCE
____________
1. It is admitted that the Defendant is the driver of vehicle registration number ---- which is the subject of these procedures.
2. It is admitted that on the material date, the Defendant’s vehicle was parked at Bay ---, ---. The Defendant has, since 10.06.2016, held legal title under the terms of a lease, to Flat No. -- at that location. At some point, the managing agents contracted with the Claimant company to enforce parking conditions at the estate.
3. The car parking area contains allocated parking spaces demised to residents using a parking permit. Guests of the residents can park in the allocated spaces marked ‘V’ using guest passes. The Defendant’s vehicle displayed a valid resident parking permit at the time of the incident, so it was well known to the Claimant that the Defendant lives in the flats as a resident, and therein authorised to park there.
4. Under the terms of the Defendant’s lease, section 1.1 lists ‘parking space numbered P -- shown edged with red on the Site Plan and numbered -- on the ground’ under ‘the premises’.
4.1. There are no terms within the lease requiring lessees to display parking permits, to park within allocated bays or to pay penalties to third parties, such as the Claimant, for non-display of same, or for parking outside marked bays.
5. The Defendant, at all material times, parked in accordance with the terms granted by the lease. The erection of the Claimant’s signage, and the purported contractual terms conveyed therein, are incapable of binding the Defendant in any way, and their existence does not constitute a legally valid variation of the terms on the lease. Accordingly, the Defendant denies having breached any contractual terms whether express, implied, or by conduct.
6. The Claimant, or Managing Agent, in order to establish a right to impose unilateral terms which vary the terms of the lease, must have such variation approved by at least 75% of the leaseholders, pursuant to S37 of the Landlord & Tenant Act 1987, and the Defendant is unaware of any such vote having been passed by the residents.
7. Further and in the alternative, the signs refer to ‘Authorised Vehicles Only/Terms of parking without permission’, and suggest that by parking without permission, motorists are contractually agreeing to a parking charge of £100. This is clearly a nonsense, since if there is no permission, there is no offer, and therefore no contract.
7.1. The Defendant’s vehicle clearly was ‘authorised’ as per the lease and the Defendant relies on primacy of contract and avers that the Claimant’s conduct in aggressive ticketing is in fact a matter of tortious interference, being a private nuisance to residents.
7.2. In this case the Claimant has taken over the location and runs a business as if the site were a public car park, offering terms with £100 penalty on the same basis to residents, as is on offer to the general public and trespassers. However, residents are granted a right to park/rights of way and to peaceful enjoyment, and parking terms under a new and onerous ‘permit/licence’ cannot be re-offered as a contract by a third party. This interferes with the terms of leases and tenancy agreements, none of which is this parking firm a party to, and neither have they bothered to check for any rights or easements that their regime will interfere with (the Claimant is put to strict proof). This causes a substantial and unreasonable interference with the Defendant’s land/property, or his/her use or enjoyment of that land/property.
7.3. The Claimant may rely on the case of!ParkingEye v Beavis![2015] UKSC 67 as a binding precedent on the lower court. However, that only assists the Claimant if the facts of the case are the same, or broadly the same. In Beavis, it was common ground between the parties that the terms of a contract had been breached, whereas it is the Defendant's position that no such breach occurred in this case, because there was no valid contract, and also because the 'legitimate interest' in enforcing parking rules for retailers and shoppers in!Beavis!does not apply to these circumstances. Therefore, this case can be distinguished from!Beavis!on the facts and circumstances.!
8. It is denied that any “parking charges, damages or indemnity costs” (whatever they might be) as stated on the Particulars of Claim are owed. The alleged debt is denied in its entirety.
8.1. 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.
8.2. The Protection of Freedoms Act 2012, Schedule 4, at Section 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper, in this case £100. The claim includes an additional £60, for ’debt collection’ costs. Request for data to evidence any ‘debt collection’ costs were ignored by the Claimant.
9. It is denied that the Claimant entered into a contract with the Defendant. The Claimant is a third party company contracted by Broomhall Management Services to provide car-park management services and is not capable of entering into a contract with the Defendant on its own account, as the car park is owned by and the terms of entry set by the landowner.
9.1. In the absence of a contract that expressly permits the Claimant to do so, it is denied that the Claimant has the contractual or other lawful authority to make contracts and/or bring proceedings against the Defendant. The Claimant is put to strict proof.
9.2. The Defendant has the reasonable belief that the Claimant does not have the necessary authorisation from the landowner to issue parking charge notices on this land in their own name, and to pursue payment by means of litigation.
10. Further and in the alternative, it is denied that the claimant's signage sets out the terms in a sufficiently clear manner which would be capable of binding any reasonable person reading them. They merely state that vehicles must be parked correctly within their allocated parking bay, giving no definition of the term 'correctly parked', nor indicating which bays are allocated to whom.
10.1. The Defendant submits that any signage present on the site even if seen by a motorist is not clear or legible in its construction, and therefore not able to form a contract. The Defendant brings to the attention of the Court A0QZ7658 UKCPS v Anonymous 4/7/14 at Bradford, and A3QZ1305 UKCPS v Anonymous 2/7/14 at Sheffield. The Judges in these cases found that UKCPS Ltd signs were ‘gibberish, too wordy and with conflicting terms’. The Defendant submits that the signs on this site fall into the same description and are therefore unable to form a contract even if seen.
10.2. The terms on the Claimant's signage are also displayed in a font which is too small to be read from a passing vehicle, and is in such a position that anyone attempting to read the tiny font would be unable to do so easily. It is, therefore, denied that the Claimant's signage is capable of creating a legally binding contract.
11. The claim states that the vehicle was parked “OUT OF DESIGNATED BAY”. The Defendant asserts that the markings of the bay are not plentiful and easily visible, as they are only marked on the corners, with no consistent line marking the parameters of the bay.
11.1. In Parking Eye v Beavis 4th November 2015 UKSC 2015/0116, in paragraph 310 Loud Toulson states “There may be reasons why a user parks with his wheels outside the marked bay (for example because of the way the adjacent vehicle is parked or because he is a wheelchair user and none of the blue bays are available). Examples could be multiplied. The point is that the penalty clause makes no allowance for circumstances, allows no period of grace and provides no room for adjustment”
12. For all the reasons stated above, the Court is invited to dismiss the claim in its entirety, using its case management powers pursuant to CPR 3.4, and to award the Defendant such costs as are allowable on the small claims track, pursuant to Civil Procedure Rule 27.14. Given that the claim is based on an alleged contractual parking charge of £100 - already significantly inflated and mostly representing profit, as was found in!Beavis!- but the amount claimed on the claim form is inexplicably!£160, the Defendant avers that this inflation of the considered amount is a gross abuse of process.

13. Given that it appears that this Claimant's conduct provides for no cause of action, and this is intentional and contumelious, the Claimant's claim must fail and the court is invited to strike it out.!
13.1. In the alternative, the Court is invited, under the Judge's own discretionary case management powers, to set a preliminary hearing to examine the question of this Claimant's substantial interference with easements, rights and 'primacy of contract' of residents at this site, to put an end to not only this litigation but to send a clear message to the Claimant to case wasting the court's time by bringing beleaguered residents to court under excuse of a contractual breach that cannot lawfully exist.

Statement of Truth:

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

Name
Signature
Date

Is this okay?
I have two tickets (over a weekend where the car wasn't used), so do I just send the same defence for both? Is there any way I can combine the two?
Thank you so much again!!!