Draft defence

[Mollygog]

Thank you for all your help, I’m just going to let the process proceed, if I end up having to pay in court , so be it, losing too much sleep over it. Appreciated all you did

[des8]

While you are waiting for matters to proceed, you might as well start preparing your witness statement.
If you start now there will be no reason to rush it when court directions are received.

I have noted that you possibly live on the road where the vehicle was parked, so if the claimant realises this you may be subjected to questioning about it

So be careful about labouring the point re the wrong address.
From your MSE thread I see that the road you parked on is actually the service road for the shops and flats of Mottingham road.
It is quite likely that the address is correct as the owner of the road is possibly the freeholder of the shops etc. so
just mention in passing that you parked on an unnamed private road connecting Mottingham Road to Court Road.

Also if you live there the claimant will argue that you must have been aware of the sign, and there might be a record of your requests for a permit.
However the sign itself gives you some arguments.
The claimant is arguing that you (or the driver) broke a contract as written on the sign but so much is unclear they have breached Section 68 of the Consumer Rights Act 2015.
1)The sign refers to "this area" but does not define the boundaries so is unclear
2)The sign directs "Vehicles must park in designated bays", but management does not provide any marked bays so is confusing
3)The sign refers to unspecified "additional costs" (see the draft addendum about this)

You should also think about the signage, or rather lack of it at the entrances to the road.