Advice on Filing a Defence for Parking Fine Claim

[des8]

I have the response to your defence (thanks Nick) and will go through it in detail over the next few days.
At first glance it is pretty standard fare, and doesn't really answer your main points.

The photo of the sign you posted earlier ... was it supplied by ELMS?
I understand there is another photo(s) attached to the response ... could you post up copies of those please.?

Very briefly i noted they are falling back on the tired old claim that not identifying the driver is the equivalent of admitting the keeper is the driver and also avoiding the problem for them that the NTK does not comply with the statutory mandated conditions.
Also noted they sent you lots of paperwork stating Excel were authorised to manage this site!

Suggest you start working on your witness statement to avoid a panic later!

[des8]

If you can manage it, it might be worth while revisiting the park to see what the signs say now.
I have found references to some cases going back several years where the court claimant was VCS

[EXC]

Silver Paw You've emailed me a large number of photo documents for des8 which I am unable to deal with.

I suggest you either:

1) Upload them to posts on this thread via the paperclip icon on the blue bar on the 'post reply' box then select 'upload attachments' and then select 'Fullsize'. This site restricts the file size of attachments (the ones you emailed are way too large) so I suggest you convert them from JPEG to PNG format and attach them a handful of documents per post.

2) Find a way to host the documents externally that Des can access.

[des8]

seems I might be snowed under.

EXC could you just forward to me that last email from Silver Paw? I think you have my email address already.

[EXC]

seems I might be snowed under.

EXC could you just forward to me that last email from Silver Paw? I think you have my email address already.

I was trying to avoid that as it doesn't seem fair on you.

It's about 5 emails with about 50 attachments so I would have to have had to resize every one individually to have been able to then post them in VIP.

It's up to you. I can't access your email address so PM it to me and I can forward them all.

[Silver Paw]

Hello EXC


As mentioned before this site do not allow me to attach anything using the paper clip. Hence why I had to upload details to ingur.com at the beginning of June as suggested by DES8 . However DES8 had trouble accessing them. DES8 said s/he was only able to see the first picture. So I stopped using ingur.com .

I had some of the documents uploaded to google drive but DES8 is saying that s/he is not able to access the google drive. I do not know what the problem was. I am not a fan of this technology and I am being force to use it to get help. I am more of a phone and fax machine person.

I will ask my neighbour to see if he can help me to load all paperwork to a difference google drive as he is a bit better at working this computer stuff than me and my partner. So many different formats. JPEG, PNG, PDF etc. I do not understand them.

I hope one day soon the sun will release massive solar flares and the EMP generated one after another will fry the global computer infrastructure. We can all go back to the way it was back in the mid 80's.

Regards

[EXC]

I can't shed any light on the issues you're experiencing but as long as des8 is happy for me to forward your emails to him, I'm happy to continue to do so.

[des8]

........... and I am happier with pen and ink (not a quill pen though)

[des8]

Earlier I admitted to being computer illiterate, and this evening I proved myself correct.

With a couple of hours to spare I thought time to have a good look at Elms defence to your counter claim.

Now I know I have seen it, as I commented on it briefly in post 46, but I have spent hours trawling through this device and cannot find it.

It has completely vanished, not attached to Nick's emails, not in trash; drafts or sent .. just gone

So do you think you could send it again, please, together with the changed sign.

I'm sure Nick won't mind if I ask him nicely EXC

[EXC]

Earlier I admitted to being computer illiterate, and this evening I proved myself correct.

EXC

I think it's more of the sort of brain malfunction I suffer from lol. I had posted it in VIP but I've forwarded it to you now anyway.

[des8]

Silver Paw just to let you know I am still ploughing through their submission, and hope to fininsh tonight/tomorrow.

In the meantime can you post up a copy of the signage photo that ELMS sent you? The photo showing VCS as parking operator.

Also you might like to start preparing your witness statement.

[des8]

My comments in red.
Your main point of defence is that the driver did not contract with VCS as the signage showed EXCEL as the operator
You will need to concentrate on that, and keep bringing the court's attention back to it.
Have you checked the current signage at the car park?

The other points are back ups, in case you get an odd judge (they do exist).
ELMS are smooth operators, so will try every trick in the book to side track the judge

If all else fails and you lose don't forget PoFA2012 Sch4 para 9 (2) (f).... that should at least reduce the award by £60

ELMS DEFENCE etc

1. The Claimant in this matter vehemently denies the entirety of the Defendant's Defence and subsequent Counterclaim and the Claimant vehemently denies that the Defendant is entitled to any sums claimed, interest and damages or to any relief whatsoever for the reasons outlined throughout this entire statement of case and in any event, the Claimant requires the Defendant to prove the matters set out in his Defence and subsequent Counterclaim.




2. The Claimant intends to prove to the Court on balance that, through the contents, submissions and exhibits outlined in this comprehensive statement of case that the Defendant has wrongfully Defended this matter and wrongfully brought an action against the Claimant. Background




3. The Claimant is engaged in providing and managing private parking facilities on behalf of Clients throughout Great Britain. At all material times, the Claimant has been an Accredited Member of Approved Trade Associations certified by the Driver and Vehicle Licensing Agency (DVLA).




4. A vehicle bearing the registration number of was identified in breach of the advertised Terms and Conditions ("Contract") known as Ivybridge Retail Park Car Park, Twickenham. TW7 7DY ("the Land") on 21 August 2024. The Contract




5. At the time the Charge was issued; the Claimant was prominently displaying signs on the Land stipulating the Terms of parking. A copy of the content of the signs is exhibited to this Statement at Exhibit ESL1. The signs formed the basis of the contract with the driver of the Vehicle ("the Contract"). The following was a term of the Contract: - Park wholly within the lines of a single marked bay PARKING CHARGE £100




The claimant was not displaying signs etc etc The signs were displayed by Excel




6. Upon the vehicle entering the Land, the driver accepted the Contract and agreed to be bound by those Terms advertised. The Contract provides that a charge is payable by the driver if it is breached; with payment falling due within 28 days. The Contract (i.e. the signs) was prominently displayed on the Land and in this regard a site plan showing the positioning is exhibited to this Statement at Exhibit ESLI.




7.. Amongst other things the above signs specifically detail the Terms and Conditions of parking and the consequences of failure to comply with these Terms and Conditions. In particular the signs specifically state that a charge is levied for breaching the Terms and Conditions.




8. This is a contractual clause which specifies the amount owed. There is sufficient and adequate signage for the Terms and Conditions to have been brought to the attention of any motorist wishing to use the car park. Breach of Contract




9. The Defendant became liable for the Charge Notices as the vehicle to which they are responsible for was found in breach of the Contract. The evidence adduced to this statement identifies that the vehicle was "not parkedwholly within the markings of a designated parking bay". The Defendant had parked not within the confines of a marked bay. The documents adduced at Exhibit ESL2 evidences the vehicle in breach. In light of the breach of the Contract, the Claimant is entitled to levy charges against the Defendant and therefore the Defendant is liable to the Claimant.




Note a quick switch from rhe “driver/motorist in paras upto no.8 to the “defendant” in para 9

The driver(if anyone) is liable




Reply to Defence




10. I will now respond to the Defendant's Defence, which appears, prima facie, to be an internet scatter gun defence (on the hope that something has credence) surrounding the legitimacy of how the Claimant manages and enforces on their Sites, which is wholly denied for the reason sets out below, unless otherwise stated. The Claimant at this juncture, would kindly invite the Court to note that the Defendant has never provided an explanation by way of a legal Defence as to why she parked in the manner she did (across two designated bays) and has rather adopted the common idiom of "the best form of defence is attack."




The Defendant has never admitted to being the driver. The claimant needs to be put to proof of this alleged fact




11. The Defendant has separated their Defence into different sub-headings, which the Claimant will address as follows.




12. In the Defendant's Defence under the sub-heading Introduction, they have stated that the signage at the Land was in the name of Excel Parking Services Ltd and the Claimant's name is Vehicle Control Services Ltd and therefore, the claim should be struck out. The Claimant would like the Court to note that the signage exhibited at Exhibit ESL1 clearly shows that the signage states that "VEHICLE CONTROL SERVICES LTD MANAGE AND CONTROL THIS PRIVATE CAR PARK" and therefore, the Claimant is the correct legal entity.




I haven’t seen this sign. Have you been back to check what is there now?







13. In the Defendant's Defence underthe sub-heading Claimant's Non-Compliance with the Civil Procedure Rules, they have stated that the Claimant have not complied with CPR16 in that the Claimant's Particulars of Claim are not adequate. The Claimant would like to submit that the Particulars of Claim were issued via Money Claim Online (MCOL) which has a character limit of 1080 characters. The Claimant states the Particulars of Claim contained enough information for the Defendant to understand what the claim relates to; namely:- i) The date and location of the charge; ii) The vehicle registration number; iii) The Parking Charge Noticе number; iv) The amount outstanding; v) That it relates to parking charges; and vi) furthermore, the Claimant was not directed by any reviewing Court to reproduce and/or make any amendments to the particulars of claim submitted. The Claimant states they were compliant with the CPR provisions 16.4.




14. Further, the Claimant would like to draw the Court's attention to the Irish case of Allied Irish Banks Plc v Pierce (2015) as a persuasive authority in that the Court found that a deficiency in the Particulars of Claim would not bring the case to an end and the Court would consider all of the correspondence exchanged in working out the nature of the claim. The Claimant, therefore, submits the Particulars of Claim were submitted properly.




That IRISH case was decided thus because there was no suggestion at all that the defendant did not know the nature of the case

A more appropriate authority would be Henchy J. in Cooney v. Browne [1984] I.R. 185, 191 where he stated in the following terms:

"…where the pleading in question is so general or so imprecise that the other side cannot know what case he will have to meet at the trial, he should be entitled to such particulars as will inform him of the range of evidence (as distinct from any particular items of evidence) which he will have to deal with at the trial."They have not addressed the insufficiency of the particulars of claim as you were not aware if you were being sued as the driver or keeper or how the claimed amount was computed

As a solicitor he should be aware that if the text box within Money Claim Online (MCOL) isn't sufficient to contain all the necessary details for a claim, the claimant should file the additional particulars separately after issuing the claim. They must serve a copy of these additional details on the defendant within 14 days of issuing the claim and file a Certificate of Service with the court. The defendant then has 14 days to respond from the date of service.

15. In the Defendant's Defence under the sub-heading Liability as the Driver of the Vehicle, they have stated that the Claimant does not have authority to manage the Land, that the Claimant has not proved that the Defendant was the driver and that the signage at the Land was not sufficient.




16. In relation to the Claimant not having authority to enforce the charges, the Claimant would like to submit that as the contract is between the Claimant and the Defendant, the Claimant does have the authority to enforce parking charges. However, both VCS v HM Revenue & Customs (2013) and Parking Eye v Beavis (CA 2015) made it clear that a contracting party need not show they have a right to do what they have promised in the performance of a contract, nor is (in the case of a parking operator) the Agreement between Operator and Landowner of any relevance. In any event, and without concession, the Agreement exhibited to this Reply to Defence and Defence to Counterclaim found at Exhibit ESL1 evidences the Claimant's authorisation to operate/manage the Site on behalf of the Landowner.




17. Lord Justice Lewison commented in VCS v HM Revenue & Customs [2013] EWCA Civ 186 "The Upper Tribunal's reasoning on this part ofthe case was that since VCS did not have the right under its contract with the car park owner to grant a licence to park, it could not have contracted with the motorist to grant such a right. In my judgment there is a serious flaw in this reasoning. The flaw in the reasoning is that it confuses the making of a contract with the power to perform it. There is no legal impediment to my contracting to sell you Buckingham Palace. If (inevitably) I fail to honour my contract then I can be sued for damages. On the stock market it is commonplace for traders to sell short; in other words to sell shares that they do not own in the hope of buying them later at a lower price. In order to perform the contract the trader will have to acquire the required number of shares after the contract of sale is made. Moreover, in some cases a contracting party may not only be able to contract to confer rights over property that he does not own, but may also be able to perform the contract without acquiring any such right. Thus in Bruton v London and Quadrant Housing Trust [2000] 1 AC 406 a housing trust with no interest in land was held to have validly granted a tenancy of the land to a residential occupier. The tenancy would not have been binding on the landowner, but bound the two contracting parties in precisely the same way as it would have done if the grantor had had an interest in the land. Thus in my judgment the Upper Tribunal were wrong to reverse the decision of the FTT on the question whether VCS had the power to enter into a contract. Having the power to enter into a contract does not, of course, mean that VCS necessarily did enter into a contract with the motorist to permit parking"




Parking companies managing parking on private land are required to be members of an Accredited Trade Association (ATA) if they want to access vehicle keeper details from the DVLA. These ATAs, such as the British Parking Association (BPA) and the International Parking Community (IPC), have codes of practice that their members must adhere to.

That single code states:

14.1. Where controlled land is being managed on behalf of a landowner(s), before a parking charge can be issued written confirmation must be obtained by the parking operator from the landowner(s) covering:

a) the identity of the landowner(s)

b) a boundary map of the land to be managed;

c) such byelaws as may apply to the land relating to the management of parking;

d) the permission granted to the parking operator by the landowner(s) and the duration of that permission

e) the parking terms and conditions that are to be applied by the parking operator, including as appropriate the duration of free parking permitted, parking tariffs, and specific permissions and exemptions, e.g. for staff, residents or those stopping for short periods such as taxi and minicab drivers, delivery drivers and couriers;

f) the means by which parking charges will be issued;




So if they have accessed your details held by the DVLA without having a contract they have broken the regulations




18. The Defendant has stated that the Claimant has not proved that the Defendant was the driver on the date of the contravention as is their right under statute. The Defendant is pursued as the Registered Keeper of the vehicle pursuant to Schedule 4 of the Protection of Freedoms Act 2012 ('the Act') Paragraph 4(1) which states: "The creditor has the right to recover any unpaid parking charges from the keeper of the vehicle."




The Act also states( Schedule 4 para 9 (2) (a) "The notice[to keeper} must specify.... the period of parking to which the notice relates"
The Notice to Keeper does not specify a period so liability for any unpaid charge cannot be transferred from the driver to the keeper
:




19. Paragraph 2 of the Act states that; the "keeper" means the person by whom the vehicle is kept at the time the vehicle was parked, which in the case of a registered vehicle is to be presumed, unless the contrary is proved, to be the registered keeper.




20. The relevant Notice was sent to the Defendant in accordance with the Act and the Registered Keeper (the Defendant) failed to nominate who was driving the vehicle prior to these proceedings which is required under paragraph 5(2) of the Act.




21. Despite having had ample opportunity to do so the Defendant to identify the driver at all. The Court is therefore invited to conclude it more likely than not that the Registered Keeper (i.e., the Defendant) was the driver.




Bollocks!

). In April 2023, His Honour Judge Mark Gargan sitting at Teesside Combined Court (on appeal re claim H0KF6C9C) held in Vehicle Control Services Ltd v Ian Edward that a registered keeper cannot be assumed to have been driving. Nor could any adverse inference be drawn if a keeper is unable or unwilling (or indeed too late, post litigation) to nominate the driver, because the POFA does not invoke any such obligation. HHJ Gargan concluded at 35.2 and 35.3. "my decision preserves and respects the important general freedom from being required to give information, absent a legal duty upon you to do so; and it is consistent with the appropriate probability analysis whereby simply because somebody is a registered keeper, it does not mean on the balance of probability they were driving on this occasion..." Mr Edward's appeal succeeded and the Claim was dismissed.




22. The Defendant has stated that the signage at the Land was not sufficient. This is vehemently denied by the Claimant, the signage on site clearly states, "park wholly within the lines ofa single marked bay". The Defendant has clearly contravened the displayed Terms and Conditions by not parking their vehicle wholly within the confines of a marked bay. As can be seen from the contravention images, the Defendant clearly parked over 2 bays in contravention of the Terms and Conditions of the site. Please see Exhibit ESL2.




23. The Claimant rejects any argument that the Defendant did not see the signs. It is evident from the site plan that there are sufficient signs; namely 10 signs. What is more, without concession, even in the unlikely event the Defendant didn't see the signs, the Claimant submits they ought to have done so. As Lord Justice Roch observed in the Court of Appeal case of Vine v London Borough of Waltham Forrest 2000; "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. Were that to be the law, it would be too easy for car drivers who trespass with their cars to evade the only method land owners have of stopping the unauthorised parking of cars in parking spaces or parking areas on their property".




I think somewhere you said it was possible to drivein, park up and not see the signs .. be prepared to show this on plan in your witness statement




24. In the Defendant's Defence under the sub-heading Liability as the Registered Keeper, they have stated that the Defendant admits that they are the registered keeper of the vehicle; however, denies that the Claimant is entitled to recover against the registered keeper. The Claimant would like to refer the Court to paragraphs 18-21 of this Reply to Defence and Defence to Counterclaim.




But the Notice to keeper still didn’t comply with the regulations




25. In the Defendant's Defence under the sub-heading Recovery of Claimant's Costs Associated with the Parking Charge, they have stated that the Claimant was not a party to the contract and that the pursuant of contractual costs is an abuse of process. The Claimant would like to submit that as per paragraph 12 of this Reply to Defence and Defence to Counterclaim the Claimant is the correct legal entity as per the signage at the Land. Further, the Claimant would like to refer the Court to the recent case law of Britannia Parking Group Ltd v Matthew Semark-Jullien whereby the Courts are no longer permitted to strike out an entire claim as an abuse of process where a debt recovery/contractual charge is claimed. The Claimant would like to refer to the learned judge's comments in support where he states: "Fourthly, even if it had been right to regard the debt recovery charge as unlawful, the effect of s67 of the 2015 Act is in principle that the contract otherwise continues to have effect. In other words, the claim for the £100 PCN did not necessarily fail as a result. However, the judge appeared not to have considered s67." This is further supported in the matter (which is only suasive as it is a Coun




26. Further, the signage on the Land allows the Claimant to charge £60.00 for costs incurred from debt recovery. The signage states "Vehicle Control Services Ltd will be entitled to charge a collection fee of £60.00 on an indemnity basis for costs incurred as a result of debt and/or legal recovery."




In respect of the claim against the keeper the imposition of this contractual charge is contrary to PoFA2012 Sch4 para 9 (2) (f). The keeper can’t be bound by any other “contractual” charges the parking operator might list on its signs as only the parties to a contract can be sued. The keeper is not a party to the contract and can only be sued for that amount of the original parking charge remains unpaid




Reply to Counterclaim




27. The Claimant repeats paragraphs 1 - 25 above, by vehemently denying the entirety of the Defendant's Defence and subsequent Counterclaim and the Claimant vehemently denies that the Defendant is entitled to any sums claimed, interest and damages or to any relief whatsoever for all the reasons outlined throughout this statement of case and the Claimant again requires the Defendant to prove the matters set out in the Defence and subsequent Counterclaim.







28. The Defendant has submitted a Counterclaim for £550.00 for "damages for distress and loss."




29. The Claimant submits that the Defendant has not provided any proof and/or substantiated his loss. Moreover, and despite the absence of evidence provided by the Defendant, the Claimant humbly submits that such costs are not recoverable in any event. This position is based on the understanding that the current legal dispute falls firmly within the jurisdiction of the small claims track, and according to the Civil Procedure Rules ("CPR") 27, costs associated with this type of claim are deemed unrecoverable. In other words, even if the Defendant were to provide evidence of her hourly rate, the Claimant humbly submits that such costs cannot be reclaimed due to the specific legal framework governing small claims cases.




CPR27.14 (g) allows costs to be awarded for unreasonable behaviour

.I suggest supplying photos of signs and contract authorising Excel, but then ELMS arguing it is VCS and supplying not the contract, but a confirmation statement is if not deliberate at very least incompetent and unreasonable







30. The Defendant has stated that the reason for their Counterclaim is due averring that the Claimant breached their duty under the Data Protection Act 2018 (“DPA") and the General Data Protection Rules ("GDPR"). The Claimant has not breached the DPA. The Claimant lawfully obtained the Defendant's name and address from the DVLA as the parking charge remained unpaid. Further, the Claimant had reasonable grounds to request the Defendant's details from the DVLA pursuant to schedule 4 (1) of the Protection of Freedoms Act 2012 which states "The creditor has the right to recover any unpaid parking charges from the keeper of the vehicle"




If the signs stated EXCEL as operator then VCS should not have had the vehicle details and should not have applied for keepers details. This is a breach og GDPR




31. The Defendant alleges that the Claimant has breached the DPA; however, has failed to provide any documentation in support. Nevertheless, this is firmly rejected.




32. It is evident that the Claimant is a private parking company which operates parking enforcement/management on the Land. Signs were erected on the Land which details the applicable parking regulations. The signs form the contract between the Claimant and the motorist.




33. The Claimant has entered into a contract with the DVLA for the provision of data regarding the keeper of the vehicle at the date of an event using an electronic service, otherwise known as the KADOE Agreement. The Claimant has to ensure that it complies fully with the data governance and control requirement and procedures laid down in that Agreement.
KADOE agreement was withdrawn in 2015 (https://www.gov.uk/government/public...event-contract)
The company now must be a member of an Accredited Trade Association (ATA) and abide by their rules


34. As stated above a parking charge notice was issued as the Defendant's vehicle was found parking on the Land not in accordance with the signs. In light of this, the Claimant had a "reasonable cause" to apply to the DVLA for the Registered Keeper (Defendant's) details. The information was sought from the DVLA in good faith.




35. The Claimant processed the Defendant's details in order to recover the unpaid parking charge (which was issued correctly and which the Defendant is liable for, pursuant to the contract) and therefore, the processing of the data was necessary. Further, the data has not been processed unlawfully or unfairly. As stated above, the Defendant's data was processed to recover the unpaid parking charge which was owed to the Claimant and therefore, the Claimant had legitimate grounds for collecting and using the data.




36. Further to the above, the signs advise that if the parking charge remains unpaid it may result in vehicle keeper details being requested from the DVLA. As such, the Claimant respectfully submits that the Defendant was or ought to have been aware that such a request would be made therefore rendering the processing of data fair. The data was then passed to ELMS Legal Ltd when the Claimant instructed them to seek recovery of the unpaid parking charge. The processing of such data did not unjustifiably have a negative effect on the Defendant.




37. Furthermore if, which is vehemently denied, the Defendant has indeed suffered a loss, the Defendant is put to strict proof to show all reasonable steps taken by her to mitigate such losses. Conclusion

No need to show loss




38. In light of all the above, the Claimant seeks that the Defendant's Defence and subsequent Counterclaim be dismissed especially as no actual legal Defence has been provided as to why the Defendant parked their vehicle in the manner she did (across 2 bays) and further, the Claimant seeks their costs, by way of summary assessment, pursuant to CPR 27.14 (2)(g).

who has shown the defendant was the driver?




I think your counter claim is quite clear that you do not have to prove actual loss



This response doesn't really go to the heart of the matter and the Respondent to this counterclaim seems to be deliberately misleading the court.

The original parking contract was between the driver and Excel as is evidenced by the photographs of signage attached (exhibit1)

Excel were authorised by savills acting on behalf of Land owner (copy contract attached exhibit 2)

There was no contract between the driver and VCS




CPR27.14 (g) costs unreasonable behaviour

[des8]

In post 4 you posted a picture of the parking sign.
Did you take the picture yourself?
If you did so on a mobile phone you can access the time and date it was taken, which will be of enormous benefit in court.

Thanks for the info sent via Nick

If the information supplied to you in response to your CPR31.14 request was false ( they sent several photos of signs showing Excel and a copy of the excel/savils contract) they are in trouble as that could/should be taken as contempt of court. It will allow the court to strike out their claim and award costs to you (which is unusual to obtain on the small claims track).
If that information supplied is correct, they will be in trouble for falsely claiming VCS are in charge and producing a witness statement confirming that fact.

[Silver Paw]

Hello Good afternoon DES8,

Yes, first picture of the parking sign I uploaded to imgur website. I took the picture on 11th May 2025. I can access it on my phone, I think it has location enabled thus also show the GPS location where the picture was taken.

As I mentioned in one of the earlier post the 2019 single page Savills / VCS limited contact they sent later on after I filed a counter claim was not supplied to me in response to my CPR31.14 request. They only sent several photos of signs showing Excel as the car park operator and a copy of the excel/Savills contract drawn up in April 2024.

I think you are the one who spotted this first, because you replied to inform me that the company which issued the PCN is not the same company which operate the car park. You mentioned that they could be sharing the same desk or something along the line.

It would be good to find out from you how to get the court to strike out the case based on the fact that the 2019 single page VCS limited contact was not supplied in response to the CPR31.14

I personally think that VCS limited had the original contract with Savills. There in April 2024 the contract was awarded to Excel Parking. Therefore not sure how VCS limited can issue a PCN in August 2024 for a car park that they have no contract to run or mange (although they many have been managing the car park for Excel Parking indirectly/ illegally as both companies are owned by the same parent company) . Let me know if I can just put this as a simple point in my witness statement without any legal jargon.

Now that the august holidays are over we are all back at work and I am in receipt of further correspondence from the local county court with details of the hearing date. I have crossed out my personal details and the time and uploaded to the google drive.

I also had two of my friends check to see if they can access the link I sent them from their own computers to ensure the link is accessible. I was told by my other half all the other links that you were not able to open should also now be able to open. So many different buttons to press to allow unrestricted access.

Please see link below for the letter from the court dated 2nd Sep 2025

https://drive.google.com/file/d/1V0a...usp=drive_link



Apparently I have to submit everything by end of September 2025.

Should I now do the following:

- Write out my own witness statement
- Print out all the pictures I have taken of the signs in the car park
- enclose copy of the response I received for the CPR 31.14 request

Then submit it to the court clark by end of this month.

If there is anything else that I need to do, especially for my counter claim then let me know please.

Thank you

Regards

[des8]

Yes, you ned to write your witness statement.
I suggested you started to draft it back in July as it is not a document to write in a rush.
The format is important,
There is guidance on this site via the SHORTCUTS panel on the right hand of this page.
If you want you can post up your draft for comment