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ostell Having gone through to the MCOL defence page on the website, i can only submit 122 lines of text, which the full defence is longer than.
Would this work...
I am X, the Defendant in this matter and was the registered keeper of vehicle X at the time of the alleged offence. I currently reside at X
This is my statement of truth and my defence
As an unrepresented litigant-in-person, I seek the Court's permission to amend and supplement this defence as may be required upon disclosure of the Claimant's case.
For the avoidance of doubt on the relevant date, I was the registered keeper of a X.
It is believed that it will be a matter of common ground that the purported debt arose as the result of the issue of a parking charge notice in relation to an alleged breach of the terms and conditions by the driver of the above vehicle when it was parked at X car park in X on 01/06/2019.
Until the receipt of the Claim Form on the 12th November, I was unaware of any PCN.
On 21st November 2020, I wrote to the Claimant requesting disclosure of their documents supporting their case. In line with the claimants CPR 31 duties. They must ensure that the document(s) requested are copied to and received by the defendant within 7 days of receipt of this letter
A copy of this letter can be supplied along with the official Post Office receipt showing when this was posted.
Without disclosure of their documents, I am unable to compile a fair and complete defence and request that the court order the claimant to produce their documents so that a proper defence can be prepared. This should be done entirely at their own cost.
Without access to these documents, I would request the court reject this claim.
Thank you
OJ
Would this work...
I am X, the Defendant in this matter and was the registered keeper of vehicle X at the time of the alleged offence. I currently reside at X
This is my statement of truth and my defence
As an unrepresented litigant-in-person, I seek the Court's permission to amend and supplement this defence as may be required upon disclosure of the Claimant's case.
For the avoidance of doubt on the relevant date, I was the registered keeper of a X.
It is believed that it will be a matter of common ground that the purported debt arose as the result of the issue of a parking charge notice in relation to an alleged breach of the terms and conditions by the driver of the above vehicle when it was parked at X car park in X on 01/06/2019.
Until the receipt of the Claim Form on the 12th November, I was unaware of any PCN.
On 21st November 2020, I wrote to the Claimant requesting disclosure of their documents supporting their case. In line with the claimants CPR 31 duties. They must ensure that the document(s) requested are copied to and received by the defendant within 7 days of receipt of this letter
A copy of this letter can be supplied along with the official Post Office receipt showing when this was posted.
Without disclosure of their documents, I am unable to compile a fair and complete defence and request that the court order the claimant to produce their documents so that a proper defence can be prepared. This should be done entirely at their own cost.
Without access to these documents, I would request the court reject this claim.
Thank you
OJ
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