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Parking Eye PCN - Help with defence

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  • #16
    Re: Parking Eye PCN - Help with defence

    Beavis is going to be 2 weeks at least as the courts are on Easter break. The defence is due to be lodged by 11/4/15 based on an issue date of 9/3/15 and the AOS having been filed.

    What i would do is ask for an extension to the period for filing your defence.

    Dear Parking Eye,

    As you will no doubt be aware the last date for filing a defence in this case is 11/04/15. You will also be aware that the Parking Eye v Beavis court of appeal judgement is due soon. In light of this i would seek your agreement pursuant to CPR 15.5 that the defence filing date be extended to 09/05/15 being the maximum allowed.

    It makes no sense to rush matters before the handing down of Beavis as the arguments would need changing which would incur time and expense for all parties and the court which is contrary to the over riding objective. I note that Parking Eye popla appeals are being held over for this exact reason.

    Yours etc


    If they fail to agree your request, which they probably will, i will be off work on 7th and 8th so can do the defence then and it also helps raise unreasonable behaviour on the part of the claimant which could help with costs further down the line.

    M1

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    • #17
      Re: Parking Eye PCN - Help with defence

      Excellent! Can't thank you enough! Will get on it

      Comment


      • #18
        Re: Parking Eye PCN - Help with defence

        [MENTION=5354]mystery1[/MENTION] should I email this request to parking eye or by post?

        Comment


        • #19
          Re: Parking Eye PCN - Help with defence

          I'd email it. You could follow up with a letter if your works buys stamps

          I'd also add to the letter/email - In the event you refuse my request for an extension i would ask that you agree to an amendment of my defence to take the Beavis result in to account which will narrow the scope of the case which fulfils both our cpr duties under the over riding objective.

          M1

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          • #20
            Re: Parking Eye PCN - Help with defence

            I'll have to send them a letter as my brother doesn't have to parking charge reference required to send an email. Unless I can email appeals@parkingeye.co.uk?

            Comment


            • #21
              Re: Parking Eye PCN - Help with defence

              Email should be fine.

              The parking charge number is on the claim form at the bottom of the statement of case.

              M1

              Comment


              • #22
                Re: Parking Eye PCN - Help with defence

                [MENTION=5354]mystery1[/MENTION] no responce to the letter as of yet. Guess we'll have to file the defence!

                Comment


                • #23
                  Re: Parking Eye PCN - Help with defence

                  Phone them up and ask.

                  I miscalculated my time off so will get to it late on 10th so you can email it on 11th.

                  M1

                  Comment


                  • #24
                    Re: Parking Eye PCN - Help with defence

                    cassas00.rtf

                    M1

                    Comment


                    • #25
                      Re: Parking Eye PCN - Help with defence

                      Your help has been greatly appreciated

                      Comment


                      • #26
                        Re: Parking Eye PCN - Help with defence

                        [MENTION=5354]mystery1[/MENTION]

                        My brother just received, what I can only describe as, a booklet through the door.

                        List of what he recieved:

                        Cover letter indicating notice to proceed
                        Photos of signage
                        Signage Plan
                        Aerial photo of car park with all signs indicated
                        Directions questionnaire (small claims track)
                        All previous letters sent
                        original penalty and photos of the car etc
                        parking eye vs beavis approved judgement (17 pages)
                        Reply to defence (13 pages)

                        Comment


                        • #27
                          Re: Parking Eye PCN - Help with defence

                          Photos of signage
                          Signage Plan
                          Aerial photo of car park with all signs indicated
                          original penalty and photos of the car etc
                          Reply to defence (13 pages)


                          Any chance of seeing those ?

                          The DQ will need filled in and a letter requesting a stay pending the Beavis supreme court verdict sent with it. http://parking-prankster.blogspot.co...yed-until.html
                          http://parking-prankster.blogspot.co...l-supreme.html

                          M1

                          Comment


                          • #28
                            Re: Parking Eye PCN - Help with defence

                            Defence will follow. I could only submit part of the defence due to text character restraints
                            Attached Files

                            Comment


                            • #29
                              Re: Parking Eye PCN - Help with defence

                              defence pages 1-5
                              Attached Files

                              Comment


                              • #30
                                Re: Parking Eye PCN - Help with defence

                                defence pages 6-10
                                Attached Files

                                Comment

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