**WON!!!!!!!** PCM (uk) ltd Gladstones court

[mystery1]

Re: PCM (uk) ltd Gladstones court

I'll do this, this weekend ;okay;

M1

[Davew2811]

Re: PCM (uk) ltd Gladstones court

I'll do this, this weekend ;okay;

M1

Thanks

As I said, I have lots of photographic evidence, even their own photos show that the signs the have taken close ups of are obscured by other vehicles.

Als, they could not access the sign they claim I was parked in front of so there is no close up of the wording on it.

Dave

[Davew2811]

Re: PCM (uk) ltd Gladstones court

Hi M1, Do you think you'll have time to do this ? I understand you're very busy on here lol

I'm out of the country for 5-6 weeks from 29th Aug on business so I'd like to file a defense before I go ..

Thanks again for the help so far.

D

[mystery1]

Re: PCM (uk) ltd Gladstones court

Hi M1, Do you think you'll have time to do this ? I understand you're very busy on here lol

I'm out of the country for 5-6 weeks from 29th Aug on business so I'd like to file a defense before I go ..

Thanks again for the help so far.

D

It's not whether i have the time, really, it's whether the sport slows down enough so i'm not distracted combined with not wanting to do it too soon in case they see sense and decide to plead properly once you've already entered a defence to the shite pleadings.

As the Olympics is tailing off tonight/tomorrow i'll be putting in a bit of effort very soon to clear the backlog.

M1

[paul1909uk]

Re: PCM (uk) ltd Gladstones court

Sounds fair enough M1. I've had a reply today from Gladstone solicitors saying that they felt there was enough detail in the Particulars of Claim to proceed to court

[mystery1]

Re: PCM (uk) ltd Gladstones court

Davew2811def.rtf

Edit to suit. Note the parking arguments are irrelevant until they plead such so do prepare but i wouldn't put them in a defence until required.

M1

[Davew2811]

Re: PCM (uk) ltd Gladstones court

Hi, Thanks for this, it's quite technical and argues against their pleading of the case but they are claiming that the pleading is acceptable?

I have to send a copy to Gladstones too?

If I send this defence then do I get a further opportunity to submit evidence related to the misleading / unreadable signage

Dave

[Davew2811]

Re: PCM (uk) ltd Gladstones court

I have JUST received this response from Gladstones in follow up to my email to them ..

I sent:
Hi, With reference to my telephone conversation with you on Wednesday afternoon (17th Aug)
Can you please confirm that you will not re-plead your case without being asked too by the court.

Also, Can you please send me the following:
1: The address & contact details of the landowner that your client claim to act on behalf of at Great West Quarter.
2: A copy of the contract between the landowner and your client for this service.

Many thanks in advance.


They replied this morning:

We are proceeding with the claim and evidence will be provided in our Client's witness statement as and when it is requested by the court.

[mystery1]

Re: PCM (uk) ltd Gladstones court

Hi, Thanks for this, it's quite technical and argues against their pleading of the case but they are claiming that the pleading is acceptable?

I have to send a copy to Gladstones too?

If I send this defence then do I get a further opportunity to submit evidence related to the misleading / unreadable signage

Dave

The pleadings are garbage, but ultimately it is for the court to decide. They always say their pleadings are perfect.

http://parking-prankster.blogspot.co...1_archive.html

"The judge then made it clear that the particulars were "spectacularly unhelpful" in determining the cause of action, and, in the absence of a contract, and no evidence of tortuous damages, together with Particulars of Claim that were "woefully inadequate" he dismissed the claim with costs of £52 to the very relieved defendant."

If the claimant is allowed to amend their pleadings, you should be able to amend your defence. We will be trying to stop them amending it though. We told them it was garbage and they should have reacted to that. You could, if you wanted, make your defence about parking but that wouldn't align very well with the case against you which, as yet, is practically non existent.

M1

- - - Updated - - -

I have JUST received this response from Gladstones in follow up to my email to them ..

I sent:
Hi, With reference to my telephone conversation with you on Wednesday afternoon (17th Aug)
Can you please confirm that you will not re-plead your case without being asked too by the court.

Also, Can you please send me the following:
1: The address & contact details of the landowner that your client claim to act on behalf of at Great West Quarter.
2: A copy of the contract between the landowner and your client for this service.

Many thanks in advance.


They replied this morning:

We are proceeding with the claim and evidence will be provided in our Client's witness statement as and when it is requested by the court.

That's fine, it confirms they are happy with your version of the call.

M1

[Davew2811]

Re: PCM (uk) ltd Gladstones court

Ok M1, Thanks.

I'll submit the defence today

D

[Davew2811]

Re: PCM (uk) ltd Gladstones court

Ok, I've submitted the defence using the online system. Do I need to send a copy to Gladstones ?

[mystery1]

Re: PCM (uk) ltd Gladstones court

No, the court does that.

M1

[emanresu]

Re: PCM (uk) ltd Gladstones court

Re: the red signs. There are a couple of live examples at the moment where claims are being issued for hot spots such as this nursery. The MO appears to be PCM or another IAS member messes up the signs and issues a lot of tickets. Landowner gets complaints and red signs go up or yellow lines go down. Problem disappears and Landowner happy.

Then they send out claims saying red signs/yellow lines were there - pay up. The only solution so far is to get copies of the timestamped pics early as you'll never see them until 14 days before a hearing.

Classic case going on in West London at the moment where PCM have been caught with a couple of bare faced lies to the local council. They'll shrug it off as usual, but be aware of the changing the signs issue.

[mystery1]

Re: PCM (uk) ltd Gladstones court

Re: the red signs. There are a couple of live examples at the moment where claims are being issued for hot spots such as this nursery. The MO appears to be PCM or another IAS member messes up the signs and issues a lot of tickets. Landowner gets complaints and red signs go up or yellow lines go down. Problem disappears and Landowner happy.

Then they send out claims saying red signs/yellow lines were there - pay up. The only solution so far is to get copies of the timestamped pics early as you'll never see them until 14 days before a hearing.

Classic case going on in West London at the moment where PCM have been caught with a couple of bare faced lies to the local council. They'll shrug it off as usual, but be aware of the changing the signs issue.

Unless they get a very friendly judge then the parking side is going to have no bearing on matters. The pleadings are crap, they've been told they are crap and stuck two fingers up. The court should be throwing this straight out, hopefully without getting to a trial.

All good ammo to have in the background just in case the judge decides pleadings don't matter and allows an amendment though.

M1

[Davew2811]

Re: PCM (uk) ltd Gladstones court

Thanks for the input, I have takem plenty of photos over the months just in case and cas show the progression of changes they have made .
If this does go to court I believe I have a very strong case against them for what is effectively fraud !