Help! defending court claime from BM legal on behalf of NCP.

[sapphys mum]

Hello all,
I hope you might be able to help me with the wording of my defence for to the claimant in respect of a parking charge notice.
* The claim is for " the sum of £170.88 being monies due from the defendant

to the claimant in respect of

a parking charge notice for a parking contravention which occurred on....in the private car park/land at …..in relation to a vehicle (model) registration mark..... The defendant was allowed 28 days from the pcn date to pay the PCN, but failed to do so. despite demands having been made, the defendant has failed to settle their outstanding liability .The claim also includes statutory interest pursuant to section 69 of the county courts act 1984 at a rate of 8% per annum....from......to.....being an amount of £10.88.The claimants claim*

includes £60 costs

as set out in the terms and conditions.
This is just shy of £250 which I cant afford to pay.* The claim form was dated 4th February 2020 and I have sent off my form today by recorded delivery to defend all the claim. I am in the process of doing the SAR form to send to National car parks by email. However, I don't think it will be back in time for when I have to have my defence into the court as I believe they have 40 days to respond ?*
The registered keeper of the car had letters with the car registration photographed arriving and leaving the multi storey car park. The driver of the car has not been disclosed.*

Is there a template I can use? The photos of the car arriving and leaving do not prove how long the car was parked or how long the space was occupied so can they prove that the car over stayed the ticket that was purchased from a machine on the ground level ?
Any help would be greatly appreciated. I'm not very technical .
Sapphys mum*
*

[ostell]

So have you still got the first letter to the registered keeper?

[sapphys mum]

No, I thought if I ignored them they would eventually give up so I got rid of them.*

[ostell]

So a letter to the solicitor demanding copies of all the documents that the intend to use in court, in order to narrow the issues between you, as expected by the courts.* You expect this by return but in any case within 7 days