County Court Claim form from Britannia Parking Group for Private carpark PCN (HELP)

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let me check i set all the images

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this?

[ostell]

So they have failed to give the invitation to keeper prescribed by 9 (2) (e)

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sorry these images did not upload first time

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what is my next move now?

[ostell]

You start preparing your defence.

They also did not give period of parking

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can you help me set out my defence. i honestly don't have a clue..

[logies]

can you help me set out my defence. i honestly don't have a clue..

[ostell]

In the Shortcuts panel there is a sample defence. Though this is for financial matters the format will be the same.

You state that you were not the driver and admit you are the registered keeper

You will be mentioning the failures to comply with POFA and hence no keeper liability,

The parking company have refused your request for details of the signs that created the contract and therefore have problems responding to the claim as you were not there at the time

You request that when details of the signage are made available that you have permission to amend your defence with the cost of this being borne by the claimant.


Have a read of this about the additional costs added and try and get the detail in. https://www.dropbox.com/s/16qovzulab...inson.pdf?dl=0

[logies]

my wife is the registered keeper

[ostell]

So do not put in that you were not the driver.

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first draft. feedback please

In the Northampton County Court Business Centre

Claim No:

Claimant
Britannia Parking Group

And

Defendant

DEFENCE
1.The Defendant received the claim from the Northampton County Court on 14/2/2021 2.Each and every allegation in the Claimants statement of case is denied unless specifically admitted in this Defense.

2.This claim £105.46 a PCN for a contractual breach which occurred on 12.5.2020 in the private car park/land at Orpington – Orpington Retail Park BR5 3SR in relation to
A PCN was issued as the driver failed to comply with the terms and condition displayed. Despite demands, the charge remains unpaid. The claim also includes Statutory Interest pursuit to section 69 of the County Courts Act 1984 at a rate of 8% per annum (a daily rate of 0.02%) from 12/5/2020 to 8/2/2021 being a total amount of £5.46.
The claimant also claims £60.00 recovery costs as set out in the Terms and Conditions and in the ATA AoS Code of Practice.

3.The Claimants statement of case fails to give adequate information to enable me to properly assess my position with regards the claim.

4.The Claimant’s Particulars of Claim. Failure to comply with POFA and hence no keeper liability,

The parking company have refused my request for details of the signs that created the contract and therefore have problems responding to the claim.

I have requested that when details of the signage are made available that I have permission to amend my defense with the cost of this being borne by the claimant.

5. The Defendant respectfully requests the court orders the Claimants to provide the necessary documentation in order for The Defendant to fully plead her case else the Claim should stand struck out.

6.In the event that the relevant documents are received from the Claimant, the Defendant will then be in a position to amend her defence, and would ask that the Claimants bear the costs of the amendment.
7.It is denied that the Claimant is entitled to the relief as claimed or at all.
Statement of Truth
The Defendant believes that the facts stated in this Defence are true.
Signed ________________________________
Dated ________________________________

[ostell]

4 You request the sign details from the solicitor?

You have request permission to amend twice

Defence is with a C and not S

[logies]

revised.

first draft. feedback please

In the Northampton County Court Business Centre

Claim No:

Claimant
Britannia Parking Group

And

Defendant

DEFENCE
1.The Defendant received the claim from the Northampton County Court on 14/2/2021 2.Each and every allegation in the Claimants statement of case is denied unless specifically admitted in this Defense.

2.This claim £105.46 a PCN for a contractual breach which occurred on 12.5.2020 in the private car park/land at Orpington – Orpington Retail Park BR5 3SR in relation to
A PCN was issued as the driver failed to comply with the terms and condition displayed. Despite demands, the charge remains unpaid. The claim also includes Statutory Interest pursuit to section 69 of the County Courts Act 1984 at a rate of 8% per annum (a daily rate of 0.02%) from 12/5/2020 to 8/2/2021 being a total amount of £5.46.
The claimant also claims £60.00 recovery costs as set out in the Terms and Conditions and in the ATA AoS Code of Practice.

3.The Claimants statement of case fails to give adequate information to enable me to properly assess my position with regards the claim.

4.The Claimant’s Particulars of Claim. Failure to comply with POFA and hence no keeper liability,

The Claimant have refused my request for details of the signs that created the contract and therefore have problems responding to the claim.

5. The Defendant respectfully requests the court orders the Claimants to provide the necessary documentation in order for The Defendant to fully plead her case else the Claim should stand struck out.

6.In the event that the relevant documents are received from the Claimant, the Defendant will then be in a position to amend her defence, and would ask that the Claimants bear the costs of the amendment.

7.It is denied that the Claimant is entitled to the relief as claimed or at all.
Statement of Truth
The Defendant believes that the facts stated in this Defence are true.
Signed ________________________________
Dated ________________________________

[ostell]

Have a look here :https://www.dropbox.com/s/16qovzulab...inson.pdf?dl=0
The case showed that the extras were abuse of process and the claim was thrown out. If you could precis this down and mention this case. It is no binding put it could be persuasive. It biled down to the Beavis case on appeal showing that the sum claimed, £85 at the time, was sufficient to cover recovery costs as well