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County Court Claim - PCM and Gladstones Sollicitor
da_tnt
post Mon, 13 Aug 2018 - 13:49
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Hi,

Back in October 2017, the following vehicle was parked in a restricted area of a residential development for about half an hour to accept a delivery of beds. Note that the registered keeper owns a flat in the development and have a secure underground parking. The driver needed to be close to the entrance to help with the unloading of bulky items.

The parking is managed by Parking Control Management. The driver has not seen a parking warden and did not get a PCN on the windscreen. Later on, a PCN was sent by post with pictures that seem to have been taken from far away from a CCTV? The PCN is for £100 and would go up to £160 after 28 days. The PCN is issued to the registered keeper of the vehicle.

I have ignored all correspondence regarding this until I received a County Court Claim Form dated 10/08/18. I have acknowledged the claim this morning (13/08) and I am planning to post here my draft defence for some advice. In addition to the £160, the claim adds £50 legal fees, £25 court fees and approx £8.95 interest.

I have attached the original ticket, the claim form, some pictures from the ticket and google maps. I will try and take a closer picture of the signage and post it here.

I am thinking to start with the following items:
1. The Claimant has no standing to bring a case.
2. The signage is not adequate and does not offer a contract with the motorist.
3. Falsified solicitor costs
4. Claimant failed to meet Notice to Keeper obligations
5. Not sure if I can include : "Claim not correctly filed under The Practice Direction"

As I have thrown away all correspondence, I was planning on asking them to send a copy of all correspondence by email.

















Any ideas would be welcome, I will now do more research on previous cases to finish my draft

Thanks

This post has been edited by da_tnt: Mon, 13 Aug 2018 - 19:05
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Eljayjay
post Fri, 7 Sep 2018 - 14:11
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In my opinion, whilst you can include what you like in your defence, it needs to focus on:-

The fact that you are a leaseholder.

Your lease governs the behaviours, relationships, rights and obligations of the parties to it.

The claim is for a parking charge but the amounts due from you on an ongoing basis under your lease do not include parking charges.

Although your lease may not have conferred a right for you to park where you parked, you needed to do so to facilitate the unloading of an awkward and heavy load from your vehicle into your apartment – just like Jopson in Jopson v Homeguard.

If by parking where you parked, you unwittingly breached a term in your lease, it is not a matter which seems to concern the other parties to it because they have not raised it as an issue.

If the other parties had deemed it to be a breach of the lease of any significance, their remedy would be to seek damages from you and/or an injunction ordering you not to repeat the breach.

The remedy would not be an arbitrary parking charge payable to a person, such as the Claimant, who is not even a party to the lease.

Even if your lease did oblige me to pay parking charges, which is denied, your lease does not contain a clause [made in accordance with the Contracts (Rights of Third Parties) Act 1999] permitting a stranger to the lease, such as the Claimant, to enforce the terms of your lease.

Your lease has primacy of contract over any arrangement agreed between a party to it and the Claimant.

Even if the above arguments do not find favour, the Claimant’s signage is forbidding in that it states in capital letters “NO PARKING IN THIS AREA / EITHER WHOLLY OR PARTIALLY AT ANY TIME” but then seeks to offer parking there contrary to the finding in PCM-UK v Bull.

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da_tnt
post Fri, 7 Sep 2018 - 16:35
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QUOTE (Eljayjay @ Fri, 7 Sep 2018 - 15:11) *
In my opinion, whilst you can include what you like in your defence, it needs to focus on:-

The fact that you are a leaseholder.


Thank you for the above, I am editing argument 1 in my letter and have added 3 more bullet points on the leasehold.

Question is shall i say the driver was a leaseholder or the registered keeper was a leaseholder?
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da_tnt
post Fri, 7 Sep 2018 - 16:51
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Ok - this is what I hope is the final version, any thoughts?

1. The claimant has no standing to bring a case.

a. The particulars of claim state that “the driver of the vehicle incurred the parking charge on 30/10/2017 for breaching the terms of parking on the land at xxxxxx”; They are therefore acting as agents of the landowner.
b. The claim does not give a cause of action
c. The claimant has not defined who they are claiming from
d. It is believed Parking Control Management (UK) LTD do not hold a legitimate contract at this car park. As an agent, the Claimant has no legal right to bring such a claim in their name which should be in the name of the landowner.
e. The driver of the vehicle is a leaseholder of this apartment block with a dedicated underground parking space. The lease governs the behaviours, relationships, rights and obligations of the parties to it. The claim is for a parking charge but the amounts due by the driver on an ongoing basis under the lease do not include parking charges. The lease gives access to the leaseholder to common parts of the development such as access roads and laydown areas which have conferred a right for the driver to park in that location, in order to facilitate the unloading of an awkward and heavy load from the vehicle into the apartment (large bed delivery) – just like Jopson in Jopson v Homeguard.
f. If the other parties had deemed it to be a breach of the lease of any significance, their remedy would be to seek damages from you and/or an injunction ordering you not to repeat the breach. The remedy would not be an arbitrary parking charge payable to a person, such as the Claimant, who is not even a party to the lease.

2. The claimant claims that the defendant is in breach of the T&Cs in which drivers are allowed to park in condition with. But the signage does not offer a contract and is also poorly light.

a. The signage at the sign entrance is sparse, with no mention of the terms and conditions of the car park or the penalty of breaching the terms, violating POFA 2012 Schedule 4 and the BPA Code of Practice.

b. The small print on the signage does not allow the driver of any vehicle to read the terms and conditions of the car park until they are already in the car park and have been photographed by the Automatic Number Plate Recognition camera. There is no opportunity to make a decision not to enter the car park after reading the signs.

c. The alleged contract is unfair, not agreed by the driver, and contrary to the Consumer Rights Act 2015 in requiring a huge inflated sum as 'compensation'.

d. No promise was made by the driver that could constitute consideration because there was no offer neither known nor accepted. No consideration flowed from the Claimant.

e. This case can be distinguished from ParkingEye v Beavis [2015] UKSC 67 (the Beavis case) which was dependent upon an undenied contract, formed by unusually prominent signage forming a clear offer and which turned on unique facts regarding the location and the interests of the landowner. Strict compliance with the BPA Code of Practice (CoP) was paramount and Mr Beavis was the driver who saw the signs and entered into a contract to pay £85 after exceeding a licence to park free. As far as I can ascertain, based upon the very vague particulars of claim and complete lack of evidence and photographs, and without having been furnished with the alleged signage none of this applies in this material case.

f. The wording of the signage forbids parking, then there is no offer to park and therefore no contract. The Claimant’s signage is forbidding in that it states in capital letters “NO PARKING IN THIS AREA / EITHER WHOLLY OR PARTIALLY AT ANY TIME” but then seeks to offer parking there contrary to the finding in PCM-UK v Bull.

3. This Claimant has not complied with pre-court protocol (as outlined in the new Pre Action Protocol for Debt Claims, 1 October 2017) by;

a. Not providing a copy of the alleged contract to the Defendant. This prevents a full defence being filed at this time as a parking charge can be for trespass, breach of contract or a contractual charge. All these are treated differently in law and require a different defence. The wording of any contract will naturally be a key element in this matter.

b. Failing to issue a compliant notice to keeper within 14 days under Schedule 4 of the Protection of Freedoms Act 2012 such that Claimant is unable to hold the Defendant liable under the strict keeper liability provisions.

c. Issuing a sparse, mail-merged and non-compliant Letter before County Court Claim; under the Practice Direction. This constitutes a deliberate attempt to thwart any efforts to defend the claim or to take stock, pursuant to paragraph 12 of the Practice Direction. Again, this contradicts the guidance outlined in the new Pre-Action Protocol for Debt Claims (2017).

d. A Schedule of information sparse of detailed information.

4. The Claim Form issued on 10/08/2018 by Parking Control Management (UK) LTD was not correctly filed under The Practice Direction as;

a. It was not signed by a legal person but signed by Parking Control Management (UK) LTD (claimants legal representative).

b. It failed to disclose any cause of action in the incorrectly filed Claim Form issued on 10/08/2018.

c. The Claim Form Particulars were extremely sparse and divulged no cause of action nor sufficient detail. The Defendant has no idea what the claim is about - why the charge arose, what the alleged contract was; nothing that could be considered a fair exchange of information.

d. The Claim Form Particulars did not contain any evidence of contravention or photographs.

e. The Defence therefore asks the Court to strike out the claim as disclosing no cause of action and having no reasonable prospect of success as currently drafted.

Alternatively, the Defendant asks that the Claimant is required to file Particulars which comply with Practice Directions and include at least the following information:

i. Whether the matter is being brought for trespass, breach of contract or a contractual charge, and an explanation as to the exact nature of the charge

ii. A copy of any contract it is alleged was in place (e.g. copies of signage)

iii. How any contract was concluded (if by performance, then copies of signage maps in place at the time)

iv. Whether keeper liability is being claimed, and if so copies of any Notice to Driver / Notice to Keeper

v. Whether the Claimant is acting as Agent or Principal, together with a list of documents they will rely on in this matter

vi. If charges over and above the initial charge are being claimed, the basis on which this is being claimed

vii. If Interest charges are being claimed, the basis on which this is being claimed.

Once these particulars have been filed, the Defendant asks for reasonable time to file another defence.

5. The claim includes a sum of £50, described as “Legal representative’s costs”. The Claimant is known to be a serial litigant. Given a standard working week, the claimant’s legal representative can spend no more than a few minutes per claim, hardly justifying the £50. Since these are fully automated, no intervention is required by a solicitor, and the Claimant is put to strict proof to show how this cost has been incurred. The Claimant maintains case notes for each person who has accessed the case, and it is suggested this would be sufficient. The Claimant cannot rely on Nossen’s Letter Patent (1969) to justify the charge, as this is part of their everyday routine, and no expert services are involved. The £50 is not valid because it is not incurred by the claimant.

6. Notice to Keeper Obligations
a. The Claimant failed to meet the Notice to Keeper obligations of Schedule 4 of the Protection of Freedoms Act 2012. Absence of such a notice served within 14 days of the parking event and with fully compliant statutory wording, this Claimant is unable to hold the defendant liable under the strict keeper liability provisions. Additionally, the Claimant has been known in other cases to specifically state during the appeal period, that they would not be relying on the Protection of Freedoms Act 2012, waiving their right to seek keeper liability. The Defendant is not therefore liable for the claim and invites the court to strike it out. In any case, there is no such obligation in law and this was confirmed in the POPLA Annual Report 2015 by parking expert barrister and Lead Adjudicator, Henry Greenslade, who also clarified the fact that a registered keeper can only be held liable under the POFA Schedule 4 and not by presumption or any other legal argument.
b. As the claimant is claiming from the registered keeper then the maximum they can claim is the amount of the original PCN (POFA 4(5)) – which is £100 according to the sign and not £160 as highlighted in the claim which includes “damages and indemnity costs”.
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Eljayjay
post Fri, 7 Sep 2018 - 19:32
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Below, I show how I believe your statement of defence should start. These are what I consider the compelling points to be. Each numbered point is important in its own right and they should not be squeezed together. Obviously, if you wish to add other points about POFA, etc., that is entirely up to you. In my opinion, however, anything else is of secondary importance.

1. I, <full name>, of <address> am the Defendant in this case and I make this my statement of defence.

2. The Defendant admits that, when the vehicle <registration number> was parked at <location> on <date of event>, the Defendant was its driver.

3. The Defendant does, however, deny that he owes any amount to the Claimant for parking on this or any other occasion.

3. The location is an apartment block where the Defendant is the leasehold owner of one of the apartments.

4. The Defendant’s lease governs the behaviours, relationships, rights and obligations of the parties to it. The lease is of paramount importance.

5. The lease covers a wide range of matters including parking.

6. The claim is for a parking charge, but the amounts due from the Defendant under his lease on an ongoing basis do not include parking charges.

7. Although the Defendant has an allocated parking space where he usually park, on this particular occasion, he was parked in an area closer to the apartment block because he had an awkward and heavy load, i.e. a large bed, to unload from his vehicle into his apartment. The circumstances bear a striking resemblance to those in Jopson v Homeguard [2016] B9GF0A9E.

8. If by parking where the Defendant parked, he unwittingly breached a term in his lease, it is not a matter which seems to have concerned the other parties to it because they have not raised it as an issue with the Defendant.

9. If the other parties had deemed it to be a breach of the lease of any significance, their remedy would have been to seek damages from the Defendant and/or an injunction ordering the Defendant not to repeat the breach.

10. The remedy would not be an arbitrary parking charge payable, and especially not a parking charge payable to a person, such as the Claimant, who is not even a party to the lease.

11. Even if the Defendant’s lease did oblige him to pay a parking charge in these circumstances, which is denied, the lease does not contain a clause [made in accordance with the Contracts (Rights of Third Parties) Act 1999] permitting a stranger to the lease, such as the Claimant, to enforce the terms of the lease.

12. The Defendant’s lease has primacy of contract over any arrangement agreed between a party to it and the Claimant.

13. In any event, the Claimant’s signage is forbidding in that it states in capital letters “NO PARKING IN THIS AREA / EITHER WHOLLY OR PARTIALLY AT ANY TIME” and, that being so, the Claimant cannot then offer a contract for something which, by the Claimant’s own admission, is forbidden. Insofar as this aspect is concerned, there is a striking resemblance to PCMUK v Bull et al [2016] B4GF26K6.

14. It is perverse that, in an area which has a dropped kerb (which must surely be there to permit vehicular access for residents), the Claimant should seek to prevent residents making use of it when a need arises.

15. It is also perverse that, if the Claimant truly believes that there should be no parking in the area, its way of handling the matter, instead of prevention, is to offer any Tom, Dick or Harry (resident or non-resident alike), parking there albeit at an exorbitant rate.

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da_tnt
post Sat, 8 Sep 2018 - 15:09
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QUOTE (Eljayjay @ Fri, 7 Sep 2018 - 20:32) *
Below, I show how I believe your statement of defence should start. These are what I consider the compelling points to be. Each numbered point is important in its own right and they should not be squeezed together. Obviously, if you wish to add other points about POFA, etc., that is entirely up to you. In my opinion, however, anything else is of secondary importance.

Great that is concise and straight to the point, i will also add that it should be 100 max as it is ddressed to the registered keeper and they have not sent the letter before claim. Thanks a lot
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da_tnt
post Fri, 9 Nov 2018 - 12:53
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Hi, I received a letter from the court on 05/11/18 saying:

"Deputy District Judge xxxx has considered the statements of case and directions questionnaire filed and allocated the claim to the small claims track.

Unless the claimant does by 4.00pm on the 27 December 2018 pay to the court the trial fee of £25.00 or file a properly completed application (i.e one which provides all the required information in the manner requested) for help with fees, then the claim will be struck out with effect from 27 December 2018 without further order and, unless the court orders otherwise, you will also be liable for the costs which the defendant has incurred."


1) This claim is allocated to the Small Claims Track and the parties are referred to Part 27 of the Civil Procedure Rule and Practice Direction of that Part for guidance on how the hearing of the claim will be conducted.

2) The claim will be heard at 2:00 PM on the 24 January 2019 at the County Court at xxxx. The Court reserves the right to change the place and/or time of the hearing.

3) From the available papers, it is estimated that the hearing will take one hour. If a party is aware of a reason why this estimate might be substantially inaccurate, that party must notify the court immediately.

4) The parties are encouraged always to try to settle the case by negotiation. The parties are encouraged to contact each other with a view to trying to settle the case or narrow the issues. The court must be informed immediately if the case is settled."


I don't understand is it struck or not. It seems that I have to wait to 27 December 2018 to confirm 100 percent it is struck but why did they set a court date then? Also, will i get a notification after 27/12/18 to confirm that the claimant has not paid the £25 and it is officially struck?

What is the chance they pay the £25 just to force me to go to court and hoping I don't show up?
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nosferatu1001
post Fri, 9 Nov 2018 - 12:57
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Well no, of course itt hasnt been struck out. This is the standard letter - saying ahearing date has been set, but if they dont pay the fee (they cant pay the fee UNTIL a date has been set, hence why it is doone at this point) then the case is struck out.

You will not get notificaiton the fee has been paid, so just call the court.
Quite high, for most PPCs

When is your deadline to get documents to the court AND claimant? It WILL be stated on that letter, i absolutely g'tee it.
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ostell
post Fri, 9 Nov 2018 - 13:04
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It's not struck out yet. Only if they do not file the fee by 27th December will it be struck out. They will probably pay the fee as Gladstones have noting to lose, they get paid no matter what happens. In the meantime start calculating your costs so that you can submit them if the fee is not paid. Your time @ £19 per hour, printing, postage etc.

The court are just planning ahead by giving you a hearing date.

Of course they are hoping you don't turn up. Equally they might not turn up.
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da_tnt
post Sun, 30 Dec 2018 - 15:18
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Hi, i called the court and they have paid the fees.

In my letter it was said that i need to submit a witness statement by 10th January.

Few questions if you can help?

1) is it compulsory to do a witness statement? My defense letter has all the information required. Maybe i can submit the letter again as a witness statement.

2) what sort of documents shall i include? I am thinking proof of the bed delivery and a copy of the lease?

3) finally i am not planning to attend the court hearing. I am planning to notify the judge asap about this. Will this affect the decision?

Thanks for the help again
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ostell
post Sun, 30 Dec 2018 - 16:13
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You will be at a distinct disadvantage by not attending court. Who is going to pick up on the their lies and mistruths?

You need to provide a witness statement that tells your side of the story, and hopefully counter all the mis-statements in their WS. Your WS also provides the link in to your exhibits, including your lease. How else are you going to prove your right to park etc

This post has been edited by ostell: Sun, 30 Dec 2018 - 16:16
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Redivi
post Sun, 30 Dec 2018 - 16:24
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If you do not provide a witness statement, the judge will only have Gladstones' story. You will lose

If you do not turn up and Gladstones do, you will lose unless you've paid a solicitor to attend

A witness statement has a different purpose from the defence statement

The defence statement is a summary of the legal reasons that you owe no payment

The witness statement is your story and the facts
It may be little more than a rewording of parts of it such as the details of your lease and the signs

Your lease MUST be included in the evidence
Also include pictures of signs and dropped kerbs where relevant

If your defence mentions the PCM code of practice and, in particular, breaches of it - include the document

Include copies of any cases you've mentioned in your defence such as Jopson v Homeguard that concerns the right of residents

Your defence hasn't mentioned that the employment of PCM is a derogation from grant (removal of a right) and therefore unlawful unless 75% ? of the tenants have agreed to it
I would still include a copy of the [i]Landlord and Tenant Act[/i] to support the argument that the lease takes precedence

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Macapaca
post Sun, 30 Dec 2018 - 16:26
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Is there a good reason why you cannot attend the hearing?
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SchoolRunMum
post Sun, 30 Dec 2018 - 16:44
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QUOTE
...vehicle was parked in a restricted area of a residential development for about half an hour to accept a delivery of beds. Note that the registered keeper owns a flat in the development and have a secure underground parking. The driver needed to be close to the entrance to help with the unloading of bulky items.


You need Jopson v Homeguard* among your evidence, too, and in your WS make sure you state clearly that this was a decision on appeal, that overturned a County Court Judge's incorrect decision in a case that was on all fours with this one.

You really SHOULD attend the hearing IMHO, unless this is somewhere anti-PPC like Manchester or Skipton Court who will 'get it' without you.



* transcript from the Parking Prankster's case law pages.

This post has been edited by SchoolRunMum: Sun, 30 Dec 2018 - 16:44
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henrik777
post Sun, 30 Dec 2018 - 17:02
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http://www.justice.gov.uk/courts/procedure...les/part27#27.9

27.9

(1) If a party who does not attend a final hearing–

(a) has given written notice to the court and the other party at least 7 days before the hearing date that he will not attend;

(b) has served on the other party at least 7 days before the hearing date any other documents which he has filed with the court; and

© has, in his written notice, requested the court to decide the claim in his absence and has confirmed his compliance with paragraphs (a) and (b) above,

the court will take into account that party’s statement of case and any other documents he has filed and served when it decides the claim.

(2) If a claimant does not –

(a) attend the hearing; and

(b) give the notice referred to in paragraph (1),

the court may strike out(GL) the claim.

(3) If –

(a) a defendant does not –

(i) attend the hearing; or

(ii) give the notice referred to in paragraph (1); and

(b) the claimant either –

(i) does attend the hearing; or

(ii) gives the notice referred to in paragraph (1),

the court may decide the claim on the basis of the evidence of the claimant alone.

(4) If neither party attends or gives the notice referred to in paragraph (1), the court may strike out the claim and any defence and counterclaim.










Not only is it much harder to influence a judge using only written argument, it's impossible to adjust to the mood in the room.
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da_tnt
post Sun, 30 Dec 2018 - 17:33
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Thank you for your replies. To be fair i thought that sending all evidence and notifying the judge of my absence will be sufficient. I will reconsider. I might post questions on the witness statement.
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nosferatu1001
post Tue, 1 Jan 2019 - 20:47
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It is highly unlikely to be sufficient
Attend.
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ostell
post Tue, 1 Jan 2019 - 21:17
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You can't post questions in your witness statement, you run the risk of it being thrown out.
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da_tnt
post Tue, 8 Jan 2019 - 14:59
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I am finalising the witness statement but in the meantime I just received the defendant witness statement by email.

Not sure if I can post this here without the personal details but it is a lengthy response. I am surprised all the time and effort put against this.
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nosferatu1001
post Tue, 8 Jan 2019 - 15:06
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Not much effort, a lot of copy and paste you will find if you spend 10 minutes looking at other witness statements. Its recycled garbage

Of course you can post it here. Host on imgur / tinypics etc, same as ever.
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da_tnt
post Tue, 8 Jan 2019 - 15:46
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attached is the defence statement.

Some items are actually detailed and responding to my initial defense.













And then they issued a copy of the previous tickets, pictures of the car, signage, their agreement with the residence etc...

let me know if i need to respond to any specific points.
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