The initial defence I submitted Roobear was a skeleton defence,
just bullet points
(especially as I managed to lock myself out of my MCOL account, and had to fill in the hard copy they sent me!).
I wouldn't worry about putting too much in this defence,
just the main points.
1. When initial PCN received the defendant immediately replied and sought clarification of key points pertaining to the charge, including clarifying their contract with the landholder that demonstrated that they had authority to both issue parking charges and litigate. The Claimant ignored this letter, and instead said it had rejected an appeal which had not been started.
2. The charge issued was not a genuine pre-estimate of loss.
3. Setting down does not constitute parking.
4. Any purported contract would be with the landowner, not ES Parking.
5. Inconsistent road markings, and poor signage mean no contract was entered into.
6. No signs displayed at the entrance to Gartside Street warning of private parking being in operation on the road.