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liverpool33

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About liverpool33

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  1. Thanks I'll make those changes. I actually received the WS from VCS when I returned home from being away yesterday. It makes interesting reading. They make some quite bizarre errors and factual inaccuracies e.g. wrong name and dates in places, refer to me by the wrong sex at times (expect they have just copied and pasted from Websters case over on pepipoo). I don't expect these error to be fatal for their case but looking forward to pointing them out. Perhaps the most interesting is the way they have worded some of their claims, they seem to be pursuing the argument that the signage
  2. I have condensed the arguments (abit) and added in some cases I've read about and seem to be relevant: PCN vs BULL CEL vs Maccafferty Pace Recovery & Storage vs Lengyel I've got photos of the signs, which I'll include in the documents I send. I notice in Crutchley, the Judge didn't pay very much attention to the small signs and how it's impossible to read them without stopping. Is it worth me pre-empting VCS use of Crutchley in their WS by putting something in about the size of those signs? Or just waiting to take it on in court? Found some statements on LJLA website w
  3. Actually don't know who was driving, for a number of reasons. Happy to let VCS try and show it was me, if the court decides on balance of probs that is was me (and I can see there is a chance of that) would it likely impact negatively on the rest of my arguements? I have seen in some court transcripts the judge ruling on one part of the case first as that affects the rest of it, do I have to ask the judge to do that? Or is that just part of their remit as judges, wouldn't want to patronise them
  4. Yes I've made a list of cases I've seen around the net, just wondered if there was a publicly available court databases for the official report etc. I'll start collating documents and reference them. Re the driver issue: So they claim I said I was the driver when I appealed on behalf of the keeper. They sent me a copy of the text of the appeal, which doesn't say anything about being the driver. However, they have manually added a line at the top of the document that says something along the lines of "Note: driver was selected option". Now, I don't recall ticking that, it's nearly 18
  5. Thanks, useful feedback, I will condense the arguements a little and add in the evidence as you suggest. Apologies, not sure where is best to look for all these cases. Is there a collection of VCS losses anywhere or is there a resource I can search? Re: above, they are pursuing me specifically as they seem to think I was the driver. They said so in correspondence and although their Particulars of Claim is keeps mentioning they are pursuing me as driver/keeper, I clearly am not the keeper and they must know this.
  6. Hi all, i've been putting together some arguments for the WS. Not sure if the stopping specifics should go in here? Or should they have gone in my defence? I hope I can still use them as arguements. I will elaborate on the airport byelaws and signage issues. Anything else that should go in or be omitted? thanks in advance Witness statement In the county court of liverpool VCS (claimaint) vs. liverpool33 (defence) 1. My name is xxxxx of xxxaddressxxx. On the DATE my wife, received a “parking charge notice” from the claimant. This notice actually referre
  7. This case seems similar to mine, VCS appear to be attempting to use some new arguements at LJLA, http://forums.pepipoo.com/index.php?showtopic=116961&st=480 Has anyone seen these arguments used before?
  8. Date now received for Notice of Allocation Date is set for October at Liverpool As I understand it I am required to pay a £25 fee and provide all documents I'll use in court to the court and also VCS at least 14 days before. I need to change my address as I'm about to move house so would a letter to the court manager and VCS (recorded of course), suffice? thanks for your help as always, I'll start putting defence documents together. Is it just the documents I need or do I need to formulate a written outline of my defence as well?
  9. Filed def within the initial 33 day window on MCOL. Have received and completed Directions questionnaire. Got a letter and phonecall asking about mediation even though I said I didn't want it. Got a letter saying it will be at Liverpool. No date yet.
  10. Have had confirmation proceedings will be in Liverpool. Should I be actively doing anything else at the moment other thank thinking about a robust defence? I am moving house soon, is there a formal way of amending my address for the case moving forwards? Or shall I just ring up and get the details changed thanks
  11. I submitted my defence and then my Directions Questionnaire. I requested my hearing in Liverpool. Do I also need to send a copy of the questionnaire to VCS as I haven't done that yet? I have received a copy of their questionnaire (strangely with a cover letter dated 27th March!) Presume it's a stock one they forgot to change the date on. They have requested Sheffield. Also had an email requesting mediation. Should I accept that or wait for court?
  12. Updated, advertising consent removed. Just to confirm, bulletpoints are ok for this submission and then I would go into more detail in my WS? Defence: 1. The claim is denied. 2. The site is subject to byelaws governing the control of motor vehicles. Hence the claimant cannot offer a civil contract in this matter. 3. There was no offer of contract as the signage the claimant refers to is clearly inadequate to do so. 4. The defendant does not admit they were the driver and/or keeper as alleged by the claimant. 5. The is no keeper liability by the POFA 2012 in this case and hen
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