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Willow2020

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  1. All sent! Many thanks for the help and advice, it has been greatly appreciated. I will keep you informed of the progress!
  2. Thanks FTMDave, I have made the changes you have suggested, in my exhibits I have attached CoP, weblink and point 9 for it to be referred to, couldn't get it on due to the 5 pages. Shall I get this emailed over now? Ive not attached it as I have added my details, etc. so its ready to be emailed over, conscious of the time limit
  3. Wow, thank you again for the help with this, been working on it all morning and managed to get down to the 5 pages. If you get chance please have a look and then I can get this emailed over to the court before the deadline. WS.pdf
  4. I've attached the other things they have sent, the multiple pictures of the signage are dated 2015 and they have also added a skeleton argument? KBT Signage.pdf
  5. Hi FTMDave, can't thank you all enough for the help and spending your own time on this. I have attached a new draft of the ws taking into account some new points, let me know what you think / what to add when you get chance, I appreciate you are busy with your own work. WS.pdf
  6. Regarding the PCN it states the observed time and then 19 minutes later the time of issuing the pcn that 's all, can I use the points that this isn't compliant, it does say Armtrac Security on the front but does this ticket specifically have to state creditor on it? I just want to make sure I don't trip up on myself if this is used. Also they have now changed / updated their signage from when I went 6 months ago to take pictures of the car park having no marked bays, in 2020 they didn't have a Just Park machine I don't think (picture attached) . I have attached a copy of their signage from Jan 2020. Lusty Glaze signage.pdf Lusty Glaze Pay Machine.pdf
  7. Hi all, sorry for the delayed reply. At the beginning of all this I stupidly contacted them direct to say I had a valid ticket and explained I bought the ticket thinking common sense would prevail and I was dealing with decent people..... So they have in an email that 'I bought the ticket' but at no point have I said I was the driver. Thank you for letting me know that sending the documents by email is ok as it gives me a little more time to add to the WS, regarding sending this to the fleecers does this also have to be sent before 4pm on the 6th ? Should I send it by post or email which they have anyway.
  8. Hi, I've made those first amendments but not 100% sure how to include POFA in the statement and the process or lack of it that followed to issue the NTD/NTK. I know admitted to them that I was the keeper of the car and bought a ticket, they then sent me letters direct but no NTD/NTK, then BW Legal took over. How do I explain the ticket was non POFA compliant. Also I was going to post these documents to the court or am I best sending them via email? If I post I would want to get it sent today to ensure it gets there in time, hopefully KBT will land today. Thanks again for your time and help
  9. Thank you for removing the two posts, I hadn't realised that it showed these details! I have reattached with the correct format, 12 font, double spacing and page numbers - at the moment it is 6 pages. Your time and help is really appreciated. WS.pdf
  10. I also called Cornwall Planning office and they couldn't find any planning permission for the signage, I have also looked at the planning applications online for the car park many years ago and there is nothing.
  11. Hi FTM Dave, Thank you for the reply and info, much appreciated. I have drafted my ws and attached. I would be very grateful if you can have a look. WS.pdf
  12. the hearing is in August but i have to get the witness statement over to the court by the 6th of May.
  13. Hi, Following on from all the last posts I have received a notice of allocation to the small claims track and have to submit my witness statement and all other documents I intend to rely on, in relation to my witness statement ... do I write down all my points of defence as this is something I have to send to the Claimant also? Is there anything specific which would help. One aspect I can prove is that their signage is incorrect in relation to 'vehicles must be parked fully within the confines of a marked bay' there are no marked bay's anywhere in the car park, therefore how can I agree to the t&cs. Many thanks
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