Hi Andy and friends.
Apologies for the lateness - I have had family illness issues this week but have now completed the attached.
Can you please let me know if compliant and any other suggestions would be appreciated.
Witness Statement Draft 1 .docx
Unless you remember exactly what the signs said it is difficult to go with anything specific
My suggestion is:
1.The defendant denies being the driver at the time and as the claimant has failed to create a keeper liabilty by way of a proper notice sent out under the POFA 2012 there is no cause for action against the defendant.
2. The notice to keeper is deficient in key phrases as required by the POFA 2012 so it fails to create ANY liability for the charge.
3. IN ANY CASE there was no breach of contract as the parking terms offered free customer parking for a specified time and the claim is for monies due as the driver failed to display a purchased ticket when no ticket is required. This means thers is no cause for action against the driver or anyone else.
4 As the claim is entirely without merit the defendant asks that he receives a full costs recovery order under CPR 27.14.2(g) as the claimant knows or should know that it is vex
that will do for the moment.
BW may well drop the hot potato now but to make sure I would send a copy of your reply to both them and their client as well as court.
Dont use the PO Box address, look up their registered address via their companies house registration
My landlords said they would deal with all bills inc. council tax, i just paid one lump sum of rent and bills to cover it. It wont send any texts to their number and says Ive dialled an incorrect number when I try to ring them, even though thats the number they call me from