Almost there, but again the use of Mitigation at 2.9.1 is harmful, to your case imho, others may well add thoughts
"2.9.1 The mitigating circumstances outlined in this complaint were dismissed out of hand, and
the Claimant insisted the PCN was [in their opinion] issued correctly and fairly."
The fact the ticket although flipped was seen in the pics by the operator. You had paid, the position of the ticket is de-minmis and irrelevant a claim of mitigation is admitting to a breach of their cockamamy alleged T & Cs, you cannot mitigate lack of guilt, that is how a judge might see it in the legal context, and take it as admission of breaching their T & Cs.
Others may have further thoughts. as that is my view, I wouldn't use any reference to a mitigation in a WS. Could do with ericsbrother's input before final edit.
Ah okay...so they haven't got a clue what they are talking about.I thought you had got it from a court direction.
If you look closely again at your Notice of Allocation it directs you to :-
Pay the hearing fee by date
States the actual hearing date.
Directs both you and the defendant to file and serve evidence (documents) by date (normally 14 days pre hearing)
Directs both of you to file and serve statements by date ...same as above 14 days.
Don't touch them owe me £500 since January 2019 make excuse after excuse. Seem they always have software problems sending money out. Keep saying they will call back or email nothing been chasing it now for 6 mths the phone staff always have the same banter we will chase it up and get back to you then nothing!