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Geocyper

VCS PCN Claimform - Broomfield Developements

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yes here just search witness statement


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couple of points to do immediatetly.

 

you have numbered every line rather than every point you are wanting to make.

That makes sense but it may be better then to label each point A, B etc so you can the exampe refered to point B starting on line 23 and it will be obvious that it is a separate argument fro the line above.

 

also the latin term for no right to bring a claim is LOCUS STANDI or locus in standi- get the spelling right.

 

The cases you have cited need to have the reports as parts of your evidence bundle.

 

The other thing I would do is relook at the order you want to present things so it tells a story that flows well so to that end your line 1 onwards should go immediately after line 9 or 17.

 

It wont hurt to repeat yourself to deny being the driver at the time etc if it means that you first give your side of events as a witness and then trash their claim.

 

Currently you have the basic info but it is a bit bitty.

 

You also need to include reference points to all of your other evidence so you will need simple labels for then so lease docs will be annexe M ( somehting that isnt used in the main statement), the signage annexe N and so forth.

 

lastly you need to chuck the kitchen sink in as well so read more court reports and even where the cases are not the same as yours use then if there is a mention of any procedural matter that you want to mention so more POFA cases, anything on trespass and harassment ( there is a big one to cite) and plenty where the parking co issued ticket to owner of land and they had to pay damages. There is one that was a cause celebre on this site a while back so look through old UKPC threads about 4 years ago.

 

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Hi thanks for your reply and I put, I will endeavour to implement points you have raise.

 

can you please explain what you mean by  “The cases you have cited need to have the reports as parts of your  evidence bundle.”  I have printed three copies each, off all the cases I am going to cite.

 

Thanks

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HI ericsbrother,

 

Is there any chance I can PM you an alleged contract VCS has sent, witness statement.  I think I will be identified if I post it up for general comment.

 

Also they say that they are nor relying on POFA 2004 Schedule 4, keeper liability because their NTK complies with POPLA ?

 

Thanks.

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pm advice is not allowed

scan it all to one multipage pdf to here

read upload

 

dx


PLEASE DONT HIT QUOTE IF THE LAST POST IS THE ONE YOU ARE REPLYING TOO.

MAKES A THREAD TWICE AS LONG TO SCROLL THROUGH!

please do not post jpg images directly to a topic..USE PDF ....READ UPLOAD.

 

WE CAN'T GIVE ADVICE BY PM - IF YOU SEND ME A LINK TO YOUR THREAD - I WILL BE HAPPY TO OFFER HELP THERE

Single Premium PPI Q&A Read Here

Reclaim mis-sold PPI Read Here

Reclaim Bank Account, Loan & Credit Card Charges Read Here

The CAG Interest Tutorial Read Here

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Hi thanks,

 

What can I do to minimise the chance of identification of myself by Parking Company,  retract all information with identifying features ie whom contract is between?

 

thanks 

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there wont be any of YOUR details on those exhibits? 

just remove claim number and your name

and poss any PCN/ref no related to your case

bar that everything else is ok inc dates.

we need the exhibits too


PLEASE DONT HIT QUOTE IF THE LAST POST IS THE ONE YOU ARE REPLYING TOO.

MAKES A THREAD TWICE AS LONG TO SCROLL THROUGH!

please do not post jpg images directly to a topic..USE PDF ....READ UPLOAD.

 

WE CAN'T GIVE ADVICE BY PM - IF YOU SEND ME A LINK TO YOUR THREAD - I WILL BE HAPPY TO OFFER HELP THERE

Single Premium PPI Q&A Read Here

Reclaim mis-sold PPI Read Here

Reclaim Bank Account, Loan & Credit Card Charges Read Here

The CAG Interest Tutorial Read Here

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Hi, Dx100uk,

This is an alleged Contract between the Parking company and Client.

 

 I have redacted what I think I should, if I need to expose some more info I will.

 

Thanks. 

 

Forgot this.

 

 

VCS Alledged Contract Redacted..pdf

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pointless redacting that

tells us nothing!!

 

 


PLEASE DONT HIT QUOTE IF THE LAST POST IS THE ONE YOU ARE REPLYING TOO.

MAKES A THREAD TWICE AS LONG TO SCROLL THROUGH!

please do not post jpg images directly to a topic..USE PDF ....READ UPLOAD.

 

WE CAN'T GIVE ADVICE BY PM - IF YOU SEND ME A LINK TO YOUR THREAD - I WILL BE HAPPY TO OFFER HELP THERE

Single Premium PPI Q&A Read Here

Reclaim mis-sold PPI Read Here

Reclaim Bank Account, Loan & Credit Card Charges Read Here

The CAG Interest Tutorial Read Here

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4 hours ago, Geocyper said:

Also they say that they are nor relying on POFA 2004 Schedule 4, keeper liability because their NTK complies with POPLA ?

 

I'd be interested to see how they're attempting to hold you, as Keeper, liable for something some unknown third party has done.

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Hi, dx100uk

 

I’ve only redacted the name off parking company and client.

 

i will post it up for you to review, unredacted, for you to look at.

 

thanks.

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Hi shamrocker,

 

They say that their Notice to Keeper and PCN Notice complies with POPLA, so they don’t use it.

 

thanks 

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as I said earlier you DO NOT need to redact anything other than YOUR info.

 

 

dx

 


PLEASE DONT HIT QUOTE IF THE LAST POST IS THE ONE YOU ARE REPLYING TOO.

MAKES A THREAD TWICE AS LONG TO SCROLL THROUGH!

please do not post jpg images directly to a topic..USE PDF ....READ UPLOAD.

 

WE CAN'T GIVE ADVICE BY PM - IF YOU SEND ME A LINK TO YOUR THREAD - I WILL BE HAPPY TO OFFER HELP THERE

Single Premium PPI Q&A Read Here

Reclaim mis-sold PPI Read Here

Reclaim Bank Account, Loan & Credit Card Charges Read Here

The CAG Interest Tutorial Read Here

spreadsheets 

 

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2 minutes ago, Geocyper said:

Hi shamrocker,

 

They say that their Notice to Keeper and PCN Notice complies with POPLA, so they don’t use it.

 

thanks 

 

Just reading over your draft WS posted further up. Is there a particular reason for admitting being present when the vehicle was parked on the site?

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Hi shamroocker

 

Yes I was with the driver, passenger.😉

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Does that really need to be mentioned?

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Well i have mentioned it, so cannot withdraw it.  I don't think it will count me saying I was there, the driver has disability I was accompanying him to see someone that lives in complex.

Need to make post clear.  I was the passenger.

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It's not ideal, but I guess it shouldn't really matter if the Claimant is not relying on POFA to transfer liability - they should still need to provide evidence that the driver and the defendant are the same person. You're only telling the truth, I guess.

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Hi shamrocker,

 

Thats what I thought, no point lying, caught out once case sunk .

 

This is the extract from their submission to the court, POPLA.

 

if it would be better I could post the whole document up.

Reasons POFLA .pdf

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Ok... so, they ARE relying on POFA - right?

 

The signage is also forbidding, so is not a genuine offer to park. You've probably covered this point within the thread already - I haven't read back over it.

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Hi, shamrocker,

No they are not relying on PPOFLA because they say there NTK and PCN are POPLA compliant, they are not.  They are just using this argument to get around Keeper Liability.

 

Thanks.

 

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