VCS PCN Claimform - no stopping Southend Airport

[ericsbrother]

couple of points

1 VCS in point 1 not VCA. i know it is a typo but get this right or they may try and get the defence chucked out on a technicality

3 delete and use the modified version

 

3 the law allows a 10 minute grace period to read and consider the offer and this grace period is also part of the Code of Practice that any parking co has to adhere to so there was no breach of conditions that all parking cos are obliged to offer.

then use your point 4 as is so it flows well

point 5  add " The defendant therefore does not believe the claimant has the necessary authority and so there is no locus standi and  cause for action against the defendant"

[ericsbrother]

also you asre still getting the name of the claimant wrong so use the standard format adn say "claimant2 rather than naming any of the parties involved

 

point 5 too verbose, just say a cpr 31.14 request for documents was sent ond no response made. forget about the date also put the first sentence last so you say " a CPR 31.14-------" and then end the point with " therefore the defendant does not believe--------"

[ericsbrother]

there are good reasons for waiting until close to the last date, it stops Simple Simon changing/adding to  his POC to fit in with what you have said