Excellent advice, thank you all so much.
I will leave making the edits for a short while, just in case any more helpful information is given in this forum, then I will amend and upload the better version for you all to review.
I cannot thank you enough for your help, I really do hope that I win the case and I would love if someone else could then one day use this thread and case as a basis for their defence against these parking pirates.
The POFA makes it clear that they have to say what the breach is on both the screen ticket and the NTK.
Now their claim is using autofill to avoid this problematical dichotomy so you need to ram it home but not yet.
All you need is a short denial of a breach of contract and thus no clause for action against you or anyone else.
I would also drop all of the flowery language that you have found online,
no-one down my pub speaks like that so common english please.
We need to see the wording of the signs to make sense of anything they claim and it will make it easier to rubbish then.
At the moment they havent said what it is you have done to make them sue you and although this is a starter for 10 to bite them with it will be wise to have a bit more but no need to write a book just to say "I didnt do it guv"
Their NTK is not POFA complaint as it doesnt say who the creditor is ( funny they cant even copy 2 lines of text from the POFA) so no keeper liability Against
you will need to aquaint yourself with the wording of the POFA very thoroughly by the time this gets to court (if it does) as many judges havent read it but think they know what it says and make bad decisions based on their beliefs rather than the law so you need to educate yours and get the right decision.
Also look at the ticket/NTK and match exactly the relevant land with the description.
My reading of "off site" means a roadway or similar rtaher than an enclosed car park so show a doubt as to where and they lose again
DCA's don't usually chase CTAX debt.
that's normally a bailiff company after the relevant council has attained a magistrates liability order against you.
did you get their name or the name of the council please?
update - nothing special to report
I've received what I should think is a standard letter from the Court today, stating that I have filed my defence and that has been sent on to the claimant.
The other letter was from Cohen saying they were in receipt of my 31.14 request and are in the process of retrieving the documents requested. They have agreed for an extension of time and when i receive the documents i'll get a further 14 days to respond.
As this letter was dated 30.11 but didnt arrive at my door until the 11th Dec my defence has already been submitted. Not that I would have agreed