VCS ANPR PCN PAPLOC Now Claimform - double dipping - St Mary's Gate Retail Park, S1 4QZ ***Claim Dismissed***

[dx100uk]

not worth it.

if simon Renshaw smith want to issue a letter of claim

let him go ahead.

 

he'll lose hands down any court claim.

 

the NTK is out of time

the event encompasses 2 visits.

there is no '1 hours free parking' limit...it will be atleast +2hrs on the originally granted planning permission from the council..and n-one can change that.

 

it will also help you to read these

https://cse.google.com/cse?cx=partner-pub-8889411648654839:3134625398&q=St Mary's Gate Retail Park%2C S1 4QZ&oq=St Mary's Gate Retail Park%2C S1 4QZ&gs_l=partner-generic.12...2930513.2930513.0.2931743.1.1.0.0.0.0.231.231.2-1.1.0.gsnos%2Cn%3D13...0.0...2.34.partner-generic..1.0.0.aogc2b9yHYI

 

dx

 

 

[dx100uk]

clearly says letter of claim...

 

time for one of EB's snotty letters.

 

 

[dx100uk]

complete the sticky in the above post please:

 

then:

 

pop up on the MCOL website detailed on the claimform.
.
 register as an individual
 note the long gateway number given
 then log in
.
 select respond to a claim and select the start AOS box.
.
 then using the details required from the claimform
.
 defend all
 leave jurisdiction unticked.
 click thru to the end
 confirm and exit MCOL.

 get a CPR 31:14 request running to the solicitors [if one is not listed send to the claimant]

no need to sign anything
.
you DO NOT await the return of paperwork.
you MUST file a defence regardless by day 33 from the date on the claimform [1 in the count]

[dx100uk]

[dx100uk]

just tighten 4-7 into one sentence whereby you atleast mention authority, signs etc, don't expand upon what might be 'wrong' 

thats for the WS.

 

dx

 

[dx100uk]

you either want a zoom meeting or in person for sure!

else simple simon WILL file a load of BS in his WS which you can't counter in person or in your WS. (you've already filed your defence!)

 

what date must your exchange WS's?

 

scan up the order please to PDF

[dx100uk]

On 15/04/2020 at 13:05, holmer444 said:

I have screenshots of the Google maps data from my phone which shows that I was in town from 11.16 to 11.47 then drove home, then drove back to town, arriving at 14.33 and leaving for the second time at 15.01, driving home again.

 

So either I was in my car and it wasn't in the car park when they say it was or I was in another car and not driving my car, hence they can only pursue me under keeper liability, which they can't do as their original PCN is more than 14 days after the date they allege the 'contravention'.

 

the above.

NTK outside of 14 days

double dipping.

no such thing as 1hrs free only.

 

all will kill this claim dead.

[dx100uk]

we will also need aLL of the exhibits..

 

other notes.

the contract was for 3yrs in 2011

there is no proof the client has paid VCS in the 2021 season nor the contract can simply roll by default past 2014..

 

what a stupid comment for his latest wally, Mr Wali, a supposed paralegal since their last one ran out the door in oct 2020 to make...(sic) this case could hinge on the weight of a single feather that tips the scales'.... i can see him soon leaving like the rest once he sees what crap simon is leading him into here.

[dx100uk]

TBH: i dont like 3 that makes the WS read more like an embarrassed defence at the start ..

 

it would be far better if you got away from the either or statements, it leads you far to wide open for this or that to be true or not.

dont forget to add i am the registered keeper of vehicle..

 

[dx100uk]

17 minutes ago, holmer444 said:

I assert that I am not liable

gobbly gooke 

you dont need it

 

1 to 4 looks like a defence or should have been.

you dont need to repeat that in your WS 

you've already filed it

 

simply start by stating i am the register keeper of the vehicle reg xxxxx

 

[dx100uk]

17 hours ago, holmer444 said:

13.   The Claimant in production AA1 of their WS presents Signage Artwork, this signage states ‘Maximum Stay 1 Hour Commencing on Entry - No return within 2 hours’

 

+ there is no evidence the council stipulated any parking time restriction upon granting the initial planning consent, the normal free parking parking period being 2 or 3 hrs at such retail parks. Nor any evidence from the Council nor the claimant applying or being granted such a variance to only a 1 hrs time period. 

[dx100uk]

the court wouldn't be sending your pers details from their copy of the N180 as the sols get their own copy from you and you should have omitted phone/sig/email.

never mind.

 

can you scan the whole thing up to one mass PDF please.

 

if this is ELMS legal, it's worthy to note ELMS have dumped Simple simon on another recent claim yesterday.

[dx100uk]

hidden .

you MUST for your protection and us as CAG, under strict data protection and GDPR rules as we can be lawfully fined, carefully redact details like the claim number and your name/address

 

least of which is do you seriously want simon to find you here?

 

 

[dx100uk]

and Wali has used his weight of feathers argument again...

[dx100uk]

On 14/05/2021 at 12:23, dx100uk said:

we will also need aLL of the exhibits..

 

other notes.

the contract was for 3yrs in 2011

there is no proof the client has paid VCS in the 2021 season nor the contract can simply roll by default past 2014..

 

what a stupid comment for his latest wally, Mr Wali, a supposed paralegal since their last one ran out the door in oct 2020 to make...(sic) this case could hinge on the weight of a single feather that tips the scales'.... i can see him soon leaving like the rest once he sees what crap simon is leading him into here.

i knew i'd seen it before...

[dx100uk]

a simple mistake a litigant in person (member of joe public) makes quite often...not important.

dx

[dx100uk]

You can only claim £90 loss of earnings

[dx100uk]

did simon himself turn up??

 

[dx100uk]

create a new thread

 

dx