VCS SpyCar PCN Claimform - Bristol Airport PCN No. 1

[southwestram]

I'll be on the phone at 9am. Thanks for the advice. We'll need to continue this tomorrow,

[FTMDave]

Regarding your other points.  Well you hit the nail on the head with -

 

4 hours ago, southwestram said:

Altogether, it's a pretty convincing case. Until it is examined in real life.

Your job is to produce a WS including all the excellent points you've made about their rubbish signage (and a lot more besides).

[southwestram]

Found it in the 'yet to be filed pile'

Claimant needs to pay the fee of £XX.XX by 4pm on the 23rd Feb.

Case is, as I said, on the 23rd March.

It states that by 4pm on February 3rd!!!! all written statements, witnesses etc must be sent to the court.

This is even before the fee must be paid. Surely that's a typo?

When asked for dates that I wasn't available, I said throughout January 2023 as I would be abroad. To demand a WS to be filed, (knowing I wouldn't be in the country throughout January) by the 3rd Feb is ludicrous

 

Edited February 17, 2023 by southwestram

[FTMDave]

Not necessarily.  Some judges do this.

 

Have you received a WS from VCS?

[southwestram]

It was in my mail when I returned to the UK on the 28th January. Dated 2nd January. They must be working overtime

[FTMDave]

Sounds legit then.  But if VCS are late you can be late too. 

 

Especially as they are the claimant.  And an, ahem, professional company.

 

Whereas you are the defendant.  And a Litigant-in-Person.

 

Just to be sure, can you upload the court document please?

[southwestram]

Best I can do - dates are clear though

court paper.pdf

[dx100uk]

we need their ws in FULL inc exhibits

sorry but its a must if you are going to win here.

 

 

[FTMDave]

18 minutes ago, FTMDave said:

Have you received a WS from VCS?

 

[dx100uk]

19 minutes ago, southwestram said:

It was in my mail when I returned to the UK on the 28th January. Dated 2nd January. They must be working overtime

 

[southwestram]

Does it need to be redacted at this stage?

[dx100uk]

sadly we are gov't by GDPR rules

 

but you only need to redact anything THEY can use to ID you HERE.

so claim,reg,  pcn, ref, -  numbers, your name address etc etc .

their details are not needed to be redacted ..no.

 

 

[southwestram]

Ok. Hang on. I'm a 60 year old dinosaur

 

[FTMDave]

Apologies, dx, I thought the OP was referring to a court order dated 2 January,.

 

All as clear as mud.

 

This is bad, ignoring a county court order and not even telling us VCS had sent a WS.

[dx100uk]

just vanishing and not reading up between downtimes is nearly always fatal.

we are SELF HELP TOO.

we don't nursemaid.

age is no excuse.

 

 

[southwestram]

claimants ws

 

 

 

 

claimants WS.pdf

[dx100uk]

well done

experts will deal

dx

[southwestram]

I appreciate the efforts you guys are making, and I'm sure you're having to bite your tongue at my continual balls-ups. Your patience is appreciated.

I imagine that I'll need to come up with a WS very quickly, to be posted to the court and VCS without delay.

I aim to keep it to concentrating on their inadequate, illegible and often absent signage that leads to confusion. I mean, telling drivers that there is no stopping past the sign is ridiculous. It doesn't say where it applies, so one could only assume that it refers to areas with visible signage prohibiting stopping. 

Whether or not VCS are permitted to act on the access road because of byelaws (of which I'm wholly ignorant) and whether or not they can impose a contract on somebody, merely because they drove past a sign, I'll leave to you fellows to advise.

How would I include the videos in my WS? Should I make the YouTube video public and send them a link? (At the moment, I have it on YouTube set to Private)

[brassnecked]

Looks like the standard CTRL-C CTRL-V Ambreen WS for No Stopping,   They refer to being Liable for a Parking Charge for NO Stopping, as is allreadl laid down stopping is not parrking.  Plenty to go on with this.

[Nicky Boy]

Guys,

The OP has left the VRN showing on the claim form in his upload!

 

Also,

Pages 7 and 8 of the contract are missing?

 

In Ambreen's missive, she states that there are images of the contravention in exhibit AA2.

 

I can't see any?

 

My last post (about pictures) prompted me to go looking for the original "Notice To Hirer" in the thread...

There isn't one uploaded?

 

Ambreen hasn't alluded to it in her regular cut and paste fashion.

 

With a Notice To Hirer needing to follow very specific different rules, I think we really need sight of it.

[southwestram]

Good morning. You obviously have more stamina than I do these days.

I will upload another badly put together PDF (in B&W) of the first 15 pages, which replaces the first pdf (Part 1) This includes the now completely redacted claim form.

The remaining pages - NTK, Notice to Hirer, Demand For Payment, Final Demand, LBC, were all previously uploaded on this thread, and as they were already redacted at that stage, saved me some time repeating the task in the early hours.

Everything else, as can be seen from the page numbers of the document is as received, so any missing contract pages were not supplied to me.

 

[FTMDave]

8 hours ago, southwestram said:

I imagine that I'll need to come up with a WS very quickly, to be posted to the court and VCS without delay.

Yes, ideally by 4pm when the court closes today, but presumably that will be impossible.

 

The next deadline would be by 4pm on Monday.  I don't mind tweaking any WS you come up with late this evening when i knock off work, and on Sunday, and you could e-mail to to the court and the fleecers late on Sunday.

 

8 hours ago, southwestram said:

I aim to keep it to concentrating on their inadequate, illegible and often absent signage that leads to confusion. I mean, telling drivers that there is no stopping past the sign is ridiculous. It doesn't say where it applies, so one could only assume that it refers to areas with visible signage prohibiting stopping.

Well yes and no.

 

Certainly include all the excellent research you've done on the rubbish signs.

 

But don't stop there.  VCS have lost no-stopping airport cases many times due to the deficient contracts with the landowners that they have produced.

 

Have a look at the attachment in post 110 here  https://www.consumeractiongroup.co.uk/topic/421775-vcs-spycar-pcn-paploc-now-claimform-no-stopping-east-midlands-airport/page/5/#comments

 

If it's not in post 110 it'll be a couple of posts above or below, sometimes the post count goes wonky.

 

This is a superb WS, the content and layout of which can be your base.  The case is very similar to yours.  Look at how Alaska101 sets out the introduction and the conclusion.  And how the clear headings show the judge instantly which legal arguments are being used.  

 

Also look at the WS in post 87 here  https://www.consumeractiongroup.co.uk/topic/441301-vcs-spycar-pcn-paploc-now-claimform-no-stopping-bristol-airport-claim-dismissed/page/4/#comments  This is for a case at the same airport.  You can use loads of research that other Caggers have done.

[Nicky Boy]

"The remaining pages - NTK, Notice to Hirer, Demand For Payment, Final Demand, LBC, were all previously uploaded on this thread, and as they were already redacted at that stage, saved me some time repeating the task in the early hours."

 

Yes southwestram, I've found them on your "other" thread.

Did they include any other documentation, such as your signed agreement with the vehicle hirer?

(Which would include waivers on such stuff on payment of parking charges, etc).

[FTMDave]

I've just read this thread from the start, and you've done superb research.

 

Get it all in a WS this evening if you can.  Then all the regulars can comment and it can be tweaked.

 

It'll arrive at the court 17 days late on Monday, but well before the hearing, it's to be hoped the judge is in a lenient mood. 

 

I'm not sure how you show videos to the court, and have flagged the matter up for more experienced Site Team members to answer.

[southwestram]

I don't actually have a hire agreement for the car. I can't remember ever being given one.

Regarding the video that I intend to show, I have it online, on YouTube, and understand that wi-fi is available in the court building. But I also have two/three laptops which could be lent to the judge, the claimant and one for my reference.

I can make the YouTube videos viewable to a select few for your review. I would suggest that I provide a shareable link to one or two of you, which others could use on request to the original one or two

I am adding the NTK etc to this post

VCS WS Notices redacted.pdf

 

I'm working on the WS, using the Paploc reference kindly provided as the cases are very similar. I will post it on here as soon as possible

Meanwhile, would anybody like to see the video? I can send a link via the message facility if required. It's on YouTube, so should be safe enough to view for those concerned about these things