CEL ANPR PCN Claimform - didn't input reg - moved address - CAR PARK AT ASM SUPERMARKET 75-83 OLDHAM RD Ashton-under-Lyne OL6 7DF***Claim Struck Out***

[FTMDave]

It's new for them to add more Unicorn Food Tax than the trade association allow though. 

Plus they don't usually claim legal expenses when they don't use solicitors.

[dx100uk]

i was just thinking of us adding another *include if this question is true....xxxxx paragraph

in our default defend section on the court sticky?

[FTMDave]

Got it!

I agree.

[xtonehari]

Hi DX,

Sorry, I was not able to find where you have highlighted. 

"now read the bit ive highlighted again ...carefully!!!!!"

Could you please provide the link. 

[dx100uk]

scroll up from my post to your post before.................

your really should always read a thread before you post on it...just like continuing to read up during downtimes.

you are infront of the judge not us....

 

[FTMDave]

In your last post on the last page dx's has highlighted an important sentence.

[xtonehari]

Okay, got it, where you have highlighted. i.e. Yes to mediation No if its statute barred or a parking claim.

Shall I say I cannot answer Yes to all three statements below for the mediation and cancel the appointment?

- I am willing to negotiate on the amount of the claim and I will consider a compromise.
- I have enough information about the claim to enter into negotiations and do not require any further evidence from the other party before starting mediation.
- I’m available for the entire time slot on the date of my appointment.

What happens when I cancel the mediation service. Will it go back to the court.

[dx100uk]

we cant be any clearer than what we've said from day one when that sticky was produced year and years ago.

you say NO to mediation.

the claim does not 'go back to the court' it never left.

dx

[dx100uk]

open

dx

[xtonehari]

Hi Dx,

I received the Notice of Allocation to the Small Claims Track (Hearing) letter on 6th Jan.

The hearing is scheduled for 19th Feb 2024. 

Please see the attached letter and let me know what needs to be done. 

Thank you

NoticeOfAllocationSmallClaimTrack-Hearing.pdf

[FTMDave]

Time to get on with your Witness Statement.

It has to be filed by 2 February.

[dx100uk]

as you've been continuing to read up here during the down time........ you should already know you have to do a witness statement by 14 days prior the hearing and send itto the court and the claimants solicitors.

post up your ideas here for checking.

dx

 

[FTMDave]

You need to get on with this. 

Tick tock.

[xtonehari]

Hi FTMDave,

Thanks for your message. I am well aware that I need to write the witness statement and everyday I am thinking about this. 

I was not sure how and what to write. I have taken a witness statement from another case found in this site and modified it. 

Please have a look the Witness Statement below and let me know if this acceptable.  Thank you...

 

Quote

Witness Statement of XXXXX

INTRODUCTION
1.  I, XXXXX am the Defendant in this claim. I represent myself as a lay person, with no formal legal training. Everything in the following statement is true to the best of my knowledge and belief. 
2.  I was the registered keeper of the vehicle: XXXXXX.
3.  In my statement I shall refer to exhibits within the evidence section supplied in this bundle referring to page and reference numbers where appropriate. 

BACKGROUND
4.  The Defendant received the Parking Charge Notice (PCN) dated 27th August 2021 (Exhibit 1). The PCN pertains to an incident on 20th August 2021 when the vehicle was parked at ASM Supermarket, 75-83 Oldham Road, Ashton-Under-Lyme, OL67DF.

The PCN was issued 6 days after the alleged contravention. Notably, the car park was almost empty and used exclusively for purchasing goods from ASM Supermarket.

Upon entering the car park, the driver did not observe any signs indicating parking restrictions and/or any notice/signs specifying that the vehicle registration should be entered at the till during/after the purchase.

On the day of the alleged contravention (20th August 2021), the driver did make a purchase from ASM Supermarket. A credit card statement reflecting this transaction is provided as Exhibit 2. 

LOCUS STANDI
5  There is no Locus Standi.  I do not believe a contract exists with the landowner that gives Civil Enforcement a right to bring claims in their own name, no contract has been produced after my CPR request (Exhibit 3). 

6.  The definition of “Relevant contract” from PoFA 2[1] means a contract, including a contract arising only when the vehicle was parked on the relevant land between the driver and a person who is-
(a) the owner or occupier of the land; or
(b) authorised, under or by virtue of arrangements made by the owner or occupier of the land, to enter into a contract with the driver requiring the payment of parking charges in respect of the parking of the vehicle on the land.
According to Companies Act 2006, Section 44. 
44 Execution of documents
(1)Under the law of England and Wales or Northern Ireland a document is executed by a company—
(a)by the affixing of its common seal, or
(b)by signature in accordance with the following provisions.
(2)A document is validly executed by a company if it is signed on behalf of the company—
(a)by two authorised signatories, or
(b)by a director of the company in the presence of a witness who attests the signature.
(3)The following are “authorised signatories” for the purposes of subsection (2)—
(a)every director of the company, and
(b)in the case of a private company with a secretary or a public company, the secretary (or any joint secretary) of the company.
(4)A document signed in accordance with subsection (2) and expressed, in whatever words, to be executed by the company has the same effect as if executed under the common seal of the company.
(5)In favour of a purchaser a document is deemed to have been duly executed by a company if it purports to be signed in accordance with subsection (2).
A “purchaser” means a purchaser in good faith for valuable consideration and includes a lessee, mortgagee or other person who for valuable consideration acquires an interest in property.
(6)Where a document is to be signed by a person on behalf of more than one company, it is not duly signed by that person for the purposes of this section unless he signs it separately in each capacity.
(7)References in this section to a document being (or purporting to be) signed by a director or secretary are to be read, in a case where that office is held by a firm, as references to its being (or purporting to be) signed by an individual authorised by the firm to sign on its behalf.
(8)This section applies to a document that is (or purports to be) executed by a company in the name of or on behalf of another person whether or not that person is also a company.

NO KEEPER LIABILITY
7.  The PCN does not mention or specify the period of parking at all, only the duration of the stay defined by arrival and departure times. The duration of the stay includes driving to a space, parking, leaving the space, walking to the supermarket, spending time inside the supermarket for purchasing, walking out of the supermarket and is not the same as specifically the period of parking. 
Schedule 4 of the Protection of Freedoms Act 2012 . Under Section 9 [2][a] it states  
(2)The notice must—
(a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;

8.  The lack of a Parking Period means that the PCN does not comply with PoFA. and so the charge cannot be transferred from the driver to the keeper. Only the driver is liable.

9.  Schedule 4 of the PoFA, Section 9 [2][f] states: 
f. warn the keeper that if, after the period of 28 days beginning with the day after that on which the notice is given—
(i)the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and
(ii)the creditor does not know both the name of the driver and a current address for service for the driver,
the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;

10.  The Claimant's PCN does not include the words in Section 9 [2][f] ii and therefore cannot transfer liability from the driver to the keeper.

11. The Claimant's Particulars of Claim state that the Claimant is pursuing the driver or the keeper. Given that the Claimant has no evidence who the driver is, the Claimant can pursue the Defendant only as the keeper, but cannot claim the Defendant is the driver as they have absolutely no proof. In this matter, the Defendant puts it to the Claimant to produce strict proof as to who was driving at the time. 

12.  As the Claimant cannot prove who was driving at the time, they can only pursue the Defendant as the keeper as being liable. It has already been ascertained that the keeper is not liable because UKPC have failed to comply with the Act.

ILLEGAL SIGNAGE
13.   At the time of writing the claimant has failed to provide the following, in response to the CPR request from myself, and has provided no Witness Statement with evidence. 

14.  The legal contract between the Claimant and the landowner (which in this case is ASM Supermarket) to provide evidence that there is an agreement in place with landowner with the necessary authority to issue parking charge notices and to pursue payment by means of litigation.

15.  Proof of planning permission granted for signage etc. under the Town and Country Planning Acts 1990 and 2007.  Lack of planning permission is a criminal offence under these Acts and no contract can be formed where criminality is involved. 

16.  Due to the failure to produce the documents in the 14-day duration following my CPR 31.14 Request dated 27/04/2023, or at all, I do not believe the claimant possesses these documents 

DOUBLE RECOVERY
17.   As well as the original £100 parking charge and £85 allowed court/legal costs, the Claimant seeks recovery of an additional £106.25.

18.   PoFA Schedule 4, paragraph 4(5) states that “the maximum sum which may be recovered from the keeper is the amount specified in the notice to keeper”. Which in this case is £100.

19.   Unless the Claimant can clearly demonstrate how these alleged additional costs have been incurred this would appear to be an attempt at double recovery.

20.   Previous parking charge cases have found that the parking charge itself is at a level to include the costs of recovery i.e. Parking Eye Ltd vs Beavis (2015) UKSC 67 which is the authority for recovery of the parking charge itself and no more, since the sum £85 was held to already incorporate the costs of an automated private parking business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages.

21.  It is indisputable that an alleged “parking charge” penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending on the parking firm) covers the costs of all the letters.

22.  Since 2019, many County Courts have considered claims in excess of £100 to be an abuse of process leading to them being struck out ab initio.
An example, in the Caernarfon Court in VCS v Davies, case No. FTQZ4W28 on 4th September 2019, District Judge Jones-Evans stated “Upon it being recorded that District Judge Jones- Evans has over a very significant period of time warned advocates (...) in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court V Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practise continued, he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared (...) the claim is struck out and declared to be wholly without merit and an abuse of process.”

23.   In Claim numbers F0DP806M and F0DP201T, Britannia vs Crosby the courts went further in a landmark judgement in November 2019 which followed several parking charge claims being struck out in the area overseen by His Honour Judge Iain Hamilton-Douglas Hughes GC, the Designated Civil Judge for Dorset, Hampshire, Isle of Wight & Wiltshire. District Judge Taylor echoed earlier General Judgement or Orders of District Judge Grand, stating “It is ordered that the claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgement in Parking Eye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for a additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998.

24.   The addition of costs not previously specified on signage are also in breach of the Consumer Rights Act 2015, Schedule 2, specifically paras 6, 10 and 14.

25.   It is the Defendant’s position that the Claimant in this case has knowingly submitted inflated costs and thus the entire claim should be similarly struck out in accordance with Civil Procedure Rule 3.3(4).

26.   The Defendant is of the view that the Claimant knew, or should have known, that to claim in excess of £100 for a parking charge on private lands is disallowed under the CPRs, the Beavis case, the PoFA AND THE CRA 2015, and that relief from sanctions should be refused.

CHANGE OF CIRCUMSTANCE
27. During the period when the first PCN dated 27th August 2021 was received and by the date the letter of claim (16/02/2023) was received, the defendant had moved to a new location and changed the address. Due to this change, the defendant was not initially in a position to respond to any claims from the claimant, as all correspondence was being sent to the previous address. 

It is by sheer coincidence the defendant happened to visit the previous address and found the Notice of Proposed Allocation To The Small Claims Track letter. 

It asserts that, had there been no change in the address, the defendant would have responded to the Letter of Claim, and the matter might not have progressed to its current stage.

IN CONCLUSION
28.  I respectfully request that the Court dismiss this claim.

Statement of Truth
I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

 

[FTMDave]

That's a good start.

I'll read things in detail and make some suggestions this evening after I knock off work.

 

[FTMDave]

OK, I've had a first go.  I haven't touched your version at all but suggest a tweaked version below.

1.  Gone is your CHANGE OF CIRCUMSTANCE section which I don't think has anything to do with establishing whether you owe the money or not.

2.  I've slimmed down the DOUBLE RECOVERY section but also underlined other fictitious charges they have made up.

3.  The bits in the BPA CoP are here  https://www.britishparking.co.uk/write/Documents/AOS/AOS_Code_of_Practice_January_2020_v8(2).pdf  You don't need to print out the whole thing.  Just the two pages referenced in the WS, and include them as an exhibit.

3.  Other changes in red.

 

Witness Statement of XXXXX

INTRODUCTION

1.  I, XXXXX am the Defendant in this claim. I represent myself as a lay person, with no formal legal training. Everything in the following statement is true to the best of my knowledge and belief. 

2.  I was the registered keeper of the vehicle: XXXXXX.

3.  In my statement I shall refer to exhibits within the evidence section supplied in this bundle referring to page and reference numbers where appropriate. 

BACKGROUND

4.  The Defendant received the Parking Charge Notice (PCN) dated 27th August 2021 (Exhibit 1). The PCN pertains to an incident on 20th August 2021 when the vehicle was parked at ASM Supermarket, 75-83 Oldham Road, Ashton-Under-Lyme, OL67DF.

The PCN was issued 6 days after the alleged contravention. Notably, the car park was almost empty and used exclusively for purchasing goods from ASM Supermarket.

Upon entering the car park, the driver did not observe any signs indicating parking restrictions and/or any notice/signs specifying that the vehicle registration should be entered at the till during/after the purchase.

On the day of the alleged contravention (20th August 2021), the driver did make a purchase from ASM Supermarket. A credit card statement reflecting this transaction is provided as Exhibit 2. 

LOCUS STANDI

5  There is no Locus Standi.  I do not believe a contract exists with the landowner that gives Civil Enforcement a right to bring claims in their own name, no contract has been produced after my CPR request (Exhibit 3). 

6.  The definition of “Relevant contract” from PoFA 2[1] means a contract, including a contract arising only when the vehicle was parked on the relevant land between the driver and a person who is-
(a) the owner or occupier of the land; or
(b) authorised, under or by virtue of arrangements made by the owner or occupier of the land, to enter into a contract with the driver requiring the payment of parking charges in respect of the parking of the vehicle on the land.
According to Companies Act 2006, Section 44. 
44 Execution of documents
(1)Under the law of England and Wales or Northern Ireland a document is executed by a company—
(a)by the affixing of its common seal, or
(b)by signature in accordance with the following provisions.
(2)A document is validly executed by a company if it is signed on behalf of the company—
(a)by two authorised signatories, or
(b)by a director of the company in the presence of a witness who attests the signature.
(3)The following are “authorised signatories” for the purposes of subsection (2)—
(a)every director of the company, and
(b)in the case of a private company with a secretary or a public company, the secretary (or any joint secretary) of the company.
(4)A document signed in accordance with subsection (2) and expressed, in whatever words, to be executed by the company has the same effect as if executed under the common seal of the company.
(5)In favour of a purchaser a document is deemed to have been duly executed by a company if it purports to be signed in accordance with subsection (2).
A “purchaser” means a purchaser in good faith for valuable consideration and includes a lessee, mortgagee or other person who for valuable consideration acquires an interest in property.
(6)Where a document is to be signed by a person on behalf of more than one company, it is not duly signed by that person for the purposes of this section unless he signs it separately in each capacity.
(7)References in this section to a document being (or purporting to be) signed by a director or secretary are to be read, in a case where that office is held by a firm, as references to its being (or purporting to be) signed by an individual authorised by the firm to sign on its behalf.
(8)This section applies to a document that is (or purports to be) executed by a company in the name of or on behalf of another person whether or not that person is also a company.

NO KEEPER LIABILITY

7.  The PCN does not mention or specify the period of parking at all, only the duration of the stay defined by arrival and departure times. The duration of the stay includes driving to a space, parking, leaving the space, walking to the supermarket, spending time inside the supermarket for purchasing, walking out of the supermarket and is not the same as specifically the period of parking. 

Schedule 4 of the Protection of Freedoms Act 2012 . Under Section 9 [2][a] it states  
(2)The notice must—
(a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;

8.  The lack of a Parking Period means that the PCN does not comply with PoFA. and so the charge cannot be transferred from the driver to the keeper. Only the driver is liable.

9.  Schedule 4 of the PoFA, Section 9 [2][f] states: 
f. warn the keeper that if, after the period of 28 days beginning with the day after that on which the notice is given—
(i)the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and
(ii)the creditor does not know both the name of the driver and a current address for service for the driver,
the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;

10.  The Claimant's PCN does not include the words in Section 9 [2][f] ii and therefore cannot transfer liability from the driver to the keeper.

11. The Claimant's Particulars of Claim state that the Claimant is pursuing the driver or the keeper. Given that the Claimant has no evidence who the driver is, the Claimant can pursue the Defendant only as the keeper, but cannot claim the Defendant is the driver as they have absolutely no proof. In this matter, the Defendant puts it to the Claimant to produce strict proof as to who was driving at the time. 

12.  As the Claimant cannot prove who was driving at the time, they can only pursue the Defendant as the keeper as being liable. It has already been ascertained that the keeper is not liable because Civil Enforcement Ltd have failed to comply with the Act.

BREACH OF CODE OF PRACTICE

13.  The Claimant is a member of the British Parking Association.  Its Code of Practice states (Exhibit XXXXX) -

"4.1b Where a Parking Charge becomes overdue and before Court Proceedings have commenced, a reasonable sum (which covers the cost of recovering debt) may be added for the debt recovery fees. This sum must not exceed £70 unless prior approval from the BPA has been granted".

The Claimant has breached the Code of Practice by demanding a sum of £82 both in its correspondence (Exhibit XXXXX) and in its Particulars of Claim.

14.  This is a car park which the driver has used frequently in the past and which did not have parking restrictions.  The BPA Code of Practice states -

"19.10 Where there is a change in the terms and conditions that materially affects the motorist then you must make these terms and conditions clear on your signage. Where such changes impose liability where none previously existed then you must consider a transition to allow regular visitors to the site to adjust and familiarise themselves with the changes.  Best practice would be the installation of additional/temporary signage at the entrance and throughout the site making it clear that new terms and conditions apply. This will ensure such that regular visitors who may be familiar with the previous terms become aware of the new ones."

I put the Claimant to strict proof that these transition signs were placed.  That should be easy - the Claimant will have a record of sign installation.  However, I know full well that the Claimant will be unable to do so because the signs were not there.  The Claimant is not really interested in sensible management of a car park, but rather in finding excuses to send out its PCNs

PCN

15.  The Claimant's PCN states that the contravention was "Permit Holders Only".  This is a nonsense.  No permits are issued for parking in a supermarket car park!  The real contravention was not registering the car registration number in the supermarket and this is not stated on the PCN.

ILLEGAL SIGNAGE

13.   At the time of writing the claimant has failed to provide the following, in response to the CPR request from myself, and has provided no Witness Statement with evidence. 

14.  The legal contract between the Claimant and the landowner (which in this case is ASM Supermarket) to provide evidence that there is an agreement in place with landowner with the necessary authority to issue parking charge notices and to pursue payment by means of litigation.

15.  Proof of planning permission granted for signage etc. under the Town and Country Planning Acts 1990 and 2007.  Lack of planning permission is a criminal offence under these Acts and no contract can be formed where criminality is involved. 

16.  Due to the failure to produce the documents in the 14-day duration following my CPR 31.14 Request dated 27/04/2023, or at all, I do not believe the claimant possesses these documents 

DOUBLE RECOVERY

17.  The Claimant has added a whole number of totally fictitious charges to their initial claim for £100.  This is simply a poor attempt to circumvent the legal costs cap at small claims.

18.  Firstly, the Claimant is claiming £50 legal representative's costs even though they have no legal representative and are in fact representing themselves.

19.  Secondly, as well as the original £100 parking charge the Claimant seeks recovery of an additional £70 which is allowed by their trade association, although not by the law in England and Wales.

20.  Thirdly, this figure of £70 has been inflated to £82 which is not only unlawful but also a breach of their own trade association Code of Practice.

18.   PoFA Schedule 4, paragraph 4(5) states that “the maximum sum which may be recovered from the keeper is the amount specified in the notice to keeper”. Which in this case is £100.

19.   Unless the Claimant can clearly demonstrate how these alleged additional costs have been incurred this would appear to be an attempt at double recovery.

29.  Since 2019, many County Courts have considered claims in excess of £100 to be an abuse of process leading to them being struck out ab initio.

An example, in the Caernarfon Court in VCS v Davies, case No. FTQZ4W28 on 4th September 2019, District Judge Jones-Evans stated “Upon it being recorded that District Judge Jones- Evans has over a very significant period of time warned advocates (...) in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court V Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practise continued, he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared (...) the claim is struck out and declared to be wholly without merit and an abuse of process.”

34.  In Claim Nos. F0DP806M and F0DP201T, District Judge Taylor echoed earlier General Judgment or Orders of District Judge Grand, stating ''It is ordered that the claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in Parking Eye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

35.  The addition of costs not previously specified on signage are also in breach of the Consumer Rights Act 2015, Schedule 2, specifically paras 6, 10 and 14.

36.  It is the Defendant’s position that the Claimant in this case has knowingly submitted inflated costs and thus the entire claim should be similarly struck out in accordance with Civil Procedure Rule 3.3(4)

IN CONCLUSION

28.  I respectfully request that the Court dismiss this claim.

Statement of Truth
I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Edited January 15 by FTMDave
Extra info added

[xtonehari]

Hi FTMDave,

Thank you for the revised witness statement. It is accurate and fits to the purpose. 

Shall I go ahead and submit the WS. Does the WS has to be submitted in person or can it be submitted online or by email. 
 

[honeybee13]

On 07/01/2024 at 17:22, dx100uk said:

as you've been continuing to read up here during the down time........ you should already know you have to do a witness statement by 14 days prior the hearing and send itto the court and the claimants solicitors.

post up your ideas here for checking.

dx

 

This should help.

HB

[FTMDave]

Wait!

You have over a fortnight yet to file it.

Plenty can happen in the meantime. 

[lookinforinfo]

Ideally you would like to see what hogwash CEL send purporting to be their Witness Statement. There may be a couple of things in it that you could add in your WS to strengthen your chances of getting the rogues to cancel before any Court case.

[FTMDave]

I agree with LFI.  Hang on to see CEL's WS.

Were you able to get details of the persuasive judgement that I PM'd you about?

[xtonehari]

I have not received any statement from the claimant. Is it time to send my witness statement or shall I wait. 

[dx100uk]

not due till fri 2nd.

if they've not filed theirs then the court can't/won't knuckle wrap you either....( and so what if the judge does......)

and you are a LiP (litigant In Person - Joe Public against the system) you are given certain leeway.

pers id not file yours till we have theirs and check yours covers their probable lies.

even if that means you are 2-3 days 'late'

dx

 

[FTMDave]

dx is spot on.

On 17/01/2024 at 13:13, FTMDave said:

Were you able to get details of the persuasive judgement that I PM'd you about?

And?

[xtonehari]

Hi FTMDave,

Sorry, from where or how do I get the details for persuasive judgement please.