That is superb - well done. Succinct but with three clear, hard-hitting legal arguments. The judge only has to agree with one. Like anything it can be tweaked a bit. I'll look in this evening in my usual Night Owl way when work has been forgotten for the day.

Well done on sticking with it until you got every last penny!

Well, D-Day has been and gone, and the money is still safely in my account - twice! Thanks to FruitSalad and everyone who helped. I'll certainly know what to do in future thanks to you all.

Not very important in the grand scheme of things but I see there is an error in the judgement - it says the defendant attended the hearing but the claimant did not.

Being in Scotland will help enormously as there is no POFA so no Keeper Liability. Please complete this -

Moved to private parking forum.

So, presuming the fleecers haven't sent anything today, start your claim tomorrow. Just be careful that as your mum got the ticket, and your mum sent the SAR and the LoC, it's your mum who starts the court case.

Understood, I too had managed to download only horrible blurry photos from Google! The reason that we are wittering on about signs is because the fleecers are likely to have put some conditions in electron-microscope readable print on their signs. It still means they haven't got a hope in hell because whatever they've hidden away will be trumped by the much bigger signs you saw. However, it would be useful to know. So please follow NB's suggestion and see what you can get from the charlatans' site.

I'm afraid evidence is completely irrelevant. You have to understand how the PPCs work. They are interested in one thing and one thing only - money. So all they do is try to bully motorists into paying. And sadly it works. Most people think these letters are fines and pay up, and most of those who initially resist give in when the legal threats start. What counts is the internal policies of each company, which we've managed to suss out over the years. One company, called Vehicle Control Services, is obsessed with punishing non-payers by starting court claims. Others see court as a time-consuming & expensive distraction and something complicated that they don't want to do. As I wrote in post 30 -

In post 17 you've uploaded a horrible blurry photo. Is that the quality that BW Legal sent you?

Well, it's up to you. However, as G24's MO is to come out with lots of threats but eventually give up, I don't see any point in poking them with a big stick. Personally I'd let sleeping fleecers lie.

OK, an ideal moment to cut e-mail contact. NB is spot on. There are a number of tactical advantages if you force them to use snail mail. 1. As scribbled above, they can't file lies right on the deadline. 2. To respect the court's deadline, they generally send out the WS quite early by post, meaning you get to see their case and can ridicule it in your WS. 3. If they don't respect the court's deadline, again you can include that in your WS. 4. If nothing arrives you can get an idea if they are going to discontinue or not.

When is the hearing date?

1. Yes, go for it. They seem to have strange ideas about data protection, but try and see what they say. They're certainly up for fighting the fleecers. 2. It was forum regular Ericsbrother who coined the term, so credit where credit's due! We generally head the section of the Witness Statement ABUSE OF PROCESS or DOUBLE RECOVERY. Just refer to it as an unfair charge or as double recovery, a very poor attempt to get round the costs cap at small claims. 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. You can lift lots of Alaska101's DOUBLE RECOVERY section. The fleecers do the same thing in every case. 3. Yes, Schedule 4 of the Protection of Freedoms Act 2012. And who cares what a biased trade association says is allowed? Its is what the law in England & Wales says is allowed that counts. 4. Either paper or e-mail. We generally advise to e-mail the court but to use snail mail with the fleecers. That way they can't get your e-mail address and file lies at one minute to the court's deadline which you wouldn't be able to rebut. 5. Use the updated version in Alaska101's WS.

Use https://www.ilovepdf.com/compress_pdf

IIRC on the other thread we had a discussion about whether the amount should be £100 or £200, before deciding on £200. I think you should stick to £200. D-Day is the day after tomorrow, right?

That looks absolutely fine to me, except ... ... why do you want to claim exactly £220?

Thinking about it, I would suggest four sections in the WS. SEQUENCE OF EVENTS - self-explanatory. FRUSTRATION OF CONTRACT - self-explanatory again. BREACH OF CODE OF PRACTICE - read 9.5 here https://www.britishparking.co.uk/write/Documents/AOS/AOS_Code_of_Practice_January_2020_v8(2).pdf ABUSE OF PROCESS - Unicorn Food Tax.

Any reply from Iceland?

OK, I had tracked down the owner of the retail centre and I was thinking you could have pushed them to have the charge cancelled - if you had lots of proof of spending dosh there.

Things like the BPA's report, the TripAdvisor page, etc., need to have an individual exhibit number and you need to refer to that number in your WS, Point taken. Indeed judges appreciate succinct WSs a lot more than pages & pages of tripe - which is what OPS will send. I still think you can flesh it out a bit. You should include a bit from the local rag. I see way back in post 6 you found an article with a photo of the broken machine. On https://llangrannogwelfare.org/beachfront-car-park there are details of two court victories against OPS for this car park. Scroll down to Report 3 (Feb 2022) & Report 5. Legally these are known as "persuasive cases" in that the judge is not obliged to take note of them, but can do if they wish. But if the judge knows that colleagues have chucked out cases elsewhere he/she is highly likely to do the same. It would be very useful to do some digging and find out the case numbers so you can quote them. As I wrote on page 1 of your thread there are the names of several motorists who it should be easy to contact through social media, a solicitor, a FB page, a sort of residents association IIRC and the journalists, who are likely to sympathetic, all publish their e-mail address. On https://llangrannogwelfare.org/beachfront-car-park scroll down to Advice from Sara Powell, retired local barrister She is someone to try to contact to get the court victory claim numbers. You should quote from the BPA report, especially that the BPA's inspector would have got a ticket too. Did we find anything wrong with the contract? You should also object to the 2 x £70 Unicorn Food Tax they've made up and added to the claim. In (4) you need to change "penalty charge" to "parking charge" or "PCN" or "parking invoice" because it's not a penalty charge. Your Statement of Truth is out of date. The new one is at the end of every WS here.

What you've written is very good - but nowhere near enough. I'm at work at the moment but will look in late this evening. Well done on getting a first draft done well in advance of the hearing date.

Excel ... not VCS ... there may be a way to get out of this but please fill in the sticky as dx says and upload the correspondence.

An idea. Have you still got receipts or bank statements for purchases you made that day at the retail centre?

Yes, laugh at them and ignore.