Thanks @FTMDave - luckily done this already as I recall it being advised previously! Donated @Andyorch thanks again

Just to update you all (and so sorry it has taken me an age to get back on here) - we received a letter from CEL to say they weren't pursuing this case due to 'the current situation' and they dropped it back in May! Woohoo! Huge huge thank you to everyone for your help and patience with this - my husband and I really appreciated it! We definitely wouldn't have carried it on to the extent that we did without the support and encouragement from you. Keep fighting the good fight La Luna

Just to let everyone know that ive submitted all of the paperwork and so please dont spend anytime reviewing any documents as i dont want to waste anyones time. I did think of leaving it and working on it more this eve but i mustve racked up over 25 hours on this now and its causing my already-in-a-state wife far more stress than i can put on her. Hopefully they were ok (still havent received CELs WS so hopefully thats a good sign) and ill keep you updated. Fingers are firmly crossed. Than you for all of your help, wisdom and encouragement over the last few days too. @ericsbrother ill review your feedback as i imagine therell be useful things in there if it goes to court. Enjoy the sunny weekend everyone, cheers LLH

Cheers guys, appreciate the positivity right now. All valid points @FTMDave cheers. Pretty certain unfortunately that "Medburn Estates" are the landowner, my wife bought the attached from Land Registry a few months ago. Waiting on the planning officer to get back to me re. looking at the original planning permission. Found this with relation to the buildings going up but no detail so hope he can provide it form e: https://portal.newcastle.gov.uk/planning/index.html?fa=getApplication&id=16184 but struggled to find anything about general policy around commercial land and parking permissions. Will keep researching! RegisterTY79684.pdf

Final draft here guys. Will be submitting it around 3:30pm if anyone is around over the next few hours. No worries if not, ill keep you all updated on the progress. Cheers final WS .pdf

I'm proof reading this and finding holes in my argument all over the place. Not feeling confident at all and Im conscious of time as i need to finalise all of the appendices etc before i can send. Had to heavily amend point 13, as the signage does mention 'additional charges' so i cant really use that. along with a few others bits too. @FTMDave @ericsbrother @brassnecked @lookinforinfo Is there anything specific and concrete that you can shed light on that i can quickly include? You previously mention that the NTK doesn't create any liability, how? I've attached the signage again along with the original NTK. Tenerife_Buildings_PCN_-_Newcastle.pdf

Pre-final draft of my WS. Any fresh eyes would be great as ive been on this for the last 7 hours now and I cant see for looking anymore. massively sorry if ive missed anything, your help, advice and guidance has been invaluable. *** Still unsure about my point 6 and POFA and how its failing to create keeper liability as NTK a. mentions POFA, it states the 28 days. Help! The only thing i'm sure of is that i defo didnt receive a notice to driver as per POFA. Any specifics that i can actually quote would be brilliant right now. Will be sending off tomorrow. Still nervous about the fact that i need to post this to CEL and will therefore be late. Will this matter? i can also email a copy to a random mediate email address they put on some correspondence in the meantime. Still havent received theirs neither FYI. cheers people LLH witness statement.pdf

All taken on board and amending, thanks. Can i 100% check that this NTK is non-compliant? It defo is in terms of it being issued to the keeper and nothing came for me before this, but it does mention me having to give them info as to who it was within 28 days etc etc. Think this POFA and keeper liability bit is what I’m most worried about. PCN.pdf

Thanks everyone, appreciate your feedback and encouragement. Definitely feeling more confident in this whole thing compared to this time yesterday. @anniebattlemum thank you and thanks for the heads up on your additional notes. I must admit that i stopped reading the page once i'd seen they had given in. your work is brilliant so thank you so much as it has been a huge help. Will go over the rest of those notes now. @FTMDave not overly critical at all, keep it coming please! All noted so far and have updated WS. They fleeced her between 3:43 & 16:25. Unfortunately I only have emails from around during the day then 4:15/4:20. got evidence of where i request a parking space if i ever have the car. Defo didnt have the car there that day so no space request so hopefully will help? Also have messages between my family where i confirm where to meet them (in Newcastle CC) during the day and CC statements proving i purchased things. Granted theyre not time stamped but is better than presenting nothing im hoping? clutching at straws haha CEL havent sent their WS yet no which is frustrating. How bad is it if mine is late to them? I would prefer to send them a paper copy (the court wants me to email theirs) so have loads of time but conscious that posting it is defo going to be late. @lookinforinfo cheers for the meaty reply. definitely think that contacting medburn is a great idea but out of time to do it in a letter for the WS (its due at 4pm tomorrow frustratingly) think ill send one anyway but not to include. ill still include some of the things youve written though as if my wife requested the contract, surely they should have sent the proper one if they have one and not just this piece of paper? Thanks for the reminder @brassnecked completely forgot to include any of that yesterday. will read up more and include now. thanks again for your time and effort with this. Vive la résistance!

Right, first draft attached. I'm bloody knackered, it's tough. It still needs bits and bobs finshing mind. Would someone be able to take a quick look at it please? I'm worried there are things in there that i've not realised don't apply to this case and i'll screw myself over with it. One thing i haven't mentioned is that there are inconsistencies within the paperwork, one letter has another vehicle/issue mentioned in it and a few others have the date stamp as 00:00:00. Is this inconsistency worth mentioning? Also feel like the keeper liability/POFA section isn't overly strong. Should i be concerned about this, ie i didnt admit who the driver was? many TIA everyone. witness statement.pdf

Thanks DX, that was my gut feeling also. However the planning portal doesn't give any information re. the original planning permission given to that site. I've been searching but can't seem to locate anything anywhere that says what the minimum duration's should be on a site. I've emailed the planning officer who originally told my wife that the signs didnt have permissions so hopefully he will come back with something. Thanks for the heads up

Wow, cheers @FTMDave and @brassnecked. Going through it all slowly, thanks. AnniesMum did some bloody good work! My wife requested (under CPR 31.14) in writing, the contract between the landowner and CEL (Please treat this letter as my request made under CPR 31.14 for the disclosure and the production of a verified and legible copy of each of the following document(s) mentioned in your Particulars of Claim: 1. The contract between Civil Enforcement LTD and the landowner that assigns the right to enter into contracts with the public and make claims in their own name. ) They have only sent back the attached. Does this provide any ammo? Seems very simple. Cheers both contract.pdf Also only mentions that it is permit holder only (insinuates the car was parked in a residents only area or something) whereas you can a. still park there for 20 mins 'free' and b. register with businesses to park there. Thoughts?

Hi all Hope you dont mind me posting on here but my wife said you've been really helpful throughout the PCN issues and recommended me writing on here. My wife has been dealing with this PCN throughout (shes like a dog with a bone) and has just told me the witness statement paperwork is due on Friday. She is pregnant and has been sick constantly over the last few weeks and has admitted that she hasn't done much work on the witness statement and is in a bit of a state about it. Granted this is my PCN as its in my name but she has been adamant that she wanted to fight it (i just wanted to pay it from day dot). I dont want her stressing over this especially the state shes already in. I'm happy to do this witness statement especially seeing as its my court case so ive taken today off work to get it sorted. I'm well aware i'm out of the loop with it though and she's not been in any state to go through it all. From what I gather: 1. The signage doesn't offer a contract. Can someone explain how this is the case please? My understanding is that its about offer and acceptance but not sure in what sense? 2. She has evidence from the council that the signage doesn't have planning permission. This then means that anything written on the signs are null and void? 3. the sign says there will be £100 charge for breach but doesnt breakdown where an additional £167 odd will come from (is this a valid argument? Read on another thread someone won on these grounds) 4. All of this is chasing me as the keeper but i wasn't the driver 5. original NKT doesnt have a photograph of the car and as i wasnt the driver i did think this was spam mail (or shouldnt i mention that) Qs 1. which of the signs are the worst? or both as bad as each other? 2. do i elaborate more on the fact that i definitely wasnt the driver? I can give dated emails etc from work for that day to prove it Any help would be amazing right now. I'll keep reading these sites to do my own research, its quite fascinating when you get in to it! Happy to just pay this though if you think its the best course of action. Cheers lalunas husband.

Hi Everyone, Hope you're all keeping well despite all of this craziness! I had hoped that this would go away but clearly they're like a dog with a bone. We've received a letter to the case has been allocated to the small claims track although haven't received a date for it yet. We do however have to submit the Witness Statement etc by 29th May so will be cracking on with this the next couple of days. Just wanted a bit of advice though please - as it was me that was driving, should I go as the witness/put the paperwork together as me? Also, re. the back story of the local businesses saying they'd add the car reg so we didn't get a fine and then didn't; should we put that in our WS or focus wholly on the elements such as that the signs haven't had planning permission and the signage doesn't form a contract etc? Thoughts welcomed Thanks