Morning everyone. So my case is scheduled on 12 of July. Last week I have received VCS witness statement which came way after the deadline (which was on 17th of May). They put THEIR date which is I think 12th of May. But on the postage stamp on the envelope in which WS came is around 28 of June. I am also enclosing it on the forum. Can I mention it to Judge that I have received their WS after the deadline? I have already emailed court on 18th of May that I have not received their WS on time. VCS-WS.pdf

how would you verbalize this kind of tactics? Is it Abuse of process?

posting allocation form to be on the safe side allocation_form.pdf

Notice to Allocation to the Small Claims Track states : by 4pm on 17th May 2022 you must file at Court and serve to your opponent. Do I need to post my WS to Court or I can just email it? Thanks

Good morning everyone, I got question. Still have not received VCS Witness statement. I was wondering - what happens when it wont be delivered on time? Thanks

Good afternoon everyone I am posting the latest WS draft. One question - my deadline for posting this WS is on 17/05/2022. So when I should post it at the latest? Still havent received VCS WS. Thanks Witness Statement - forum.pdf

I forgot to ask. Should I include it in my WS, chronological order of events? I mean should I write down - why I stopped? Unfortunately, unconsciously I admitted that I have been driving during that event on my appeal back in 2018. The reason was - car has broken down. Following @lookinforinfo advice to include Section F.3 Appeals, I would like to emphasise my case. but that would mean simultaneously admitting that I was the driver.

Good morning everyone I would really thank you very much for words of appreciation. To be honest I used whole body of @Flamjam Witness Statement, and added some small bits of pieces. I also tried to approach this as best as I can. @FTMDave I have amended those parts which you mentioned in your last post. Posting soon @brassnecked Thank you very much @lookinforinfo Thank you mate. I am trying find the source where you got Section 9 with comments, and with F.3 Section. Is it on gov site?

Here is very first WS draft Witness Statement - forum.pdf

Good morning everyone, So I got my case has been allocated to small claims court. Hearing is on July. I need to submit my WS before 17/05/2022. Later on I will upload first draft. I was just wondering, when I will receive VCS Witness statement. Do I need to send them my WS as well?

Morning everyone, 1 copy to ELMS , 1 to court and the last one to whom?

ok I think I got my answer...

Yes

Good afternoon everyone I have submitted my defence. I am about to fill N180 Why I should choose No to meditation? I heard it cant go against me ,but it could go in my favour, couldnt it?

I would explain what is KADOE contract before 5.2

What case was it?

It looks like same generic copy paste WS by VCS? Am I right?

Where it can be proven that Airport is owned by Ancala 45%, Peel Group 45% and Liverpool council 10%

Thank you guys for clarification

Hello everyone, Lately I came across another hint which can be used aginst VCS. The thing which I managed to figure out is If VCS cited in their various PCN or NTK, that driver made contravention on ''private land'' then it is a '' false misrepresentation'' ( because we know that airport roads are under bylaws). So trying to recover money on that premise is classified as a fraud (Sec 2 chpt 35 Fraud Act 2006). Is it good idea to use this in my defence? How to properly formulate that point in defence?

ok thank you very much guys. I really appreciate help

I have just noticed 5 para in my defence 5. The Particulars of Claim is denied in its entirety. It is denied that the Claimant is entitled to the relief claimed or any relief at all. Can I expand this line of defence in WS by ''abuse of process'' by adding additional 60£ as Debt recovery costs?

No worries FTMDave Sorry for rising another concern, but during the weekend I have tried to spend maximum time to do research. I just also found that PPCs often introduce debt recovery. Now I know I should be concise and simple with my defence, keeping my cards coverd, but I have heard that I wont be able to introduce another points of defence in my WS. What you think about introducing last point 6. The Claimant alleged recovery costs include an additional £60 for “debt collection charge”. Aforementioned sum represents an attempt at double recovery, which may be considered an abuse of process, and invite the Court to strike out the claim ab initio for that reason. or extending exisiting 5 para by aforementioned '' Abuse of Process '' line of defence 5. The Claimant's invoice was issued in early April 2018 and it is unreasonable for the Claimant to delay litigation for nearly four years and to claim 8% interest for that whole period.

Good evening everyone. I am almost ready to submit my defence. I also want to add another point in regards cost of attendance at Court ( lost of earnings) In the matter of costs, the Defendant seeks: 7. (a) standard witness costs for attendance at Court, to CPR 27.14, and (b) that any hearing is not vacated but continues as a costs hearing, in the event of a late Notice of Discontinuance. The Defendant seeks a finding of unreasonable behaviour in the pre-and post-action phases by this Claimant, and will seek further costs pursuant to CPR 46.5.

IS there any information what is the outcome of this case? Was it lost or won?