Defence.
1. I am the named Defendant in this case.
2. It is acknowledged that I was the Registered Keeper of the vehicle at the material time.
3. That I deny that any money is owed by myself to the Claimant.
4. That the Claimant does not know who was driving the vehicle at the material time.
5. That there is no legal requirement for a vehicle keeper to provide driver details in a contractual dispute such as this one.
6. That I am not prepared to reveal the drivers details under any circumstance since the law does not require it - (VCS Ltd v Edward)
7. That the Claimant is, in the alternative, attempting to pursue me on the grounds of 'keeper liability' under the terms of Protection of Freedoms Act 2012 (POFA).
8. However, in this instance, the Claimant's Notice to Keeper (NtK) does not meet the statutory requirements set out in POFA Schedule 4 Paragraph 9(2).
9. That, in particular, the Claimant's NtK does not meet the requirements of Schedule 4 Paragraph 9(2)(e)(i) since the NtK does not 'invite the keeper to pay the unpaid parking charges'.
10. That a previous County Court Case has already found that the Claimant's NtK did not meet the above requirements and, as such, the Claimant is aware that their NtK is not POFA compliant.
11. That, subsequent to their defeat in the aforementioned case, the Claimant altered the pro-forma wording on their NtK in an effort to make it POFA complaint and, as such, their behaviour in that respect appears to demonstrate that they accept that their previous notices were not complaint.
12. That the Claimant's pro-forma NtK in this case is an NtK which pre-dates the re-worded NtK and is, therefore, clearly not POFA complaint.
13. That keeper liability can not therefore occur in this case.
14. That, therefore, there is not legal route to liability in relation to the alleged debt.
15. That liability for the debt is therefore denied in its entirety.