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Thank you so much, it covers all the points I was trying to get across and more.

Do I need to attach an appendix with all the cases mentioned- or can I submit the witness statement as is. As the claimant witness statement has all the letters- do I need to attach them to my witness statement? 
CPR 16.4, POFA act 2012,
ParkingEye v Beavis [2015].

The cases mentioned

So, I have just recieved the documents from SIP carpark now- about 10 minutes ago! It's 36 pages long- and double sided! What is the best way to upload to the forum?

Thanks.
Deadline to submit is tomorrow 3pm and I don't know where to start!

It's at Manchester county court.

I have attached the whole document I recieved. I double checked both the fee deadline and the document submission deadlines are the same.

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Hi,
I have recieved a notice of allocation to small claims track a few weeks ago- with a deadline for claimant to submit fee/ and to submit a witness statement and all documents to rely on at the hearing by 4pm on 22nd July 2025 to the court and to the claimant.

I have not yet recieved any witness statement from the claimant.

I'd appreciate help in what to include in the witness statement, as well as any documents which should be included.

I used the defence as advised earlier- do I rely on the defence statements ie non compliance with CPR 16.4.

Or

Would I base my witness statement on the series of events- such as the first letter being recieved later than 28 days and without details and not fulfilling the conditions of PofA 2012, para 7(2) (c) and 8 (2) (c) about insufficient fees paid- "...the notice should specify the remaining unpaid amount".

Would I also attach a copy of my appeal letter? Photos of the site? What other documents would need to be attached.


Many Thanks in advance.

Thank you so much for your reply.

Apologies if this is basic, I just wanted to clarify how best to do the following:

"When you're ready you combine both documents as a single PDF attachment and send as an attachment in an email.."

Would it be fine to Copy past the defence and in the same document (new page) paste the draft order and save as PDF? Does the draft order need a title/ eg appendix/"copy of draft order" or just keep it as it is.

I received a payment overdue letter on 13/10/2022 with a fee of £115; for insufficient fee paid on 31/8/2022. It referred to a Notice to Keeper sent on 6/9/22, which I didn't receive, nor was a ticket placed on the windscreen. I ignored this  as I thought it was a scam as no details on letter. Subsequently, 2 more letters fortnightly with additional charges to £160- again ignored.
On 9/11/2023 received another letter for £100 due- I then emailed SIP car parks to appeal and get further details, they sent a copy of the first letter sent dated 6/9/22 and photos of signs. They confirmed 2 hours were paid, 26 mins overstay (including 10mins grace period). They then sent a letter stating no further direct communication will be made. I was not the driver, but am the registered keeper named on V5C for the vehicle. I felt these charges for the overstay were just extortionate!

Now, I have a county court claim for money- issued 30/1/2025. Acknowledgment of service sent on 8/2/25 via Moneyclaim.gov.uk website.
I believe I must submit a defence before 4pm 4th March 2025, and have been looking at previous defence letters that have been adviced on this forum- of CPR 16.4 POC inadequate- will that apply in my circumstance?

I would appreciate your help to formulate a defence. Thank you in advance
I have attached the claim form with details redacted.

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