He has:
I said that there is nothing that is stated as "Annex 1"
They haven't included it in the SAR.
You could challenge them to produce a full and unredacted contract in the defence, including Annex 1.
That is what I thought (and what I thought I had stated), but thanks for confirming. I will request he contract in full as you suggest.
So far I understand the advice is to:
- Read the template defence as you referenced in your PM and adapt any relevant sections
- Request a full and unredacted contract including Annex 1
I know this doesn't seem to be meeting with much enthusiasm, but I am still keen to include a statement from the landowner's representative along the lines of "the driver had been advised to park in that position and we do not consider it to be an obstruction". As the charge is for obstructive parking, it seems the crux of the matter is whether it actually was obstructive. Given that this is hard to prove one way or the other, a statement from the landowner that they do not consider it obstructive should surely be worth something?
Thanks
*EDIT*
I would also appreciate confirmation on timescales. The MCOL summary states:
Your acknowledgment of service was received on 16/10/2023
When would be the final day for submission of a defence?
Thanks