DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX

Would this be ok to send? Or should I amend/add anything else in?

IN THE COUNTY COURT AT BRIGHTON
CLAIM NO:
BETWEEN:
G24 LIMITED (Claimant)
-and-
[YOUR FULL NAME] (Defendant)
WITNESS STATEMENT OF [YOUR FULL NAME]
I, [YOUR FULL NAME] of [YOUR FULL ADDRESS], am the Defendant in this matter and will say as follows:
1. INTRODUCTION & CURING OF PROCEDURAL DEFECT
1.1 I am the Defendant in this claim and the registered keeper of the vehicle [VEHICLE REGISTRATION]. I represent myself as a Litigant in Person.
1.2 I make this statement in support of my defence and in response to the Claimant’s Witness Statement prepared by Annalise Cogley of DCB Legal Ltd.
1.3 In paragraph 32 of the Claimant’s statement, they invite the Court to strike out my defence on the grounds that it lacked a signed Statement of Truth. As a Litigant in Person using the online portal, the signing requirements were unclear to me. I respectfully ask the Court to exercise its case management powers under CPR 3.1(2)(m) and accept this signed Witness Statement as the formal verification and curing of any defect in my original defence.
2. UNREASONABLE DELAY AND PREJUDICE
2.1 The Claimant is pursuing charges for parking events that allegedly occurred on 16 September 2019, 07 October 2019, and 06 March 2020. The Claimant inexplicably waited nearly six years to issue this claim.
2.2 While within the statutory limitation period, this excessive delay is highly unreasonable and has severely prejudiced my ability to defend myself, as I am no longer in possession of the original photographs I took at the time. I respectfully submit that the Court should exercise its discretion to deny any statutory interest claimed, as the Claimant should not profit financially from their own tactical and unreasonable delay.
3. FAILURE TO PROVE A CONTRACT WAS FORMED (CONFUSING SIGNAGE)
3.1 The core of the Claimant’s case is that a clear contract was offered via signage, which I allegedly breached. I dispute that any valid contract was formed. My recollection of the site is that the signage was chaotic, contradictory, and completely unclear as to the terms of parking.
3.2 I exhibit at "MC1" a collage of photographs I have sourced showing the historical condition of the Homebase car park, 182 Old Shoreham Road, Hove (BN3 7EX). As the Court will see, multiple operators have left overlapping, contradictory signs prominently displaying varying maximum stay limits of 60 minutes, 120 minutes, and 150 minutes simultaneously.
3.3 Under the contra proferentem rule, any ambiguity in a drafted contract must be interpreted against the party that drafted it. Because the Claimant’s site was historically mismanaged with conflicting terms, no clear offer was made, and no contract was formed.
4. THE CLAIMANT'S FLAWED AND OUTDATED EVIDENCE
4.1 The burden of strict proof rests entirely on the Claimant to prove that clear, legible, and unambiguous signage was present on the specific dates in question. They have failed to do so.
4.2 In Exhibit AC2, the Claimant provides generic, zoomed-in photographs of a G24 sign. Crucially, these photographs contain absolutely no time or date stamps. The Claimant has provided zero evidence to prove these specific signs were actually in situ, unobscured, and legible to a driver on the dates of the alleged events.
4.3 Furthermore, in Exhibit AC4, the Claimant relies on a "Site Commissioning Sheet" and map dated 19 October 2017. This map pre-dates my alleged parking events by two to three years. It is utterly irrelevant and fails entirely to prove the layout, condition, or existence of the signage on the material dates in 2019 and 2020.
4.4 In Exhibit AC1, the Claimant provides a letter from Homebase purportedly granting them authority to operate. This letter is completely undated. It fails to specify the duration of the contract or confirm that the Claimant actually held legal authority to issue charges and pursue litigation on the specific dates in 2019 and 2020.
5. UNENFORCEABLE ADDITIONAL COSTS
5.1 The Claimant is attempting to recover additional, inflated "debt recovery" costs on top of the original parking charge.
5.2 I direct the Court’s attention to the open letter issued by the Competition and Markets Authority (CMA) to the private parking sector on 16 July 2026. In this letter, the CMA explicitly warned operators against the potentially unfair practice of attempting to recover arbitrary additional fees, reminding them that all consumer terms must comply with the fairness requirements of the Consumer Rights Act 2015. The Claimant’s added debt recovery costs are an unfair penalty, disproportionate to any actual loss, and are legally unenforceable.
6. ATTENDANCE AND REQUEST FOR LAY REPRESENTATIVE
6.1 I suffer from severe anxiety and other health conditions which make public speaking in a formal setting extremely difficult and distressing for me.
6.2 I will be attending the hearing in person alongside my partner, [PARTNER'S FULL NAME]. Under the Lay Representatives (Rights of Audience) Order 1999, I respectfully request that the Court permits [PARTNER'S FULL NAME] to act as my Lay Representative and exercise rights of audience to speak on my behalf during the hearing, while I remain present.
STATEMENT OF TRUTH
I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
Signed: _____________________________
Name: [YOUR FULL NAME]
Date: [DATE OF SIGNING]

This is a good start. Well done for drafting something up for us to feedback on - that's always much better than expecting forum members to write one from scratch 

2. UNREASONABLE DELAY AND PREJUDICE
2.1 The Claimant is pursuing charges for parking events that allegedly occurred on 16 September 2019, 07 October 2019, and 06 March 2020. The Claimant inexplicably waited nearly six years to issue this claim.
2.2 While within the statutory limitation period, this excessive delay is highly unreasonable and has severely prejudiced my ability to defend myself, as I am no longer in possession of the original photographs I took at the time. I respectfully submit that the Court should exercise its discretion to deny any statutory interest claimed, as the Claimant should not profit financially from their own tactical and unreasonable delay.

This feels like 2 points mashed into one. It might benefit from separation. You seemingly have 2 issues with their delay:

• That their delay has adversely impacted your ability to properly defend the case - your recollection of relatively unremarkable events from nearly 6 years ago has understandably faded, and previous evidence gathered has been lost.
• That the delay is entirely their own doing, and accordingly, you don't believe they should be entitled to be unfairly enriched to the sum of 6 years of interest on the sum claimed, in the event they win the claim.

3.2 I exhibit at "MC1" a collage of photographs I have sourced showing the historical condition of the Homebase car park, 182 Old Shoreham Road, Hove (BN3 7EX). As the Court will see, multiple operators have left overlapping, contradictory signs prominently displaying varying maximum stay limits of 60 minutes, 120 minutes, and 150 minutes simultaneously..

I assume the 'collage' to which you refer is this:

If so, it suffers the same problem as the Claimant's evidence: namely that the photos are undated. As you rightly note elsewhere, what matters is what signage was there at the time of the alleged incidents. 4 of the 6 images in that collage appear to be of the same lamp-post, taken at different times. I'm not sure this demonstrates the point that varying terms have been displayed 'simultaneously'.

At face value, it might weaken your argument if you rely on undated photographs to support your arguments in relation to signage, then in the next paragraph argue that the claimant cannot rely on undated photographs to make their argument.

3.3 Under the contra proferentem rule, any ambiguity in a drafted contract must be interpreted against the party that drafted it. Because the Claimant’s site was historically mismanaged with conflicting terms, no clear offer was made, and no contract was formed.

To play devil's advocate here:

Contra Proferentem is reverenced in Section 69 of the Consumer Rights Act:


"The meaning that is most favourable to the consumer is to prevail" is not the same as "If a term in a consumer contract, or a consumer notice, could have different meanings, no contract is formed". If we accept that there were 3 different maximum stays advertised (60 mins, 120 mins, 150 mins), then the meaning most favourable to the consumer would appear to be the one that allows him to stay the longest (150 mins) - even if that meaning were to prevail, the driver would still have exceeded that limit on all three occasions.

You can argue that the signage showing conflicting times was confusing, but it might be an uphill battle to argue that, having read all of the conflicting signage, the driver was left with the belief that he was entitled to park for 355 minutes.

See what others think on this point.

4. THE CLAIMANT'S FLAWED AND OUTDATED EVIDENCE

Looking at the photos they've included of the signage - several of them are pretty badly damaged, with important terms obscured. I'd draw attention to this.

Even if we give them the benefit of the doubt and assume the undated photos were taken when the 'commissioning sheet' was prepared in October 2017 - if the signs were in such bad condition when the site was 'commissioned', this is shoddy. I'd say you can make the case that if G24 were happy to 'commission' the site with the signage in such poor condition, it is reasonable to assume they have not conducted regular maintenance, and the signage (if present) would have been likely to deteriorate further in the 2 years following.

I have made amendments, also added new photos time stamped from Google maps would this work?

Removed the Photo Collage & Contra Proferentem Argument: Removed the 60/120/150-minute sign collage and argument to avoid the trap of using undated photos or conceding that a 150-minute limit applied.

Separated the Delay Argument (Section 2): Split the delay issue into two distinct legal points: (1) severe prejudice to my ability to defend myself and lost evidence, and (2) preventing G24 from being unfairly enriched by claiming 6 years of statutory interest.
New Google Street View Evidence (Section 3 & Exhibit MC1): Added historical Google Maps screenshots from March 2019 and September 2020. These show that the sign on the main brick wall had physically fallen off/been removed, leaving only adhesive marks. This proves site neglect during the exact timeframe of the alleged breaches and completely invalidates G24’s 2017 commissioning map.

Highlighted Damaged Signs in G24's Evidence (Section 3.3): Added a point drawing attention to the fact that G24’s own exhibit (AC2) shows signs that were already damaged and obscured.
Sharpened Authority Challenge (Section 4): Emphasized that the Homebase authority letter (AC1) is completely undated and lacks any start/end dates or contractual terms.

Added Generic Pleadings / Track Record (Section 5.3): Added a reference calling out G24's generic Particulars of Claim and noting their track record of having claims struck out for inadequate pleadings.

Fill version attached

IN THE COUNTY COURT AT [COURT LOCATION e.g., BRIGHTON]
CLAIM NO: [CLAIM NUMBER ]
BETWEEN:
[CLAIMANT COMPANY NAME (Claimant)
-and-
[DEFENDANT FULL NAME] (Defendant)
WITNESS STATEMENT OF [DEFENDANT FULL NAME]
I, [DEFENDANT FULL NAME] of [DEFENDANT FULL ADDRESS], am the Defendant in this matter and will say as follows:
1. INTRODUCTION & CURING OF PROCEDURAL DEFECT
1.1 I am the Defendant in this claim and the registered keeper of the vehicle [VEHICLE REGISTRATION]. I represent myself as a Litigant in Person.
1.2 I make this statement in support of my defence and in response to the Claimant’s Witness Statement prepared by Annalise Cogley of DCB Legal Ltd.
1.3 In paragraph 32 of the Claimant’s statement, they invite the Court to strike out my defence on the grounds that it lacked a signed Statement of Truth. As a Litigant in Person using the online portal, the signing requirements were unclear to me. I respectfully ask the Court to exercise its case management powers under CPR 3.1(2)(m) and accept this signed Witness Statement as the formal verification and curing of any defect in my original defence.
2. UNREASONABLE DELAY AND PREJUDICE
2.1 The Claimant is pursuing charges for parking events that allegedly occurred on 16 September 2019, 07 October 2019, and 06 March 2020. The Claimant inexplicably waited nearly six years to issue this claim.
2.2 This excessive delay has severely and adversely impacted my ability to properly defend the case. My recollection of relatively unremarkable parking events from nearly six years ago has understandably faded, and any evidence I may have been able to gather at the time has been lost.
2.3 Furthermore, this delay is entirely of the Claimant's own making. Accordingly, I respectfully submit that the Court should exercise its discretion to deny any statutory interest claimed. The Claimant should not be unfairly enriched by accumulating six years of interest on a claim they unreasonably delayed in bringing to Court.
3. FAILURE TO PROVE A CONTRACT WAS FORMED (INADEQUATE & UNMAINTAINED SIGNAGE)
3.1 The core of the Claimant’s case is that a clear contract was offered via signage, which I allegedly breached. I dispute that any valid contract was formed, as the Claimant has failed to prove that adequate, legible signage was present on the specific dates in question.
3.2 In Exhibit AC2, the Claimant provides generic, zoomed-in photographs of their signage. Crucially, these photographs contain no time or date stamps. The Claimant has provided zero evidence to prove these specific signs were actually in situ, unobscured, and legible to a driver on the exact dates of the alleged events.
3.3 The Claimant relies heavily on a "Site Commissioning Sheet" (Exhibit AC4) dated 19 October 2017—two to three years prior to the alleged events. The Claimant relies on the Court assuming the site was perfectly maintained during that multi-year gap.
3.4 I exhibit at "MC1" historical imagery sourced from Google Street View which proves the site was, in fact, suffering from severe neglect and degradation. The images show that between March 2019 and September 2020, signage was physically missing or had fallen off the walls of the building, leaving only adhesive marks behind.
3.5 Because the Claimant failed to conduct regular maintenance, resulting in signs falling down or going missing during the exact period of the alleged parking events, the Claimant's 2017 commissioning map is factually obsolete. The Claimant has failed to strictly prove what signage (if any) was actually standing and readable to form a contract on the material dates.
4. LACK OF PROVEN LEGAL AUTHORITY
4.1 In Exhibit AC1, the Claimant provides a letter from Homebase purportedly granting them authority to operate. This letter is completely undated.
4.2 It fails to specify the duration of the contract, termination clauses, or confirm that the Claimant actually held legal authority from the landowner to issue charges and pursue litigation on the specific dates in 2019 and 2020. An undated document does not prove authority at the time of the alleged contraventions.
5. UNENFORCEABLE ADDITIONAL COSTS & INADEQUATE PLEADINGS
5.1 The Claimant is attempting to recover additional, inflated "debt recovery" costs on top of the original parking charge.
5.2 I direct the Court’s attention to the open letter issued by the Competition and Markets Authority (CMA) to the private parking sector on 16 July 2026. In this letter, the CMA explicitly warned operators against the potentially unfair practice of attempting to recover arbitrary additional fees, reminding them that all consumer terms must comply with the fairness requirements of the Consumer Rights Act 2015. The Claimant’s added debt recovery costs are an unfair penalty, disproportionate to any actual loss, and are legally unenforceable.
5.3 Finally, I remind the Court that I previously noted the Claimant's Particulars of Claim were entirely generic and failed to specify the precise contractual terms allegedly breached. I note that G24 Limited has a documented history of having claims struck out for this exact reason (e.g., at Peterborough County Court in October 2024, where their inadequate pleadings were heavily criticized). I invite the Court to view their generic, copy-and-paste pleadings in this matter with the same scrutiny.
6. ATTENDANCE AND REQUEST FOR LAY REPRESENTATIVE
6.1 I suffer from severe anxiety and other health conditions which make public speaking in a formal setting extremely difficult and distressing for me.
6.2 I will be attending the hearing in person alongside my partner, [PARTNER'S FULL NAME]. Under the Lay Representatives (Rights of Audience) Order 1999, I respectfully request that the Court permits [PARTNER'S FULL NAME] to act as my Lay Representative and exercise rights of audience to speak on my behalf during the hearing, while I remain present.
STATEMENT OF TRUTH
I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
Signed: _____________________________
Name: [DEFENDANT FULL NAME]
Date: [DATE OF SIGNING]

Sorry to chase any update on the above? I have to submit by Monday but will be flying on Monday so need to get it done this weekend thank you.