Horizon Claim

[mouse]

Thank you for confirming all that info it really does help. 


A wild amount when it should be nothing but I assumed it would be the higher one. I didn't want Gladstone's having my phone number but it will be on the email for the court, not sure if there's a way they don't have access to it. 

Thanks again

[mouse]

Morning @b789

So had an email from the court this morning saying:

I refer to your below email, due to it exceeding 50 pages or having a total size (including attachments and any photocopies the court is required to make) of 10 megabytes it cannot be accepted by email, as per CPR PD 5b (2.3). Please note that we require applications and any supporting evidence in triplicate (3 copies) and whilst one copy is within the limit, if we print 3 copies it will exceed the 50 page limit.

Please also note that also under CPR PD 5b, multiple emails cannot be used to file one document or application with the court.

I will now print it all and send it off to the court. Am I right in reading the want 3 copies of it all for the application being sent to the court?

More time faffing about which I am sure Gladstones are lapping up. I will keep you updated as I hear back.

Have a great day.

[b789]

You don't have to print it out if it is less than 25 A4 pages (50 sides). If your file size is too bib, make sure you compress the images and the PDFs to amore manageable size. A simple N244 application such as this should not be that big unless you have used massive files sizes.

There are plenty of PDF and image compression sites you can use to reduce the file sizes.

[mouse]

The attachments are 1mb total, and 29 pages. I would have compressed them if I thought I would have run into issues on the size. They are just PDFs of the emails and the forms. is it worth contacting them again stating that it is well under the limit. Thanks

[b789]

Yes. If it is only 29 pages total and about 1 MB, it is comfortably within the email limits. That is nowhere near 25 sheets/50 sides of A4 when printed double-sided, so there is no point arguing with the court about it further. Just file it by email. If they still refuse for some reason, then it can be printed and posted, but on those figures it ought to be acceptable by email.

The practical point is that the page and size limits are only really relevant to the court’s copy because that is the copy the court may have to print onto the paper file.

There is no need to worry about those limits for the claimant’s copy or your own copy. Gladstones can be served electronically and you can keep your own electronic set without any issue. So the only question is whether the pack being emailed to the court fits within the County Court email limits. On 29 pages (sides of A4) total, it plainly does.

[mouse]

Appreciate that, I will question it and get back to you with what they say. Gladstones were CC'd in too so should be aware of it unless they no longer read their emails. They certainly don't reply anymore!! 

Have a good evening.

[mouse]

Good morning @b789,

little update on the case...

After sending all the documents in, paid £123 over the phone and then waited to see if they were calling back after they informed me the Judge would need to review it as to whether it would require additional payment and a hearing.

Received the general form of judgement this morning and the new trial date which I have attached.

As expected, not had any response from Gladstones to any of the emails sent. I think I am now on the do not reply list   

There's no mention of witness statements and deadlines, am I jumping the gun on this?  Should I get another letter from the court in due time regarding when it will need to be submitted etc? Want to make sure I have everything covered.

Thanks for everything you have provided so far, truly grateful. 


  General Form of Judgment or Order2_compressed.pdf (Size: 75.54 KB / Downloads: 4)
  Notice of Trial Date sept_compressed.pdf (Size: 141.65 KB / Downloads: 4)

[b789]

@mouse, this is a good result. The judge has dealt with the N244 on the papers, vacated the original hearing and relisted the trial for 17 September 2026 at 10:00am. The costs of the application have been reserved, so the £123 fee can still be argued at the final hearing. 

The only point not to overlook is the witness statement deadline. The new order changes the hearing date, but it does not expressly say that the earlier directions for witness statements and evidence have been varied. So do not assume another letter will automatically arrive with a fresh deadline.

Check the original Notice of Allocation. If it contained a specific date for exchanging witness statements and evidence, email Nottingham County Court now, attach the new order, and ask them to confirm whether that original deadline still stands or whether a revised deadline will be issued. Copy Gladstones in. In the meantime, keep preparing the witness statement rather than waiting.

[mouse]

So from the original letter, the witness statement was due 17th July. 

Obviously without being legally savvy I would never have known that a new deadline may not exist. Having never done anything like it they aren't very clear on the information!


 I haven't received anything from Gladstones if that was the case anyway. I will get on and email the court to confirm the date and get on with the statement. 

Thank you for that it helps a great deal.

[b789]

I suggest you submit the following to the court (and CC Gladstones) today:

IN THE COUNTY COURT AT NOTTINGHAM

Claim No: [CLAIM NUMBER]

Between:

HORIZON PARKING LIMITED
Claimant

-and-

[DEFENDANT’S FULL NAME]
Defendant

WITNESS STATEMENT OF THE DEFENDANT CONCERNING CLAIMANTS NON-COMPLIANCE WITH DIRECTIONS

1. I am the Defendant in these proceedings and a litigant in person. I make this witness statement concerning the parties’ compliance with the court’s directions for the service of witness statements and evidence.

2. The facts in this statement are within my own knowledge unless stated otherwise.

3. By the court’s original Notice of Allocation, both parties were required to serve their witness statements and documentary evidence by 4:00pm on 17 July 2026.

4. The trial was subsequently vacated and relisted from 20 August 2026 to 17 September 2026 following my successful application. The order relisting the trial did not state whether the original deadline of 17 July 2026 remained in force and did not provide a replacement deadline.

5. As a litigant in person with no previous experience of civil proceedings, I did not appreciate that the original evidence deadline might remain operative after the trial had been vacated and relisted. Upon becoming aware of that possibility, I acted immediately to clarify the position and to place this statement before the court.

6. The Claimant is a professionally represented commercial litigant. Its solicitors, Gladstones Solicitors Limited, conduct private parking litigation as part of their ordinary business and cannot credibly claim to have been unaware of the court’s deadline.

7. As at the date and time of signing this statement, neither the Claimant nor Gladstones Solicitors has served upon me any witness statement or evidential bundle in accordance with the deadline of 4:00pm on 17 July 2026.

8. The Claimant has therefore failed to comply with the court’s express direction. It has also failed to provide the particular evidence which the court specifically ordered it to produce, including evidence of the alleged contracts, its authority to operate and litigate, readable photographic evidence, particulars of the alleged breaches and a proper explanation of the sums claimed.

9. The absence of the Claimant’s witness statement and evidence materially obstructs my ability to prepare my own complete evidence. I do not know which documents, alleged contractual terms, witness evidence or factual assertions the Claimant intends to rely upon at trial.

10. This is particularly prejudicial because the Claimant’s Amended Particulars of Claim advance several alternative and inconsistent bases of liability, including alleged driver liability, keeper liability under Schedule 4 of the Protection of Freedoms Act 2012, a purported presumption that I was driving, and alleged vicarious liability.

11. The Claimant should not be permitted to obtain a tactical advantage by withholding its evidence beyond the court-ordered deadline and then serving it after the Defendant has been forced to disclose their case without first seeing the evidence relied upon by the Claimant.

12. CPR 32.10 provides that, where a witness statement is not served within the time specified by the court, the witness may not be called to give oral evidence unless the court gives permission. The Claimant should therefore be prohibited from relying upon any late witness statement or calling any witness whose statement was not served by the deadline unless it first applies for and obtains relief from sanctions.

13. Any application by the Claimant for relief from sanctions should be supported by proper evidence explaining the default. Administrative convenience, bulk litigation practices or oversight by its professional representatives should not be treated as sufficient justification.

14. I respectfully ask the court to ensure that the parties remain on an equal procedural footing. It would be unjust and contrary to the overriding objective for a professionally represented claimant to disregard an express direction and then be permitted to ambush an unrepresented Defendant with late evidence.

15. Insofar as permission is required for the late service of this statement, I respectfully seek such permission. My delay arose from the ambiguity created when the trial was vacated and relisted without any express reference to the existing evidence deadline. I acted promptly upon appreciating that the original deadline might remain operative.

16. In contrast, the Claimant was professionally represented throughout, knew or ought to have known of the deadline, and has provided neither its evidence nor any explanation for its failure to comply.

17. I respectfully request that the court make the following directions:

a. The Claimant may not rely upon any witness statement or documentary evidence which was not served by 4:00pm on 17 July 2026 unless it first applies for and obtains relief from sanctions;

b. Unless the Claimant serves its complete witness statement and evidential bundle, together with any application for relief from sanctions, within seven days of the court’s order, the claim shall be struck out;

c. The Defendant shall have 14 days after service of the Claimant’s complete evidence to serve or supplement the Defendant’s substantive witness statement and evidence;

d. Any evidence served late by the Claimant without permission shall be excluded from consideration at trial;

e. The costs occasioned by the Claimant’s non-compliance shall be reserved, with liberty to the Defendant to seek those costs at trial.

18. Alternatively, if the court does not make those directions immediately, I ask that this statement be placed before the trial judge when considering the admissibility of any late evidence, relief from sanctions, case management and costs.

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: [DEFENDANT’S FULL NAME]

Dated: