3 private parking tickets being pursued for all 3 and had a ccj claim made

[Barbudaprince]

Noted - 

Just received new hearing date. It looks to be back at Brentford despite the judge saying Brentford hearings were being held at Wandsworth.

https://drive.google.com/drive/folders/1...R-LpxQyzSt

[b789]

Noted - 

Just received new hearing date. It looks to be back at Brentford despite the judge saying Brentford hearings were being held at Wandsworth.

The system is in disarray. Just go with the flow.

[Barbudaprince]

Hi @b789  I will send it to both courts for completeness.

Please see final draft of the witness statement would be grateful for a final view from yourself. 

So I just need to send this to the courts and BWlegal by 4pm on 24 June 2026? I don't need to send it before then to BWlegal for them to include in the bundle?

https://docs.google.com/document/d/1uKEc...ue&sd=true

[b789]

Para 46 should refer to the persuasive Brennan appeal court decision. That is why or have included the transcript as evidence.

In the defence, the following was stated (for some reason your copy of the defence shows bullet points rather than paragraph numbers):

The Defendant understands that the Claimant’s own boundary/authority map does not cover the hard-standing area where the vehicle was located for at least two of the alleged PCNs. The Claimant is put to strict proof that it had contractual authority at the precise location of each alleged contravention.

Has the claimant evidenced their contract with the landowner? If not, that must be highlighted in your WS.

[Barbudaprince]

Thanks. Will make those changes now.

The claimant had provided a contract but the contract dates were redacted.

[Barbudaprince]

Hello.

Just received the updated witness statement from BW legal. 

Really interestingly they have moved the 2 points of where the vehicle was during the alleged contravention so that the points now fall within their enforcement red line boundary. How cheeky !!!
https://drive.google.com/drive/folders/1...rrIOaYUth3

I have my drafted response so we'll send that before 4pm today.

[b789]

@Barbudaprince, the claimant's latest witness statement arguably creates more problems than it solves. The key issue is not the location markers. The key issue is that the claimant appears to have changed the enforcement boundary itself.

You had already identified the alleged vehicle locations on the claimant's original site map. On that original map, two of the alleged contraventions were outside the claimant's red-line enforcement area. Rather than explain that discrepancy or produce contemporaneous evidence showing the original map was wrong, the claimant has now produced a different, lower-quality satellite image and drawn a thicker, altered boundary which conveniently brings those same locations within the alleged enforcement area.

That raises an obvious question: which map is correct?

If the original map was correct, the claimant had no authority over those locations. If the new map is correct, why was the original map wrong, and where is the contemporaneous evidence proving the true boundary at the material time?

The claimant cannot simply redraw the boundary during litigation to overcome a defence point. What matters is the actual enforcement area authorised by the landowner at the time of the alleged contraventions. The claimant should therefore be put to strict proof by production of the contemporaneous contract and site plan in force at the material time, not a litigation-generated map produced after the issue was identified.

Preserve both versions of the map immediately. Put them side by side. The court needs to see that the claimant’s boundary evidence has changed after the defect was pointed out.

The claimant's witness is a BW Legal paralegal with no first-hand knowledge. She cannot personally verify where the vehicles were located, who identified those locations, who altered the boundary, or why the latest map differs from the earlier one. The witness statement is therefore largely commentary upon documents rather than evidence of fact.

The claimant also continues to ignore the residential nature of the case. You were not a visitor entering a business park and deciding whether to accept a contractual licence from signage. You were a resident whose tenancy already contained parking provisions. The claimant still has not explained how its alleged signage contract interacts with, supplements, or overrides those existing residential rights.

Likewise, the claimant relies on the non-binding County Court appeal decision in VCS v Crutchley, yet fails to engage with Liberty Homes, which is a binding High Court authority. Liberty Homes goes directly to the issue in this case: a claimant must properly plead the contractual basis of its claim. Even after being forced to provide further particulars, the claimant still has not properly explained the contractual terms allegedly breached, how those terms were incorporated into your existing residential arrangements, or how UKCPM acquired authority to impose contractual charges on a resident.

In short, the claimant's latest evidence does not resolve the boundary issue. It arguably demonstrates it. The more they alter their maps, the more they undermine confidence in the accuracy of their own evidence. The court should be invited to prefer the contemporaneous documents and require strict proof of the true enforcement boundary at the material time.