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.

[Barbudaprince]

Hi, just recieved the attached letter from BWLegal:

https://drive.google.com/drive/folders/1...xUBxra03N1

The court did order that the parties prepare this and agree it but is any of this relevant to the case feels like further information I need to learn and refer to when I'm trying to focus on my defence points.


Also side note received email from Brentford County Court asking for physical copies of my witness statement as this exceeds the page limit. No instruction as to who to deliver this to or by when. Hearing is scheduled for end of August so not ideal.

[b789]

There is nothing controversial about this at all. The court has ordered the parties to try to agree a trial bundle and BW Legal have simply produced a proposed index.

You don't need to "learn" any of it. The index is just a contents page telling the judge what documents will be in the bundle and in what order. It is not evidence and it does not change either party's case.

The only things you need to check are:

• Does it include every document you intend to rely on?
  
• Is anything missing?
  
• Is anything listed inaccurately?
  
• Does it include documents that shouldn't be there?
  

Looking at what they've produced, I can already see one obvious issue. They have listed your witness statements, but they haven't listed your authorities (Liberty Homes, Brennan, VCS v Edward etc.). If the court order requires an authorities section or you intend to rely on those cases, they should be included in the bundle rather than leaving the judge to hunt for them.

I'd also check that all of your exhibits are actually included, particularly the original site boundary map. Given the claimant has now produced a different map with what appears to be an altered red boundary, I would absolutely want both versions before the judge for comparison.

As for Brentford's email, reply to it rather than guessing. It appears to be that the court requires a paper copy because the electronic bundle exceeds its page limit. If BW Legal already have an electronic copy (which they plainly do, because they list both of the defendant's witness statements in the proposed bundle index), there is no reason to serve them with another hard copy unless the court order specifically requires it.

I'd suggest you reply to the court along these lines:

Thank you for your email.

Please could you confirm:

  1. Whether the court requires a single hard copy for the court file only, or whether multiple copies are required.

  2. The address to which the hard copy should be sent or delivered.

  3. Whether the court would prefer the documents to be delivered by hand or sent by post.

As the claimant has already been served electronically with my witness evidence and has acknowledged receipt by including it within the proposed trial bundle, I assume only a single hard copy for the court is required. However, I should be grateful if you could confirm the above so that I comply fully with the court's request.

That avoids unnecessary printing and puts the question back to the court. If they reply saying "please provide three copies", then do that. If they simply want one for the judge/court file, one copy is sufficient.

[Barbudaprince]

thanks @b789 I also noted the BWLEGAL's costs have increased over time from a letter of claim of £510, to the hearing of 29th April 2026 of £650, to £709 for this hearing without any breakdown and have asked them for this.

What is the outcome if I win my defence? I don't think I ticked the MCOL box which says I will counterclaim so is that lost...? I am taking time off work for these hearings and it is a bit of faff administering. Could I counterclaim or could judge award costs against BWLEGAL ?