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       #Post#: 111894--------------------------------------------------
       Imperial Wharf - BW Legal (At Hearing Stage)
       By: bz.08 Date: March 3, 2026, 9:02 am
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       Hi all,
       I received the below claim form in July 2025.
  HTML https://ibb.co/9968BtWD
       I defended it and had a mediation appointment in October 2025.
       It has now reached the hearing stage (scheduled for mid April
       2026) and was wondering what I should submit to BW Legal and the
       court in advance of this?
       Please see my defence below:
  HTML https://ibb.co/tprf3PKk
  HTML https://ibb.co/B8d4Wfb
       Should I be uploading an amended defence and/or witness
       statement? Are there any templates for this I can use?
       Also, the deadline for serving copies of the above is in a few
       days.. I plan to meet it but the claimant hasn't served anything
       to me yet - if they indeed fail, will it invalidate their claim?
       #Post#: 111898--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: jfollows Date: March 3, 2026, 9:37 am
       ---------------------------------------------------------
       When does the claimant have to pay the court fee?
       If paid, your defence is already submitted and you both have a
       deadline for submitting Witness Statements, as you note.
       #Post#: 111910--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: bz.08 Date: March 3, 2026, 10:58 am
       ---------------------------------------------------------
       [quote author=jfollows link=topic=10115.msg111898#msg111898
       date=1772552276]
       When does the claimant have to pay the court fee?
       If paid, your defence is already submitted and you both have a
       deadline for submitting Witness Statements, as you note.
       [/quote]
       Strangely, the date for paying is 12 days after the date by
       which each party needs to submit their documents..
       #Post#: 112059--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: bz.08 Date: March 4, 2026, 10:32 am
       ---------------------------------------------------------
       Any advice from anyone? I have to serve a copy on the other
       parties by end of week (claimant hasn't served anything to me
       yet though..)
       #Post#: 112067--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: InterCity125 Date: March 4, 2026, 11:13 am
       ---------------------------------------------------------
       Does the claimant know who the driver was or are they just
       assuming that it was you?
       Has the driver been revealed in any appeal etc?
       #Post#: 112160--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: bz.08 Date: March 5, 2026, 8:28 am
       ---------------------------------------------------------
       [quote author=InterCity125 link=topic=10115.msg112067#msg112067
       date=1772644401]
       Does the claimant know who the driver was or are they just
       assuming that it was you?
       Has the driver been revealed in any appeal etc?
       [/quote]
       The claimant does not know who the driver was. I have merely
       responding as the keeper in my defence.
       #Post#: 112165--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: InterCity125 Date: March 5, 2026, 8:55 am
       ---------------------------------------------------------
       To be honest, in this particular case, I would ditch the defence
       you have set out.
       Is this instance the Claim Form states that they are pursuing
       you as driver.
       The is no stated alternative pursuit as vehicle keeper under
       PoFA 2012.
       This means that their claim can never succeed assuming what you
       say is true.
       So you could simply set out a very simple defence which states;
       [font=Verdana]I deny the claim in its entirety and no debt is
       owed.
       That the information set out in the PoC on the Claim Form are
       imprecise but I will do my best to engage.
       It is accepted that I was the Registered Keeper of the vehicle,
       stated on the claim form, on the date in question.
       That this is a contract dispute and, as such, there is no legal
       requirement for a Registered Keeper to reveal any driver details
       to an unregulated private parking contractor.
       That I will not, under any circumstance, be revealing the
       drivers identity and, as such, no assumption can be drawn by me
       exercising my legal right to remain silent in that respect.
       I may rely on the persuasive Appeal Court case of VCS Ltd v
       Edward [H0KF6C9C] if required.
       That the Claimant appears to have no evidence which proves who
       the driver was.
       That the Claimant is therefore unable to demonstrate that I am
       liable for any charge or debt.
       The claim is therefore denied.[/font]
       #Post#: 112170--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: DWMB2 Date: March 5, 2026, 9:12 am
       ---------------------------------------------------------
       You can't generally simply 'ditch' a defence, nor amend without
       paying a fee. But much of the above could be incorporated into a
       good Witness Statement which draws out the most important points
       from the defence.
       #Post#: 112171--------------------------------------------------
       Re: Imperial Wharf - BW Legal (At Hearing Stage)
       By: InterCity125 Date: March 5, 2026, 9:14 am
       ---------------------------------------------------------
       Ah, sorry, I assumed that that was the defence he was
       suggesting!
       Doh!
       So, yes, make it into a Witness Statement.
       But wait until the last possible moment before submitted as you
       may be able to see the Claimant's WS before submitting your own.
       Can you post up the Court documentation which states the dates
       for WS etc?
       PS I've added a reference to VCS v Edward just in case.
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