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#Post#: 126996--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: DWMB2
Date: August 6, 2026, 3:36 am
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Are you able to organise those photos in folders so they appear
in order?
When I open the folder they're not in order making the witness
statement and exhibits difficult to navigate.
#Post#: 127001--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: Paulfamhughes
Date: August 6, 2026, 4:33 am
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Sorry Google photos for some reason mixed them all up they
should now be in order. Thank you.
#Post#: 127007--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: DWMB2
Date: August 6, 2026, 4:59 am
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I've not had chance to have a thorough look through but some
initial observations to factor into any witness statement:
- There are no apparent time/date stamps on their images of the
signage they allege was present on the site, nor is the wider
document dated. As far as I can see the witness statement from
the DCB Legal rep likewise doesn't make any claims as to when
the images of the signage were taken. I'd challenge this - your
point here can be that they have failed to demonstrate that the
signage was in place at the time of the alleged contraventions.
Those images could have been taken several years after your
vehicle was there (or several years before, giving plenty of
time for them to fall off/deteriorate).
- The same issue exists with the letter from Homebase,
apparently confirming G24's authority to operate on the site.
There are absolutely no dates on the document. You therefore
cannot determine when their apparent authority began. There are
also no contractual terms - it doesn't state the duration of the
authority, or when/under what circumstances the contract may be
ended. I would suggest that an undated document does not prove
that the company had authority on the dates in question.
- Going back to signage, even if the signage was there on the
dates in question, the positioning of the entrance signage
appears poor - a van in the space in front of the entrance sign
would block it from view entirely. I'm on the fence about
including this (if you do, we should think about how we do it),
as it would involve you introducing further evidence of the
signage - we should think about how to do this in a way that
does not undermine the point about the Claimant failing to prove
the signage was there at all at the relevant time.
- I would challenge the imposition of interest across the entire
time period. The delay in bringing about a claim is due to the
claimant's unreasonable delay. Whilst they have 6 years to bring
a claim, there's no obvious reason why a simple claim such as
this should have taken so long to be filed.
#Post#: 127011--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: InterCity125
Date: August 6, 2026, 5:29 am
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Also use the CMA open letter to demonstrate that the additional
charges are contra to consumer regs.
#Post#: 127096--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: Paulfamhughes
Date: August 6, 2026, 5:45 pm
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Ok, so what do I need to do now 😂. Thank you.
#Post#: 127098--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: Paulfamhughes
Date: August 6, 2026, 6:29 pm
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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]
#Post#: 127117--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: DWMB2
Date: August 7, 2026, 5:00 am
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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 :)
--- Quote ---
> 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.
--- End Quote ---
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.
--- Quote ---
> 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..
--- End Quote ---
I assume the 'collage' to which you refer is this:
HTML https://i.ibb.co/TDHwbN57/20260418-212359-COLLAGE.jpg
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.
--- Quote ---
> 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.
--- End Quote ---
To play devil's advocate here:
Contra Proferentem is reverenced in Section 69 of the Consumer
Rights Act
HTML https://www.legislation.gov.uk/ukpga/2015/15/section/69:
[indent]"If a term in a consumer contract, or a consumer notice,
could have different meanings, the meaning that is most
favourable to the consumer is to prevail.[/indent]
"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.
--- Quote ---
> 4. THE CLAIMANT'S FLAWED AND OUTDATED EVIDENCE
--- End Quote ---
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.
#Post#: 127126--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: Paulfamhughes
Date: August 7, 2026, 5:37 am
---------------------------------------------------------
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.
#Post#: 127129--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: Paulfamhughes
Date: August 7, 2026, 5:50 am
---------------------------------------------------------
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]
#Post#: 127265--------------------------------------------------
Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
DIR By: Paulfamhughes
Date: August 8, 2026, 10:53 am
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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.
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