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       #Post#: 67775--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&D ticket, Upper Tollington Park
   DIR By: stamfordman
       Date: April 19, 2025, 1:04 pm
       ---------------------------------------------------------
       --- Quote from: cp8759 link ---
       >
       > [quote author=stamfordman link=topic=5948.msg67753#msg67753
       date=1745081668]
       > Why they need to use the sign for a lunchtime game (as today)
       as a match day though is a bit daft as it was over by 14:30.
       >
       --- End Quote ---
       So there might be an argument that the restriction was
       ultra-vires, similarly to the box junction case in Ricardo
       Bowden v London Borough of Newham (2240295228, 2 January 2025)
  HTML https://drive.google.com/file/d/1X3SEOqKaiXoh1m6I-E0jMATjztIEyOVG/view.
       [member=2249]stamfordman[/member] what evidence is there about
       the end time of the relevant event?
       And crucially, was the end time something that was known in
       advance?
       [/quote]
       The kick-off for the 1 April game when the OP parked was 19:45.
       I'm just pointing out that flipping it to the match day plate
       makes little sense for a 12:30 kick-off if all it does is add 2
       hours after the usual 18:30 end time.
       There could be another event though on the same day (eg in
       Finsbury Park).
       As I said though the advantage of this signage is you don't need
       to know anything about events and just obey the sign.
       #Post#: 67799--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&D ticket, Upper Tollington Park
   DIR By: stamfordman
       Date: April 19, 2025, 4:05 pm
       ---------------------------------------------------------
       Yes there are entry signs with event days but as we know these
       control only single yellows.
       If you park in the bay with that parking sign I do think the
       only conclusion you can make is it that those times are
       operational on that day. The only alternative IMO is that there
       are no restrictions on non-event days, which is a point that
       could be tested.
       But it could be clearer and also say 'Event day today'.
  HTML https://imgur.kageurufu.net/BzoyLQC.png
       #Post#: 67806--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&D ticket, Upper Tollington Park
   DIR By: fraser.mitchell
       Date: April 19, 2025, 6:11 pm
       ---------------------------------------------------------
       Within the controlled times Mon-Sat, the Pay-by-Phone times are
       identical for normal and event days being 10am to 5pm
       #Post#: 67840--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&D ticket, Upper Tollington Park
   DIR By: ivanleo
       Date: April 20, 2025, 7:19 am
       ---------------------------------------------------------
       A few nonsense posts have now vanished. We all need to remember
       that it's not up to any of us to decide the rights and wrongs,
       what we have to bear in mind is, if the adjudicator asks the
       appellant "what's wrong with this sign ?"
  HTML https://imgur.kageurufu.net/vzG0yjB.png
       there needs to be a compelling answer, not one that they can
       deal with by saying "I disagree and find as a fact that the
       contravention occurred".
       Simply saying that it was impossible to know whether the sign
       applied or not is not going to cut it. Please let's be realistic
       and remember that we need to give legal advise on arguable
       points and on the prospects of success of those arguments, this
       is not a philosophical debate about the rights and wrongs of
       what the council has done. Further posts that ignore this will
       be removed without further warning.
       Going back to the previous issue, clearly for the 1st April the
       council could say that the extended hours means people wouldn't
       turn up and occupy all the bays before kick-off, so the
       ultra-vires argument doesn't work either.
       In these circumstances the best option might be the strategy of
       last resort
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/ealing-cumberland-road-w7-code-53j-failing-to-comply-with-a-restriction-on-vehic/msg56444/#msg56444,<br
       />though I have come up with a few variations of it they all
       depend on the OP having some sort of mitigating evidence for the
       council to (fail to) look at.
       #Post#: 67864--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&amp;D ticket, Upper Tollington Park
   DIR By: elucidate
       Date: April 20, 2025, 5:00 pm
       ---------------------------------------------------------
       Thank you all for your ongoing discussion. In particular thank
       you [member=2249]stamfordman[/member] for going through the
       trouble of going to the location to take a photo.
       I'm honestly at a loss for how I got it so badly wrong, I have
       good vision and don't normally make these kinds of mistakes.
       Is me saying the sign hadn't been flipped over a poor defence?
       Would there be any onus on the authority to prove it had been
       done? The rejection letter says they do it "days before" an
       event, therefore any assertion that the sign wasn't flipped to
       match mode cannot be correct.
       ... surely that can't be true, because, if what they're saying
       is indeed the case, the implication is that, on the days leading
       up to an event, people are able to park without any restrictions
       whatsoever?
       --- Quote from: cp8759 link ---
       >
       > In these circumstances the best option might be the strategy
       of last resort
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/ealing-cumberland-road-w7-code-53j-failing-to-comply-with-a-restriction-on-vehic/msg56444/#msg56444,<br
       />though I have come up with a few variations of it they all
       depend on the OP having some sort of mitigating evidence for the
       council to (fail to) look at.
       >
       --- End Quote ---
       The only thing I can come up with is just a screenshot of GSV
       which I saw before I set off. Or proof of purchase at the
       restaurant. They probably won't bother to look at either of
       those things.
       If I wait for the NtO, appeal and then they reject it, will they
       re-offer the discounted rate?
       #Post#: 67865--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&amp;D ticket, Upper Tollington Park
   DIR By: ivanleo
       Date: April 20, 2025, 5:26 pm
       ---------------------------------------------------------
       --- Quote from: elucidate link ---
       >
       > Is me saying the sign hadn't been flipped over a poor defence?
       >
       --- End Quote ---
       It's arguable, as the quality of the photo from the CEO is so
       bad, an adjudicator might decide that he can't be sure it had
       been flipped. But by your own admission, you don't really recall
       if it was flipped or not.
       --- Quote from: elucidate link ---
       >
       > ... surely that can't be true, because, if what they're saying
       is indeed the case, the implication is that, on the days leading
       up to an event, people are able to park without any restrictions
       whatsoever?
       >
       --- End Quote ---
       No, if that's what they're saying the implication is that
       they're imposing event day restrictions on non-event days.
       --- Quote from: elucidate link ---
       >
       > The only thing I can come up with is just a screenshot of GSV
       which I saw before I set off. Or proof of purchase at the
       restaurant. They probably won't bother to look at either of
       those things.
       >
       --- End Quote ---
       OK so that's something.
       --- Quote from: elucidate link ---
       >
       > If I wait for the NtO, appeal and then they reject it, will
       they re-offer the discounted rate?
       >
       --- End Quote ---
       You can't appeal an NTO, you can only make a formal
       representation against it. They would normally reoffer the
       discount but you can take it as read that they will reject. It's
       only when you appeal to the tribunal that you get a fair
       hearing.
       #Post#: 83903--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&amp;D ticket, Upper Tollington Park
   DIR By: elucidate
       Date: August 3, 2025, 11:23 am
       ---------------------------------------------------------
       Good afternoon everyone,
       Some linked updates:
       - My formal representation
  HTML https://drive.google.com/file/d/1VR24bRwkj7PiA-o2deTKLLgxa_mqOOUP/view?usp=drive_link
       - Their rejection of my formal representation
  HTML https://drive.google.com/file/d/1zWnjDUXzTiQ3KPBylL9pCAVkuz4jChBR/view?usp=sharing
       In order to try and leverage the Strategy of Last Resort, I did
       provide them with a Bitly link as mitigating evidence, and my
       Bitly analytics clearly show no-one ever clicked on it.
       [member=1]cp8759[/member] Can you please advise on how to
       proceed on this basis?
       [EDIT: Broken links fixed]
       #Post#: 83912--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&amp;D ticket, Upper Tollington Park
   DIR By: H C Andersen
       Date: August 3, 2025, 12:28 pm
       ---------------------------------------------------------
       OP, pl read what you've posted.
       Their NOR was sent on 7 July. Their letter dated 29 July advises
       you and includes a copy.
       Assuming you didn't receive the original NOR, you could simply
       ignore the copy and wait for the process to unfold i.e. Charge
       Certificate, Order for Recovery, revocation order, authority
       referral to adjudicator and your appeal.
       Or you could register an appeal now - and add procedural
       impropriety to what you had in your reps- and carry on. This
       would be quicker and you would be in control.
       With a NOR dated 7 July the mandated (as opposed to the period
       stated in the NOR) 28 days to appeal ends on TUESDAY 5 AUGUST.
       WaIt for other views.
       ...but don't wait too long.
       #Post#: 83917--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&amp;D ticket, Upper Tollington Park
   DIR By: elucidate
       Date: August 3, 2025, 12:53 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > OP, pl read what you've posted.
       >
       > Their NOR was sent on 7 July. Their letter dated 29 July
       advises you and includes a copy.
       >
       > Assuming you didn't receive the original NOR, you could simply
       ignore the copy and wait for the process to unfold i.e. Charge
       Certificate, Order for Recovery, revocation order, authority
       referral to adjudicator and your appeal.
       >
       > Or you could register an appeal now - and add procedural
       impropriety to what you had in your reps- and carry on. This
       would be quicker and you would be in control.
       >
       > With a NOR dated 7 July the mandated (as opposed to the period
       stated in the NOR) 28 days to appeal ends on TUESDAY 5 AUGUST.
       >
       > WaIt for other views.
       > ...but don't wait too long.
       >
       --- End Quote ---
       I received the original NOR but I misplaced it hence I asked
       them to send me another one, with the intention to abide by the
       given timeline, hence I am getting everything in place for me to
       file a case with the adjudicator by midnight tonight. Is today
       not the last day, then?
       Here
  HTML https://docs.google.com/document/d/1yLXbbtUi7nMmSEN6oJQPd_Bq3Dto6QDs/edit?usp=sharing&ouid=117727268490317838063&rtpof=true&sd=true<br
       />is the draft (if you want to skip the points I have previously
       submitted to the Council then you can start reading from halfway
       down the second page).
       And here
  HTML https://drive.google.com/file/d/16sLCNZfuD7Kn7lhsE0n33CXkEPlQhtwg/view?usp=sharing<br
       />are the URL analytics.
       Link to full folder of docs -->
  HTML https://drive.google.com/file/d/16sLCNZfuD7Kn7lhsE0n33CXkEPlQhtwg/view?usp=sharing
  HTML https://drive.google.com/file/d/16sLCNZfuD7Kn7lhsE0n33CXkEPlQhtwg/view?usp=sharing
       #Post#: 83921--------------------------------------------------
       Re: Haringey, code 12(r) Parked in a shared use place without
       P&amp;D ticket, Upper Tollington Park
   DIR By: stamfordman
       Date: August 3, 2025, 1:17 pm
       ---------------------------------------------------------
       There's no discount now so may as well appeal.
       It could be worth getting the traffic order. The case below
       suggests those CPZ entry signs could be wrong with all the dates
       but the case is for Newham not Haringey.
       -------------
       Case reference
       Appellant
       Authority
       VRM
       
       PCN Details
       PCN
       Contravention date
       Contravention time
       Contravention location
       Penalty amount
       Contravention
       
       Referral date
       
       Decision Date
       Adjudicator
       Appeal decision
       Direction
       Owner.
       Reasons
       The Appellant’s case is essentially that there was no signage in
       the immediate vicinity to inform her that the day in w question
       was an event day. This may be so. However the Council clearly
       relies on this information being given on Controlled Zone
       signage which the motorist must pass in order to reach the
       eventual parking place – a standard form of stadium signage.
       In the present case, however, although plans have been provided
       together with photographs of the signs relied on, these are of
       very poor quality and do not clearly show either the location of
       the signs or the location where the vehicle parked. I am not
       satisfied this evidence is sufficient to prove what is needed to
       be proved, namely that the Appellant could not have reached her
       parking place without passing such a sign.
       I would also add that the Secretary of State’s authorisation for
       the sign allows the lower panel to be varied to the “date of the
       next event” – not the date of the next event and the event
       following that.
       The Appeal must therefore be allowed
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