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       #Post#: 13161--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: H C Andersen
       Date: January 1, 2024, 5:06 am
       ---------------------------------------------------------
       But they did put their reasoning in writing and therefore it
       forms part of the evidence trail.
       The OP's position has been consistent. We need to check whether
       the council's responses are similar.
       We haven't yet seen the PCN (!!) and therefore the issue of obs
       time is still an unknown.
       We still do not know definitively whether the discount was
       re-offered, although one could guess from 'Key Events'.
       The NOR does not address the issues which arise under 15(3),
       15(4), 15(7) and 15(11), did the initial response?
       IMO, we need to see their response.
       But if we don't, we don't.
       But OP, at least post the PCN.
       #Post#: 13169--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: zwi
       Date: January 1, 2024, 8:55 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > But they did put their reasoning in writing and therefore it
       forms part of the evidence trail.
       >
       > The OP's position has been consistent. We need to check
       whether the council's responses are similar.
       >
       > We haven't yet seen the PCN (!!) and therefore the issue of
       obs time is still an unknown.
       >
       > We still do not know definitively whether the discount was
       re-offered, although one could guess from 'Key Events'.
       >
       > The NOR does not address the issues which arise under 15(3),
       15(4), 15(7) and 15(11), did the initial response?
       >
       > IMO, we need to see their response.
       >
       > But if we don't, we don't.
       >
       > But OP, at least post the PCN.
       >
       --- End Quote ---
       Thank you for your response. I've included all the documents in
       the links provided in the posts, as resizing and attaching
       directly is a bit complicated.
       Here's a new link with everything:
  HTML https://photos.app.goo.gl/FopLEd9DKPLxyDf97
       
       Let me know if there's any problem viewing it.
       Additionally, I'm attaching as many main documents as possible
       directly in this post. But please check the link for more
       details
       Thanks.
       P.S. If necessary, My appeal to the council on 30/10/23: "Dear
       London Borough of Haringey, I challenge liability on the basis
       that my vehicle was not parked, it was merely stopped. Section
       15(1) of the Greater London Council (General Powers) Act 1974
       uses the expression "parked", which is seldom used in
       legislation, but is generally understood to mean waiting. On
       this occasion I was delivering goods to North London Cost Shop,
       the shop has off-street parking but when I arrived the gate was
       locked. I therefore had to stop my car temporarily to get the
       key from the shop staff so I could open the gate. Stopping
       temporarily to open a gate or other barrier to off-street land
       is not a contravention on red routes, loading restrictions or
       other locations, because such temporary stopping is not deemed
       to be "waiting" within the meaning of the legislation. I would
       contend that in these circumstances my vehicle was not "parked"
       within the meaning of section 15(1) of the 1974 Act, because my
       vehicle was merely temporarily stopped and it remained stopped
       for no longer than was strictly necessary for me to open the
       gate and drive the vehicle into the off-street land attached to
       the shop. As my vehicle was not parked, the alleged
       contravention did not occur. Yours faithfully"
       [attachment deleted by admin]
       #Post#: 13205--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: zwi
       Date: January 2, 2024, 7:50 am
       ---------------------------------------------------------
       Today is the last day I can pay the reduce penalty charge.
       Please advice if and how to appeal.
       Can somebody please draft me a letter to make the appeal to the
       adjudicator.
       Thank for kind help
       #Post#: 13228--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: fraser.mitchell
       Date: January 2, 2024, 5:16 pm
       ---------------------------------------------------------
       What you were doing is a well known activity, and it has won
       appeals in the past at PATAS (the old name for London Tribunals)
       and also at London Tribunals.
       I can only suggest that you register an appeal at London
       Tribunals.
       I would suggest you could alter them slightly: -
       "I challenge liability on the basis that my vehicle was not
       parked, but was temporarily stopped waiting access to gated
       premises in order to unload goods.
       On the day concerned, I was engaged in delivering goods to the
       North London Cost Shop. The shop has gated off-street parking
       where deliveries are made, but when I arrived for the booked
       delivery, the gate was locked. I therefore had to leave my car
       temporarily to get the key from the shop staff so I could open
       the gate. Stopping temporarily to open a gate or other barrier
       to off-street land is not a contravention because such temporary
       stopping is not "waiting" within the meaning of the legislation.
       I contend that leaving my vehicle to obtain keys in order to
       enter the premises was part of the loading activity. Loading is
       not just the physical unloading of goods from a vehicle and
       their delivery to premises, but includes all the activities
       necessary to start and complete the loading.
       I therefore contend that in the circumstances described above,
       my vehicle was not "parked" because my vehicle was merely
       temporarily stopped for no longer than was strictly necessary
       for me to obtain keys, open the gate and drive the vehicle into
       the off-street land attached to the shop. As my vehicle was not
       parked, the alleged contravention did not occur. Yours
       faithfully"
       #Post#: 13270--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: Pastmybest
       Date: January 3, 2024, 3:40 pm
       ---------------------------------------------------------
       Adjudicators will not always go with the argument waiting isn't
       stopping use the exemption i posted earlier  File your appeal
       and write only " i rely on my representations and will add
       further evidence later
       #Post#: 13272--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: zwi
       Date: January 3, 2024, 3:54 pm
       ---------------------------------------------------------
       --- Quote from: Pastmybest link ---
       >
       > Adjudicators will not always go with the argument waiting
       isn't stopping use the exemption i posted earlier  File your
       appeal and write only " i rely on my representations and will
       add further evidence later
       >
       --- End Quote ---
       Thanks for the advice.
       Just don't understand: why "later" will I have further evidence?
       i.e. what will change then?
       #Post#: 13298--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: Pastmybest
       Date: January 4, 2024, 11:35 am
       ---------------------------------------------------------
       You will see the council evidence which should include the
       resolution, but when I typed yesterday i was thinking I might
       draft an appeal for you but am out of the UK ATM so cannot do so
       until I return next week
       #Post#: 13319--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: Hippocrates
       Date: January 5, 2024, 4:42 am
       ---------------------------------------------------------
       --- Quote from: zwi link ---
       >
       > [quote author=Pastmybest link=topic=761.msg13270#msg13270
       date=1704318013]
       > Adjudicators will not always go with the argument waiting
       isn't stopping use the exemption i posted earlier  File your
       appeal and write only " i rely on my representations and will
       add further evidence later
       >
       --- End Quote ---
       Thanks for the advice.
       Just don't understand: why "later" will I have further evidence?
       i.e. what will change then?
       [/quote]
       Because tactically it is more often than not better to bat
       second.  This is our usual advice and has been for years.  And
       it works.
       #Post#: 13334--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: Grant Urismo
       Date: January 5, 2024, 10:37 am
       ---------------------------------------------------------
       Just to expand on this a little for the benefit of the OP...
       Producing an evidence pack is a specialist job, it requires a
       considerable investment of time (and therefore money) on the
       council's part by someone who knows the fine points of all rules
       intimately. This means that it's the first point in the process
       where the council risks anything much more than the price of
       sending a couple of letters. They make you play 'double-or-quit'
       with the discount, making them produce an evidence pack is point
       where they have to up the stakes on their side. We often see
       councils fold at this point, which they do by presenting no
       evidence. This is one good reason to let them go first... you
       would be wasting your time assembling your evidence if they
       don't present anything.
       Sometimes they fold because it's the first time anyone who
       understands some of the more technical challenges to PCNs will
       ever look at what you have been saying which means it's also the
       first time the council know they will lose at adjudication. Some
       more cynical councils play a numbers game, they know a lot of
       people will fold at the NTO stage, so they go that far even in
       cases where they don't have a leg to stand on. Occasionally they
       fold because they lack the resources to produce decent evidence
       packs, Barking and Dagenham seemed to go through a phase of not
       being able to produce evidence packs at all for several months
       last year. So another reason to let them go first is that they
       might not bother.
       Another reason is to maximise their workload. If you go first
       and only have 1 or 2 lines of defence, they can do less work and
       concentrate purely on rebutting your points. If you make them go
       first they have to cover all possibilities, which they probably
       won't do so well. Because councils are weighing up the cost of
       carrying on against the chances of winning, they have to wager a
       bit more (non-reclaimable) effort and are therefore more likely
       to fold when they know they will lose.
       This leads to another reason: some defects in council
       documentation only come to light at this stage. We sometimes see
       councils folding for no readily understandable reason. Given the
       fact that we quite often find defective (or missing) TMOs and
       TMOs that don't match up to signage, it's reasonable to suspect
       that sometimes the council finds this sort of thing out in the
       process of producing evidence packs, and folds rather than
       having to admit they messed up.
       Next, there's the old military adage that you should never
       interrupt your enemy when they are making a mistake. A lot of
       the time cases are won at tribunal not on anything to do with
       the alleged offence, but because the council has missed
       something essential out of the evidence pack, produced the wrong
       documents, or not understood that their documents are not up to
       scratch. So, this is another reason to let them go first: Allow
       them to shoot themselves in the foot.
       Others could probably add to the list, but I hope that's enough
       to explain it.
       #Post#: 13347--------------------------------------------------
       Re: Contravention Code 62(4) - Parking on Footpath: Unloading
       Dilemma
   DIR By: Hippocrates
       Date: January 5, 2024, 2:26 pm
       ---------------------------------------------------------
       Succinctly expressed.
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