OK, so at the risk of coming across as really harsh, the statement of case is weak and in need a rethink. Most of it isn't relevant.
we have some evidence statements from neighbors were [the witness claming 20 years use] turned people away claiming it to be a private lane on numerous occasions by at least 3 independent witnesses.
This doesn't contribute anything for or against your case. There can be a public footpath on a private lane.
we have emails from the definitive map officer saying it was as clear as mud why it was marked up
This tends to support the route being a public right of way.
I apologies if the section 130A(6)(a) notice has confused matters again.
This is a distraction of no relevance.
We have photographic evidence the way in question was blocked by scaffolding and in-passable for a period of weeks
This really isn't a long enough period to demonstrate anything - paths can be closed for maintenance.
We are also trying to seek a statement off the previous land owner
This is important and you need something more than a statement that she or he occasionally stopped a few people.