a couple of quick updates for this week. On Tuesday, I received an email from DCB Legal with its usual pre-N180 Directions Questionnaire wording as follows: ****************************************************************************************************************************** Good morning Having reviewed the content of your defence, we write to inform you that our client intends to proceed with the claim. In due course, the Court will direct both parties to each file a directions questionnaire. In preparation for that, please find attached a copy of the Claimant's, which we confirm has been filed with the Court. Without Prejudice to the above, in order to assist the Court in achieving its overriding objective, our client may be prepared to settle this case - in the event you wish to discuss settlement, please call us on 0203 434 0433 within 7 days and make immediate reference to this correspondence. If you have provided an email address within your Defence, we intend to use it for service of documents (usually in PDF format) hereon in pursuant to PD 6A (4.1)(2)(c). Please advise whether there are any limitations to this (for example, the format in which documents are to be sent and the maximum size of attachments that may be received). Unless you advise otherwise, we will assume not. Kind Regards, Shannon Robinson DCB Legal Ltd ******************************************************************************************************************************* Hours later, I also then received a formal notification letter (N149A Notice of Proposed Allocation to the Small Claims Track) from the Civil National Business Centre. Deadline given to complete and file the Small Claims Directions Questionnaire (N180) is 15 Feb 2024 and so will get cracking on that over the weekend.

Morning all. Thanks for the additional info. Submission on MCOL is just moments away.

Thanks I'll draft up that defence asap and hopefully get it all submitted before close of play today, once all other comments/feedback here have been considered.

Hello All. With my defence statement on MCOL due in just over 24 hours, are there any additional points anyone has in mind for my submission other than the one from the regular sticky and that put forward by?

All, so a quick update. I received a letter from the HM Courts service on Friday to acknowledge receipt of my defence statement and also to advise that a copy had been served on the claimant who must contact the court within 28 days, if they wish to proceed after attempts at a joint resolution has proved unsuccessful.

[[ Draft Letter to DCB re: Email Comms ]] Dear Sir/Madam, Thank you for your e-mail of [[ date ]]. I see you confirm your client has reviewed the contents of my defence and wish to continue with the claim and indeed move straight on to completing the N180. I do also note you have already prepared your N180. I will of course comply with the Directions Questionnaire when the court orders me to. Regarding your reference to e-mail for communications between us, kindly be advised that you are henceforth not to use my e-mail address again and I wish for all such communication to take place via Royal Mail post. I am therefore taking the necessary steps to block any further emails from yourself and DCB Legal as an entity, until further notice. Thank you.

Yep, you're absolutely right. Just their usual intimidation tactics. They've made no such submission on MCOL. Will definitely email and warn them not to dare contact me again via email. I'll reuse a similar letter I sent out to them last year.

All, a quick update on some new developments, following my MCOL defence submission just before Xmas. Last Friday, DCB Legal emailed me the below email as perhaps their New Year pressie to me. Good morning Having reviewed the content of your defence, we write to inform you that our client intends to proceed with the claim. In due course, the Court will direct both parties to each file a directions questionnaire. In preparation for that, please find attached a copy of the Claimant's, which we confirm has been filed with the Court. Without Prejudice to the above, in order to assist the Court in achieving its overriding objective, our client may be prepared to settle this case - in the event you wish to discuss settlement, please call us on 0203 434 0433 within 7 days and make immediate reference to this correspondence. If you have provided an email address within your Defence, we intend to use it for service of documents (usually in PDF format) hereon in pursuant to PD 6A (4.1)(2)(c). Please advise whether there are any limitations to this (for example, the format in which documents are to be sent and the maximum size of attachments that may be received). Unless you advise otherwise, we will assume not. Kind Regards, xxx xxx DCB Legal Ltd PS: Will upload the N180 received very shortly.

I eventually went through my box of letters and managed to discover 2 Spring Parking PCNs (attached) which I believe relate to this case. I'm however still hoping to find any other associated material such as NTKs, Debt Demand letters, etc, if any such letters were received. In the meantime, kindly find attached the two significant PCNs in question. I have already spotted some date discrepancy (PCN vs Court Form) for the PCN alleged to have been issued on 19/11/2019, but for now I'll let you all peruse and provide your feedback. 2021-07-26 Spring PCN.pdf 2019-12-20 Spring NTK for PCN 2019-11-21.pdf

Happy New Year all. Wishing everyone the very best for 2024.

My bad, I'm guessing what LFI was specifically enquiring about was whether I'd received any related PCNs.........and not just the answering of the sticky. Due to my recent house move, I've got a lot of letters and other paperwork needing unpacking, but good thing is that I store all PCNs and other such 'junk mail' in a dedicated folder so should be relatively easy to find and scour through them after work.

unless my PC let me down by crashing during submission, I am quite certain I filled in the questionnaire last week. Will verify though asap.

Well, they’re on course for another bloody nose, that’s for sure.

Which Court have you received the claim from ? MCOL Northampton N1 ? If possible please scan redact and upload a full page copy of page 1 of the claim form. (not the response page or AOS) Name of the Claimant : Spring Parking Limited Claimants Solicitors: DCB Legal Ltd Date of issue – 07 Dec 2023 Date for AOS - Tue, 26 Dec 2023 Date to submit Defence - (Tue, 09 Jan 2024 What is the claim for – 1. The Defendant (D) is indebted to the Claimant (C) for a Parking Charge(s) issued to vehical XXXX XXX at 1 3 Upper Green East, Mitcham, CR4 2PE. 2. The PCN(s) were issued on 17/11/2019, 20/07/2021. 3. The defendant is pursued as the driver of the vehicle for breach of the terms on the signs (the contract). Reason: Exceeded Maximum Stay Period (ANPR). 4. In the alternative the defendant is pursued as the keeper pursuant to POFA 2012, Schedule 4. AND THE CLAIMANT CLAIMS 1. £330 being the total of the PCN(s) and damages. 2. Interest at a rate of 8% per annum pursuant to s.69 of the County Courts Act 1984 from the date hereof at a daily rate of £.04 until judgment or sooner payment. 3. Costs and court fees What is the value of the claim? - £521.72 Amount Claimed - £421.72 court fees - £50.00 legal rep fees - £50.00 Total Amount - £521.72 Have you moved since the issuance of the PCN? - (Yes, since 01/11/2023) Did you receive a letter of Claim With A reply Pack wanting I&E etc about 1mth before the claim form? - TBC, but definitely never communicated with Claimant or Solicitor Claimform (1).pdf

Hello, I recently received the attached Claim Form filed by DCB Legal on behalf Spring Parking Limited, for two alleged parking infringements in 2019 and 2021. No doubt, following on from the outcome of my last dealings with these same two leeches, this their latest move has come as little surprise to me, as they desperately seek to enact their own warped form of vengeance. I have today completed the AoS on MCOL and will be proceeding next with a CPR 3.14 and SAR submission to both parties respectively. By my calculation, my defence submission on MCOL should be no later than Tue, 9th Jan 2024. In the meantime, just looking forward to enjoying a break over the festive period and to recharge the batteries for this new battle with those unpleasant parasites. Will also scour through my mail to see if I can retrieve any 'junk mail' I may have received from them and upload here for the usual expert review, observations and comments. Claimform.pdf

Ok. All done now. Template defense submission on MCOL is completed. We wait to see what transpires next. Meantime, I'm going to get started on the Spring PCN and start that new thread. AoS was due on Boxing Day but as a result of that, I chose to submit it today. CPR and SAR on that will follow in the next few hours.

@dx100uk @FTMDave, thanks for the feedback guys. Will submit the template defence to ensure all cards are kept under wraps for now and perhaps even delete the draft I posted earlier.

All, any thoughts or feedback on the below defence statement I'm planning to submit on MCOL this afternoon please? I incorporated some of the info @lookinforinfo kindly provided to highly the PCN defects I am ...... of ......, defendant in this matter. The claim is denied in its entirety except where explicitly admitted here. I assert that I am not liable to the Claimant for the sum claimed, or any amount at all, for the following reasons, any one of which is fatal to the Claimant's case. The Defendant contends that the particulars of claim are vague and generic in nature which fails to comply with CPR 16.4. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 1. The Defendant is the recorded keeper of motor vehicle XXXX XXX. 2. It is denied that the Defendant entered into a contract with the Claimant. 3. As held by the Upper Tax Tribunal in Vehicle Control Services Limited v HMRC [2012] UKUT 129 (TCC), any contract requires offer and acceptance. The Claimant was simply contracted by the landowner to provide car-park management services and is not capable of entering into a contract with the Defendant on its own account, as the car park is owned by and the terms of entry set by the landowner. The Claimant is put to strict proof that it has sufficient proprietary interest in the land, or that it has the necessary authorisation from the landowner to issue parking charge notices, and to pursue payment by means of litigation. Accordingly, it is denied that the Claimant has authority to bring this claim. 4. In any case, it is denied that the Defendant broke the terms of a contract with the Claimant. 5. Further and in the alternative, it is denied that the claimant's signage sets out the terms in a sufficiently legible manner which would be capable of binding any reasonable person reading them. They merely state that vehicles must be parked correctly within a marked parking bay, giving no definition of the term 'marked'. 6. The PCN is not compliant with the Protection of Freedoms Act 2012 (PoFA) and the following breaches are cited to buttress this salient point. Schedule 4 S9 [2][a] of PoFA states inter alia that: The notice must: (a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates; Schedule 4 S9 [2][e] of PoFA states inter alia that: The notice must: (e) state that the creditor does not know both the name of the driver and a current address for service for the driver and invite the keeper: (i) to pay the unpaid parking charges; or (ii)if the keeper was not the driver of the vehicle, to notify the creditor of the name of the driver and a current address for service for the driver and to pass the notice on to the driver; 7. The Particulars of Claim is denied in its entirety. It is denied that the Claimant is entitled to the relief claimed or any relief at all. I believe the facts contained in this Defence are true. Name Signature Date

Next posts below, the draft CPR to DCB Legal and SAR request to UK Parking Control Limited, both readied for tomorrow's post. Would greatly appreciate some proofreading of both and any subsequent feedback, please. Thanks.

Will get onto the CPR immediately and get that through the post to them by registered post.

Not yet, but I was hoping to do so probably today, but definitely before my defence statement submission before the Friday 4pm deadline. Would that be advisable?

Probably not.........but just thought anything to perhaps keep them sweating and on the back foot wouldn't go amiss

No need for a SARS demand from the Claimant, etc, at this stage then you reckon?

Apologies all. Been neck-deep with my house move activities and been a wee bit absent the last couple of days, hence the silence. By the way, in terms of timelines and considering the Claim Issue Date of 21st Nov, I hope there's still a reasonable amount of time available to tackle this PCN head-on with: 1. Any immediate requests, responses, or submissions to the Claimant/DCB Legal. 2. Any immediate requests, responses, or submissions to the Court. 3. Preparation of any evidence-gathering or defence statement. By the way, I also managed to obtain these merged additional images from the UKPC website. UKPC Website images.pdf

Hmmm, that's an interesting one @dx100uk I traded in my old vehicle at a car dealership with a replacement which has me down as the registered keeper. As far as the old car is concerned though, I handed the V5C over to the dealership during the trade-in. Is there any further action required though from me, as I've assumed all along that the dealership had dealt with it?