@FTMDaveI posted both the SAR to Spring Parking and the CPR 31.14 to DCB on the 26th September.

@FTMDavehmmmm, did they actually amend and resubmit the Particulars of Claim to the court.............or did they simply send me that hand-written amendment to give me the jitters? Perhaps I may be wrong, but if they'd amended and resubmitted the Particulars of Claim, surely my expectation would have been that the court would send me the revised copy and also update the case on the MCOL portal with that information. To date, none of this has happened, suggesting to me that they never resubmitted a revised claim..........hence they opting now to apply for the case to be sent to the Small Claims Track...................or have I got this all completely wrong?

Hi All, So, some further update to share. 1. Unfortunately, my bank (Lloyds) has advised that they do not retain account transaction details that include location of those transactions, over such lengthy time periods. 2. I have in the last couple of days received from the court, an N149 (front copy attached) advising of a proposal to allocate the case to the Small Claims Track. The letter requests that I complete and file with the court office, a Form N180 (Small Claims Directions Questionnaire by Monday 14th November 2022. Would be grateful for any advice on how to proceed next. N149 - Notice_of_Proposed_Allocation_to_SCT_pg001.pdf

By the way, is it unusual that a full week after DCB emailed me that N180 Directions Questionnaire and also the N244, there's no evidence of it logged or recorded in my case profile, on the MCOL portal?

@lookinforinfoand therein lies the issue I raised some days ago regarding the accuracy and validity of the evidence they claim to gather via their cameras? Is it ever put to any proper scrutiny at all? Let's say the defendant couldn't dig up any backing evidence like Google Location History or some other evidence to exonerate them, does that mean they become "sitting ducks" and are left entirely at the mercy of the parking company's claim and perhaps the leniency of a court? We've already seen DCB Legal come out with the excuse that a faulty IT system was the reason for them submitting a completely incorrect Claim. Is there any reason therefore not to believe that those car park camera data aren't falsified or inaccurate too................whether deliberate or accidental?

@dx100ukthat was a brilliant suggestion!! I'd forgotten completely about the option of Google Location Tracking.......even though the disappointing aspect of it is that it doesn't always provide 100% guaranteed tracking history. Unfortunately, none of my location data is logged for four of the dates in question, but for one of the dates, Google logged my time at my Gym (car park premises) as 15:22 - 17:19 which is less than 2 hours. The morons on the other hand claim my entry and exit times were 15:21 and 17:38 respectively. I intend to contact my banks, etc, to provide me with all location and transaction times for the remaining dates, if Google can't provide the needed supporting evidence.

@Nicky Boyyou're absolutely right and it's something I'd picked up too because those sneaky images are of the vehicle being on the public road..........not within the car park premises. There is even another exit as you approach the entrance to the car park. Initially, I dismissed the alleged PCNs because they only showed me driving on that public road and besides, I was most convinced there was absolutely no chance of me staying 2+ hours in that car park on any visit.

@FTMDave unfortunately, proving I was elsewhere will be a hard ask due to the amount of time that has passed and the limited record or recollection of my activities back then. Even the electronic copies of my bank statements obtained only give a high-level summary of my transactions on the dates in question and do not confirm any time and location.

@dx100ukyep, pretty much so - amend their PoC. Below is the full statement they submitted towards the amendment request. The Claimant's Solicitor's ("DCB Legal") case management system ("CMS") suffered an IT malfunction when the Claim was issued, resulting in the Particulars of Claim incorrectly repeating the date of one of the Parking Charge Notices ("PCN's"), rather than listing the respective dates of all PCNs. DCB Legal has analysed the system and has contacted their developers, who are frequently consulted to develop DCB Legal's CMS and is familiar with it's business. DCB Legal is working closely with developers and is taking steps to put further testing procedures in place to prevent such issues occurring again. In the interest of the correct administration of justice, an Order as per the Draft Order is respectfully sought. It is DCB Legal's position that this is the most cost effective, proportionate and just solution for both the Claimant and the Defendant. It will allow the Defendant to fully understand the Claim, if they do not already. Although, it is of note that a Letter of Claim was sent to the Defendant prior to a Claim being issued in compliance with Pre-Action Protocol, and that letter correctly listed the PCN dates. Therefore, the Defendant has received full details of the amount claimed in any event. A version of the Claim Form with 'red pen' amendments is attached.

Thanks @FTMDave

@FTMDave thanks for the prompt feedback. Kindly find below the exact wording from the email with the N244 attachment. Dear xxxx xxxx, We write further to your recent correspondence. Please see attached a copy of the Application filed with the Court. Both parties must still continue to follow Court directions. If you are unsure as to your position, you may wish to seek your own independent legal advice. Kind Regards, xxxx xxxx DCB Legal Limited Thanks

All, some latest update on the case. So I have just discovered in my inundated Outlook Inbox that DCB Legal also sent another email just an hour or so earlier, on the day they emailed me with the N180 Directions Questionnaire, last Wednesday 19th October. Unfortunately, I failed to spot this email until just moments ago, as I was catching up on the nearly 2,000 unread emails sat in my inbox. This email in question relates to their submission of an N244, a copy of which I have attached here for your perusal. Firstly and in terms of timing, I do hope it hasn't compromised my position in terms of the earlier letter that @FTMDave advised I send them last Friday. Secondly, should I be taking any immediate action on this letter and N244 submission, or should I wait till I'm officially notified by the Court? Thanks PS: As usual, I've masked all personal information from the attached file. N244 Bundle_1.pdf

@dx100uk on the MCOL portal, as at this very minute, nothing regarding an N180 is mentioned under the Claim status summary. The last entry was the submission of my defence which they confirm receipt on Oct 03.

Couldn't get round to provide this update yesterday, but this is what happened after my previous post. I sent DCB Legal a curt reply to their email asking whether there was supposed to be an attachment to their email, as I'm actually incensed by the fact they're contacting me directly and I'd appreciate any clarification on whether this is actually acceptable or in adherence with due process. By lunchtime, they'd replied to my email with the below response which also had an N180 Directions Questionnaire attached. I'll display contents of the N180 right after this post. Dear xxx, 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, xxxx xxxx DCB Legal Limited

Well, the latest update is that I received a letter from the County Court a few days ago, informing me they'd processed my defence, notified the Claimant, etc. I then received an email from DCB Legal a couple of days ago, advising me to find attached an Application they'd filed with the court. Not surprisingly, there was nothing attached to the email and frankly, I've since been too busy to even revisit or bother with it.

All done. Just submitted my defence statement on MCOL successfully, in the last couple of minutes.

Will definitely be submitting that defence statement before close of business today @ 4pm. By the way, this is just a personal thought, but are there any official channels for Joe Public to challenge current legislation on how parking companies should be operating, etc? I ask because I personally find it rather exploitative and deliberate that they use these ANPR devices to constantly hound motorists, when for instance local authorities continue to invest in parking meters which issue you with tickets to stick on the window or windscreen of your car, but more importantly, provide full visibility of any parking time limits you're bound to. Thanks to these stick-on tickets, how many motorists in the past can we all recall rushing back to the car to "top-up" at the parking meter and then head back to carry on with their shopping or other activity, when they realised their parking duration was nearly up? Countless..........but at least fair to the motorist!! And if you failed to return to "top-up" and were given a ticket, you had little cause to dispute it because the evidence was there in black and white and available to all parties, including the motorist................ unlike these ANPR devices which are available solely to the parking company, but we're required to acknowledge their "evidence" as gospel. What's there to prove these parking companies do not manipulate these ANPR devices (entry and exit times, etc) for their own ffinancial benefit? After all, we all know how speed cameras, etc, have for years been purposely used as a money-making tool for many a council/local authority, so what's there to prove parking companies aren't installing these ANPR devices influenced purely by similar money-making motive? Why not use parking meters where the motorist could park, pay and have full visibility and awareness of any parking time limits to be adhered to? Today, there are even parking apps like RingGo which allow you to park, pay and/or top-up remotely without being anywhere near the vehicle or parking machine, or even having to rush back to obtain a new adhesive ticket for the car windscreen or window. I personally think the use of these ANPR devices by parking companies to monitor vehicle entry and exit times is abhorrent, unethical and sneaky, especially in light of the current financial crisis we're all facing and they're simply installed to entrap and exploit the ordinary motorists for financial gain. I for one would strongly lobby for them to be completely abolished for the aforementioned use by parking companies, if I had any such influence.

By the way, this weekend, I managed to obtain pictures of the parking signs around the premises of the land in question and have a couple of them attached. Hopefully, they might have some flaws that can be incorporated into in my defense statement. Thanks. pixs.pdf

Both SAR and CPR requests were sent by recorded delivery on Monday 26th Sept.

@FTMDaveI was actually planning to submit my defence on Sunday night.........or should I perhaps leave that till Monday evening/night? Regarding the SAR, I already sent that out to Spring Parking, same day as I mailed the CPR request to DCB Legal.

Well said, @FTMDave. I have access to lots of my bank statements, electronic and hard copy. I'll go through them asap and see what it reveals.

@brassneckedspot-on!! Was entirely my initial thought too. Only, there's the small and almost impossible matter now of trying to trace back my whereabouts more than three years ago.

@FTMDave thanks. All points are acknowledged and well-noted. However, if there was one thing I'd strongly refute, it is the claim that I regularly tend to stay beyond two hours at the car park in question. I could stake my last dime on this being a false claim, but sadly, I don't have the benefit of a camera or any other form of evidence to back my argument, so I tend not to even argue the point. My typical Saturdays are extremely busy, highly mobile/on the move and with lots of personal engagements, be it at home or away from home. Therefore, the suggestion that I'd even stay in any particular car park for over two hours, has me scratching my head. I just couldn't afford that luxury on a Saturday of all days.........and on a regular basis too. I can assure you, there's absolutely no reason why anything in or around the alleged premises would keep me parked there for over two hours. There's no shopping mall and barely anything of interest to keep one there for that length of time, on a frequent basis. Aside the Better Gym where being a member I used to visit on weekends and whose members were entitled to use this very car park (and by the way as a personal policy, one hour was always my maximum workout duration), I cannot for the life of me imagine how or why I'd stay on those premises beyond two hours. With the exception of a medium-sized Morrisons supermarket, the only other notable shops or businesses around those premises (Superdrug, Lloyds Bank, Boots and Farmfoods) are very small branches. Aside the two Morrisons and Farmfoods branches, I barely ever visit any of the others anyway. All this has me wondering whether they're not making this claim based perhaps on two separate visits to that car park on each given date, where they've paired the time of my first entry (let's say 2pm) with the time of my exit of a later visit (let's say 5:30pm). Judging by how they've gone on to botch the Particulars of Claim and the revelation by @FTMDave about their possible use of some dodgy software, would this be too far-fetched a thought? I just pray for the day when all of these wretched private car park companies would be outlawed for good and we can have some peace at last from all their exploitation and outrageous practices.

Thanks once again for all your support, Gents. Managed to edit the LoC and strip out some personal and other revealing details. Attached is the LoC. letter_of_claim-merged.pdf

@FTMDaveapologies, but I have to correct an earlier information I provided. I have just managed to find a "Letter of Claim" from DCB Legal, dated 27 June 2022. Not surprisingly, the dates given for the alleged PCNs do not match what's been stated on the Particulars of Claim. In contrast with the Court Claim, only one single PCN is listed for 16/02/2019, with 5 different dates cited for the other alleged PCNs. I'll scan and upload the Letter of Claim here very shortly.