So I submitted a CPR 31.14 and SAR requests to DCB Legal and Highview Parking respectively and have now received the below responses from them. On their part, DCB Legal replied that as a claim has been issued, they are not obliged to provide evidence at this stage unless ordered to do so by the Court. Highview Parking on the other hand have requested I complete a return a form they've sent me, as they are required under GDPR to validate my identity prior to releasing personal data. Looking further, I am now rather keen to begin putting together a defence statement and would be extremely grateful for any assistance or advice towards that.

@dx100uk, I'm afraid you've got this wrong. My fear of compromising my defence wasn't with regards my response to DCB Legal's initial letter per se. It was more in reference to any subsequent advice posted on this thread by other forum members and I was only being wary due to the numerous instances when some have cautioned about parking companies and their legal reps trawling these pages to stay a step ahead. As I did also state however, I'm happy to provide full details of that initial reply to DCB Legal and have therefore reproduced it below. Thanks.

I can personally confirm the town and county details, but I can assure you this is all the address given on the N1 POC. Can even take a screenshot and paste it on here if it helps.

@dx100ukthanks for the prompt response. As requested, kindly find below the details of claim as given on the Court Form N1. Name of the Claimant: Highview Parking Limited 10 Flask Walk London NW3 1HE Claimants Solicitors: DCB Legal Ltd Direct House Greenwood Drive Runcorn WA7 1UG Date of issue: Thu, 31 Dec 2020 Date for AOS: Sun, 17 Jan 2021 Date to submit Defence: Mon, 1 Feb 2021 What is the claim for? 1. The Defendant(D) is indebted to the Claimant (C) for a Parking Charge(s) issued to vehicle [CAR REG] at 1-3 Upper Green East. 2. The PCN details are 04/03/2017,2xxxxx7xxxxxx 3. The PCN(s) was issued on private land owned or managed by C. The vehicle was parked in breach of the Terms on Cs signs (the Contract),thus incurring the PCN(s). 4. The driver agreed to pay within 28 days but did not. D is liable as the driver or keeper. Despite requests, the PCN(s) is outstanding. The Contract entitles C to damages. AND THE CLAIMANT CLAIMS 1. £165 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 £0.04 until judgment or sooner payment. 3. Costs and court fees. What is the value of the claim? Amount Claimed: £215.57 Court fee: £25.00 legal rep fees : £50.00 Total Amount: £290.57 Do I still need to send out a SAR to Highview Parking even though I've already got a CPR 31.14 off to DCB Legal?

My fault @dx100uk. Sincere apologies, I should have indeed read fully the text in red. AOS has now been submitted and CPR is also on its way to the solicitors.

@dx100ukthank you ever so much. I'm extremely grateful for your kindness and assistance. Good news is that I have managed to access the claim on MCOL and plan to submit the AOS by this weekend, as I believe I still have until 19th Jan to do so (The Claim issue date was 31st Dec 2020). In the meantime, I have also downloaded a copy of the CPR 31.14 you included in your last post, edited it where required and pasted its contents below for any review comments. You'll note that I have also sought clarification on the Claim Form receipt date and for that I'll greatly appreciate any feedback. Finally, I've also pasted the Particulars of Claim below (albeit with some minor editing), as I believe this should help validate the CPR 31.14 requested documents. Thank you. (removed - dx) [[THE PARTICULARS OF CLAIM]] 1. The Defendant(D) is indebted to the Claimant (C) for a Parking Charge(s) issued to vehicle [CAR REG] at [ADDRESS]. 2. The PCN details are 04/03/2017.2xxxxx7xxxxxx 3. The PCN(s) was issued on private land owned or managed by C. The vehicle was parked in breach of the Terms on Cs signs (the Contract),thus incurring the PCN(s). 4. The driver agreed to pay within 28 days but did not. D is liable as the driver or keeper. Despite requests, the PCN(s) is outstanding. The Contract entitles C to damages. AND THE CLAIMANT CLAIMS 1. £165 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 £0.04 until judgment or sooner payment. 3. Costs and court fees. By the way, I'm gathering from some of your advice that sending a CPR 31.14 request by email is a complete no-no..........would that be right?

@dx100ukthe feedback is much appreciated. Will follow the advise (as above) promptly.

So, acting on advice gathered via some third parties, I responded to DCB's letter by challenging them on a number of key points which not surprisingly, prompted a swift reply from them. In order not to risk compromising my defence, I've opted not to place extracts of the aforementioned key points from my letter into this public domain, but would be happy to share them privately with the right person(s) on this forum willing to offer genuine and sincere assistance with no ulterior motive. DCB Legal have since proceeded to submit a money claim against me in a County Court and I've in the last few days received the Claim Form from the court, with an Issue Date of 31 Dec 2020. My intention now is to submit an Acknowledgement of Service within the next couple of days, but I'm keen to look beyond that by desperately beginning to prepare a cast-iron defence to submit to the court. I'll therefore be extremely grateful for any advice or assistance in putting together a sound defence statement to help me see off this irritation at such a challenging time in our respective lives. PS: I'm not sure how much this is going to go against me and whether it is too late to do so, but I did not submit a SAR request to CP Plus Limited and rather chose to deal solely with DCB Legal.

Lol. Thanks @FTMDave Will most definitely "snotty letter them" in my final action

Thanks for all the feedback peeps. They're well appreciated and I'm still trying to figure out which advice would be best to follow. @FTMDave, no I haven't moved to a new address during the last 3-4 years. As it happens, I've actually resided at my current address for well over a decade and so there's no chance of any paperwork being sent to another address. I would definitely though have no recollection of this alleged contravention over 3 years ago, even if I tried. When you have family, work and far more purposeful things in life to deal with, you don't waste your time and recollections on these vampires and their PCNs......especially when they date back years.

Hello, I recently received a Letter of Claim from DCB Legal, advising that they were acting on behalf of a client and demanding immediate settlement of an alleged PCN dating back to March 2017. Not surprisingly, I have absolutely no recollection any such PCN, let alone any parking contravention. I must admit, I was rather incensed by it all and considered ignoring the letter entirely, especially as the car park in question is outside the premises of a gym of which I'm a member and regular user, and a couple of supermarkets I visit on an almost daily basis to this day in London. After careful consideration however, I decided to seek a second opinion on here, particularly from people who've had similar dealings with DCB Legal. By the way, considering this alleged parking offence dates nearly 4 years ago, does it not exceed the permitted time limit for the pursuit of its settlement? DCB Legal Letter of Claim.pdf

Thanks @DragonFly1967

Well, well, well.......this case developed further when a few days ago I received the below email, on the back of the letter I wrote to DPR in response to their demand letter. Would be grateful for any helpful feedback on how to treat this. I have truncated and/or stripped out bits of it to ensure anonymity. Start of Email PS: By the way, the parking company involved in this case have now been replaced at the car park in question by a new parking company. Thank you for your email regarding the above Parking Charge Notices (PCNs). The time to challenge these charges has now expired and therefore access to the Independent Appeals Service (if applicable) is no longer available. However, in order to resolve this matter, I will offer the following comments as to why these PCNs were correctly issued and are still payable. My findings The sites in question are subject to terms and conditions, which are stated on signs throughout the area. Those signs state that there is a time limit at the site. On the dates in question the vehicle was parked for longer than the time stated and a PCN was correctly and legitimately issued as a result.Please be advised, there are currently seven outstanding Parking Charge Notices (PCNs) under the vehicle registration. The claim in question is based in contract law. When you parked your vehicle on the site in question, you contractually agreed to abide by the terms and conditions attached to that site. As stated, these terms and conditions are adequately displayed on signage at the site. If you did not wish to abide by these terms and conditions, you were under no obligation to park on the property in question. I draw your attention to the decision made by the Supreme Court in ParkingEye vs Beavis [2015]. The Supreme Court ruled that the charge appealed did not contravene the penalty rule or the Unfair Terms in Consumer Contracts Regulations 1999 and was therefore enforceable. The charge in that case was ruled not to be a penalty as both ParkingEye and the landowners had a legitimate interest in charging motorists who contravene parking restrictions, which extended beyond the recovery of any loss. The interest of the landowners was the provision and efficient management of parking. The interest of ParkingEye was in income from the charge, which met the running costs of a legitimate scheme plus a profit margin. Further, the charge was neither extravagant nor unconscionable, having regard to the practices around the United Kingdom and taking into account the use of the particular car park and the clear wording of the signs. Please see this link for a summary of the Judgment: https://www.supremecourt.uk/cases/docs/uksc-2013-0280-press-summary.pdf The signage on site is sufficient and is in line with the guidelines laid down by the British Parking Association (BPA). The majority of motorists who park at the site do so without receiving a PCN. This is undoubtedly due to the fact that they are aware of the terms and conditions of the site. If, as you claim, the signage was inadequate, the terms and conditions of the site would be unknown to the majority of drivers and many more PCNs would be issued here. If you refer to the British Parking Association’s code of practice, you will discover that the sum in question is within what this body deems reasonable. I also draw your attention to the decision made by the Supreme Court in ParkingEye vs Beavis [2015]. The Supreme Court ruled that the charge appealed did not contravene the penalty rule or the Unfair Terms in Consumer Contracts Regulations 1999 and was therefore enforceable. The charge in that case was ruled not to be a penalty as both ParkingEye and the landowners had a legitimate interest in charging motorists who contravene parking restrictions, which extended beyond the recovery of any loss. The interest of the landowners was the provision and efficient management of parking. The interest of ParkingEye was in income from the charge, which met the running costs of a legitimate scheme plus a profit margin. Further, the charge was neither extravagant nor unconscionable, having regard to the practices around the United Kingdom and taking into account the use of the particular car park and the clear wording of the signs. Please see this link for a summary of the Judgment: https://www.supremecourt.uk/cases/docs/uksc-2013-0280-press-summary.pdf I must also stress that simply sending in standard template responses, most likely obtained from the internet, will not resolve the matter. In addition, I would recommend that professional legal advice be sought on this matter as an alternative. What you need to do now Please ensure that £xxxx.xx is paid by xx/01/2017. Payment can be made online or by phone. End of Email

I believe so, but as I was away for a few months, I believe it/they got binned. Let's just assume therefore that I did receive an NTK but no longer have it. All, Drafted the below letter which I plan to send to SCS Law and Debt Recovery Plus. I'm therefore desperately in need of some kind, expert review and some feedback please. As I have no NTK letter(s), I'm particularly unsure whether it's worth stating this in the letter below and requesting for a copy/copies. Thank you --------------------------- LBCC Response Letter ------------------ Dear Sirs, Re: Debt owed to Highview Parking Ltd - Reference xxxxxx Thank you for your letter of DD-MM-2017. As registered keeper of the vehicle, this is a formal response to challenge the Parking Charge Notice in question, on the basis of the key points outlined below. You letter fails to: Supply any photographic evidence, nor even the 'contract' (in this case presumably a sign). Set out clearly, the basis upon which you are attempting to hold me liable, with the charge disingenuously described in your letter as your ‘debt’. State what the cause of action is, nor contain any mention of what evidence your client intends to rely on, or enclose copies of such evidence. This action on the part of your client is a clear breach of its pre-action obligations set out in the Practice Direction - Pre-Action Conduct, with which as solicitors you must surely be familiar (and with which your client, a serial litigator of small claims, must also be familiar). As you (and your client) must know, the Practice Direction binds all potential litigants, whatever the size or type of the claim. Its express purpose is to assist parties in understanding the claim and their respective positions in relation to it, to enable parties to take stock of their positions and to negotiate a settlement, or at least narrow the issues, without incurring the costs of court proceedings or using up valuable court time. Nobody, including your client, is immune from the requirements and obligations of the Practice Direction. I therefore require your client to comply with its obligations by sending me the following information/documents: An explanation of the cause of action. Whether they are pursuing me as driver or keeper. Whether they are relying on the provisions of Schedule 4 of POFA 2012. What the details of the claim are (where it is claimed the car was parked, for how long, how the monies being claimed arose and have been calculated, what contractual breach (if any) is being claimed). A copy of the contract with the landowner under which they assert authority to bring the claim. A copy of any alleged contract with the driver. A plan showing where any signs were displayed. Details of the signs displayed (size of sign, size of font, height at which displayed). If they have added anything on to the original charge, what that represents and how it has been calculated. I am clearly entitled to this information under paragraphs 6(a) and 6© of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b). If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) – Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13 ,15(b) and © and 16. I will draw to the court the fact that I have expressly requested this information, yet been denied it by your client. Until your client has complied with its obligations and provided this information within 14 days from the date of this letter, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided. Otherwise, I expect to hear from you within 14 days, confirming that the charge is cancelled. Yours faithfully, [Name and Address of Vehicle Keeper]

Well, so this is the current state of affairs. I contacted the gym to request for the ticket to be cancelled as advised and received a call back. If I have to be honest, I'm not entirely sure who's probably annoyed me more - Highview Parking Ltd, or the rather obnoxious gentleman from the gym who contacted me. He was rude, unhelpful and even had the temerity to insist that I had no option than to pay the fine and that based on past experience, no amount of intervention from the gym would change the outcome. As a result, I believe I can well and truly now forget about wasting any more time seeking any assistance from the gym, take the bull by the horns and directly challenge SCS Law and/or Highview Parking. What do we therefore do next kind friends?

By the way, also now uploaded is a copy of the letter received from SCS Law as requested.

In the absence of any positive response or assistance from the gym, what would be the next best course of action to take on my part?

Thanks for the feedback @dx100uk. Followed the link you provided and can confirm this particular case falls under the one titled - "For PNC's received through the post [ANPR camera capture]" Now, there's no record of receiving any Notice To Keeper letter(s) and even if any was sent, it is definitely not currently available. The alleged incident is saidto have occurred at the start of March this year and one fact is that I was also abroad for 3 months from the end of April till end of July. As there's currently no NTK to refer to at this point in time, I cannot also ascertain any of the following: 1. The date on the NTK [including if received within 14 days from the 'offence' date] 2. Date received 3. Whether the NTK mentions schedule 4 of The Protections of Freedoms Act 2012? 4. If there's any photographic evidence of the event? With this in mind, how can one proceed please? For example, should I be requesting for copies of the NTK for starters? Should I submit an appeal and if so to whom? To date, no appeal has been made yet to the parking company, SCS Law or the debt recovery company. Thank you.

Hello, I have today received a letter from SCS Law who claim they've been instructed by Highview Parking Limited to recover an alleged penalty charge notice incurred by myself/my vehicle. Incensed by the content of this letter, I sought to establish what the address of the alleged contravention was supposed to have taken place it turns out to be my local gym where I've been a member for nearly 20 years and as such a legitimate user of their car park. I initially contacted Highview Parking to enquire about the reason for the letter and/or alleged contravention was advised by a lady to write to their Appeals Team who're based in Barnet. A second call to SCS Law drew a complete blank as the gentleman on the line advised that the firm had not been given any details on the alleged offence and had only been instructed by Highview to send out to me an initial notification letter. Now, knowing how some of these cases can be won and lost through technicalities and not wanting to allow my heated emotions overrule any logical thinking on my part, I'd be grateful for any advice on how I should proceed with this please, e.g. how and who to contact, my line of argument, etc. Thank you.

Well, well, well, guys. Some rather unfortunate and unpleasant developments. I left the UK on 30th April for a trip abroad and only just returned last Friday, 28th July. Prior to my departure and following the submission of my defence tothe claim, I contacted the Northampton County Court to discuss my impending trip and whether it would have any possible impact on my case was advised that nothing could be done and that I had to simply wait until the court contacted me again. Alas, upon my return, I found two letters delivered from the court and named as follows: 1. General Form of Judgment or Order, dated 15 June 2017 2. Judgment for Claimant (in default), dated 14 July 2017 Crucially, the first letter (General Form of Judgment or Order) mentioned that if I failed to file a Directions Questionnaire with the County Court Business Centre before a certain date, my defence/counterclaim would be struck out without further order of the Court. Whether this was by design or just my rotten luck, I have found absolutely no sign or trace of this Directions Questionnaire among the pile of mail diligently and carefully set aside for me by my wife, in my absence. I even phoned Northampton County Court to point this out, but was unfortunate enough to have to deal with the most unhelpful and unpleasant court clerk I could have wished for and made no headway. Bottom line is, I now have a default judgment of just under £270 to pay the Claimant would like to apply for the judgment to be set aside, as I strongly believe that I have a sound defence and it's only right that I be granted an opportunity to present this defence and receive a fair hearing. As I'm currently unemployed, a number of questions have also been racing through my mind including.... a) Considering the application to set aside judgment incurs a fee of £255 and considering the judgment sum is just under £270, is it worth my while putting in this application at all? b) As I'm now unemployed, can I have the application fee waived or reduced when applying to have the judgment set aside? c) If the application fee cannot be waived or reduced, can I claim it back from the Court or the Claimant if I'm successful with my appeal? d) Should I have to proceed with the application to set aside judgment, can anyone provide some advice/guidance on how I should go about this please? Thank you.

Well, well, well, guys. Some rather unfortunate and unpleasant developments. I left the UK on 30th April for a trip abroad and only just returned last Friday, 28th July. Prior to my departure and following the submission of my defence to the claim, I contacted the Northampton County Court to discuss my impending trip and whether it would have any possible impact on my case and was advised that nothing could be done and that I had to simply wait until the court contacted me again. Alas, upon my return, I found two letters delivered from the court and named as follows: 1. General Form of Judgment or Order, dated 15 June 2017 2. Judgment for Claimant (in default), dated 14 July 2017 Crucially, the first letter (General Form of Judgment or Order) mentioned that if I failed to file a Directions Questionnaire with the County Court Business Centre before a certain date, my defence/counterclaim would be struck out without further order of the Court. Whether this was by design or just my rotten luck, I have found absolutely no sign or trace of this Directions Questionnaire among the pile of mail diligently and carefully set aside for me by my wife, in my absence. I even phoned Northampton County Court to point this out, but was unfortunate enough to have to deal with the most unhelpful and unpleasant court clerk I could have wished for and made no headway. Bottom line is, I now have a default judgment of just under £270 to pay the Claimant would like to apply for the judgment to be set aside, as I strongly believe that I have a sound defence and it's only right that I be granted an opportunity to present this defence and receive a fair hearing. As I'm currently unemployed, a number of questions have also been racing through my mind including.... a) Considering the application to set aside judgment incurs a fee of £255 and considering the judgment sum is just under £270, is it worth my while putting in this application at all? b) As I'm now unemployed, can I have the application fee waived or reduced when applying to have the judgment set aside? c) If the application fee cannot be waived or reduced, can I claim it back from the Court or the Claimant if I'm successful with my appeal? d) Should I have to proceed with the application to set aside judgment, can anyone provide some advice/guidance on how I should go about this please? Thank you.

Thanks for the feedback @BankFodder

Hello, I need help desperately and would be extremely grateful for some kind assistance. A county court claim was recently made against me by Pace Recovery and Storage for an alleged breach of the terms of parking on the land behind a shop in Surrey. I proceeded to submit my Acknowledgment of Service on MCOL within the required deadline, however I got the deadline for filing my defence horribly wrong and now appear to have missed it. As a result, the MCOL site even rejects all my attempts to log on to submit the defence. What contributed mostly to this aberration is that I submitted a CPR 31.14 request to the claimant's solicitors, giving them 14 days to respond to my request. This 14 day deadline officially ended today and not surprisingly, I have to date received no response from the solicitor. It was therefore my intention to include this bit of information as part of my defence to be submitted on MCOL today. Other important dates relating to this case are as follows: Claim Issue Date: 10th March 2017 Day of Service: 15th March 2017 Acknowledgment of Service: 27th March 2017 I am at a loss now what to do, as I certainly don't wish to pay this claim and I definitely wish to submit a defence. Someone please, please, help. Thank you.

@dx100uk, Thanks very much for the advise. By some coincidence, I received notification of your message on my phone inside my local post office where I was about to send my CPR31.14 Request to Gladstones Solicitors. Thanks @silverfox1961. Unfortunately, I kept any of the letters received previously. Hopefully though, Gladstones Solicitors will send me copies, following my CPR 31.14 Request. @dx100uk, not sure I'm with you. Please clarify which link you're referring to. Thanks

Hello, A number of PCNs from Pace Recovery and Storage Limited of Croydon were delivered to my address in the last few weeks, for an alleged breach of the terms of parking at the rear of a shop where it is claimed a vehicle owned by myself was parked one Sunday in November 2016. All of the PCNs, which also failed to include any photo evidence of the alleged breach, were ignored and are no longer available. In February, the PCNs were followed by a "Letter Before Claim" from Gladstones Solicitors which was also ignored. Finally, a few days ago a Claim form issued by the County Court Business Centre of Katharine Street in Northampton was delivered, stating the following Particulars of Claim: The driver of the vehicle registration XXXXXX (the "Vehicle") ignored the parking charge(s) on [date] for breaching the terms of parking on the land at [Address of premises]. The Defendant was driving the Vehicle and/or is the Keeper of the Vehicle. AND THE CLAIMANT CLAIMS £160 for Parking Charges / Damages and indemnity costs if applicable, together with interest of £2.42 pursuant to s69 of the County Courts Act 1984 at 8% pa, continuing to Judgment at £0.04 per day Would now appreciate the kind assistance of our very valued forum members to advice on how to defend this claim successfully, having submitted my Acknowledgment of Service in the last few days. Should I kick things off for instance by submitting a CPR 31.14 request to the Gladstones Solicitors? Thank you.