I haven't forgotten about this. I've just done a bit of work on the WS, and will do more late this evening when I knock off work. But two questions spring to mind. Would your "jump leads" friend be prepared to write a short Witness Statement? We could even write it at this end and just ask him/her for a signature. Your inability to move the car is called Frustration of Contract and could be your ace. Secondly, did you tell UKPC about the flat battery when you appealed?

It's no problem to have left some small bits out, your WS is excellent anyway.

It's common sense that they have a contract with the airport to manage the area. That's not in dispute. What is in dispute is that the airport has given them the authority to sue under their own name. If you really have done something bad on airport land then it is the airport who should sue. Can you upload the contract?

Don't worry about the SAR for the moment, acknowledge the claim and send off the CPR request as dx says, they may reply to the CPR and send the paperwork.

It's not essential, but if you have time a persuasive case for the DE MINIMIS section and including your PAPLOC letter as an exhibit in your current (5) wouldn't go amiss.

Most of what they have written is waffle, but if you want you could add little bits to your WS. After your current (4) you could add 5. The Claimant is incorrect in stating in their Witness Statement (para 13) that "no payment for parking was made by the Defendant". My exhibits show that payment was made. They again state (para 22 vi) "a valid parking session was not purchased by the Defendant" which is incorrect and the Claimant knows the statement is incorrect. You could expand your current (5) to 5. The Defendant informed the Claimant during PAPLOC about the wrong registration being incorrectly entered. The Claimant can witter on all they want (their WS para 21) about their laughable appeals procedure where they judge themselves, and my "unreasonable behaviour" (para 31), but the simple fact is that they knew they were paid and they suffered no loss but decided to start a court claim anyway. You could add to your current (11) 11. There is no presumption in law that the keeper was the driver and nor is a keeper obliged to name the driver to a private parking firm. This was confirmed in the POPLA Annual Report 2015 by the POPLA Lead Adjudicator and barrister, Henry Greenslade, when explaining the POFA 2012 principles of 'keeper liability' as set out in Schedule 4. The Claimant (their WS, para 20) can "believe that the Defendant was the driver" all they like but such belief has no basis in law nor indeed in the opinion of their own trade association's appeals body.

OK, will have a quick look now.

I can do some work on it on Friday afternoon. Normally that would mean you could get it to the court by the 4pm deadline. The problem is that Friday is a Bank Holiday and the earliest you will be able to get it to the court is Tuesday.

So presumably that is Total Car Parks' Witness Statement. Have you filed yours yet?

There's no problem giving your name. You are the registered keeper and the person they sent the invoice to. Don't sign it though. No clue should be given to them at all about the identity of the driver,. I've made suggested changes in red above. Get the letter off tomorrow. I wouldn't get your hopes up too much. But nothing ventured ...

That's a good start, but the WS still needs a lot of work. The problem is the lack of time. Your deadline is tomorrow. At my end a Bank Holiday means doing the work of five days in four, so the earliest I could help would be Friday. Up to you if you want to send it off tomorrow or risk sending a better version but slightly late.

"We will be forced to incur further legal costs for preparation, attendance and travel, which we will seek to recover at the upcoming hearing". Absolute, total lies. Costs are capped at small claims. Very kind of them to supply extra photos - all in the name of ABC Parking Solutions Ltd Fingers crossed all goes well in Drtford.

Have UKPC sent you their Witness Statement? If not, you can afford to be slightly late, they can hardly moan if they are late too.

Well spotted dx. That needs to go in the defence.

You are not appealing. There are no grounds for appeal. You did fail to input the registration number. I would send ECP a letter by 2nd class post (all they are worth), obtaining a free Certificate of Posting, and enclosing a redacted copy of the appointment, saying Hornsey Central Health Centre* have told you to do this to get the charge cancelled. I think there is a huge chance that reception are fobbing you off, but it's only a stamp so worth a try. * Or whoever the organ grinder is.

Make sure you get a CPR request off. They may cooperate and you get to see the PCN. If they haven't replied by your defence date then you can SAR the PPC.

As this bloke is apparently all over social media, it would be a good idea for your mate to contact him and ask if she can quote his case as a persuasive case in her WS. The claim number is the most important bit, and then anything else he would be willing to state - judge name, court name, hearing date.

You need to move on this.

You obviously know the area well. Do you know, more or less, when NPC took over? I ask because in their own trade association's Code of Practice there is - Changes in Operator’s Terms and Conditions Where there is any change to any pre-existing terms and conditions that would not be immediately apparent to a person visiting the Car Park and which materially affects the Motorist the Operator should place additional (temporary) notices at the entrance making it clear that new terms and conditions/charges apply, such that regular visitors who may be familiar with the old terms do not inadvertently incur Parking Charges. Notices should be in addition to the signage ordinarily required and left in place for an appropriate period.

We have a bland defence which covers all cases. Click on https://www.consumeractiongroup.co.uk/topic/393251-received-a-court-claim-from-a-private-parking-speculative-invoice-how-to-deal-with-it-hereupdated-dec-2021/ and scroll down to Q2) How should I defend?

I'm sure dx100uk will come on the forum this afternoon with details of how to defend.

I just don't get what the Directors want to do here. Surely they must know the bays are used by residents and what will happen if they bring in this one hour maximum nonsense.

Just in the last ten days or so MET have given in when the two cases reached Witness Statement stage. There are no guarantees that will happen in your case, but it is promising. We have over 100 threads for this car park and MET have only got money out of someone the once , when they started a court claim and the person was daft and didn't defend.

Any update here? In the last week or so MET have given in and discontinued two court cases for this site.

Thank you for the information. You haven't got a hope in hell of getting PE to accept a lower amount. They make their money through these invoices and in particular enjoy making money by increasing the amount whenever they can. You either cough up or you stick two fingers up to them and refuse to pay. We would prefer you did the latter. 1. If you decide to fight you need to send them a snotty letter, as others have said, that (a) formally tells them of the new address and (b) shows them you'd be big trouble for them if they did do court, so they'd better leave you in peace. 2. There is a reasonably good record on CAG of organ grinders being sympathetic to motorists. So in parallel to the snotty letter e-mail both the normal customer services of Welcome Break [email protected] and the CEO [email protected] Lay it on thick about being a genuine customer, attach any proof of purchase, emphasise your overstay was only short and you didn't abuse the car park, underline it was the early hours of the morning and for road safety you needed to sleep for ten minutes - and ask them to get the invoice cancelled. 3. Point taken about insurance but not updating the log book will mean that you won't get any mail about traffic "offences". You're extemely lucky that PE didn't send court papers to the old address meaning you would have lost by default. You can also be fined a grand - a real fine, not PE's rubbish - for not informing the DVLA.