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UKCPS Ltd 1200 Century Way Thorpe Park Business Park Colton LS15 8ZA 25th May 2017 Dear Sir or Madam, Re: UKCPS Ltd v Blue Jeans CPR 31.14 Request On 17th May 2017 I received the claim formicon in this case issued by you out of the UKCPS Ltd county courticon. I confirm having returned my acknowledgement of service to the court in which I indicate my intention to contest all of your claim. Please treat this letter as my request made under CPR 31.14 for the disclosure and the production of a verified and legible copy of [each of the following / the] document(s) mentioned in your Particulars of Claim: 1. the contract between UKCPS Ltd and the landowner that assigns the right to enter into contracts with the public and make claims in their own name,. 2.proof of planning permission granted for signage etc under the Town and Country Planning Act 2007 3.copies of the notice to driver, notice to keeper and any other correspondence from UKCPS Ltd to the defendant that they intend to rely upon in court. You should ensure compliance with your CPR 31 duties and ensure that the document(s) I have requested are disclosed at your earliest convenience.. Your CPR 31 duties extend to making a reasonable and proportionate search for the originals of the documents I have requested, the better for you to be able to verify the document's authenticity and to provide me with a legible copy. Further, where I have requested a copy of a document, the original of which is now in the possession of another person, you will have a right to possession of that document if you have mentioned it in your case. You must take immediate steps to recover and preserve it for the purpose of this case. Where I have mentioned a document and there is in your possession more than one version of that same document owing to a modification, obliteration or other marking or feature, each version will be a separate document and you must provide a copy of each version of it to me. Your obligations extend to making a reasonable and proportionate search for any version(s) to include an obligation to recover and preserve such version(s) which are now in the possession of a third party. In accordance with CPR 31.15© I undertake to be responsible for your reasonable copying costs incurred in complying with this CPR 31.14 request. If you are unable to comply with this request within 14 days and believe that you will never be able to comply with this request please confirm in your response. You are reminded that as this case is yet to be allocated to a track, CPR31:14 does apply, a refusal to comply because you 'think' at this stage you dont have too will be used against you in any filed defence. Yours faithfully Does this sound right? I have put my address above in the letter Thanks
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Name of the Claimant ? UKCPS LTD Date of issue – 17th May 2017 Date of defence filing 16th June What is the claim for – 1.A claim for the outstanding parking charge has been issued against the registered keeper of vehicle registration XXXX parked on FLEECE YARD KIMGSGATE SHOPPING CENTRE. 2.The driver of the vehicle parked on 19/01/2017 at 09:57hrs. A ticket was issued for parking WITHOUT A VALID PERMIT OR AUTHORITY. 3.This land is managed by the claimant UKCPS Ltd and vehicles parked on this land are subject to parking conditions which are set out on signage on this land forming a contract between the driver of the vehicle and UKCPS Ltd. 4.The registered keeper who may have been the driver or alternatively has chosen not to name the driver is responsible for payment as required under Schedule 4 of the Protection of Freedoms Act 2012. 5.By parking on this land the driver contractually agrees to pay a charge of £100.00. This amount remains unpaid, an additional charge of £50.00 had been incurred in collection fees whereby this becomes a commercially justifiable figure. What is the value of the claim? £175.00 Has the claim been issued by the Private parking Company or was the PCN assigned and it is the Debt purchaser who has issued the claim ? UKCPS Ltd Were you aware the account had been assigned – did you receive a Notice of Assignment? I did receive letters. ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------- I think that's right but let me know if I've missed anything. Thankyou
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Hi I've just received through a county court claim form from ukcps. I currently pay and have done for a while £85 per month to park in a private Carpark for work. It was owned by the shopping centre but was then taken over and we were issued permits that we had to display. On the day I got the fine my permit had blown onto the foot well so I sent a letter to ukcps and stated this. They have carried on with court proceedings even though I have my receipts for paying every month and now I have no idea how to appeal this online but refuse to pay the £175 they are now asking when they receive £85 a month off me already! Hoping someone has a template I could use to appeal this asap as I've been on holiday so I'm down a few days into my 14 days to appeal already grrrr Thankyou
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