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  1. should i refer to them as Client or Claimant ? thinking client is right because it hasnt been filed yet ....
  2. So I've written a toned down version of your letter EB, am fearful to antagonise them. - But thats how they win is suppose. Will this be ok ? Dear Will and John, Thank you for your Letter Before Action. (LBA) I couldn't stop laughing when I read it and may well use it as therapy should I get depressed at the thought of your clients wasting more money on what is an utterly pointless exercise. I believe that the land that is the subject of this attempt at blackmail from the Claimant is not “relevant land" under the POFA and is covered by its own byelaws and so not subject to made up rules. The paperwork sent out by the Claimant has failed to create any liability. so even if the law covering the land wasn't sufficient reason to negate their demand, their failure to follow protocol is. It is denied that the Claimant has complied with Schedule 4, Protection of Freedoms Act 2012. Under paragraph 8&9 of the Protection of Freedoms Act 2012, it states there should be a NTK (notice to keeper) sent to the registered owner. This notice was not sent to the Defendant from the Claimant within the required time, thus making any claim null and void. I would have thought that IPC would have advised their members better than this as their members VCS always lose the same sort of claim at Liverpool Airport and you are no stranger to helping them amass their losses there. Please advise your clients that any claim will be robustly defended and an unreasonable conduct costs order sought. Sincerely,
  3. @Lookingforinfo Cheers for that, i thought they had messed up with the 56 days, think i know whatim doing now @ericsbrotherI've had that light bulb moment, what a bunch of scoundrels.!! So you think they will give up if I send them this letter, once they realise that the 56 days were well exceeded? Amazed the system let them take these cases to court
  4. Thanks for coming back to me EB, Will this letter be enough? I assume when you say MMouse has failed to create any liability you mean that they have sent the NTK after 56 days? Who are Will and John? sorry for questions Cheers
  5. Can someone direct me towards ones of EB's letters or how do i contact him? TY
  6. I have received two letters that I have uploaded, neither of them seem to be notice to keeper, 1st one is a Notice to driver and 2nd is Letter before claim. The Letter before claim has taken 8 days to arrive from their date of issue so I need to work out how to proceed quickly. Any help defending this much appreciated. 1 The date of infringement? 29/12/18 09:32 2 Have you yet appealed to the parking company yet? [Y/N?] NO if you have then please post up whatever you sent and how you sent it and the date you sent it, suitably redacted. [as a PDF- follow the upload guide has there been a response? please post it up as well, suitably redacted. [as a PDF- follow the upload guide] If you haven't appealed yet - ,......... have you received a Notice To Keeper? (NTK) [must be received by you between 29-56 days] YES what date is on it 01/03/19 Did the NTK provide photographic evidence? YES ( not showing any bay marks or signage) 3 Did the NTK mention Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) [Y/N?] YES, in the second letter received it mentions it 4 If you appealed after receiving the NTK, did the parking company give you any information regarding the further appeals process? [it is well known that parking companies will reject any appeal whatever the circumstances] 5 Who is the parking company? GXS Services Ltd 6. where exactly [Carpark name and town] did you park? Shoreham Port Authority Basin Rd Southwick W Sussex BN41 1WF uploads.pdf
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