Jason MS
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VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Thank you for this, much appreciated! -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Can anyone think of one more to add then? Maybe something to do with issuing a parking charge notice for stopping? -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Just asking again so others might see. Is there anything I should add to my defence? 1) The land is covered by its own byelaws so not "relevant land" under the POFA. VCS has no Locus Standi to claim a prohibited act is a parking Event. 2) The signage is prohibitive in nature and not a genuine offer of a contract for consideration. Should I mention my reason for stopping briefly outside the arrival terminal was to assist my disabled father? Thanks -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Okay thank you, will do. -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Hey, so i'm submitting the defence. I've got two points: 1) The land is covered by its own byelaws so not "relevant land" under the POFA and that the byelaws create a supremacy of contract over VCS signage so no liability created, 2) The signage is prohibitive in nature and not a genuine offer of a contract for consideration. Should I mention my reason for stopping briefly outside the arrival terminal was to assist my disabled father? Thanks -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
I just wanted someone to check over the template to make sure I hadn't made any mistakes in who i was sending to. Is that OK? Turns out I had made a mistake as FTMDave pointed, so that's why I wanted someone to check it. -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Oh, sorry. Is it ok to send? -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
On the claim form it's got VCS as the claimant on the top left, but at the bottom it's signed by simple and says claimant in brackets, so i wasn't sure. But yeah i think it is VCS -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Thanks for that info ericsbrother. I've got the CPR 31.14 request template ready. Can someone check it over and make sure it is ok to send off please? My Address My Address My Address My Address Vehicle Control Services Limited 2 Europa Court Sheffield Business Park Sheffield S9 1XE (template removed - dx) -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Name of the Claimant ? VCS/Simon Renshaw-Smith claimants Solicitors: Date of issue – 20 Feb 2020 What is the claim for – 1.The claim is for breach of contract for breaching the terms and conditions set on private land. 2.The defendants vehicle reg xxxxx was identified in Southend Airport on the 12/10/2019 in breach of the advertised terms and conditions; namely stopping in a zone where stopping is prohibited. What is the value of the claim? £185 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 ? The claim was issued by a private parking company I've read another thread which is ahead of mine slightly in the process, I've done an AOS on the MCOL site. Now I need to send off a CPR 31.14 request and submit a defence, right? -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
I got a claim form from "Money Claims Online". Is it an official court document or should I ignore it? -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Ah okay yeah, so I'll just remove the last sentence and then it's good to send off? -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
I found this response by Ericsbrother: "Unfortunately for you I wasn’t born yesterday so I won’t be paying the demand to you, as you know what I know and that there is no liability in this matter because the land is covered by its own byelaws, The signage is prohibitive and not an offer of a contract so none has been breached and anyway the POFA limits any charge to the specified sum so your demand for £160 is just a nonsense. As VCS has been spanked at court on this very same thing several times before I suggest that you discontinue this foolishness and that way you will at least obey the SRA rules of conduct and obey Civil Procedure as well. I know that may well be a first for you but call it your new year's resolution. Should you decide to continue then I shall be asking for a full costs recovery order for unreasonable behaviour and then seek damages for breach of the DPA as per VCS v Philip, Liverpool CC Dec 2016. Even Will and John, the parking worlds’ worst solicitors seem to have got fed up with Simple Simon's stupidity and greed and presumably that is why you are wasting your ink on his behalf." I think it covers my case pretty well. Do you think there is anything I should add? -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Yeah, I found one that does. Just have to reword it slightly. -
VCS PCN Claimform - No Stopping - Southend Airport
Jason MS replied to Jason MS's topic in Private Land Parking Enforcement
Ah I see, no worries.
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