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  1. Had a good dig through the PP site at the time, and there's nothing up there. Made me chuckle when nothing came through after the request. I guess on emailing the council I can submit their response as proof they don't have PP?
  2. Great stuff, thanks for sense checking, saves on the photocopying anyhow. Also great shout on the hearing fee. Hoping me tell them to shove it will mean they just don't bother. Will let you know what they say on Friday. Thanks for the links, will get drafting my witness statement in the meantime. The other 'evidence' is the lack of planning permission for any of the signage or ANPR cameras, but not quite sure how to show the 'lack' of something. Any tips on how to include this would be welcome! Cheers
  3. Thanks BankFodder, Apologies for the radio silence, been a crazy couple off months. But thought I'd check in. The Case has been allocated, CE tried to mediate with a Without Prejudice Save as to Costs letter, which I told them mostly politely to shove up their... So just wanted to check in on: What evidence I should be sending to the court. When I should send evidence (which I realise will need to be sent to CE as well.) Evidence wise, I have: Bank statement showing the two transactions I made that day, for for exactly £10 which refunded my parking ticket. And the other being the art shop I visited that day. Photograph of the payment machine, which doesn't display the terms and conditions of the car park. Photograph from the car park to Morrisons showing signage is all out of line of site from parked car to the shop. Is it worth also sending things such as ownership documentation of the car, as I only had it for 3 weeks, so didn't remember the reg. Confirmation of testing that I'm dyslexic, making reading the various signage difficult. The last two are very spurious, so feel free to tell me not to be a d***h***. Cheers as ever, and Happy New Year all! NoticeofAllocation.pdf
  4. Thanks DX, going through now, apologies. C1. Do I state No, that the Claim is unjustified, or state yes? D - Local court to me, obv no experts and only me as witness. Thanks again!
  5. Hi all, the ball keeps rolling, and unfortunately arrived home to this after a week away, so have a quick turn around to get this back to them. There was also included a mediation info sheet, which I assume you've all seen before. Should I go this route and try to get them to drop it for nothing or just go with the below form? Not entirely sure why it's coming from Northhampton, as I live in London near the car park, also in London. So assume this form is to get the case assigned to London? Thanks again for your help. Y NoticeofProposedAllocation-SCC.pdf
  6. Thanks dx100uk, Reading through the prior art, am I correct to think these are the points you recommend in the defence. Glad I have a bit of time to get this right, but hope to get it sorted so I can get on with my life. 1. The Defendant is the recorded keeper of [motor vehicle]. 2. It is denied that the Defendant entered into a contract with the Claimant. 3. In any case it is denied that the Defendant broke the terms of a contract with the Claimant. 4. The Claimant is attempting double recovery by adding an additional sum not included in the original offer. 5. The Particulars of Claim is denied in its entirety. It is denied that the Claimant is entitled to the relief claimed or any relief at all. Original point 3 is interesting: 3. As held by the Upper Tax Tribunal in Vehicle Control Services Limited v HMRC [2012] UKUT 129 (TCC), any contract requires offer and acceptance. The Claimant was simply contracted by the landowner to provide car-park management services and is not capable of entering into a contract with the Defendant on its own account, as the car park is owned by and the terms of entry set by the landowner. Accordingly, it is denied that the Claimant has authority to bring this claim. But from what I've seen they are licensed to pursue people with PCNs. So assume it's a null point. Also, on my point 3, should I mention that I contend that I did purchase and display a valid ticket, it was the fault of a broken ticket machine (which has since been fixed) that allowed me to purchase a ticket without entering my registration details. This machine also did not have any of their 'contract details' displayed on it. Thus meaning I had no information on said contract at point of purchase, extending to point 2. Thanks all!
  7. CPR Sent yesterday, Should I get on writing up defence? Is it best to writ up briefly, focusing on main points of defence, and should I leave factors such as no 'car park rules shown on point of purchase' out for the time being? Cheers
  8. AOS is sorted, Just working through the CPR form letter now. Besides the 3 doc types the template is there anything else worth adding to this request? Realise the CCTV is likely a lost cause, but Is this the place to request it anyway?
  9. Well speaking with Morrisons last year, they essentially said all CCTV and transaction data is only kept for a month. On finding out that the PPC owned the CCTV, I thought it would be a good point if going to court that they will obviously have footage of me purchasing a ticket then displaying it in my car. My worry is that they have deleted their footage, but I could also use this as a point, if you were attempting to prove someone didn't purchase a ticket surely they should have retained that footage to show wrongdoing. At the moment I need to know if I should write to the carpark, requesting the footage of the day, under ICO guidelines. It's just going to a problem if they revert to a 'we only hold our CCTV footage on file for 1 month' response. Thanks
  10. ANPR Camera on the way in/out, Then 2 or 3 CCTV cameras in the car park, checked with the Morrisons who do not have access to the footage. All cameras owned and operated by the carpark.
  11. Thanks very much indeed dx100uk. Some great information in there, will have a thorough read, but definitely the information I need right now! I'm keen to request the car parks CCTV footage of the day, should I hold off until it's confirmed we're going to court, or is now the right time to request it? Name of the Claimant : Civil Enforcement Limited Claimants Solicitors: S Wilson, Head of Legal Date of issue 26 July 2021 (Received 30th July) Date for AOS - 13th August Will get this sent out on Monday (2nd August) Date to submit Defence - 27th August What is the claim for – Claim for money relating to a Parking Charge for breach of contract terms/conditions(TCs) for parking in private car park (CP) managed by Claimant. Drivers may only park pursuant to TCs of use displayed in CP and agreed upon entry/parking. ANPR cameras or manual patrols monitor vehicles entering/exiting the CP and TC breaches. Charges of GBP182.00 claimed. Violation date: 02/07/2020 Payment due date: 31/07/2020 Time in: 12:20 Time out: 12:49 PCN: Vehicle reg mark: Car park:-Butterfly Walk What is the value of the claim? Amount Claimed £197.40 court fees £35 legal rep fees £50 Total Amount £282.40 Thanks for your help through this everyone!
  12. Right last version before I throw it in the Post. Dear Civil Enforcement Limited (CEL) I write in response to your Letter Before Action - Claim for Debt , which I have received in relation to PCN Number: xxx I am writing to notify you that I have no intention of paying these ridiculous invented penaltys, for allegedly breaking an imaginary contract with yourselves. Muddied misplaced signage does not magically create a contract, that after having paid for a ticket, of which you are well aware, allow you to harass and extort me for money. Especially in the current climate, bombarding me with invented penaltys has cast a dark cloud over an already incredibly difficult year. You have also put yourselves in a poor standing moving forward, aside harrassing me with threats of bailiffs being sent to my house without due process, but illegally adding a £82 administration fee, presumably as some sort of unicorn food tax. I suggest that you look at DDJ Harvey’s judgement at Lewes County Court on 05/02/2020 (Claim number F0HM9E9Z). He was not very happy with these made-up amounts. You can either drop this foolishness now or I will instruct legal council, compile my case against your dispicible company, and look forward to walking over you in court. I hope we can call this matter over with, and that to that end I will never have to suffer another one of your pointless letters again.
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