Thank you all, this is incredibly helpful!

thanks @dx100uk I was advised i'll be able to flesh out my points in the witness statement. Is that correct? I hope i'll have the opportunity to at least challenge their defence.

Hi there, BW legal have responded to my CPR 31.14 request! - Please see attached, which includes "all PCN evidence" They have since sent me a letter advising the will proceed to court, feel things will not go in my favour and have given me one more opportunity to pay I wanted to start preparing for this. I've noticed a few inconsistencies in the evidence they've sent through. The NTK - 1719 325 Greenford Rd but the camera's showing the vehicle state 327 A Greenford Rd Along with the difference in time on the NTK versus the original PCN (15:45 vs. 03:45) and again ("illegally parked" vs. unauthorised parking) I wondered If anyone can spot anything else that might be useful in my defence as the registered keeper? Thanks, Bunny BW legal evidence 2-compressed.pdf I also remember this post from @Nicky Boy who spotted this a while ago! Is there anything I could/should get from the local council records to highlight that 325 doesn't exist?

Thanks guys, defence submitted.

Ok brilliant thank you. So I can file defence as is today?

Hi Everyone, The deadline for filing is this Friday! How early is early in terms of filing? I don't want to miss it! Is it fine to file today? As advised I'm sticking to the 6 bullet points below. Can I check that there will definitely be the opportunity for me to expand on these points before a hearing? Will UKPP at some point have to turn over any evidence they plan to use and will I have the opportunity to respond? I've tried to read as much as I can about the 'legality' of the additional recovery fees being charged. I've decided to keep point 5 in as I can’t see anything that legally prescribes that they are allowed to add recovery costs at this stage. As the claimant has pointed out the £60 fee has been added based on their own ATA AOS (IPC) code of conduct and ‘the terms and conditions’ of presumably the contract that I did not enter into! defence 1. The Defendant is the recorded keeper of [vehicle registration] 2. It is denied that the Defendant entered into a contract with the Claimant. 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. 4. In any case it is denied that the Defendant broke the terms of a contract with the Claimant. 5. The Claimant is attempting double recovery by adding an additional sum not included in the original offer. 6. 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. Lastly I just wanted to clarify if my understanding of the following is correct (this won't be included in my defence - I'm just trying to think a few steps ahead): I believe that unless the claimant can produce a contract demonstrating that they have the authority to form a contract with the public on the landowner’s behalf, they cannot legally bring a claim against me. I have proof that a request for a copy of any contract between UKPP and the landowner was posted on the 27th June 2023 but has been ignored. Should I mention for the purpose of the court that my CPR 31.14 request has not been responded to? I also note that in order for any contract to be deemed legal, the signage would have to meet certain requirements. I have taken photos of the signage (previously shared) which is appears inadequate, mainly in terms of positioning, ambiguity. I have recently been to the location to purchase something from BJ plumbing ‘the landowners.’ I was told verbally by the person who issues the tickets behind the counter that it’s fine for customers to park there and “they won’t get a ticket” if he knows they are in the shop. However the signage says that parking is for “parking is restricted to vehicles displaying a valid parking patrol permit only”. As no permits seem to exist and the stated terms and conditions are not consistently enforced, is there anything I could or should do to highlight this in advance of a court hearing? Note the landowner is still not co-operating. I have been told multiple times he is away and unable to deal with any requests relating to parking disputes? Apologies for the long one today! Just trying to make sure I don't give these fleecers any opportunity to win! Thanks in advance

thank you for clarifying @dx100uk

Here is a copy of the POC Claim form _redacted .pdf

Hi all, apologies for the delay in responding. Thanks for your replies. Please see the exact figures below. The instructions on the claim form thread shared above advised numbers to be rounded up/down. Amount Claimed - £166.90 court fees - £35 legal rep fees - £50 Total Amount - £ 251.90 I have sent the CPR 31.14 request. The deadline to submit my defence is 4pm on July 21st, I plan to do this well in advance by the end of this week. My understanding is that this should not be done online but instead by post on the form received? @FTMDave the parking ticket was for £100 but would have been £60 if paid within the discount period. It seems a little excessive to me but would this still count as double recovery?

Thanks again for all of your help, I've now completed the AoS via the MCOL website. I'm putting together the CPR 31:14 request Based on the template linked above i'm requesting the following which I believe are all applicable in my case - 1. The contract between UK Parking Patrol 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 UK Parking Patrol Office LTD and BW Legal to the defendant which they intend to rely upon in court. Is it worth including a fourth point? " Copies of any other documents that the claimant will rely on in court as evidence" I just noted that CPR 31.6 mentions that this forms part of disclosure

Planning to complete the AoS with following generic points: 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. 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. 4. In any case it is denied that the Defendant broke the terms of a contract with the Claimant. 5. The Claimant is attempting double recovery by adding an additional sum not included in the original offer. i presume this is applicable as they are charging £50 legal representative fees ? 6. 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.

Thank you @dx100uk Northampton - COUNTY COURT BUSINESS CENTRE Name of the Claimant : UK PARKING PATROL OFFICE LTD, 7 CHRISTIE WAY, CHRISTIE FIELDS, MANCHESTER Claimants Solicitors: BW LEGAL, ENTERPRISE HOUSE, 1 APEX VIEW, LEEDS, LS11 9BH Date of issue – 19TH JUNE 2023 Date for AOS - 8TH JULY 2023 Date to submit Defence - JULY 21ST (4PM) What is the claim for - 1. The claim is for the sum of £107 being due from the defendant in respect of a penalty charge notice (PCN) for a contractual breach which occurred on 7th July 2022 in the private car park/land at 325 Greenford road, Greenford in relation to a [car make model + registration]. 2. The PCN was issued as the driver failed to comply with the terms and conditions as displayed. 3. Despite demands the charge remains unpaid, The claimant also includes statutory interest pursuant to section 69 of the county courts act 1984 at a rate of 8% per annum (a daily interest rate of £0.02) from [date of alleged contravention - date claim submitted to court - 3 days]. The claimant also claims £60.00 recovery costs as set out in the terms and conditions of the ATA AoS code of practice. What is the value of the claim? Amount Claimed - £167 court fees - £35 legal rep fees - £50 Total Amount - £ 252 Have you moved since the issuance of the PCN? N Did you receive a letter of Claim With A reply Pack wanting I&E etc about 1mth before the claimform? Y - April 6th 2023

Hello! I'd appreciate some advice please. I've received the dreaded county court claim form. I intend to fight it - I know I don't have a huge amount of time but would appreciate some advice from the experienced caggers. I plan to use the following previous advice to help formulate my argument, as well as some of the points about signage/confusion over the address. Interestingly, I also when back to the area recently and parked. I went into the plumbing shop and said, "i'm here to purchase a shower head is it fine to park?" and he said "yes, don't worry i'm the person who issues the tickets, as long as you let me know it's fine" Their address is registered as 331-333 Greenford Rd. Extremely confusing! As was pointed out previously from photos it looks as though 325 Greenford road doesn't even exist. Lastly, will I see UKPP's evidence before my day in court? If they have photos of the vehicle parked (which would be at the wrong time), would I see this before hand? Thanks in advance for your help.

Thank you @FTMDave - sending this off today!

@dx100uk Really helpful, thank you