Thank you FTMDave, really appreciate your help!

Thank you FTMDave. I've made the suggested changes and will see if there is any other feedback before posting a final copy. I would be grateful if you could attached the Beavis judgment as I can't seem to find it. Do I also need to attach copies of the other judgments referenced in the WS? And is there an easy way to find them? Many thank in advance!

Apologies dx100uk, I'm posting the PDF version of my revised WS below for perusal by the experts. Hoping to post it on Monday. Thanks in advance for any further advice/guidance! WS Combined excl Ex2 .pdf

Apologies, not sure what happened there....trying again Defendant WS.pdf

Thank you everyone for your help so far. I have compiled the attached WS, any feedback/advise would be much appreciated. Many thanks in advance Defendant WS.pdf

Thanks for the guidance FTMDave, I'll start working on the Witness Statement. I have also received an email for a mediation appointment on 25/04/2024.. I can't remember requesting this and not sure where to check either. Do I reply and say that mediation IS NOT SUITABLE in my case? Many thanks

Thanks for reopening the thread HB. My case has been allocated to Hertford Magistrates court for 16 May 2024. The claimant (UKPC) has to pay the court fee by 18 April. I have to provide copies of all documents to the court and other parties no later than 14 days before the hearing. Could someone please point me in the right direction on where to find guidance for the next step? I understand I have to compile a witness statement also. Any help and guidance at this stage would be much appreciated. Many thanks in advance! Notice of Allocation.pdf

Hi dx100uk, I used the MCOL website to file the defence. The form I uploaded is a printout after it was filed. Attached is the status of the claim from the MCOL website - says DQ sent out to me...(does not mention claimant) MCOL - MoneyClaim Online - Status Summary - details removed.pdf

Hello all, Thanks for all your assistance to date. Unfortunately I had already filed the standard defence as per Nicky Boy's 1st reply, so did not include the subsequent comments from FTM Dave, Nicky Boy and brassnecked in my defence. Please see attached for the defence filed. I have also received the following in the post: 1) Small Claims Track from the Court - I've completed this and send copies to the court and UKPA with certificate of postage. Said No to mediation and determination without a hearing. Can scan and upload a copy if needed. 2) CPR 31:14 Reply from UKPA - Copy attached in 2 parts due to size. Note that they did not send details of planning permission for signage as requested. They also didn't send a copy of the Landowner contract, only a witness statement. 3) Reply to Defence and Small Claims Track from UKPA - Copies attached Is there anything else I need to do at this stage? The Defendant contends that the particulars of claim are vague and generic in nature which fails to comply with CPR 16.4. The Defendant accordingly sets out its case below and relies on CPR r16.5 (3) in relation to any particular allegation to which a specific response has not been made. 1. The Defendant is the recorded keeper of the registration . The Claimant is not in a position to state if the Defendant was the driver at the time. 2. It is denied that the Defendant entered into a contract with the Claimant as stated in paragraphs 1 , 4 and 5 by 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 Defence Particulars 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. The Claimant is also adding fictitious "Legal Representative" fees when not using a legal representative. 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. Reply to Defence and Small Claims Track.pdf Reply to CPR request.pdf

Thanks Nicky Boy - so just stick to points 1 - 6 above?

I have also added the following: Therefore the Claimant is put to strict proof to evidence its cause of action and contractual costs and what loss it has suffered. The Claimant is further put to strict proof that it has sufficient proprietary interest in the land, or that it has the necessary authorisation from the landowner to issue parking charge notices, and to pursue payment by means of litigation. The Particulars of Claim is denied in its entirety. It is denied that the Claimant is entitled to the recovery or any recovery at all.

I have added another line to my defence below: 7 Not withstanding the above on 29 August 2023 I made a request pursuant to CPR 31.14 for the claimant to disclose its necessary evidence in support if its claim. To this date the claimant has failed to respond to said request.

Hello all, I have prepared the following defence, would appreciate some feedback before filing it. Many thanks in advance! ................................................................................................................................................................................................................................................................... The Defendant contends that the particulars of claim are vague and generic in nature which fails to comply with CPR 16.4. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 1. The Defendant is the recorded keeper of the xxxxxxxxxxxx registration xxxxxxx. The Claimant is not in a position to state if the Defendant was the driver at the time. 2. It is denied that the Defendant entered into a contract with the Claimant as stated in paragraphs 1, 4 and 5 by 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. The Claimant is also adding fictitious “Legal Representative” fees when not using a legal representative. 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 and brassnecked for your replies. I have submitted the AOS on the Moneyclaim website today and will post the CPR 31:14 letter to UKPC Ltd tomorrow (no solicitors mentioned anywhere, only a legal representative, ANGELIKA BRZOZOWSKA, so do I address the letter to her at the UKPC LTD address?). At no point have I admitted to being the driver. Do I need to do anything else at this stage? Thanks in advance!

Hello all, I have now received the Letter of Claim, see attached. Also see my answers to the questions below. Appreciated any comments and guidance on next steps. Understand I have to Acknowledge Service, will do that in the next day or 2 on the back of any guidance received. Which Court have you received the claim from ? MCOL Northampton N1 If possible please scan redact and upload a full page copy of page 1 of the claim form. (not the response page or AOS) - DONE Name of the Claimant : UK PARKING CONTROL LTD, UNION HOUSE, 111 NEW UNION STREET, COVENTRY, CV1 2NT Claimants Solicitors: NONE STATED, ONLY LEGAL REPRESENTATIVE - ANGELIKA BRZOZOWSKA Date of issue – 14 AUGUST 2023 Date for AOS - NOT YET DONE, UNDERSTAND IT IS 19 DAYS FROM DATE OF ISSUE, THEREFORE BY 4PM ON 1 SEPTEMBER 2023 Date to submit Defence - UNDERSTAND THIS TO BE BY 4PM ON 15 SEPTEMBER [NOTE : WHEN CALCULATING YOUR TIMELINE - PLEASE REMEMBER THAT THE DATE ON THE CLAIMFORM IS ONE IN ANY COUNT [an example: Issue date 01.03.2020: + 19 days = 19.03.2020 :+ 14 days to submit defence = 02.04.2020: a total of 33 days] What is the claim for – SEE ATTACHED LETTER OF CLAIM 1. The Defendant (D) is indebted to the Claimant (C) for a Parking Charge (PCN) issued to the vehicle xxxxxx at Rom Valley Retail Park, Rom Valley Road, Romford, Essex, RM7 0AF. 2. The PCN details are 17/03/2023, xxxxxxxxxxxx 3. The PCN was issued on private land, which is managed by C. 4. The vehicle was parked in breach of terms and conditions provided by signage (the contract), resulting in the PCN. 5. The driver agreed to pay within 28 days but did not; D is liable as the keeper. Despite requests, the PCN is outstanding. 6. The C claims £170 being the total of the PCN and damages. 7. C claims costs and court fees. The Claimant claims interest under section 69 of the County Courts Act 1984 at the rate of 8% a year from 17/03/2023 to 11/08/2023 on £170.00 and also interest at the same rate up to the date of judgement or earlier payment at a daily rate of £0.02 **IMPORTANT** WE NEED TO SEE THE FULL POC MINUS YOUR PERS DETAILS>> NOT AN ABRIDGED VERSION**THIS MUST INCLUDE THE LOCATION - ATTACHED What is the value of the claim? Amount Claimed - 170.00 court fees - 35.00 legal rep fees - 50.00 Total Amount - 255.00 Have you moved since the issuance of the PCN? (y/N - if Y state Date too) Did you receive a letter of Claim With A reply Pack wanting I&E etc about 1mth before the claimform? Y/N + date and did you reply? Letter of Claim Redacted.pdf