I believe their whole plan is that people will not want the hassle of a court claim or fall foul of a default CCJ for missing a deadline. They never plan on going through with the court case. I read somewhere that they have a 90% success rate with this tactic. This site was amazing for their help.

Well good news arrived in the post today... they chickened out of continuing their claim against me. I didn't think they had much of a leg to stand on, especially after reading the posts on here. I've attached the notice. I'll pop a small donation to your site, thank you for everyones help and encouragement. NoticeofDiscontinuance.pdf

Thanks FTMDave (and others). This is really helping draft a knock-out WS. I'll work on it over the next few days and look to post something for your review/critique probably later next week, assuming the they still want to proceed with this nonsense.

I've noted from the MCOL transactions screen that DQ's have been filed by both sides and that the claim has now been transferred to my local court as of the 18th of March. I await to receive a letter from the court detailing next steps, but in the meantime have been reading up on WS formats for defendants, and will post a draft for review soon. I noted this one was quite well written: https://www.consumeractiongroup.co.uk/topic/406892-highview-parking-anpr-pcn-claimform-urban-exchange-manchester-claim-dismissed/page/3/#comments but do any of the caggers here know of other ones to look at? Any help where to look would be appreciated as I find the search function quite hard to use.

Well done wisnniawy! Glad it's over for you. As we both received the claims around the same time, I'm hoping they will also see the error in their ways and drop my case too!

I have noted on MCOL that a DQ has been sent to me on the 01/02/2024, but nothing has been received through the post. I have tried ringing them, but after 30 minutes on hold gave up. Now emailed, but the auto response has said it may take 10-20 days to reply. Question for the knowledgeable. Are delays in receiving the DQ to be expected, even though the MCOL system states it's been sent? Worried about the time frames to return the DQ, what are these normally, wouldn't want to become foul of a default judgement? Should I download the online form from the Gov website and complete and return via email without receiving official form via post? I've tried looking on this site, and the wider internet but apart from mentions of delays and backlogs, could not see anything about DQ's not received.

Letter attached. CSTLaw-17Jan24.pdf

Had a follow up letter from CST Law relating to my CPR31-14 request, regarding the planning permission of signage: "Our client have advised that it is not their responsibility to obtain any relevant planning permission for the signage. It is the responsibility of the site owner to obtain advertising permission to put the signs up. You will therefore need to contact the landlord for this information/evidence. We recommend that you seek independent legal advice if you have any queries heron."

Yes, I did the same, as email and telephone were optional.

I left it blank on mine as didn't want Met Parking or their sols ringing or emailing me.

I have emailed both Euro Garages and the MP for Stansted (Kemi Badendoch). I've received a response from the MP which is word-for-word the same as the response received by HONDA Z50 (October 2023) - see wording: (https://www.consumeractiongroup.co.uk/topic/462450-met-anpr-pcn-occupants-left-southgate-premises-appeal-refused-starbucksmcdonalds-southgate-park-stansted-airport-cm24-1py-cancelled-by-euro-garages/?do=findComment&comment=5230662) - post #44. Oh well, at least it's another complaint about MET Parking Services registered with the MP's office if nothing else. I have also filed my MCOL defence submission today (per the template in an earlier post). Now it's time to wait... but in the meantime I'm enjoying reading all the forum posts from other motorists who've also had issues with MET Parking Services and this car park in particular, and the great advice given, it's helping build my case. I'll report back if there's any progress on my story.

does the POFA line of defence only cover NTKs issued after the 14 day period? Why is this 14 day period relevant? I appreciate this is only one line of defence in my case, but just want to understand the basis here, and will possibly help others reading.

I'm a bit confused what the legality of this is. I've read around the internet that NTK should be issued within 14 days for ANPR when no ticket has been stuck to the windscreen, and if later the keeper can not be held liable. How does this work in law? Can a claim be thrown out of court simply because the claimant failed to issue a NTK within 14 days, and they do not know the identity of the driver to prosecute? Could a court demand that you identify the drivers details in order for the claim to be correctly addressed to the driver, or to confirm that you were not the driver in question? Plan for this week is to complete the MCOL defence before the deadline, write to EURO Garages as suggested. Will also be penning a letter to my MP to highlight the issues this car park is having on motorists.

I received a response from CST Law on behalf of my CPR31-14 request (I didn't think they'd bother). It consists of: 1) All letters sent to myself (NTK, Debt Recovery Plus Letters, Letter Before Claim) 2) Parking enforcement contract with landowner 3) Photographic evidence of the parking contravention 4) Relevant signage I have uploaded these documents for reference. I have not uploaded copies of previous debt chasing letters or the NTK and Letter Before Claim as these have been previously uploaded. In summary, I note the following: 1) Notice to Registered Keeper was dated 25 days after parking contravention (is this too late for a claim to be made against the keeper?) 2) Vehicle entered at 10:41am and left at 11.09am (a total duration of 27 minutes 3) Photographic evidence of occupants heading towards McDonalds 4) Photographic evidence of occupant heading to Starbucks. 5) Two signs behind vehicle parking location: a) Sign 1 indicates 60 Minutes Free Max Stay, and then in smaller print indicating that the parking is for South Gate Park -Stansted Customers Only, Park within lines, Disabled Badge Areas, and Hatched Areas. b) Sign 2 (placed below Sign 1) refers to Pay By Phone for stay greater than 60 minutes, and within the small print of this sign they have written "McDonald's is not in Southgate Park" The issues I have with the ludicrous court claim by Starbucks/Met Parking Services/CST Law 1) Vehicle parked for only 27 minutes 2) Occupants used the facilities within the service area. 3) It is not clear from the prominent sign that Southgate Park does not include the whole services area, you would only read sign 2 if you had the intention of "paying by phone" for a longer stay and therefore they have not made it clear that McDonald's is not in Southgate Park. Signage indicating that the car parking spaces are for "STARBUCKS CUSTOMERS ONLY - WE WILL PROSECUTE YOU IF YOU GO TO MCDONALDS" in large font would make it less confusing to people. 4) You enter the service area via McDonalds, if there really are two different service areas, why is there not a separate access point to the Starbucks carpark. Or an automatic barrier control for access to and from the Starbucks car park making it clear you are entering a separate area. 5) Why is pedestrian access not restricted between Starbucks and McDonalds (a gate/fence with restrictions on would be clearer) 6) Why is there a zebra crossing leading from Starbucks out of the area and a paved footpath to McDonalds? This is an encouragement for visitors to Starbucks to also visit McDonalds? Surely, this is all common sense and it is nonsense to pursue a claim for parking contraventions. But if they want to go ahead with their court claim it won't worry me, as win or lose they will be the ones highlighting the nonsense of their regulations to the court and press, and just maybe something will be done to change their behaviour to save others falling foul CPR Response.pdf

Hi everyone, I know I have until the 8th of January to submit my defence on MCOL but as Christmas and New Year is fast approaching just wanted to get my ducks in a row and any helpful advice/comments on my defence while you guys are still around. I've had a look through the forums and understand that a generic defence at this stage needs to be submitted. I am assuming the following wording is ok, but any comments or advice much appreciated, as this is not my area of expertise and have never dealt with a court claim before. 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 [XXXX XXX]. 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. 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. It is denied that the Defendant breached any terms and conditions set on private land. 5. It is denied that the Defendant entered into a contract with the Claimant, or broke any such contract. 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.