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holmer444

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About holmer444

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  1. Thanks all as always. Defence was filed on Tuesday and this morning I received a Notice of Proposed Allocation to the Small Claims Track, presume I complete this and select 'No' to mediation?
  2. Thanks both, how about: [1. It is admitted that Defendant is the recorded keeper of [motor vehicle]. 2. It is denied that the Defendant parked continuously in St Mary's Gate Retail Park Car Park at the times mentioned in the Particulars. The Claimant is put to strict proof of the same. 3. It is denied that the Claimant has complied with Schedule 4, Protection of Freedoms Act 2012, as the notice to keeper was issued by post, paragraph 9, sub-paragraph (5) allows the claimant 14 days to deliver to that address. The issue date on the notice to keeper was 9 Janu
  3. Apologies for the silence, unfortunately I have one of those jobs that is busier in the current climate. I've done a fair bit of reading and have constructed the following which I was proposing to submit as my defence: [1. It is admitted that Defendant is the recorded keeper of [motor vehicle]. 2. It is denied that the Defendant parked continuously in St Mary's Gate Retail Park Car Park at the times mentioned in the Particulars. The Claimant is put to strict proof of the same. 3. It is denied that the Claimant has complied with Schedule 4, Protection of Free
  4. Thanks all, please see details below: Name of the Claimant : Vehicle Control Services Limited Claimants Solicitors: Cannot see one stated Date of issue – 26 OCT 2020 Date for AOS - 13 November 2020 Date to submit Defence - 27 November 2020 What is the claim for – The Claim is for a breach of contract for breaching the terms and conditions set on private land. The Defendant's vehicle, [registration no], was identified in the St Mary's Gate Retail Car Park on the 24/12/2019 in breach of the advertised terms and conditions; n
  5. Many thanks Andyorch for re-opening the topic and apologies all for reawakening this, but somewhat disappointingly I received a county court claim form this weekend, I was panicking a little until I saw the next letter was one from VCS reminding me I could still pay them and make it all go away....so naturally I'm going to defend. The issue date on the Claim form is 26 October, if I've read the pack (and the various helpful threads on here right), I have 14 days to acknowledge receipt of the form and 28 days to send my defence, which I reckon to be acknowledge no later than Monday
  6. Sorry just one more thing, simple Simon is Simon Renshaw-Smith? Just making sure I get the envelope right...
  7. Thanks all, really appreciate the input, have made some tweaks and planning to go with the version below... Dear Simple Simon, I am in receipt of your ‘ Letter before Claim’ but fail to see what the cause for action by VCS is against me as the vehicle in question simply wasn’t parked on the site when you claim it was, you’re clearly ‘double dipping’ . In addition, your ‘Notice to Keeper’ was dated 9 January, which was 16 days after the date you allege a contravention took place and as I’m sure you know is outside the statutory 14 days allowed. I
  8. I have screenshots of the Google maps data from my phone which shows that I was in town from 11.16 to 11.47 then drove home, then drove back to town, arriving at 14.33 and leaving for the second time at 15.01, driving home again. So either I was in my car and it wasn't in the car park when they say it was or I was in another car and not driving my car, hence they can only pursue me under keeper liability, which they can't do as their original PCN is more than 14 days after the date they allege the 'contravention'.
  9. I'm thinking of going with the below, any thoughts or comments are more than welcome. Dear Jackass Jake, I am in receipt of your ‘Letter before Claim’ but fail to see what the cause for action by VCS is against me as the vehicle in question simply wasn’t parked on the site when you claim it was. You’re clearly ‘double dipping’ given that any parking on site would have been carried out in line with your pretend ‘rules’. In addition, your ‘Notice to Keeper’ was dated 9 January, which was 16 days after the date you allege a contravention took place and as I’m s
  10. Hi all, I've received what puports to be a 'Letter before claim' which I've attached (apologies for the delay in getting this on here), having read through some of the other threads I believe that as it's come from VCS and not from one of their 'legal partners' it can be added to the 'ignore' pile, but just wanted to check ? Thanks in advance (and hope you're all staying safe!) Letter before claim.pdf
  11. Thank you for taking the time to time to reply. I did wonder if there would be any mileage in making a subject access request to the data controller in the hopes that would mean them sending me pictures of my car leaving the car park earlier that day, but not sure if the SAR would require they send me copies of all the pictures they had of my car?!
  12. For PCN's received through the post [ANPR camera capture] please answer the following questions. 1 Date of the infringement - 24.12.19 2 Date on the NTK [this must have been received within 14 days from the 'offence' date] - 09.01.20 3 Date received - 13.01.20 4 Does the NTK mention schedule 4 of The Protections of Freedoms Act 2012? [Y/N?] N 5 Is there any photographic evidence of the event? Y 6 Have you appealed? [Y/N?] N Have you had a response? [Y/N?] N 7 Who is the parking company? VCS (Ve
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