ukcps/? PCN claimform - FLEECE YARD KIMGSGATE SHOPPING CENTRE Huddersfield

[Blue jeans]

Perfect

[Blue jeans]

UKCPS Ltd

1200

Century Way

Thorpe Park Business Park

Colton

LS15 8ZA

 

25th May 2017

 

Dear Sir or Madam,

 

Re: UKCPS Ltd v Blue Jeans

 

CPR 31.14 Request

 

On 17th May 2017 I received the claim formicon in this case issued by you out of the UKCPS Ltd county courticon.

 

I confirm having returned my acknowledgement of service to the court in which I indicate my intention to contest all of your claim.

 

Please treat this letter as my request made under CPR 31.14 for the disclosure and the production of a verified and legible copy of [each of the following / the] document(s) mentioned in your Particulars of Claim:

 

1. the contract between UKCPS 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 UKCPS Ltd to the defendant that they intend to rely upon in court.

 

You should ensure compliance with your CPR 31 duties and ensure that the document(s) I have requested are disclosed at your earliest convenience..

 

Your CPR 31 duties extend to making a reasonable and proportionate search for the originals of the documents I have requested, the better for you to be able to verify the document's authenticity and to provide me with a legible copy.

 

Further, where I have requested a copy of a document, the original of which is now in the possession of another person, you will have a right to possession of that document if you have mentioned it in your case. You must take immediate steps to recover and preserve it for the purpose of this case.

 

Where I have mentioned a document and there is in your possession more than one version of that same document owing to a modification, obliteration or other marking or feature, each version will be a separate document and you must provide a copy of each version of it to me. Your obligations extend to making a reasonable and proportionate search for any version(s) to include an obligation to recover and preserve such version(s) which are now in the possession of a third party.

 

In accordance with CPR 31.15© I undertake to be responsible for your reasonable copying costs incurred in complying with this CPR 31.14 request.

 

If you are unable to comply with this request within 14 days and believe that you will never be able to comply with this request please confirm in your response.

 

You are reminded that as this case is yet to be allocated to a track, CPR31:14 does apply, a refusal to comply because you 'think' at this stage you dont have too will be used against you in any filed defence.

 

Yours faithfully

 

Does this sound right?

I have put my address above in the letter

Thanks

[ericsbrother]

that will do nicely.

 

 

They will have seen them before and probably wont give you sight of them before the hearing

but that means they are running the risk of being instructed to hand them over beforehand or even having their claim struck out if when you compain to court later about their failure to follow protocol the judge reads the case files beforehand.

Admittedly a summary strike out is rare but it does happen so always go for it.

 

I also note that they have dropped the use of the worlds greatest solicitors, Gladstones.

 

 

Presumably they have learnt so much from them they believe that it is cheaper to lose by their own incompetence rather than pating someone else to screw up

[Blue jeans]

Perfect I'm going to send it recorded delivery today so I know they definitely receive it.

TBH I've still no idea what I'm doing so I'm just following everyone's great advise and hoping for the best!

Thankyou

[Cutty Sark]

Perhaps an admin should delete your name and case number from your letter?

Then delete this post to clean things up?

[Blue jeans]

Sorry I didn't realise it mattered. Please done delete the post though I'll need more help I'm sure

[Cutty Sark]

Dont worry, I'm just concerned in case the parking company are watching.

When these helpful people ask for details they usually ask for personal details to be hidden.

I'm just assuming they don't want the parking company or their solicitors to be handed free information.

Looking through this thread there maybe two copies of your CPR request letter with your details on

 

Once they've done this could they please delete my comments as not adding any value to the thread.

 

Just had another look and there's only the one 1

[dx100uk]

done

 

 

dx

[dx100uk]

opps done properly

for want of ref we don't need to see what you send re 31:14

[Blue jeans]

Hey everyone Thankyou for your help just to let you know they cancelled my fine and all court costs whoop thanks again x

[dx100uk]

fine?

 

 

dx

[Cutty Sark]

Sounds good!

But do keep all documents and advice safe for at least 6 years.

I got a court case coming up from an alleged parking infringement/claim from 2011.

Just in case they try it on again.

[Blue jeans]

oh no that's not good! I've filled all the paper work away so fingers crossed

[ericsbrother]

well, it keeps them out of trouble with the authorities, who must be taking a real interest in them by now. are yo going to sue them for breaching the DPA and harassment?

Hey everyone Thankyou for your help just to let you know they cancelled my fine and all court costs whoop thanks again x