VCS ANPR PCN PAPLOC Now Claimform - No stopping - JLA Liverpool Airport ***Claim Discontinued***

[maximus81]

Hi,

 

I am in the same position and have received a 'scary letter' from BW legal.

 

It was alleged at l'pool airport, Vehicle Control Services. I have not acknowledged anything they've sent me so far but now it's with their 'legal team' and the price has gone up to £160 with the threat of county court proceedings etc.

 

Do you have any advice on best course of action please?

 

thanks.

[maximus81]

Hi there.

 

I have been issued with a Parking Charge Notice from Vehicle Control Services at John Lennon Airport for allegedly stopping in a no stopping zone.

 

I've read lots about this but have seen some contradictory advice about whether or not to respond to their charges.

 

So far I haven't acknowledged any correspondence from them, most recently a letter from 'BWLegal' stating that they've taken over the debt and that the fine has now gone up to £160 to cover their admin costs.

 

Failure to comply will result in court proceedings, CCJ's legal costs etc. etc.

 

Not sure if they have a case to proceed with against me and I should cut my losses?

 

thanks.

[AndyOrch]

Thread moved to the appropriate forum..please continue to post here to your thread.

 

Regards

 

Andy

[dx100uk]

please complete this:

 

https://www.consumeractiongroup.co.uk/forum/showthread.php?462118-Have-you-received-a-Parking-Ticket

 

 

and its NOT A FINE

 

nowhere do they use that word

 

its a private parking speculative invoice.

 

dx

[maximus81]

thanks - see below:

 

For PNC's received through the post [ANPR camera capture]

 

please answer the following questions.

 

1 Date of the infringement 05/07/2017

 

2 Date on the NTK [this must have been received within 14 days from the 'offence' date] posted: 10/07/2017

 

3 Date received unsure but within 14 days I would say.

 

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?] post up you appeal] n

 

Have you had a response? [Y/N?] post it up

 

7 Who is the parking company? Vehicle Control Services

 

8. Where exactly [carpark name and town] Liverpool, outside John Lennon airport.

 

For either option, does it say which appeals body they operate under. IPC

 

There are two official bodies, the BPA and the IAS. If you are unsure,

please check HERE

 

If you have received any other correspondence, please mention it here

1. Parking Charge Notice - Final Reminder (11/08/17)

2. Balance Passed to Legal Team BWLegal (09/10/17)

 

thanks,

Phil

[dx100uk]

https://www.consumeractiongroup.co.uk/forum/showthread.php?476269-Liverpool-Airport-VCS&highlight=vcs+liverpool

 

see Erics post

[maximus81]

Many Thanks.

 

So it's a 2 liner sent to BW Legal, something along the lines of:

 

"Dear VCS,

 

I reply to your letter sent on .....

there has been no breach of any contractual condition therefore we owe you nothing."

 

Then ignore any more correspondence from them UNTIL (or unless) I get a claim letter from the court...

 

regards,

Phil

[dx100uk]

looks right

[ericsbrother]

airports are covered by byelaws and therefore no POFA so no reason for them to contact keeper.

 

Also no stopping is a false reason to claim,

if you dont stop how are you supposed to read the contract offered to you by their signage?

They always lose any claims on this point and have changed the wording of their signs but that still doesnt change the law

[maximus81]

Hi,

 

thanks for your correspondence on this thread.

 

I have since received 3 letters from BW Legal:

 

A response to my letter stating that by entering the site,

I have accepted the 'terms & conditions' operated by 'Our Client' which were clearly visible and by stopping on the roadway I have breached the terms.

 

A "Final Notice" dated 14th November giving me 17 days to pay before county court proceedings commence against me.

 

A "Letter of Claim" dated 13 December sating the BW Legal have been instructed by VCS to commence legal action in the form of issuing a claim against me in the county court.

(Estimated total cost would be £238.42 with court fees, interest and solicitors costs.)

 

I have not responded to these but I expect my next letter to be from the court, in which case I won't be able to ignore?

 

thanks.

[honeybee13]

Hello there.

 

Yes, if you get a letter from the court you need to come back here for further advice and we'll advise you what to do.. The guys may ask to see the letter of claim, but I'll leave them to ask you if they think it would be helpful. Chances are it's something we've seen before and was harmless. Hang on in there.

 

HB

[dx100uk]

quite correct

you should never ignore a letter of claim.

nor a court claimform

 

its a shame the letter of claim is so old now

you ideally should have replied to it

 

what did you write before please

as that might well have covered it mind

[ericsbrother]

respond using the same words as I suggested to CW182 in their post. To nt be afraid to be rude, they deserve it and will take you for a mug if you try to be reasonable.

[maximus81]

Hi,

 

my letter to them was the 2 liner with no further details contained.

 

Dear VCS,

 

I reply to your letter sent on .....

there has been no breach of any contractual condition therefore 1 owe you nothing.

 

In the letter of claim, the've sent me a reply form giving me 30 days to respond or it 'could' result in court proceedings, but they state they've been instructed to do so.

 

The reply letter is 'tick the box':

 

box a: I agree I owe the debt

box b: I owe some of the debt but not all

box c: I don't know if I owe the debt

box d: I dispute the debt

box e: I will pay what I owe now

box f: I will pay but need time

box g: I intend to get debt advice

box h: I have provided documents

box i: I need more documents or info

 

obviously there is then space to add further detail.

 

I can write my own letter or use theirs to reply?

 

thanks

[dx100uk]

no IGNORE THE PAP stuff

and the response form

 

it does not apply to Private parking Speculative invoice 'claims'

 

see post 12 here

https://www.consumeractiongroup.co.uk/forum/showthread.php?483934-VCS-PCN-bw-legal-letter-of-claim-liverpool-airport&p=5087450&highlight=vcs#post5087450

[maximus81]

Great Thanks.

 

One question before I type up - is there a risk that receiving 2 or more identical letters from different people makes it less credible and so would you reword anything?

 

cheers

[dx100uk]

nope

[ericsbrother]

as said on the other post,

if they got 1000 letters they would then realise the game was up for them.

If 200 of the people sending those identical letters got togehter for a class action they could put VCS out of business ( well, certainly at this site).

 

They make money out of ignorance and the fact that when they tell lies it doesnt impinge on any other claim when they are caught out in a case.

 

If they sued the same person for false reasons 6 times they can be barred from ever suing anyone again but sue 6000 people once for false reasons and nothing can be done

[maximus81]

Hi,

 

I had a thread running previously with yourselves which is now locked due to time expired.

https://www.consumeractiongroup.co.uk/forum/showthread.php?t=482432&goto=newpost

 

A no stopping "Fine" from 2017 ay John Lennon Airport. The last correspondence from myself to them (at the time I think it was DVS?) was the letter you advised me to send below.

 

You did advise that at times there can still be a 2 year gap, and I have now had a letter (dated June 10th, giving me 14 days) for the same charge from "dcbl"  - notice of debt recovery. 

 

I would be very grateful if you could pick up and advise if i should respond, ignore or even pay...

 

thanks,

Phil

 

Dear sirs,

 

Unfortunately for you I wasn’t born yesterday so I wont be paying the demand to your client as both you and they know what I know and that there is no liability in this matter because the land is covered by its own bylaws, the signage is prohibitive and not an offer of a contract so none has been breached, and anyway the POFA limits any charge to the specified sum so your demand for £160 is just a nonsense.

As VCS has been spanked at court on this very same thing several times before I suggest that you tell you client to discontinue this foolishness and that way you will at least obey the SRA rules of conduct and obey civil procedure as well. I know that may well be a first for you but call it your New Year's resolution.

Should they decide to continue then I shall be asking for a full costs recovery order for unreasonable behaviour and the seek damages for breach of the DPA as per VCS vs Philip, Liverpool CC December 2016.

Even Will and John, the parking worlds worst solicitors seem to have got fed up with Simple Simon's stupidity and greed and presumably that is why you are wasting your ink on his behalf.

Regards,
 

[dx100uk]

as long as it not repeat letter of claim 

you are safe to ignore a mere DCA as advised before 

[maximus81]

Hi Gents,

 

can I ask - how do I file a defence?

 

Exactly the same scenario with John Lennon Airport stopping charge. (previous thread running from 2017/18 but i think is now locked.)

 

Have submitted AOS with MCOL, completing the CPR 31.14 Request today,  and my deadline would be 23rd February to file a defence.

 

thanks,

Phil

[FTMDave]

Post moved to your own thread.

 

Simply go on MCOL and follow the instructions for filing a defence.

 

Alternatively a defence can be filed by e-mail or snail mail.

 

It would be a good idea to post up here a draft of your defence first.  In fact it would have been a good idea for you to post after June last year and tell us that things had progressed to a court claim.

[maximus81]

Thanks - no first sign of a court claim was the most recent letter from Northampton dated 21st Jan 2022.

 

Between June and now only letters from ELMS legal which I followed  advice from threads on CAG and responded with snotty letter to Simon

 

I've been told I should demand/request a face to face rather than online defence?

 

regards,

Phil

[dx100uk]

please complete this:

 

 

as for face to face you mean a hearing rather than on the papers only.

 

dont worry about all that

that very much later

and plays no part in your initial bland defence 

 

get reading a good few no stopping threads

100's here.

 

do not file your defence early!! always run the clock

 

dx

 

[maximus81]

POC updated. 

 

I have completed the Q's and attached the claim form in PDF. Hope this is correct.

 

Which Court have you received the claim from?

MCOL, St. Katherines house, Northampton NN1 2LH

 

If possible please scan redact and upload a full page copy of page 1 of the claim form. (not the response page or AOS):

 

Stopping Claim County Court Claim Form 2022.pdf102.02 kB · 3 downloads

 

Name of the Claimant :

Vehicle Control Services Ltd

Sheffield S9 1XU

 

Claimants Solicitors:

ELMS Legal Ltd.

Sleaford NG34 7TQ

 

Date of issue –

21 Jan 2022

 

Date for AOS - 

Submitted online 07 Feb 2022

 

Date to submit Defence -

22 Feb 2022

 

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 **** ***, was identified in the Liverpool John Lennon airport on the 05/07/2017 in breach of the advertised terms and conditions; namely stopping in a zone where stopping is prohibited.

At all material times the defendant was the registered keeper  and/or driver.

The terms and conditions upon entering private land were clearly displayed at the entrance and in prominent locations.

The sign was the offer and the act of entering private land was the acceptance of the offer herby entering into a contract by conduct.

The signs specifically detail the terms and conditions and the consequences of failure to comply, namely a parking charge notice will be issued, and the defendant has failed to settle the outstanding liability.

The claimant seeks the recovery of the parking charge notice, contractual costs and interest. 

 

**IMPORTANT** WE NEED TO SEE THE FULL POC MINUS YOUR PERS DETAILS>> NOT AN ABRIDGED VERSION**THIS MUST INCLUDE THE LOCATION

 

What is the value of the claim?

 

Amount Claimed: £160.00

court fees:  £35.00

legal rep fees £50.00

Total Amount: £245.00

 

Thanks.