VCS PCN Claimform - no stopping - spycar CCTV - Liverpool Airport "offence"

[dx100uk]

did you select the start AOS section not the defence section?

but if you didn't you are the defendant, as it says on the claimform!

 

 

[dx100uk]

No follow my sticky

you are the defendant

 

no one else has ever had this issue.

 

Dx

 

[dx100uk]

you are yes....

 

look at the claimform who's name is stated as the defendant.........

[dx100uk]

Post hidden

what does it say at the very top of our template i posted in red??

 

also you do mean you completed the online aos

 

Dx

[dx100uk]

you don't

you just send it as is.

 

other than entering yours and their details there is no other adaption necessary....

 

you not written it at all ...simply entered what is necessary to/from.

 

we know what it says...

 

dx

 

[dx100uk]

dont even need to use registered post waste of money ....really they won't reply.

simply get free proof of posting from any PO counter 1st class stamp will do.

 

i believe as with the 'dont reproduce on the open forum' all the red is standard wording on all our temples, some need things changing others don't im not our publisher...this one doesn't.

 

ok you got the 2 basic bits done

you now need to get reading up a few 10's of no stopping claimform threads here. what the process is as the claim progresses, what to do when you get to that stage. but id always advise, and we dont mind, check with us before you ever do anything going forward.

 

simple simon is a  slippery customer, and although we win 99% of no stopping claims, innocent slip-ups or mistakes will be exploited by him to the extreme so be careful.

 

dx

 

 

 

 

 

[dx100uk]

On 08/11/2021 at 20:17, dx100uk said:

pop up on the MCOL website detailed on the claimform

.

register as an individual on the Gov't Gateway Site
Go to HMRC's login page.

Click the GREEN sign in button.
Click “Create sign in details”
Enter your email address where asked.
You will now be emailed a confirmation code. ...

You will now be issued with a User ID for your government gateway account.
 note down your details inc the long gateway number given, you might need it later.
 

then log in to the MCOL Website

.

select respond to a claim and select the start AOS box.

.

then using the details required from the claimform

.

defend all

leave jurisdiction unticked.

click thru to the end

confirm and exit MCOL.

.

get a CPR 31:14 request running to the solicitors

https://www.consumeractiongroup.co.uk/forum/showthread.php?486334-CPR-31.14-Request-to-use-on-receipt-of-a-PPC-(-Private-Land-Parking-Court-Claim

type your name ONLY

no need to sign anything

.

you DO NOT await the return of paperwork.

you MUST file a defence regardless by day 33 from the date on the claimform.

………….
 

you must always read things carefully....^^^^

 

god NO!!

you do not wait!!

 

[dx100uk]

Use our enhanced google search box

 

vcs no stopping

 

our generic 3-5 line defence is in most

 

you do not file it yet!!

 

post it up here for checking

 

it would help if yo u read the full threads too, they will teach you so much...

[dx100uk]

Line 3 claimant and defendant need swapping??

[dx100uk]

READ THE OTHER THREADS ALL WILL BE ANSWERED.

[dx100uk]

As long as you did AOS as i advised earlier, you have a total of 33 days whereby date on claimform is ONE in the count.

 

this was explained carefully in the Q&A you filled in in the 1st place and in my AOS/cpr post.

 

Dx

[dx100uk]

On 08/11/2021 at 19:22, Hobnail said:

Name of the Claimant : VCS

 

Claimants Solicitors: ELMS LEGAL

 

Date of issue – 4 NOV 2021

 

Date for AOS – 22 NOV 2021

 

Date to submit Defence – 6 DEC 2021

 

What is the claim for –

 

1. A breach of contract for breaching the terms and conditions set on private land.

 

2.Defendants vehicle was identified in Liverpool John Lennon Airport on 30/08/2019 in breach of the advertised terms and conditions; namely Stopping in a zone where stopping is prohibited .

 

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

 

4.The terms and conditions upon entering private lane 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 hereby entering into a contract by conduct.

 

5.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.

 

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

 

What is the value of the claim?

 

Amount Claimed £160

court fees £35

legal rep fees £50

Total Amount  £245

 

[dx100uk]

nope use our std 3 -5 line defence in every no stopping thread already here.

 

dx

 

30 minutes ago, Hobnail said:

Found this.................

 

1.  It is admitted that Defendant is the recorded keeper of [motor vehicle].

 

2.   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 only contracted 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.  The proper claimant is the landowner

 

3.  It is denied that the Defendant breached any terms and conditions set on private land.

 

4.  It is denied that the Defendant entered into a contract with the Claimant, or broke any such contract.

 

5.  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.

thats the one!!

 

whatever made you think the other was correct. not searching outside of CAG are we...

[dx100uk]

I think poss the 2nd might have been from a very old thread, things have moved on

 

but please let the experts check and advise....youve a few days yet

 

dx

[dx100uk]

Always best scan up anything they send to one mass pdf.

you never know wholl spot what

[dx100uk]

no you never counterclaim no. you've not seen that mentioned here either.

 

please try and remember to use pdfmerge website , ive merged single pages for you above again.

 

34 minutes ago, Hobnail said:

What about any additional details on the MCOL form.

 

They have partners name, address and d.o.b only.

 

cheers

not sure what you mean?

 

dx

 

[dx100uk]

NO!!

the only people you dont give those too are the fleecers.

[dx100uk]

Give full details to mcol

[dx100uk]

not for a good few weeks/months if at all.

 

however the court will write upon whats next and should ACK your defence filing.

 

no harm in you reading as many no stopping 

threads as you can HERE.

 

then you'll know what MIGHT be to come and how to deal IF it does progress through the various stages of the claim.

however as always, dont ever do anything toward anyone without check here 1st 

[dx100uk]

No you state your local court

 

and yes to a hearing...you dont want a papers only decision.

 

3 copies

1 to the court

1 to there are using one (omit phone/sig/email

1 for you file

[dx100uk]

file ...urm. no spelling check.

 

sols urm.. must have had internet issues whilst typing... with 2 errors me thinks.

 

choose her most local county court or the one easiest to attend IF it ever goes there, for her.

 

use this PDF much tidier

 

 

[dx100uk]

Cant see why not its free

[dx100uk]

thats his new mate he has conned onboard at Simple Simon towers, won't be around long like the others i bet.

there is no litigation dept, just another desk nearer the bog, with a bloke at it in a different coloured skirt.

he'll soon learn he is onto loser and even get his collar felt by this cilex regulator too and run away.

 

ftmdave quite nicely explain what this means in sev threads with regard to who's in court IF it ever goes that far. bottom line is it should mean an easy win for you with the right WS as a locum knows nothing about the cases they represent.

[dx100uk]

What have you seen others advised?

And what do you think you can do.?

 

NOT being funny, but this thread is now 167 posts in length, a good portion of which mostly relates to us nurse maiding you at every stage.

 

And we are only at dq the n180 stage.

 

Your 1st post within a few lines says ive read lots of threads......

 

Please for her and your sake get your act together...research..focus.know whats to come and how to deal..

 

We have no issue's with, and you should, always check here before doing anything... But.......try and conclude each stage first to the best of your ability first..

 

Dx

[dx100uk]

nope, i will use any tool in my book to make sure you get things right.

we give vague answers because it's oneway to make people research and investigate by searching here on CAG .

 

i've lost count of the times here various CAG members have also asked you to research and read up.

 

its not done to annoy, it's not done to belittle, it's done because simon is a very very slippery customer and WILL exploit the slightest error.

 

you are now fast approaching the most important stage - witness statement exchange and unless that's done in a way that naisl him SHUT, she will have a very difficult time understanding and explaining everything infront of and to a judge. You can't be there, only she can and if you don't 1000% understand what is being put and done, how are you going to pass that understanding on?

 

me and other members can help you all we can and will to the dying end, but if it doesn't sink in...i dread to think of her chances....

 

dx