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VCS PCN Claimform - no stopping Southend Airport

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pop up on the MCOL website detailed on the claimform.
.
 register as an individual
 note the long gateway number given
 then log in
.
 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 [if one is not listed send to the claimant]

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 [1 in the count]

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please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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Good morning I’ve done the steps including MCOL now I need to file a defence. Can a defence be just Weitem with my own words or should it be written by a solicitors ? If by solicitors is it the link from your last post I need to contact ? 
regards 

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Hi.

 

You don't need a lawyer, we'll help you. Your defence will be a few lines and later on you'll do a longer witness statement [WS] to flesh out the detail.

 

Have a look at other VCS airport claim form threads for an idea of what to put and post it up when you think you have what you need so we can refine it if need be.

 

HB

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Illegitimi non carborundum

 

 

 

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please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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So I guess the below is okay?

 

1. No keeper liability as this is not "relevant land" under the POFA 2012 and the defendant puts it to strict proof that VCA show as to who the driver was at the time.

 

2. No contract was ever offered by VCS, the land is subject to its own byelaws and in any case the signage is prohibitive so there can be no monies due as a result of either a contractual charge or as a result of a breach of contract.

 

3. The claimant has not shown locus standi in this matter.

 

4. It is denied that there is the ability to enter into a contract with the Claimant as the signs which are in place refer to no stopping which it is denied creates a contract for the Defendant to enter into and rather this is a prohibitive notice.

 

5. A CPR 31.14 request was sent to the Claimant on the 24th February 2020 for the disclosure and the production of a verified and legible copy of proof of assignment from the landlord to create contracts and make claims in their own name. No response to this has been received. 

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I much prefer the KISS approach 

 

dx

 

 

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please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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couple of points

1 VCS in point 1 not VCA. i know it is a typo but get this right or they may try and get the defence chucked out on a technicality

3 delete and use the modified version

 

3 the law allows a 10 minute grace period to read and consider the offer and this grace period is also part of the Code of Practice that any parking co has to adhere to so there was no breach of conditions that all parking cos are obliged to offer.

then use your point 4 as is so it flows well

point 5  add " The defendant therefore does not believe the claimant has the necessary authority and so there is no locus standi and  cause for action against the defendant"

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Good evening dx100uk, ericsbrother and honeybee13 thank you for your help I've made some changes as ericsbrother suggested ( hope dx is ok with that) and this is the final version I will submit :

 

 

1. No keeper liability as this is not "relevant land" under the POFA 2012 and the defendant puts it to strict proof that VCA show as to who the driver was at the time.

 

2. No contract was ever offered by VCS, the land is subject to its own bye laws and in any case the signage is prohibitive so there can be no monies due as a result of either a contractual charge or as a result of a breach of contract.

 

3. The law allows a 10 minute grace period to read and consider the offer and this grace period is also part of the Code of Practice that any parking co has to adhere to, so there was no breach of conditions that all parking cos are obliged to offer.

 

4. It is denied that there is the ability to enter into a contract with the Claimant as the signs which are in place refer to no stopping which it is denied creates a contract for the Defendant to enter into and rather this is a prohibitive notice.

 

5. The defendant therefore does not believe the claimant has the necessary authority and so there is no locus standi and  cause for action against the defendant. A CPR 31.14 request was sent to the Claimant on the 24th February 2020 for the disclosure and the production of a verified and legible copy of proof of assignment from the landlord to create contracts and make claims in their own name. No response to this has been received. 

 

as I will submit it what would be the next step ? would I hear from court? 

regards

Eric 

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you need to improve on your grammar and not just copy and paste.

 

try reading it..

lots make no sense in it's present form. 


please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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also you asre still getting the name of the claimant wrong so use the standard format adn say "claimant2 rather than naming any of the parties involved

 

point 5 too verbose, just say a cpr 31.14 request for documents was sent ond no response made. forget about the date also put the first sentence last so you say " a CPR 31.14-------" and then end the point with " therefore the defendant does not believe--------"

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Thank you for the pointers just corrected it will send it off later as the service isn't available now. 

Regards 

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you don't send it off ANYWHERE YET

its not due to be filed till day 33 ....weeks away.

 

WAIT.

 

dx

 


please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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there are good reasons for waiting until close to the last date, it stops Simple Simon changing/adding to  his POC to fit in with what you have said

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Good afternoon, 

 

I have received a "notice of proposed allocation to the small claims track" letter speaking about the mediation service  and a directions questionnaire. Is there anything I should know for filling out before sending? Any important information? 

 

Regards

 

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so you've not been reading up and self helping in the last 2 weeks then?

 

dx

 


please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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I have been reading all that I can, however for someone who understands it is breeze, for me it is not. That is why I came here and asked for help, as I wish to do this as accurately as I can. 

 

Is there anything you can tell me actually relating to the small claims track and mediation service?

 

I appreciate your help so far but your condescension isn't helpful or needed.

 

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n180

 

no to mediation

1 wit you

the rest is obv

 

3 copies

1 to court

1 to vcs minus phone/sig/email

1 for you file.

 

 


please don't hit Quote...just type we know what we said earlier..

 

if everyone stopped blindly paying DCA's tomorrow

the biggest financial industry in the UK, the whole DCA industry would collapse overnight.

 

 

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