vcs pcn claimform - JLA Liverpool Airport-no stopping

[dx100uk]

correct just yours .... if others are not your data no need to redact other peoples.

 

 

[Didusha]

I have scanned and uploaded the letter and contract only. The rest of the pack includes the initial PCN, various demand for payment letters, the letter before claim, which I have uploaded previously. In a separate pdf, I have included my appeal, for which I had no record up until now, because it was done via their site.

CPR reply 1.pdfapp.pdf

Edited January 28 by Didusha
Incorrect wording

[FTMDave]

I've just had the most superficial of looks at the contract, and see it started 8 July 2013 ... "for a fixed period of 24 months".  Ho! Ho! Ho!

[lookinforinfo]

Have you written to Liverpool airports about why you stopped? The reason I ask is because in their contract with the crooks it states  at 3.8 that LJA can write to VCS and ask them to cancel.

A letter similar to the one you wrote yourself to VCS with a couple of tweaks might get them to see sense where it is sadly lacking with VCS  [Very Certainly  Scumbags].

[Didusha]

No, I haven't written to JLA, but I did notice it when reading through the contract.

I suppose it wouldn't affect the court claim negatively.

Not sure whether they will be any more reasonable than VCS, however it may be worth a try.

 

Normally, at those type of  barriers you can speak to someone to let you go through and come out on the other side, I know they have them at other airports. But in this case I don't remember seeing one, hence my panic.

What tweaks would you advise to use?

 

 

On 28/01/2022 at 11:53, FTMDave said:

I've just had the most superficial of looks at the contract, and see it started 8 July 2013 ... "for a fixed period of 24 months".  Ho! Ho! Ho!

 

Would the Contract witness statement at the end signed on 19.10.2015,  with no mention of contract end date, mean that the contract is in place indefinitely?

[FTMDave]

Not at all.  It's not a contract.  It's just some bod saying something. 

 

So they have shown a contract which lasted from 08.07.2013 to 07.07.2015, and then a statement (not a contract) saying they were running the place in 2015. 

 

You got your ticket in 2020!

[Didusha]

After reading through several posts, the below defence is what people have used.

I will be submitting it today.

 

Do I need to admit to being the driver as well as the keeper(1). I have appealed, so they know I was the driver.

 

1. It is admitted that Defendant is the recorded keeper of xxxxxxx

 

 

 

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.

 

I will be submitting my defence today.

Do I need to admit to being the driver as well as the keeper. I have appealed, so they know I was the driver.

[dx100uk]

as is.

at this stage it doesnt matter about your appeal

 

dx

[honeybee13]

Thread reopened.

 

HB

[Didusha]

Hello,

 

I have had a recent development regarding the court claim.

I received a letter from the court ordering VCS to resubmit their particulars of claim 1653045170645_1653044813811653045170645_1653044813810_May 20, Doc 1 (1).pdf0_May 20, Doc 1 (1).pdf

 

In response to the letter, recently I received the below from VCS.

May 20, Doc 2.pdfMay 20, Doc 2.pdf

 

I have until 15 of June to respond. I have a few of questions:

1. Do I resubmit my defense, and change its content to reflect the new particulars of claim? It claim hasn't changed significantly, but there are now paragraphs.

2. If so, do I do it online or directly to the court, as it has already been allocated.

3. Also, the last communication with VCS prior to this, has been from Elms and their instructions were to send everything to Elms. I now see that they are sending everything themselves. In the letter from the court, it says send copies to the claimant's solicitor. If I need to resubmit my defence, who do I send copies to? 

 

Thank you in advance.

 

I am trying to find another thread where this has happened, so far I haven't been successful, so if you know of any, please could you share.

 

[FTMDave]

The court order says that you "may send ... a defence in substitution" so you don't have to, but you have the opportunity to do so if you wish.

 

A quick superficial read through VCS's document seems to show they have actually bothered to comply with the court order and give the details the judge ordered.

 

Work calls now but I'll have a proper read through things this evening and get back to you.