TPS/BW ANPR PCN Claimform - Purley Way Retail Park, CroydonRetail park parking ticket

[TheAntiTicket]

I don't know why the earlier letters were not received.

The car is registered at the home address.

The person did spend a number of weeks in Italy last year visiting a sister who lives there.

 

What is a dca?

[dx100uk]

debt collection agency = powerless muppets on any debt who are not bailiffs and have zero legal powers on any debt no matter what it's type.

[brassnecked]

A DCA  is the set of clowns that alsoadd unlawful and legally unenforceable fees to an invoice, such additions like the £60 they add to the £100 invoice or anything else if suing the Keeper, is as shown in the Lewes OPS Judgment, abuse of process and very very naughty.  Hoping a PPC director is jailed for contempt for such very soon.

[TheAntiTicket]

The N157 form was received yesterday. 

 

It is a bit confusing because on the first page it is dated 18th August but at the end on page 2 it has a date of 20th July, the envelope it was posted in has a franking date of 4th September.

Do we just now wait for the court to send a further letter giving the exact date of the hearing? 

 

Also is the directions numbered 6, 7 and 11 easily achievable or is this just standard protocol? 

The defendant will not wish to be there.

 

N157.pdf

[dx100uk]

bog std n157 in 100's of threads here

 

you await hearing date.

 

the defendant must partake as directed

 

if there ever is a case

and if its even this year

or in person

or by phone..

 

is down to the court you chose.

[FTMDave]

14 hours ago, TheAntiTicket said:

The defendant will not wish to be there.

No way out of it I'm afraid, your father's mate is the one being sued, he/she has to be in court for his/her own case.

[AndyOrch]

Topic open..please post your update here.

[TheAntiTicket]

I think I might have done something wrong. 

 

A letter has been received today informing of a small claims court hearing next Friday the 28th.

It states information that is misleading as it is does not say what was originally stated by us.

 

This has come from their solicitors and is their witness statement.

I was expecting to receive a letter from the court so that we could connect to a video platform for the hearing.

I think I have got it all wrong.

We have not send a witness statement only the original defence statement in February 2020.

[dx100uk]

you mean your friend has, he's the defendant.

 

so where has his notification of the hearing date and details of when to submit his WS gone too?

he need to ring the court and tell them so.

we will need to see ALL the claimants WS inc exhibits ASAP please

ONE multipage PDf only!!

read our upload guide carefully

 

[FTMDave]

Well, this is what happens when the person who is being sued won't deal with their own case and gets their mate's son to do it for them.

 

I appreciate the person is elderly, but ...

 

It seems a court date has been fixed, and your dad's mate should have sent in his WS 14 days before.  As a Litigant in Person he will be allowed some leeway so if he sends it by e-mail tomorrow he might be OK.

 

So - tomorrow he needs to ring the court and ask what stage his case is at, and if I'm right he needs to get his WS in.  I presume he has already prepared a draft.

[FTMDave]

23 minutes ago, TheAntiTicket said:

It states information that is misleading as it is does not say what was originally stated by us. This has come from their solicitors and is their witness statement. I was expecting to receive a letter from the court so that we could connect to a video platform for the hearing. I think I have got it all wrong. We have not send a witness statement only the original defence statement in February 2020.

You need to understand that your dad's mate is being sued, no-one else, and he will have to defend himself during the hearing against the fleecers, so he needs to understand the arguments to do so.

[FTMDave]

So?  What stage is the case at?  What did your dad's mate find out from the court today?

[TheAntiTicket]

The court has asked them to send the witness statement by email and it is going to be sent to the solicitor as well tomorrow. I don't think he has got time to show it to you he has only just finished it. Hopefully it will work and thank you for all your previous advice.

[FTMDave]

Even if there are only a few hours to spare, feel free to post it up here tomorrow for comments.  Some of the regulars work, but some are retired, so will have some time to help.

[TheAntiTicket]

Shall I just post up his witness statement  and just remove name and address and claim numbers

[dx100uk]

and anything else that directly can be used by the fleecers to ID him here , refs/reg numbers etc.

we must abide by GDPR rules.

[dx100uk]

and where is the claimants WS too?

much better to counter theirs than just write some random bits from the internet that might work.

 

where is he getting the date for WS submission from 

what date is the hearing

what date must they pay the fee by?

 

he can be a day or 2 late

 

might be much easier to simply scan up the court order that states these things.

[TheAntiTicket]

Having received a claim for a parking infringement in February 2020 my friend went to discover where the Purley Way Retail Park was.

 

He told me what the 6 shops within this complex were and I then knew that I had never been inside these shops or the car park that is situated in front of these stores.  Apparently, he had also spoken to a member of staff within one of the shops who confirmed that there was no time limit for parking in this car park.

 

I then replied to this with a defence claim stating the following. 

 

"I have just received notification of a parking infringement which occurred 25/5/19."

"Obviously, I can't remember where I was on that day but I have now visited the Purley Way Retail Park where the offence is alleged to have occurred and I can confirm that I have never shopped in any of these six shops in that retail park. also there doesn't appear to be any parking restrictions apart from caravans" 

 

 Perhaps I should have said that I had not parked there on that day in question 25/5/19 but that is what I meant.

 

I received a reply to this defence claim dated 5/3/20 rejecting my defence.

 

Mr then said he would help me in this matter and he returned to Purley Way Retail Park and took photographs of the entrance and the signs available at the entrance. He then emailed them to BW on the 20/4/20 as shown above after a phone conversation with them.

 

As requested, the 3 photos (numbered 1,2 and 3) of Purley Way Retail Park. The drive-in entrance is the only way into the units and although the 2 car parks either side of this unit only allow parking up to 3 hours, this car park has no parking restrictions which was confirmed to me by a member of staff about 2 months ago.

 

I suppose it's possible that a year ago parking restrictions were different and if so, can you please let me know when they changed. He received confirmation that they had been passed on to their client and would get back with a reply.

 

As he had not had a reply, he phoned on two more occasions but no reply had been received from TPS.

Eventually he phoned on the 3/8/20 to be told that they now had a reply, after over 100 days and they would forward it on. On receiving that email, he immediately knew they were not photos of the Purley Way Retail Park (photo 4) as it was a much larger car park and he told that to BW. 

 

On the following day further photographs were sent of my vehicle in the same car park as the previous days offering which is not the Purley Way Retail Park.

 

He was not completely sure what the car park was but on his return to this county he discovered they were photographs taken in the Lombard Retail Park (photo 5) which is situated over 3/4 mile (1.2km) from the Purley Way Retail Park. I have also enclosed photos of the same car park (numbered 6 and 7) in which you can clearly see the Matalan store and also the Range which replaced Homebase when it shut down.

 

Bearing in mind that you have shown a photo of my vehicle in this car park it could not be in the Purley Way Retail Park at the same time and I confirm it was not ever left in the Purley Way Retail Park.

 

I believe that the facts stated in this statement are true.

 

[dx100uk]

worthy to note on google earth that is the purley way carpark in their NTK pictures and if thats his car , the defence and that WS is not going to work.

 

he is looking at the WRONG carpark, in his statement, the caravan one with the bailff notice is not purley way !!

[FTMDave]

That WS is appalling.

 

I got lost with all the "I", "he", there is only one person being sued.

 

You, personally, have been great at supporting your dad's mate, but as the mate is presumably retired I don't understand why he/she hasn't used the time to look up WSs that were successful on the forum.

 

 

Edited May 19, 2021 by FTMDave

[TheAntiTicket]

https://completelyretail.co.uk/scheme/2418                                                                                                                                                                                                                                                                                                                                                                                                                                                                  I do think he is right about the car park.   This is the Purley Way Retail Park and the photos of the vehicle were taken in the other park.                           

[dx100uk]

look at the pix on the NTK that show his car going in/out

look at the drain covers .

 

now look at the picture in the PDF.

same car park.

 

 

purley way carpark.pdf

[TheAntiTicket]

Actually that photo on Google Earth is an old photograph as the big store in the background is Homebase and that store has been closed for at least 2.5 years. Also that is the same car park as shown in the car going in/out but it is not the Purley Way Retail Park car park which is situated about 1.2km further back down that road.

 

Purley Way is approx. 3miles long starting at Purley Cross right through to the Lombard roundabout in Mitcham Road Croydon. There are probably somewhere in the region of 40+ different car parks in the final 2 miles stretch of that road on both sides of the mainly dual carriageway and each car park has a totally unique and different name to each other.

[dx100uk]

well i know that , but that's somewhat immaterial..it proves the location.

The postcode is correct on the NTK, so are the postcodes of the stores and the location on their addresses as Purley Way Retail Park

 

getting hung up on a 'name' is not the way to beat these fleecers.

he did go in/out whatever the place is called.

 

 

 

 

[FTMDave]

Any update on this?  I ask as TPS have raised their ugly head elsewhere.