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    • My WS as I intend to send it... any problems anyone can spot?         In the county court at Middlesbrough Claim No:  Between Vehicle Control Services Limited (Claimant) V   (Defendant) Witness Statement Introduction It is admitted that the Defendant is the registered keeper of XXnn XXX   Locus standi/bye-laws and Relevant land Schedule 4 of the Protection of Freedom Act 2012 (PoFA) allows recovery of unpaid parking charges from the keeper of the vehicle. However, the first paragraph 1 (1) (a) states that it only applies “in respect of parking of the vehicle on relevant land:”. The definition of “relevant land” is given in paragraph 3 (1) where subsection (c) excludes “any land ... on which the parking of a vehicle is subject to statutory control”.  The bus stop is not on relevant land because the public road on which that stand is on is covered by the Road Traffic Act.  Notwithstanding that the claimant claims that " the claimant has given the Defendant its contractual licence to enter the site", the claimant has not given any contractual licence whatsoever. This is a road leading to/from the airport which is covered by the Road Traffic Act.  A list of highways on the Highways act 1980 does not even exist. The defendant brings the attention of the court that VCS is using this non existent document issue as a deliberate strategy to debunk the fact that this road is not relevant land. VCS are put to strict proof that it is relevant land not covered by the Road Traffic Act nor by Byelaws. While it is true that landowners can bring in their own terms, it is also true that whatever terms they bring  cannot overrule Byelaws and the Road Traffic Act. If Bye Laws are involved then the bus stop is not relevant land and neither is the specious argument about First Great Western Ltd. Is the claimant ignorant of the Protection of Freedoms Act 2012? The road outside of Doncaster Sheffield Airport is not relevant land and is not covered by the Protection of Freedoms Act. That makes the charge against the claimant tantamount to fraud or extortion. The claimant mentions a couple occasions where they have won such cases. It is brought to the attention of the court that none of those cited cases were on airport land. VCS actually has also lost a lot more cases than they have won using their prohibitive signs.  Airport land is covered by Bye Laws and hence the claim by VCS is not applicable in this instance. The remit of VCS ends in the car park and does not extend to the bus stops on public roads or land which they have no jurisdiction over. All classes of people go to the airport. This includes travellers, taxis, fuel bowsers, airport staff, companies delivering food and drink for each aircraft, air traffic controllers and buses with passengers. It is therefore absolutely ridiculous to attribute VCS with any sort of permissions. The defendant submits that VCS should not confuse a major thoroughfare with a car park and presume to act as land owners and usurp the control of any land which is not relevant to them.   Protection of Freedoms Act The clearest point on section 4.1 of the Protection of Freedoms act is that “The provisions in Schedule 4 are intended to apply only on private land in England and Wales. Public highways are excluded as well as any parking places on public land which are either provided or controlled by a local authority (or other government body). Any land which already has statutory controls in relation to the parking of vehicles (such as byelaws applying to airports, ports and some railway station car parks) is also excluded.” Therefore, as this case pertains to an airport, the claimant unlawfully obtained the registered keeper’s details against the defendant’s vehicle. Thus, on this basis alone, the defendant implores the court to throw out this case. Notwithstanding the above point, if perchance Schedule 4 of the Protection of Freedoms act 2012 were to apply, the claimant is put to strict proof that they complied with the requirements of section 7 stating, “(1)A notice which is to be relied on as a notice to driver for the purposes of paragraph 6(1)(a) is given in accordance with this paragraph if the following requirements are met. The notice must — (a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;” Without such proof the court must of necessity throw out this case forthwith.   Deceit, Intimidation and Extortion The Claimant’s Particulars of Claim include £50 legal costs, yet in the letter dated  03/06/2021, the Claimant stated that they were no longer represented by Elms Legal and all further correspondence should be sent to the VCS in-house litigation department. Why should the Claimant be asking the Defendant to contribute to their employee’s salary?  Furthermore, as per another letter dated 30th July 2021, the Claimant wrote, ‘Should you fail to accept our offer of settlement then we will proceed to Trial and bring this letter to the Court’s attention upon question of costs in order seek further costs of £220 incurred in having to instruct a local Solicitor to attend the hearing in conjunction with the amount claimed on the Claim Form.’ I find this an extraordinary statement given the Claimant knows legal costs are capped at £50 in Small Claims Court. I cannot think of any reason why the Claimant would write this letter other than to intimidate the opposing party with the threat of an extortionate sum of money, hoping they would be able to take advantage of someone not knowing the Small Claims Court rules. Given that this letter came from the Claimant’s in-house litigation department, clearly well-versed in the law, this cannot be anything but deceitful and disingenuous behaviour which the court should never tolerate.    Contractual costs / debt recovery charge  In addition to the £50 legal costs, the Claimant is seeking recovery of the original £100 parking charge plus an additional £60 which is described as ‘debt collection costs’. In the Vehicle Control Service v Claim Number: 18 on 4th September 2019, District Judge Jones-Evans stated, ‘Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates […] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court in Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law. It is hereby declared […] the claim be struck out and declared to be wholly without merit and an abuse of process.’  In Claim number F0DP806M and F0DP201T, Britannia v Crosby went further in a landmark judgement in November 2019 which followed several parking charge claims being struck out in the area overseen by His Honour Judge Iain Hamilton-Douglas Hughes GC, the Designated Civil Judge for Dorset, Hampshire, Isle of White & Wiltshire. District Judge Taylor echoed the earlier General Judgement or Orders of District Judge Grand stating, ‘It is ordered that the claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedom Acts 2012, Schedule 4 nor with reference to the judgment in ParkingEye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998…’ Vehicle Control Service v Claim Number: 19 51. Moreover, the addition of costs not specified on signage are also in breach of the Consumer Rights Act 2015, Schedule 2, specifically paras 6, 10 and 14.  It is the Defendant’s position that the Claimant in this case has knowingly submitted inflated costs and thus the entire claim should be similarly struck out in accordance with Civil Procedure Rule 3.3(4).  The Defendant is of the view that the Claimant knew, or should have known, that to claim in excess of £100 for a parking charge on private lands is disallowed under the Civil Procedure Rules, the Beavis Case, the Protection of Freedom Act 2012 and Consumer Rights Act 2015, and that relief from sanctions should be refused.   Alleged contract The court should consider if there is any contract to start with and if the alleged offence is on relevant land. The consideration will inevitably lead the court to conclude that there is no contract.  Also the court should note that there is no valid contract that exists between VCS and Peel. Under the Companies Act, a contract should be signed by the directors of both companies and witnessed by two independent individuals. This alleged contract, which makes no mention of pursuing registered keepers of vehicles to court, makes its first appearance as a Witness Statement. Thus the alleged contract is null and void.  The Beavis case referred to by the claimant is about parking in a car park. The claimant is here attempting to equate that case to stopping, not parking, in a bus stop and on a road that is covered by the Road Traffic Act. The defendant submits that there can be no contract as there is no offer but there is only a prohibition. Again, it is not relevant land and VCS has absolutely no rights over it. Further, the defendant would like to point out that motorists NEVER accept any contract just by entering the land. First they must read it and understand it and then, and only then can they realise that "No stopping" is prohibitive and cannot offer a contract.   Bus stop signage The signs around the bus stop do not mention who issued the “No Stopping” signs so it could not have been issued by VCS since the IPC CoP states that their signs should include the IPC logo and that the creditor should be identified. Nothing on the signs around the bus stop that says “NO Stopping” mentions VCS or Peel Investments who are now purporting to be the land owners of a public road. As the signage should identify the creditor, since it does not, this is a breach of the CoP.   The Traffic Signs Regulations and General Directions 2016 does not prohibit stopping in a restricted bus stop or stand, it prohibits stopping in a clearway. The defendant would like to ask the court to consider if any clause of the Traffic Signs Regulations and General Directions 2016 that the claimant alleges has been violated by the defendant. There is no mention of permits on the signage. If there were, would it mean that Permit holders were allowed to stop on “No Stopping” roads? Notwithstanding what the claimant calls it, the mentioned signage is NOT a contractual clause. A “No stopping” sign is not an offer of parking terms.  Since the signage around the bus stop is prohibitive, it is as such is incapable of forming a contract. Further, the defendant would like to point out that the prohibitive sign is not actually at the bus stop but a few metres before the stand itself. There is no mention of a £100 charge for breaching the “No stopping” request, or if there is one then it is far too small to read, even for a pedestrian. As already stated, a Witness Statement between VCS and Peel Investments is not a valid document. It will need more than the Claimants feather to outweigh the case against the Defendant regardless of who was driving. There is no law of agency involved. This is not a case of employer/employee relationship. VCS cannot transfer the driver's liability to the registered keeper. There can be no comparison between a railway station and an airport. This is a totally fatuous analogy which cannot be applied to this case.  As stated in the defence, it is denied the Claimant is entitled to the recovery or any recovery at all. The nefarious parking charge notice given for a vehicle on a public road bus stop was ill advised to start with.   Conclusions:   VCS has failed to present ANY reasonable and valid cause to apply to the DVLA for the Defendants details. VCS has failed to provide ANY valid  contract with the landowners. “No stopping” is prohibitive therefore cannot form a contract the event happened on a bus stop over which VCS has no jurisdiction the signage either does not show that there was a charge of £100 for stopping, or the font size was too small for any motorist to be able to read it  the signage does not show the Creditor which fails the IPC CoP and hence the signage is not valid the WS contract does not authorise VCS to pursue motorists to Court Given all these factors it seems that VCS have breached the GDPR of the Defendant quite substantially and it would appear right that an exemplary award is made against VCS in the hope that they will drop all further cases at Doncaster airport where they are pursuing motorists on non relevant land. The Defendant wishes to bring to the attention of the court that the Claimant cites an irrelevant case of a car park and tries to apply its merits to a bus stop. That in itself invalidates the entire fallacious claim. Accordingly, this case is totally without merit. Some statements are pretty close to perjury and others are designed to mislead or misdirect. None of the analogies seem appropriate or relevant. All the false information presented as a statement of truth could have been stated using half the words and without all the repetition which appears to be trying to build a strong case where there is none at all. One particularly bad example of misdirection is in the photographs. The Clearway sign shown near the bus stop is very unclear unlike the Clearway sign two photos before it which may well include terms and conditions. The one by the bus stop is totally different.   47. Lastly I wish to bring to the attention of the court, a systematic pattern of the Claimant’s court action behaviour in several of their cases. They tend to have a VCS paralegal writing a Witness Statement, then mentioning in the last paragraph of the Witness Statement that they may be unable to attend court and subsequently the paralegals never turn up to be cross examined. In the event that Mohammed Wali is unable to attend court to be asked about his claims, then I would like to know why he is not able to attend when the hearing has been scheduled months in advance, is during working hours and as a result of covid, is online, meaning there is no travel involved. Ambreen Arshad, the other paralegal employed by VCS, does exactly the same. 
    • Hang on. don't panic!   You sent the snotty letter which has told the fleecers to put up or shut up.  So far they've haven't taken you to court.  This might change, but so far you're in the driving seat.  You don't have to deal with them any more.  It's up to them if they have the gonads to start court action or not.   Regarding DCBL, they are not representing their client in the normal way that a solicitor represents a client, because the sums of money involved are too low for that.  They are just chucked a few quid to send a couple of "threatening" letters.  There is no point in dealing with them.   If you want the original PCN send a SAR to UKPCM only.  For the SAR letter simply click on "SAR".   However, the SAR has nothing to do with the 30 days, you've already dealt with that with the snotty letter.  You need to read lots of similar threads and familiarise yourself with the legal process.  CAG is a superb free library.    
    • Hi again, so I will send a SAR to UKPC because I don't remember seeing the  NTK.  Then should I let DCBL know otherwise they will probably issue the court papers but they might hold off if i tell them about the SAR?   what do you think?  I need to do it this weekend or it will be beyond the 30 days.  Otherwise to let it run will definitely lead to a court case perhaps??   Can I get a copy of a SAR letter on here? thanks
    • 👍   One thing, write "unlawful", not "illegal".   Sorry to be pernickety, but "illegal" = "a crime".   "unlawful" = "not in accordance with the law".    They've lied to the DVLA but that's not actually a crime, it's misuse of your personal data which is a civil matter, and you can sue the idiots once your case is over for breach of GDPR, but it's not a criminal offence.
    • Just added also paragraph 11 stating " Notwithstanding the above point, if perchance Schedule 4 of the Protection of Freedoms act 2012 were to apply, VCS should prove that they complied with the requirements of section 7 stating, “(1)A notice which is to be relied on as a notice to driver for the purposes of paragraph 6(1)(a) is given in accordance with this paragraph if the following requirements are met. The notice must — (a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;” Without such proof the court must of necessity throw out this case forthwith."
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Parking Eye ANPR PCN claimform - University Hospital of Wales, Cardiff - Staff 4, Heath Park, Cardiff, CF14 4XW


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I received a Claim Form issued on 19 Jul 2021. The claimant is ParkingEye Limited. 

 

The alleged offence took place on 22/10/2019. The particulars of claim read as follows:

 

1.Claim for monies outstanding from the Defendant in relation to a Parking Charge (reference xxxxxx/xxxxxx) issued on 25/10/2019.

 

2.The signage clearly displayed throughput University Hospital of Wales, Cardiff - Staff 4, Heath Park, Cardiff, CF14 4XW states that this is private land, managed by ParkingEye Ltd, and that it is subject to terms and consitions, including authorisation being required for parking, by which those who park agree to be bound (the contract).

 

3.ParkingEye's ANPR system captured vehicle xxxxx entering and leaving the site on 22/10/2019, and parking without authorisation. Pursuant to Sch 4 of the Protection of Freedoms Act 2012, notice has been given to the registered keeper, making them liable for the Parking Charge payable upon breach."

 

As they claim the PCN was issued in October 2019, I do not recall receiving anything in the post. I did receive a Final notice of Debt Recovery from dcbl, demanding £140. However, it had no reference on the letter so I just ignored it.

 

I logged on to ParkingEye's portal to access photographic evidence and did not manage to find the complete PCN, however, there were just two pictures of the car with a time stamp (please see the attached files). I have copied the parking charge details from ParkingEye's website:

 

Parking charge details

Parking Charge Reference: xxxxxx
 
Vehicle Registration Number: xxxxxx
 
Contravention date/time: 22/10/2019 19:41:52
 
Contravention location: University Hospital of Wales, Cardiff - Staff 4  Heath Park, Cardiff, CF14 4XW
 
Stay duration: 0 hours 30 minutes
Allowed duration: 0 hours 10 minutes
 
Status: Open
 
Outstanding balance: £155.00 (Please allow 24 hours after payment for it to be reflected on the balance)
 
I do not recall parking there, however I may have entered the car on multiple occasions on the day to turn the car around.

I visited the car park yesterday to take some pictures (please see the second attached file)

 

I have completed the AOS on moneyclaim.gov.uk

 

I am looking to file my defence based on the following points:

 

  1. The photographic evidence supplied by the claimant does not prove the car parked in the above mentioned car park. It just shows the front and the back of the car with two different time stamps.
  2. The notice which states that it is a staff car park is located right at the end of the car park, which is not noticeable as you approach the car park and the board seems fairly new to me, the claimant has not provided any proof to suggest that it was there when the alleged alleged offence took place?
  3. As they have allowed a 10 minute grace period, a £70 charge for 20 minutes is unreasonable.

 

Any advice would be much appreciated!! Thanks a lot.

Parking Eye 2-converted.pdf 20210725_232345-converted_compressed.pdf

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please complete this:

 

 

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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  • dx100uk changed the title to Parking Eye ANPR PCN claimform - University Hospital of Wales, Cardiff - Staff 4, Heath Park, Cardiff, CF14 4XW

quicknote 

please dont file that defence ... it gives away too much.

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Thank you for your quick response.

 

Name of the Claimant : PARKINGEYE LTD

 

Claimants Solicitors: n/a

 

Date of issue – 19 Jul 2021

 

Date for AOS - 6 Aug 2021

 

Date to submit Defence - 20 Aug 2021

 

What is the claim for 

 

1.Claim for monies outstanding from the Defendant in relation to a Parking Charge (reference xxxxxx/xxxxxx) issued on 25/10/2019.

 

2.The signage clearly displayed throughput University Hospital of Wales, Cardiff - Staff 4, Heath Park, Cardiff, CF14 4XW states that this is private land, managed by ParkingEye Ltd, and that it is subject to terms and consitions, including authorisation being required for parking, by which those who park agree to be bound (the contract).

 

3.ParkingEye's ANPR system captured vehicle xxxxx entering and leaving the site on 22/10/2019, and parking without authorisation. Pursuant to Sch 4 of the Protection of Freedoms Act 2012, notice has been given to the registered keeper, making them liable for the Parking Charge payable upon breach."

 

What is the value of the claim? £155.00

 

 

Amount Claimed  £70.00

court fees              £35.00

legal rep fees        £50.00

Total Amount         £155.00

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thank you 

 

if you have any other paperwork...

can we had bothsides of the PCN and the NTK to one PDF please

and did you get a letter of claim about 1 month before the claimform please?

if you did page 1 of that too but not any of the reply pack.

 

have you moved or changed car since or just before the incident, i'm puzzled as to why you never got all the required paperwork.

 

dx

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Sorry, I do not have any other document other than this (please see the attached file)

 

I have not moved or changed car in a while. I may have received the original PCN but thrown it away, but as it was over a year ago, I have no recollection.

 

Many thanks

20210727_121939-converted-compressed.pdf

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There was nothing other than that letter from DCBL before the Claimform, that doesn't look like a compliant Letter Before claim

We could do with some help from you.

PLEASE HELP US TO KEEP THIS SITE RUNNING EVERY POUND DONATED WILL HELP US TO KEEP HELPING OTHERS

 

Have we helped you ...?         Please Donate button to the Consumer Action Group

 

If you want advice on your thread please PM me a link to your thread

 

The bailiff: A 12th Century solution re-branded as Enforcement Agents for the 21st Century to seize and sell debtors goods as before Oh so Dickensian!

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a dca cant send a letter of claim, only their mates at DCB legal can on behalf of PE.

something weird going on here is you've never gotten numerous letters prior to the claim.

 

might be worthy in this instant to send PE an sar.

 

as for the claim, you've done AOS so now need to send PE this:

 

 

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Really appreciate your continuous help.

 

I have sent the CPR 31 request in the post today and obtained a proof of postage. 

 

In terms of preparing the defence, should I refer to the one posted on this page?

 

Many thanks

 

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yes thats the sort of basics you need but plenty of time to fine tune it

 

dx

 

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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  • 3 weeks later...

ParkingEye have obviously failed to respond to my CPR 31 request. Below is the defence that I have prepared:

 

Defence:

 

The Defendant contends that the particulars of claim vague and are generic in nature which fails to comply  with CPR 16.4.  The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made.

 

1. Paragraph 2 is denied. It s denied that I ever entered into a contract to breach any terms and conditions of the stated private land.

 

2. Paragraph 2 and 3  are denied.  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. 

 

3. It is admitted that Defendant is the recorded keeper of the vehicle. The claimant is not in a position to state if I was the driver at the time.

 

4.  It is denied that the Claimant’s signage is capable of creating a legally binding contract.

 

5. Not withstanding the above on 28 July 2021 I made a request pursuant to CPR 31.14 for the claimant to disclose its necessary evidence in support if its claim. To this date the claimant has failed to respond to said request

 

Therefore the claimant is put to strict proof to evidence its cause of action and contractual costs and what loss it has suffered. 

 

The Claimant is further put to strict proof that it has sufficient proprietary interest in the land, or that it has the necessary authorisation from the landowner to issue parking charge notices, and to pursue payment by means of litigation.

 

The Particulars of Claim is denied in its entirety.  It is denied that the Claimant is entitled to the recovery or any recovery at all.

 

 

Really appreciate all the help. Many Thanks!!

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pers i'd stick to the generic defence in post 10 

no need to fluff it out.

 

did you sar PE?

 

dx

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Less is more at that stage, all the points will be in a Witness Statement later.

We could do with some help from you.

PLEASE HELP US TO KEEP THIS SITE RUNNING EVERY POUND DONATED WILL HELP US TO KEEP HELPING OTHERS

 

Have we helped you ...?         Please Donate button to the Consumer Action Group

 

If you want advice on your thread please PM me a link to your thread

 

The bailiff: A 12th Century solution re-branded as Enforcement Agents for the 21st Century to seize and sell debtors goods as before Oh so Dickensian!

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Well their NTK is compliant meaning that they can transfer the liability to pay the charge from the driver to the Keeper.  And how ridiculous to suggest that their contract with the land owner  is largely not relevant when if there is a fault with it, there is no contract so there can be no breach of said contract.

 

Cardiff Council have an unusual way of arranging planning permission results. They do them weekly so as we don't know when let alone if, planning has been granted. The only way now is to contact the planning department and ask them if PE have planning permission for their signs and ANPR cameras under the Town and Country [advertisements ] regulations .

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no go ring them.

 

dx

 

 

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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  • 4 weeks later...

I rang the council, however, they said that all the planning enquiries are dealt through email only. Sent them an email after and still waiting for them to respond. May fire a reminder email if I do not receive by end of Monday.

 

Also received the notice of N180 directions questionnaire in the post and below is how I plan to respond:

 

C1 Do you agree that the small claims track is the appropriate track for this case? (yes)

 

D1 At which county court hearing centre would you prefer the small claims hearing to take place and why? (Cardiff)

 

D2 Are you asking for the court's permission to use the written evidence of an expert? (no)

 

D3 How many witnesses, including yourself, will give evidence on your behalf at the hearing? (0)

 

D4 Are there any days within the the next six months when you, an expert or a witness will not be available to attend court for the hearing? ( 17-25 November)

 

Will you be using an interpreter at the hearing either for yourself or for a witness? (no)

 

Any help would be much appreciated!! Thanks a lot

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1 wit you

the rest is obv

Dupe to pe

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

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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