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  • FIRST POST
    • Luke Rick
    • By Luke Rick 16th Jan 17, 3:20 PM
    • 24Posts
    • 9Thanks
    Luke Rick
    IAS Appeal Lost - Now what?
    • #1
    • 16th Jan 17, 3:20 PM
    IAS Appeal Lost - Now what? 16th Jan 17 at 3:20 PM
    I've been one of the unlucky few around the same area that has a parking ticket thanks to the operators that "patrol" (they live here to enforce it...). The company in question is "Link Parking Ltd"

    Started an internal appeal to which, obviously, was rejected straight away. Went to the IAS to also appeal, and this has come back appeal rejected.

    Original reason for the ticket was that of "Not parking within a designated bay".

    My Appeal:
    "There were insufficient signage in proposed area of enforcement for parking in designated areas. Not even taking into consideration the apparent "designated parking bay" not having ANY lines other than "bricks" molded into the pavement, this is insufficient especially in the darker hours. The spot i was parked on had indeed enough room for 2 cars, to which no SIGNAGE in view, or any apparently relating to said parking spots only having the exceed limit of ONE motor vehicle. The sign pictured from the operator was that of a parking sign NOT IN DIRECT VIEW of the parking bays in question, but that of a SIDE CAR PARK leading from the main road. (As exhibited REF: EV01) - this displays the car park you are about to ENTER leading FROM the main road, THESE terms are met should you wish to park there.

    Going from the fact this sign is leading to believe this sign relates to the CAR PARK you will enter (REF: EV01), you cannot DIRECTLY see this sign, OR ANY OTHER SIGN, from where the car was situated once it received its PCN. You can see this with exhibit (REF:EV02) attached.

    Two DIRECT huge walls from the flats are that of PLAIN walls to which potential SIGNAGES could have been placed to enforce their terms on the ISOLATED 4 parking bays. This was not done so. As exhibited (REF:EV03), you can see NO SIGNAGE at all present when looking at this.

    Going further from this, exhibit (REF:EV02) clearly shows from google maps that this space was ONCE indeed a 2 car parking spot, so it's not "out of the ordinary".

    Exhibiting (REF: EV04) for clarity, NO DRIVING OBSTRUCTIONS were made in any shape of form, relating to any Traffic Offences under the Road Traffic Act 1988. As stated in exhibit EV04, no pavements, roads or any other MOTOR VEHICLE was at subsequent financial loss due to the parking of my MOTOR VEHICLE. The vehicle that was "blocked in", had my full authorization to park there and do so stop that car from moving, due to that spot being THEIR parking spot. [This is clearly unrelated but making it apparent that no offences were committed whilst parking in said "non-designated parking spot"]

    Should a SIGNAGE be posted at the ENTRANCE to the ROAD (HARSCOMBE DR) then cars entering will adhere to said terms. This is NOT the case. The signage in question is relating onto a wall, that is at the ENTRANCE of another CAR PARK, for residents/visitors.

    I exhibit all referenced articles as stated in the upload documents area, along with my original appeal to LINK PARKING.

    Summary: Grounds for appeal, INAPPROPRIATE SIGNAGE FOR SAID PARKING OFFENCE."

    EV01: hxxps://i.imgsafe.org/cdf557d562.png
    EV02: hxxps://i.imgsafe.org/cdffc9a19c.jpg
    EV03: hxxps://i.imgsafe.org/cdf576fb10.png
    EV04: hxxps://i.imgsafe.org/cdf572be8a.png

    ----------------

    Operator's Prima Facie Case:

    "The operator made their Prima Facie Case on 08/12/2016 07:42:40.

    The Operator Reported That...

    The appellant was the driver.
    The appellant was the keeper.
    The operator is seeking keeper liability in accordance with PoFA..
    A manual ticket was placed on the vehicle.
    The ticket was issued on 28/11/2016.
    The charge is based in Contract.

    The Operator Made The Following Comments...

    The appellant parked their vehicle in an area we manage and incurred a charge as they were not parked in a designated parking area(not in a bay) The appellants own images confirm this. Our signage clearly advertises the parking requirements and the charges which apply if they are not met. The appellant received a PCN from us on the 01-10-16 which was paid so the appellant is well aware of the parking requirements"

    Their evidence: hxxps://i.imgsafe.org/ce0375ca33.jpg
    Another : hxxps://i.imgsafe.org/ce0662389c.jpg

    ----------

    My next response:

    LinkParking operates the grounds but to what extent. No signage states where this starts/ends. The signage that is posted as evidence in the pictures provides LEADS any persons to believe the car park they WILL enter, will adhere to these terms. The entire occupants of the flat i visited at that particular time lacked "Mens Rea", to any unlawful doing with parking 2 cars on that spot, that can clearly fit, TWO cars.

    That SIGNAGE as posted as evidence is fixed on a wall, approx 26 meters away from said "undesignated parking" bay(s), one of which that i was parked on. This also does not state that the parking bay i was parked is contract to ONE vehicle, and ONE vehicle only.

    The SIGNAGE, as stated before, is NOT in view of the ISOLATED 4 parking bays, and leads persons to believe the CAR PARK they WILL enter leading from the MAIN road (Harescombe Drive) adhere to said rules of the SIGNAGE as posted for evidence via LinkParking.

    This SIGNAGE is absolutely, without a doubt, disproportionate with the size of the apparent enforced area . At nighttime, the SIGNAGE provided as evidence was not able to be seen in the dark. This is too far aware from these ISOLATED bays.

    The opportunity LinkParking have as a parking enforcement agency to post signs that DESIGNATE THOSE 4 PARKING BAYS is not unreasonable. They have a fence directly opposite, and two walls to the left and directly infront of the bays.

    As stated by LinkParking, their information is false. I was NOT aware of the parking requirements as i have parked there for the last 6 months, with no previously tickets applied. I have had only one from another area in their enforcement area, for not displaying a parking permit, to which i paid in full. within 2 days.

    I the "defendant", lacked "Mens Rea", to any wrong doings with these allocated 4 parking bays. Inappropriate SIGNAGE is the sole purpose I am appealing this PCN.

    --------------

    Our signage clearly informs the motorist of the area we cover, and has been audited by the IPC.

    The appellant received a previous ticket on the same estate and we have attached prove of this so we are unsure why he claims it was in another area. This was issued in the month prior to the ticket now on appeal. This supports our claim that he was aware of the parking requirements.

    They attached their sitemap... : hxxps://i.imgsafe.org/ce2f31d196.png

    Take note here. This is THEIR own evidence that they have supplied... i have circled the yellow to where the road is in question. Also, i have done an orange box to show where my car where. Look at their drawing and how they have circled and crossed where their signs are, THEN they draw a bound box to where their enforment areas are!!!!! It's not even in the area yet my PCN was still dismissed!!! HOW?!?!?!

    (They attached the copy of the previous ticket) - Bit of background here. I stated this parking ticket to declare i knew that i was in the wrong with THAT parking ticket.

    --------

    My next response:

    Your SIGNAGE does NOT specify to which area you cover. You have multiple SIGNS, which do NOT dictate to where their respective areas cover. Your evidence which shows these areas are clear once a ticket HAS BEEN GIVEN but NOT before.

    New Evidence attached shows the AREA in question to which the SIGNAGE in question is not within an ACCEPTABLE position relating to the 4 ISOLATED parking spots, one of which i was parked in.

    "PCN New Ev 001" - Shows the bounding box to which the SIGNAGE APPEARS to enforce with the FACT it is on a wall ADJOINING to a SEPERATE CAR PARK leading from the MAIN ROAD (HARESCOMBE DRIVE).

    "PCN New Ev 002" - Illustrates this (apologies for the AA Van, was grabbed from Google Maps) BOUND box that the SIGNAGE IS ADVERTISING to adhere to.

    "PCN New Ev 003" - Viewing ENTERING the road (Harescombe Drive). The SIGNAGE as drawn in ORANGE shows upon leaving HARESCOMBE DRIVE and ENTERING A CAR PARK, YOU WILL follow these terms if you wish to park there. How does this even suggest this also includes the 4 ISOLATED CAR SPOTS that is 25 METERS + FURTHER DOWN THE ROAD?

    "PCN New Ev 004" - Another view looking UPWARDS from where the CAR WAS PARKED at the time of the PCN issued. LinkParking has a duty to FULLY display PARKING REQUIREMENTS that is RELEVANT TO SAID "DESIGNATED PARKING BAYS". How is it that ONE SIGN, 25 METERS AWAY, is deemed as SUITABLE? As drawn in by PINK, there is MORE than enough places to display APPROPRIATE SIGNAGE for these 4 ISOLATED PARKING BAYS.

    New EV01: hxxps://i.imgsafe.org/ce38253535.jpg
    New EV02: hxxps://i.imgsafe.org/ce382296fc.jpg
    New EV03: hxxps://i.imgsafe.org/ce382756ab.jpg
    New EV04: hxxps://i.imgsafe.org/ce382adf57.jpg

    -------

    Adjudicator's Decision:

    The Operator has provided evidence of the signs at the site which make it clear any driver failing to park within the confines of a marked bay agree to pay the parking charge. The Operator has also provided photographic evidence of the Appellant’s vehicle parked on land they manage, in close proximity to a sign advertising the terms, and a signed statement of truth that the vehicle was outside of a bay. I am therefore satisfied there is a prima facie case the charge was lawfully issued.

    The Appellant first claims the bay is not clearly marked. Had this claim been based on the Operator’s evidence alone I may have agreed, but the Appellant’s evidence makes it quite clear that the area in which they parked their vehicle was not a bay and, although it is not relevant, causing obstruction.

    The Appellant claims the signage was insufficient. I was unsure whether the evidence provided was sufficient on this point as it did not show the whole area around the vehicle. However, the Operator’s evidence that this is the second notice received on this vehicle in a little over a month means I am satisfied the Appellant was aware and had notice of the terms on this occasion, irrespective of the situation before the first notice.

    The Google maps are not current and the legislation referred to has no jurisdiction over private land. The issue of ‘mens rea’ is irrelevant as this relates to criminal law, and there is no requirement to show any intent or recklessness on the part of the driver for the charge to be lawful.

    The appeal is dismissed.

    -----


    So that's it, can i do anything from here? They're basically doing this on insufficient evidence on my part? The bay itself is showing by lines, and does not show it is restricted to one car, at all. In fact, the occupants of the flat to whom the parking space is linked to, said they've parked there with two cars before and had no hassles/issues/complaints and more importantly, no tickets!!

    Any information would be much appreciated!
    Last edited by Luke Rick; 16-01-2017 at 3:32 PM. Reason: Edited
Page 2
    • Coupon-mad
    • By Coupon-mad 24th Mar 17, 12:41 AM
    • 51,504 Posts
    • 65,105 Thanks
    Coupon-mad
    Well to be fair it's not as if most people actually need to be spoon-fed on the subject of AOS...dead simple acknowledgement (just an annoying Government Gateway system to get through).

    Already explained by bargepole in another post on the NEWBIES thread post #2, all is covered there.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Luke Rick
    • By Luke Rick 26th Mar 17, 6:40 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Update: I believe i have completed my defense. Would anyone be able to give it a once over and advise accordingly? How would i go about this? Would it not be wise to post my entire defense on here..?

    Much appreciated. Thanks.
    • Coupon-mad
    • By Coupon-mad 26th Mar 17, 11:13 PM
    • 51,504 Posts
    • 65,105 Thanks
    Coupon-mad
    It is fine to show us here in full view, your defence (not defense, that's American spelling)!
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Luke Rick
    • By Luke Rick 12th Apr 17, 7:39 AM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Apologies about the delay. Here is my defence (that was my google auto-correct extension!!!) so far.

    1) It is admitted that the defendant, xxxxxxxxxxxxxxxxx, residing at xxxxxxxxxxxxxxxxxxxx is the registered keeper of the vehicle.

    2) The vehicle was parked on the land alleged in the defendant’s claim.

    3) It is denied that any 'parking charges/damages and indemnity costs' (whatever they might be) are owed and any debt is denied in its entirety.

    4) This is a completely unsubstantiated and inflated three-figure sum, vaguely and incoherently adduced by the claimant's solicitors in the following claim: xxxxxxxxxxxx. The Particulars are not clear and concise in their Particulars of Claim found on the Claim Form.

    5) The Particulars of Claims fails to fulfil CPR16.4 because it does not include a statement of the facts on which the claimant relies, only referring to a “Parking Charge Notice(s)” with no further description. The defendant also believes there has been a similar Particulars of Claims dismissed at another court, and suggest they are simply “robo-filing”. This is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers.



    6) 12. The Claimant has at no time provided an explanation of how the sum has been calculated, the conduct that gave rise to it or how the amount has climbed from £100 to £16x.x9. This appears to be an added cost invented fancifully and an attempt at double recovery, which the Protection Of Freedoms Act 2012 Schedule 4 specifically disallows.

    7) This claim and the other very similar one merely states: ''parking charges/damages and indemnity costs if applicable'' which does not give any indication of on what basis the claim is brought. For example whether this charge is founded upon an allegation of trespass or 'breach of contract' or contractual 'unpaid fees'. Nor are any clear times or coherent grounds for any lawful claim particularised, nor were any details provided to evidence any contract created nor any copy of this contract, nor explanation for the vague description 'parking charges' and 'indemnity costs'. As the contractors are not the land owners, it is also unclear as to how “damages” are caused.

    8) The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.

    9) I have reason to believe that this is a claim that will proceed without any facts or evidence supplied until the last possible minute, to my significant detriment as an unrepresented Defendant.

    a) This is a speculative serial litigant, issuing a large number of identical 'draft particulars'. The badly mail-merged documents contain very little information.

    b) The Claim includes a sum of £50, described as ‘Legal Representative’s costs’. Given the Claimant uses a fully automated, bulk processing service, requiring no intervention from a Solicitor often generating up to £50,000 of income they are put to strict proof to show how this cost has been incurred. The Claimant is put to strict proof of all his assertions.


    c) The Claim is in excess of £230. Without information to the contrary, I believe the original amount for a Parking Charge would have been £100 or £60 if paid within the first 14 days. Given the Claimant uses a fully automated, bulk processing service, I also object to all additional charges associated with this Claim and the Claimant is put to strict proof of all his assertions.
    10) I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.

    11) A sitemap was requested from the defendant to which a sitemap had been provided. The sitemap clearly indicates the area of coverage by a key that had been drawn at the bottom of the sitemap, symbolizing 3 different enforceable signs and their respective locations, along with bounding boxes to distinguish areas of enforcement. The defendants parked vehicle was not in fact inside any enforcement zone as shown in the sitemap provided by the claimant. Therefore, the defendant asks the court to strike the claim on this ground.

    12) I request the court strike out this claim for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.

    Statement of Truth: I confirm that the contents of this statement are true to the best of my knowledge and belief.

    ---

    Any feedback would be much appreciated!

    Thanks.
    • Coupon-mad
    • By Coupon-mad 12th Apr 17, 6:38 PM
    • 51,504 Posts
    • 65,105 Thanks
    Coupon-mad
    7) This claim and the other very similar one merely states:
    Unless you have 2 claims, you need to remove anything talking about 2 claims, like the above.

    And remove the '12' from here:

    6) 12. The Claimant has at no time provided an explanation of how the sum has been calculated, the conduct that gave rise to it or how the amount has climbed from £100 to £16x.x9.
    ...and why above, do you say the claim is £16x.x9, yet later you give a different sum in 9c:

    c) The Claim is in excess of £230.

    And this is too wordy and I think this should be nearer the top of your defence if this is true:

    11) A sitemap was requested from the defendant to which a sitemap had been provided which The sitemap clearly indicates the area of coverage by a key that had been drawn at the bottom of the sitemap, symbolizing 3 different enforceable signs and their respective locations, along with bounding boxes to distinguish areas of enforcement. The defendants parked vehicle was not in fact inside any enforcement zone as shown in the sitemap provided by the claimant. Therefore, the defendant asks the court to strike the claim on this ground.
    ...and near the top of the defence you should spell out what the parking event was about because the draft so far is all template stuff and almost no facts of the case, so you need to tell the Judge things like this (these points will need numbering, per paragraph):



    A parking charge was issued for an allegation of "not parked within a designated bay" but this was contested on appeal because there were no bay lines other than "bricks" in the pavement and no signs at all in view, relating to this spot. The nearest sign is on another wall some 25 metres away and relating to a separate car park area.

    The place where the car was parked has room for two cars and the residents confirm that it is usual to park two cars here, as was the case. Indeed I have evidence from Google maps that this is/has historically been used as a two car space and the residents confirm they are not charged for using it for two vehicles. No signs preclude or restrict the parking of two vehicles at this place so there was no contravention. Even if the signage terms are considered by the court to be possibly capable of creating a contract, they were unlit and 25 metres away, at the entrance to a car park and it is not reasonable to assume that a car park sign elsewhere on a dark wall, relates to these isolated/unmarked spaces.

    The signs are in any event, prohibitive and make no offer. Consideration does not flow between a driver and this Claimant, when parking in these double-car spaces on this roadway, so there was no agreed contract.

    I was parked as a legitimate visitor, upon the invitation of the residents who are tenants at this location where there is no restriction upon this unallocated double car space and no known charge for using it. The residents have rights of way and easements flowing from their Tenancy Agreement and, as this area is outside the enforcement area, Link Parking have no right to disregard the rights of residents and their visitors.

    In this regard, I rely upon the transcripts in the (Gladstones solicitors) cases of:
    - Link Parking v Parkinson - C7GF50J7
    - PACE v Noor - C6GF14F0
    - and the persuasive Appeal decision from 2016 by His Honour Charles Harris QC: Jopson v Home Guard - B9GF0A9E.

    The residents' Tenancy terms/permit terms (which do not mention any parking charge risk) and the above court transcripts will be provided in evidence. The cases support the view that penalties which ignore the rights of residents make life in a block of flats ''unworkable'' and it was found in each case that the signs - such as they are - were of no consequence and created no new contract terms capable of unilaterally varying the grant under a residential lease. Indeed the parking restrictions foisted upon residents and visitors were a matter of derogation from grant and I believe my case, as a legitimate visitor of a resident with primacy of contract, is on all fours with those cases.

    In any event, this space is not within the 'site map' enforcement area as evidenced to the IAS stage appeal, where it can be noted that the anonymous (Trade Body provided) so-called 'adjudicator' saw and commented that the evidence from this operator failed to show sufficient nearby signs and/or marked lines. Bizarrely, the decision still went against me on the spurious reasoning that a previous PCN issued in another area for a completely different reason must mean that I was 'aware of the restrictions'.

    I realise now I had little or no chance of success during the spurious 'appeal' process. It is a fact that this Claimant is a member of the 'International Parking Community' (IPC), a Trade Body which also operates the Independent Appeals Service (IAS) which is seen as anything but a fair 'ADR'. Turning down my appeal based merely on the fact I had paid a different PCN months before, is sadly typical of the spurious decisions regularly reported in the public domain, calling into question the independence of the IAS.

    Both the IPC and IAS are run by the same two Directors who also run Gladstones Solicitors. The individuals in question are John Davies and William Hurley. This set-up is incapable of providing any fair means for motorists to challenge parking charges, as well as potentially breaching the SRA Code of Conduct. Due to this conflict of interests, the Claimant and their representatives do not come to this matter with clean hands and far too many cases are resulting in claims because this notorious industry runs two conflicting Trade Bodies, both proving incapable of self-regulation/fair appeals.
    Last edited by Coupon-mad; 12-04-2017 at 6:56 PM.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Luke Rick
    • By Luke Rick 15th Apr 17, 3:52 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Unless you have 2 claims, you need to remove anything talking about 2 claims, like the above.

    And remove the '12' from here:



    ...and why above, do you say the claim is £16x.x9, yet later you give a different sum in 9c:
    These were the charges for the original PCN, to the inflated price that they further amounted to. The original charge was that of £60, risen to £100 if not paid to in 14 days. Total charge now is £237.49. £162.49 amount claimed, £25 court fee and £50 legal representative's costs.



    And this is too wordy and I think this should be nearer the top of your defence if this is true:



    ...and near the top of the defence you should spell out what the parking event was about because the draft so far is all template stuff and almost no facts of the case, so you need to tell the Judge things like this (these points will need numbering, per paragraph):



    A parking charge was issued for an allegation of "not parked within a designated bay" but this was contested on appeal because there were no bay lines other than "bricks" in the pavement and no signs at all in view, relating to this spot. The nearest sign is on another wall some 25 metres away and relating to a separate car park area.

    The place where the car was parked has room for two cars and the residents confirm that it is usual to park two cars here, as was the case. Indeed I have evidence from Google maps that this is/has historically been used as a two car space and the residents confirm they are not charged for using it for two vehicles. No signs preclude or restrict the parking of two vehicles at this place so there was no contravention. Even if the signage terms are considered by the court to be possibly capable of creating a contract, they were unlit and 25 metres away, at the entrance to a car park and it is not reasonable to assume that a car park sign elsewhere on a dark wall, relates to these isolated/unmarked spaces.

    The signs are in any event, prohibitive and make no offer. Consideration does not flow between a driver and this Claimant, when parking in these double-car spaces on this roadway, so there was no agreed contract.

    I was parked as a legitimate visitor, upon the invitation of the residents who are tenants at this location where there is no restriction upon this unallocated double car space and no known charge for using it. The residents have rights of way and easements flowing from their Tenancy Agreement and, as this area is outside the enforcement area, Link Parking have no right to disregard the rights of residents and their visitors.

    In this regard, I rely upon the transcripts in the (Gladstones solicitors) cases of:
    - Link Parking v Parkinson - C7GF50J7
    - PACE v Noor - C6GF14F0
    - and the persuasive Appeal decision from 2016 by His Honour Charles Harris QC: Jopson v Home Guard - B9GF0A9E.

    The residents' Tenancy terms/permit terms (which do not mention any parking charge risk) and the above court transcripts will be provided in evidence. The cases support the view that penalties which ignore the rights of residents make life in a block of flats ''unworkable'' and it was found in each case that the signs - such as they are - were of no consequence and created no new contract terms capable of unilaterally varying the grant under a residential lease. Indeed the parking restrictions foisted upon residents and visitors were a matter of derogation from grant and I believe my case, as a legitimate visitor of a resident with primacy of contract, is on all fours with those cases.

    In any event, this space is not within the 'site map' enforcement area as evidenced to the IAS stage appeal, where it can be noted that the anonymous (Trade Body provided) so-called 'adjudicator' saw and commented that the evidence from this operator failed to show sufficient nearby signs and/or marked lines. Bizarrely, the decision still went against me on the spurious reasoning that a previous PCN issued in another area for a completely different reason must mean that I was 'aware of the restrictions'.

    I realise now I had little or no chance of success during the spurious 'appeal' process. It is a fact that this Claimant is a member of the 'International Parking Community' (IPC), a Trade Body which also operates the Independent Appeals Service (IAS) which is seen as anything but a fair 'ADR'. Turning down my appeal based merely on the fact I had paid a different PCN months before, is sadly typical of the spurious decisions regularly reported in the public domain, calling into question the independence of the IAS.

    Both the IPC and IAS are run by the same two Directors who also run Gladstones Solicitors. The individuals in question are John Davies and William Hurley. This set-up is incapable of providing any fair means for motorists to challenge parking charges, as well as potentially breaching the SRA Code of Conduct. Due to this conflict of interests, the Claimant and their representatives do not come to this matter with clean hands and far too many cases are resulting in claims because this notorious industry runs two conflicting Trade Bodies, both proving incapable of self-regulation/fair appeals.
    Originally posted by Coupon-mad


    I think i mat be out of time here? I'm kinda panicking!! I've been away with work and i understand 28 days from court date? The issue date is 17/03/17 so i make it 29 days?? Am i out of time!!?!? Help!!

    Your help is much appreciated here! I cannot thank you enough!
    • Luke Rick
    • By Luke Rick 15th Apr 17, 4:06 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    To speed things up, hopefully, here is the newly drafted one with your input Coupon-Mad.

    ----


    1) It is admitted that the defendant, Mr -------, residing at ----------- is the registered keeper of the vehicle.

    2) The vehicle was parked on the land alleged in the defendant’s claim.

    3) It is denied that any 'parking charges/damages and indemnity costs' (whatever they might be) are owed and any debt is denied in its entirety.

    4) A sitemap was provided which the sitemap indicates the area of coverage by a key that had been drawn at the bottom of the sitemap, symbolizing 3 different enforceable signs and their respective locations, along with bounding boxes to distinguish areas of enforcement. The defendants parked vehicle was not in fact inside any enforcement zone as shown in the sitemap provided by the claimant. Therefore, the defendant asks the court to strike the claim on this ground.

    5) A parking charge was issued for an allegation of "not parked within a designated bay" but this was contested on appeal because there were no bay lines other than "bricks" in the pavement and no signs at all in view, relating to this spot. The nearest sign is on another wall some 25 metres away and relating to a separate car park area.


    6) The place where the car was parked has room for two cars and the residents confirm that it is usual to park two cars here, as was the case. Indeed I have evidence from Google maps that this is/has historically been used as a two car space and the residents confirm they are not charged for using it for two vehicles. No signs preclude or restrict the parking of two vehicles at this place so there was no contravention. Even if the signage terms are considered by the court to be possibly capable of creating a contract, they were unlit and 25 metres away, at the entrance to a car park and it is not reasonable to assume that a car park sign elsewhere on a dark wall, relates to these isolated/unmarked spaces.

    7) The signs are in any event, prohibitive and make no offer. Consideration does not flow between a driver and this Claimant, when parking in these double-car spaces on this roadway, so there was no agreed contract.

    8) I was parked as a legitimate visitor, upon the invitation of the residents who are tenants at this location where there is no restriction upon this unallocated double car space and no known charge for using it. The residents have rights of way and easements flowing from their Tenancy Agreement and, as this area is outside the enforcement area, Link Parking have no right to disregard the rights of residents and their visitors.

    9) In this regard, I rely upon the transcripts in the (Gladstones solicitors) cases of:
    - Link Parking v Parkinson - C7GF50J7
    - PACE v Noor - C6GF14F0
    - and the persuasive Appeal decision from 2016 by His Honour Charles Harris QC: Jopson v Home Guard - B9GF0A9E.

    10) The residents' Tenancy terms/permit terms (which do not mention any parking charge risk) and the above court transcripts will be provided in evidence. The cases support the view that penalties which ignore the rights of residents make life in a block of flats ''unworkable'' and it was found in each case that the signs - such as they are - were of no consequence and created no new contract terms capable of unilaterally varying the grant under a residential lease. Indeed the parking restrictions foisted upon residents and visitors were a matter of derogation from grant and I believe my case, as a legitimate visitor of a resident with primacy of contract, is on all fours with those cases.

    11) In any event, this space is not within the 'site map' enforcement area as evidenced to the IAS stage appeal, where it can be noted that the anonymous (Trade Body provided) so-called 'adjudicator' saw and commented that the evidence from this operator failed to show sufficient nearby signs and/or marked lines. Bizarrely, the decision still went against me on the spurious reasoning that a previous PCN issued in another area for a completely different reason must mean that I was 'aware of the restrictions'.


    12) I realise now I had little or no chance of success during the spurious 'appeal' process. It is a fact that this Claimant is a member of the 'International Parking Community' (IPC), a Trade Body which also operates the Independent Appeals Service (IAS) which is seen as anything but a fair 'ADR'. Turning down my appeal based merely on the fact I had paid a different PCN months before, is sadly typical of the spurious decisions regularly reported in the public domain, calling into question the independence of the IAS.

    13) Both the IPC and IAS are run by the same two Directors who also run Gladstones Solicitors. The individuals in question are John Davies and William Hurley. This set-up is incapable of providing any fair means for motorists to challenge parking charges, as well as potentially breaching the SRA Code of Conduct. Due to this conflict of interests, the Claimant and their representatives do not come to this matter with clean hands and far too many cases are resulting in claims because this notorious industry runs two conflicting Trade Bodies, both proving incapable of self-regulation/fair appeals.

    14) This is a completely unsubstantiated and inflated three-figure sum, vaguely and incoherently adduced by the claimant's solicitors in the following claim: ------. The Particulars are not clear and concise in their Particulars of Claim found on the Claim Form.

    15) The Particulars of Claims fails to fulfil CPR16.4 because it does not include a statement of the facts on which the claimant relies, only referring to a “Parking Charge Notice(s)” with no further description. The defendant also believes there has been a similar Particulars of Claims dismissed at another court, and suggest they are simply “robo-filing”. This is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers.

    16) The Claimant has at no time provided an explanation of how the sum has been calculated, the conduct that gave rise to it or how the amount has climbed from £100 to £162.49. This appears to be an added cost invented fancifully and an attempt at double recovery, which the Protection Of Freedoms Act 2012 Schedule 4 specifically disallows.

    17) This claim merely states: ''parking charges/damages and indemnity costs if applicable'' which does not give any indication of on what basis the claim is brought. For example whether this charge is founded upon an allegation of trespass or 'breach of contract' or contractual 'unpaid fees'. Nor are any clear times or coherent grounds for any lawful claim particularised, nor were any details provided to evidence any contract created nor any copy of this contract, nor explanation for the vague description 'parking charges' and 'indemnity costs'. As the contractors are not the land owners, it is also unclear as to how “damages” are caused.

    18) The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.

    19) I have reason to believe that this is a claim that will proceed without any facts or evidence supplied until the last possible minute, to my significant detriment as an unrepresented Defendant.

    a) This is a speculative serial litigant, issuing a large number of identical 'draft particulars'. The badly mail-merged documents contain very little information.

    b) The Claim includes a sum of £50, described as ‘Legal Representative’s costs’. Given the Claimant uses a fully automated, bulk processing service, requiring no intervention from a Solicitor often generating up to £50,000 of income they are put to strict proof to show how this cost has been incurred. The Claimant is put to strict proof of all his assertions.


    c) The Claim is in excess of £230. Without information to the contrary, I believe the original amount for a Parking Charge would have been £100 or £60 if paid within the first 14 days. Given the Claimant uses a fully automated, bulk processing service, I also object to all additional charges associated with this Claim and the Claimant is put to strict proof of all his assertions.

    20) I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.

    21) I request the court strike out this claim for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.

    Statement of Truth: I confirm that the contents of this statement are true to the best of my knowledge and belief.
    • Luke Rick
    • By Luke Rick 15th Apr 17, 4:32 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Could someone just clarify and confirm this please?

    "2. You should now Acknowledge Service of the claim, ticking the box that says you will defend in full. Do NOT put anything in the 'Defence and Counterclaim' text box, not even a full stop. By doing this, you have extended the time to submit a defence to 28 days from date of service, which is the date printed on the claim form plus 5 days. Now it's time to burn the midnight oil, and research relevant defences on these forums. Only look at recent stuff, and don't just blindly cut and paste text, you must adapt it so that it's relevant to your claim."

    Why is this +5 days? The issue date on my form is the 17th March. Does this mean i have until 18th April? Thank you in advanced.
    • Coupon-mad
    • By Coupon-mad 15th Apr 17, 9:32 PM
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    Coupon-mad
    ''...and why above, do you say the claim is £16x.x9, yet later you give a different sum in 9c:''
    These were the charges for the original PCN, to the inflated price that they further amounted to. The original charge was that of £60, risen to £100 if not paid to in 14 days. Total charge now is £237.49. £162.49 amount claimed, £25 court fee and £50 legal representative's costs.
    So you still need to consistently object to the full sum of £237.49 (in both places). It reads wrong to state two different sums.


    Why is this +5 days? The issue date on my form is the 17th March. Does this mean i have until 18th April?
    Yes. Up to 5 days is added for service (delivery) of the court claim form to you, and yours was dated on a Friday anyway, so that's only fair.

    I would finish this defence this long weekend then email it to the CCBC as a PDF attachment on Tuesday morning. You are not out of time.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Coupon-mad
    • By Coupon-mad 15th Apr 17, 9:35 PM
    • 51,504 Posts
    • 65,105 Thanks
    Coupon-mad
    Just to add that you could nail it more here near the start, so the Judge in the end, at a hearing, doesn't miss this crucial point:

    2) The vehicle was parked on the land alleged in the defendant’s claim but not within their enforcement boundaries, according to evidence provided by this Claimant themselves.
    And did I understand it right that you were visiting friends who are tenants? Or are you the tenant here?
    Last edited by Coupon-mad; 15-04-2017 at 9:38 PM.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Luke Rick
    • By Luke Rick 16th Apr 17, 12:07 AM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Okay thanks. I did have it planned out i would drive and hand deliver the letter Monday to the court, but if i can e-mail it, i'll do that.

    That is correct. Edit: -

    Also to state, there was a letter sent to them stating that Link Parking would start enforcing their area. This was dated 19/09/15 and it stated...

    "Dear Resident, Due to a recent increase in complaints related to on site parking we wish to inform you of the following:

    - As a result of numerous complaints by residents regarding outsiders parking in the development, we are implementing parking permits for visitors bays and ticketing on site.
    - Visitor bays will be clearly marked as of Friday 25th September 2015.
    - 1 Visitor permit will be issued per unit.
    - A permit must be clearly displayed when any vehicle is parked within a visitor parking bay.
    - Residents must park their vehicles in their designated parking bays only.
    - Any cars parked outside the boundaries of a bay will be ticketed.
    - Parking in front of the Crescent building is prohibited. Cars will be ticked.
    - If you wish to have your designated bay monitored free of charge please register your parking bay and car registration numbers on the Link Parking Website.
    - The car parking area is monitored by an independent company; Link Parking Ltd.
    - Any issues related to car parking on the site must be addressed to Link Parking Ltd and not First Port Bespoke Property Services. First Port has NO control over the revoking of tickets. These queries must be directed to Link Parking Ltd.

    This was the letter addressed to my friend, and no doubt what so ever would the other tenant (his friend, the spot i was in) have the same letter stating this.

    Edit: I have a copy of the letter that the friend has taken a picture of for me, should i need this in Court. Will this in anyway help?
    Last edited by Luke Rick; 17-04-2017 at 10:45 AM.
    • Luke Rick
    • By Luke Rick 16th Apr 17, 4:01 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    I appreciate all the help from everyone, namely Coupon-Mad.

    Would anyone be able to just confirm the e-mail address i can file my defence to? I don't want to get caught out by sending this to the wrong people!! I cannot see an email address on the court documents either....

    Thanks in advanced on this part.
    Last edited by Luke Rick; 16-04-2017 at 9:41 PM.
    • Coupon-mad
    • By Coupon-mad 16th Apr 17, 9:17 PM
    • 51,504 Posts
    • 65,105 Thanks
    Coupon-mad
    I don't think that letter helps, I would edit that post and remove that quote above. Better evidence came from Link themselves with those boundaries marked out showing the area was not part of the enforcement - plus you could ask your friends AND the owner of the allocated parking space, to provide witness statements for you later when you do your one before the hearing, confirming this:

    {they had} permission from the owner of that spot to use it as they did not have any cars to park there. This had been agreed verbally between them and over the course of nearly 2 years tenancy, no PCN tickets have been issued, even with 2 cars parked on the exact spot where i received my PCN.
    Email for CCBC is:

    ccbcaq@hmcts.gsi.gov.uk

    No need to send a copy to the other side. CCBC do that at this stage.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Luke Rick
    • By Luke Rick 17th Apr 17, 1:47 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Just had another breakthrough with this. Well, not maybe a breakthrough, but was just double checking all paper work and evidence they have provided. On their sitemap, they have done this by a key, symbolizing all their signs (there are a total of 3 different signs throughout the site). They have shown that the particular sign in question would be that designated as "Type 5". Now, they have attached Type 5 sign to their evidence, however, i have a picture of the sign that is there on site and it is NOT as they describe.

    Their Sign 5 Evidence as states: "Vehicles displaying a Valid Parking Permit and Parked in the Correct Allocated Bay"...

    Whereas..

    The sign actually reads: "Vehicles parking within the confines of a marked bay".

    Could this also be used as a defence in regards to their completely stupidity when submitting evidence that is completely inaccurate?
    • Umkomaas
    • By Umkomaas 17th Apr 17, 4:06 PM
    • 15,490 Posts
    • 24,199 Thanks
    Umkomaas
    Could this also be used as a defence in regards to their completely stupidity when submitting evidence that is completely inaccurate?
    Why not? Just adds to the hoops they will need to jump through, although it's not necessarily the showstopper.
    We cannot provide you with a silver bullet to get you out of this. You have to be in for the long run, and need to involve yourself in research and work for you to get rid of this. It is not simple. We will help, but can't do it for you.

    Give a man a fish, and you feed him for a day; show him how to catch fish, and you feed him for a lifetime.
    • Luke Rick
    • By Luke Rick 17th Apr 17, 6:00 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Final draft i believe till i can submit via e-mail.Feedback much appreciated.

    -----------

    1) It is admitted that the defendant, Mr --------, residing at --------- is the registered keeper of the vehicle.

    2) The vehicle was parked on the land alleged in the defendant’s claim but not within their enforcement boundaries, according to evidence provided by this Claimant themselves.

    3) It is denied that any 'parking charges/damages and indemnity costs' (whatever they might be) are owed and any debt is denied in its entirety.

    4) A sitemap was provided at the IAS appeals stage, which the sitemap indicates the area of coverage by a key that had been drawn at the bottom of the sitemap, symbolizing 3 different enforceable signs and their respective locations, along with bounding boxes to distinguish areas of enforcement. The defendants parked vehicle was not in fact inside any enforcement zone as shown in the sitemap provided by the claimant. Therefore, the defendant asks the court to strike the claim on this ground.

    5) Along with the sitemap provided, all 3 enforceable signs within the site were posted as their evidence. The claimant shows in the sitemap that the sign in question for this PCN, would be that designated as "Type 5". The “Type 5” signage as the claimant evidence at the appeals stage reads: "Vehicles displaying a Valid Parking Permit and Parked in the Correct Allocated Bay". Whereas, the signage in question actually reads: "Vehicles parking within the confines of a marked bay".

    6) Not only have they failed to follow their own enforcement areas, but the evidence they’ve also supplied is incorrect.

    7) A parking charge was issued for an allegation of "not parked within a designated bay" but this was contested on appeal because there were no bay lines other than "bricks" in the pavement and no signs at all in view, relating to this spot. The nearest sign is on another wall some 25 metres away and relating to a separate car park area.

    8) The place where the car was parked has room for two cars and the residents confirm that it is usual to park two cars here, as was the case. Indeed I have evidence from Google maps that this is/has historically been used as a two car space and the residents confirm they are not charged for using it for two vehicles. No signs preclude or restrict the parking of two vehicles at this place so there was no contravention. Even if the signage terms are considered by the court to be possibly capable of creating a contract, they were unlit and 25 metres away, at the entrance to a car park and it is not reasonable to assume that a car park sign elsewhere on a dark wall, relates to these isolated/unmarked spaces.

    9) The signs are in any event, prohibitive and make no offer. Consideration does not flow between a driver and this Claimant, when parking in these double-car spaces on this roadway, so there was no agreed contract.

    10) I was parked as a legitimate visitor, upon the invitation of the residents who are tenants at this location where there is no restriction upon this unallocated double car space and no known charge for using it. The residents have rights of way and easements flowing from their Tenancy Agreement and, as this area is outside the enforcement area, Link Parking have no right to disregard the rights of residents and their visitors.

    11) In this regard, I rely upon the transcripts in the (Gladstones solicitors) cases of:
    - Link Parking v Parkinson - C7GF50J7
    - PACE v Noor - C6GF14F0
    - and the persuasive Appeal decision from 2016 by His Honour Charles Harris QC: Jopson v Home Guard - B9GF0A9E.


    12) The residents' Tenancy terms/permit terms (which do not mention any parking charge risk) and the above court transcripts will be provided in evidence. The cases support the view that penalties which ignore the rights of residents make life in a block of flats ''unworkable'' and it was found in each case that the signs - such as they are - were of no consequence and created no new contract terms capable of unilaterally varying the grant under a residential lease. Indeed the parking restrictions foisted upon residents and visitors were a matter of derogation from grant and I believe my case, as a legitimate visitor of a resident with primacy of contract, is on all fours with those cases.

    13) In any event, this space is not within the 'site map' enforcement area as evidenced to the IAS stage appeal, where it can be noted that the anonymous (Trade Body provided) so-called 'adjudicator' saw and commented that the evidence from this operator failed to show sufficient nearby signs and/or marked lines. Bizarrely, the decision still went against me on the spurious reasoning that a previous PCN issued in another area for a completely different reason must mean that I was 'aware of the restrictions'.

    14) I realise now I had little or no chance of success during the spurious 'appeal' process. It is a fact that this Claimant is a member of the 'International Parking Community' (IPC), a Trade Body which also operates the Independent Appeals Service (IAS) which is seen as anything but a fair 'ADR'. Turning down my appeal based merely on the fact I had paid a different PCN months before, is sadly typical of the spurious decisions regularly reported in the public domain, calling into question the independence of the IAS.

    15) Both the IPC and IAS are run by the same two Directors who also run Gladstones Solicitors. The individuals in question are John Davies and William Hurley. This set-up is incapable of providing any fair means for motorists to challenge parking charges, as well as potentially breaching the SRA Code of Conduct. Due to this conflict of interests, the Claimant and their representatives do not come to this matter with clean hands and far too many cases are resulting in claims because this notorious industry runs two conflicting Trade Bodies, both proving incapable of self-regulation/fair appeals.

    16) The full charge is a completely unsubstantiated and inflated three-figure sum, vaguely and incoherently adduced by the claimant's solicitors in the following claim: ------------. The Particulars are not clear and concise in their Particulars of Claim found on the Claim Form.

    17) The Particulars of Claims fails to fulfil CPR16.4 because it does not include a statement of the facts on which the claimant relies, only referring to a “Parking Charge Notice(s)” with no further description. The defendant also believes there has been a similar Particulars of Claims dismissed at another court, and suggest they are simply “robo-filing”. This is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers.

    18) The Claimant has at no time provided an explanation of how the sum has been calculated, the conduct that gave rise to it or how the amount has climbed from £100 to £162.49. This appears to be an added cost invented fancifully and an attempt at double recovery, which the Protection Of Freedoms Act 2012 Schedule 4 specifically disallows.

    19) This claim merely states: ''parking charges/damages and indemnity costs if applicable'' which does not give any indication of on what basis the claim is brought. For example whether this charge is founded upon an allegation of trespass or 'breach of contract' or contractual 'unpaid fees'. Nor are any clear times or coherent grounds for any lawful claim particularised, nor were any details provided to evidence any contract created nor any copy of this contract, nor explanation for the vague description 'parking charges' and 'indemnity costs'. As the contractors are not the land owners, it is also unclear as to how “damages” are caused.

    20) The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no due diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar poorly produced claims and the solicitor's conduct in many of these cases is believed to be currently the subject of an active investigation by the SRA.

    21) I have reason to believe that this is a claim that will proceed without any facts or evidence supplied until the last possible minute, to my significant detriment as an unrepresented Defendant.

    a) This is a speculative serial litigant, issuing a large number of identical 'draft particulars'. The badly mail-merged documents contain very little information.

    b) The Claim includes a sum of £50, described as ‘Legal Representative’s costs’. Given the Claimant uses a fully automated, bulk processing service, requiring no intervention from a Solicitor often generating up to £50,000 of income they are put to strict proof to show how this cost has been incurred. The Claimant is put to strict proof of all his assertions.

    c) The Claim is £162.49 without the added “Court Fee” and “Legal Representative’s Costs”. Without information to the contrary, I believe the original amount for a Parking Charge would have been £100 or £60 if paid within the first 14 days. Given the Claimant uses a fully automated, bulk processing service, I also object to all additional charges associated with this Claim and the Claimant is put to strict proof of all his assertions.

    22) I suggest that parking companies using the small claims track as a form of aggressive, automated debt collection is not something the courts should be seen to support.

    23) I request the court strike out this claim for similar reasons cited by District Judge Cross of St Albans County Court on 20/09/16 where a similar claim was struck out without a hearing, due to Gladstones' template particulars for a private parking firm being 'incoherent', failing to comply with CPR16.4, and ''providing no facts that could give rise to any apparent claim in law''.

    Statement of Truth: I confirm that the contents of this statement are true to the best of my knowledge and belief.
    Last edited by Luke Rick; 17-04-2017 at 6:34 PM.
    • Luke Rick
    • By Luke Rick 22nd Jun 17, 3:36 PM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    Update here: So i've filed for no specials directional hearing (i.e. to be heard on papers alone) and has been submitted to my local court. I'm guessing it's time to start getting my court documents ready?
    • Redx
    • By Redx 22nd Jun 17, 4:51 PM
    • 16,504 Posts
    • 20,667 Thanks
    Redx
    yes, all explained in the NEWBIES thread, post #2

    evidence , pictures , documents , transcripts , witness statements , etc
    Newbies !!
    Private Parking ticket? check the 2 sticky threads by coupon-mad and crabman in the Parking Tickets, Fines & Parking Board forum for the latest advice or maybe try pepipoo or C.A.G. or legal beagles forums if you need legal advice as well because this parking forum is not about debt collectors or legal matters per se
    • Coupon-mad
    • By Coupon-mad 22nd Jun 17, 11:26 PM
    • 51,504 Posts
    • 65,105 Thanks
    Coupon-mad
    Update here: So i've filed for no specials directional hearing (i.e. to be heard on papers alone) and has been submitted to my local court. I'm guessing it's time to start getting my court documents ready?
    Originally posted by Luke Rick
    What? Why? Look at other threads by:

    Jack Basta

    Gin and Milk


    both usernames with Gladstones cases showing how to have refused that idea. I hope I am misunderstanding you and you have asked for 'no' paper hearing, and that you are having a face to face hearing?

    Please tell us you didn't go along with Gladstones little trick where they 'suggest' a paper hearing would be good?
    Last edited by Coupon-mad; 22-06-2017 at 11:31 PM.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Luke Rick
    • By Luke Rick 7th Jul 17, 7:33 AM
    • 24 Posts
    • 9 Thanks
    Luke Rick
    What? Why? Look at other threads by:

    Jack Basta

    Gin and Milk


    both usernames with Gladstones cases showing how to have refused that idea. I hope I am misunderstanding you and you have asked for 'no' paper hearing, and that you are having a face to face hearing?

    Please tell us you didn't go along with Gladstones little trick where they 'suggest' a paper hearing would be good?
    Originally posted by Coupon-mad
    Apologies, may have been my wording. I have opted for a hearing, absolutely. I am not doing this on papers.
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