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  • FIRST POST
    • faith_f
    • By faith_f 15th Mar 17, 11:11 AM
    • 8Posts
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    faith_f
    PCM Hayes and Harlington
    • #1
    • 15th Mar 17, 11:11 AM
    PCM Hayes and Harlington 15th Mar 17 at 11:11 AM
    Hello everyone,
    The acknowledgment has been done and I am working out on my defense. Can you please have a look at it and let me know if it's ok.
    Tnx
    This is what I think to write as a defence:

    1 I am the Defendant, .........., DOB, and reside at ......... and it is admitted that I was the driver of the vehicle on the day of this event.
    2 I deny any liability to the Claimant whatsoever on the following basis:

    a) Insufficient signage: The PCN was issued on a poorly signed road, where the car had to pull over. The Driver was completely unaware that it is not allowed to park for more that 20 minutes, because of the insufficient signage. I refer to the IPC Code of Practice, Part E, highlighting that entrance signs are necessary- there were none, at that time.
    b) There were no signs at all to highlight that the Driver was not allowed to stay longer than 20 minutes.
    c) There were no entrance signs at all to show that drivers were entering an area of 'parking enforcement' or 'private land'. The road was not marked as a no-stopping zone nor transparently signed as a permit-holders or 'managed' site, as their CoP requires.
    d) In their evidence, PCM have stick to that the Driver have parked in a manner whereby it agreed to pay a charge, as the signage in the area is clear and informs motorist of the restrictions the parking is managed under and that enforcement action will be taken for parking in breach of the restrictions. The only sign was attached to high and the text too small for a driver to see while is in the vehicle, meaning it is not obvious for the motorist , where there were other equally unremarkable building company signs. There was nothing to suggest that one sign could relate to parking on the roadway where the kerb was unmarked. There was no clearway sign nor red lines/hatched lines to communicate 'no stopping' and certainly nothing was seen about permits or how to obtain one, or the charge itself. The IPC Code of practice also gives an example of what the sign should look like. There was no sufficient signage at the site. There was no "P" drawing attention to rules about parking.
    e)The signage was insufficient and illegible, meaning that the Driver did not enter into any agreement about pulling over. I have to state, that the Driver has not parked.The Driver had to stop temporarily to assist a medical incident suffered by a disable child in the car. The Driver was completely unaware, due to insufficient signage. No PCN was placed on the windscreen, the charge was instead issued by the post after remote photos were taken of an occupied car without any attempt to talk to the Driver,whilst it was sat in it. The driver was not alert to move on or if there was any issue. This breaches Part B, section 13.1 of the Code of Practice, referring to professionalism.
    f) The Claimant did not comply with the Part B, section 15 of the Code of Practice regarding grace periods. The photographic evidence submitted by PCM are date and time stamped. It shows the vehicle at 11:58 from the rear back. It then shows the vehicle again from the back at 12:19. I refer to case Vehicle Services LTD vs Ibbotson (2012), in which it is agreed that the Claimant was responsible for mitigating the losses to the landowner. The parking operative had every opportunity to tell the Driver in person that they needed to move the car, but failed to do so.
    3 The IAS is not considered an independent appeals system due to the Assessors' names remaining secret and well-publicised concerns over a conflict of interest. The IAS is a trading name of the IPC who are owned by the same people as the Claimant's Solicitors, Gladstones, who are now bringing this claim. Given this, I do not accept its dismissal of my appeal. Furthermore, PCM submitted false evidence that was accepted by this corrupt system without question.
    I am not willing to accept the decision of the IAS adjudicator who dismissed the appeal, for the reasons stated above.
    4 The Claimant has not complied with the pre-court protocol. The Particulars of Claim contains no details and fails to establish a cause of action which would enable the Defendant to prepare a specific defence. It just states “parking charges” which does not give any indication of on what basis the claim is brought. There is no information regarding why the charge arose, what the original charge was, what the alleged contract was nor anything which could be considered a fair exchange of information. The defendant therefore asks that the court orders the case to be struck out for want of a detailed course of action and/or for the claim as having no prospect of success.
    5 The claimant failed to include a copy of their written contract nor any detail or reason for - nor clear particulars pertaining to - this claim (Practice Directions 16 7.3(1) and 7C 1.4(3A) refer).

    6 The Particulars of Claim (PoC) do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how any terms were breached. Indeed the PoC are not clear and concise as is required by CPR 16.4 1(a) and CPR 1.4. It just vaguely states “parking charges” 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', so I have had to cover all eventualities and this has denied me a fair chance to defend this in an informed way.
    7 The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no diligence, no scrutiny of details nor even checking for a true cause of action. HMCS have identified over 1000 similar sparse claims. I believe the term for such conduct is ‘roboclaims’ which is against the public interest, unfair on unrepresented consumers and 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. On the basis of the above, I request the court strike out the claim.
    8 The Supreme Court Judges in the Beavis case held that a CoP is effectively 'regulation' for the private parking industry, full compliance with which is both expected and binding upon any parking.
    9 No terms were seen because the car was ticketed before the Driver even set foot out of the car. It was given no fair chance to read any terms at all, so the elements of a contract and agreement on any (unknown) charge are absent. Where terms on a parking sign are not seen/known, then there can be no contract. I rely upon the case of Vine v London Borough of Waltham Forest; CA 5 APR 2000, a case won by the consumer on appeal where the Judges also found that clear entrance signs are expected operator.
    10 Any ‘charge’ or terms on signage on the day was not seen but even if the court believes signs were displayed, the terms were in such small print as to be illegible, contrary to the Consumer Rights Act 2015.
    11 I submit that the IAS decision should be disregarded; it is ostensibly described as an appeal service, yet the Assessors' names remain secret. No figures or reports are published by the IAS but the publication 'Parking Review' reported that only 20% of appeals were upheld (compared to POPLA where 50% have consistently been upheld since its inception in 2012). There is no scrutiny board, unlike POPLA. The IAS decisions in the public domain blatantly disregard recognised standards of law or justice.

    12 The IAS is a trading name of the IPC, whose Directors are Will Hurley and John Davies. These Directors, having overseen my IAS appeal being unfairly refused, have now filed this claim because they are also the directors of Gladstones solicitors. It is submitted that this chain of events is founded upon a conflict of interest and operates in breach of the CPUTRs and is contrary to good faith.
    13 The Claimant may try to rely upon ParkingEye Ltd v Beavis [2015] UKSC 67, ('the Beavis case') yet such an assertion is not supported by any similarity in the location, circumstances nor signage. Absent any offer or agreement on a charge, the Beavis case does not assist the claimant and in fact,supports this defence. Further, there is no ‘legitimate interest’ served by immediate ticketing of a car on arrival, with no attempt to mitigate loss or draw terms to the attention of drivers, or allow any period of grace to obtain any permit or even read the signs.
    14 Even if the court is minded to accept that a sign was visible, the wording on the sign was prohibitive. Unlike in the Beavis case, the Claimant offered no licence to park if ‘unauthorised’. A purported licence to stop without a permit, in exchange for payment of a ‘charge’ on the one hand, cannot be offered when that same conduct is, on the other hand, expressly prohibited in the signage wording. This does not create any possible contract.
    15 It is submitted that (apart from properly incurred court fees) any added solicitors fees are simply numbers made up out of thin air, and are an attempt at double recovery by the Claimant, which would not be recoverable in any event.
    16 It is submitted that the Claimant is merely an agent acting ‘on behalf of’ the landowner who would be the only proper claimant. Strict proof is required of a chain of contracts leading from the landowner to this Claimant, to allow them the right to form contracts and to sue in their name.
    17 Even if this is produced, it is submitted that there is no contract offered to drivers not displaying a permit, so alleged 'unauthorised' parking (denied) can only be an event falling under the tort of trespass.
    18 As was confirmed in the Beavis case, ParkingEye could not have claimed any sum at all for trespass, whereby only a party in possession of title in the land could claim nominal damages suffered (and there were none in this material case).
    19 I refer to case Vehicle Services Ltd vs Ibbotson (2012) in which it was agreed that a private parking firm was responsible for mitigating any loss. The parking operative had every opportunity to tell the Driver in person to move on, but failed to do so.
    20 It is submitted that the conduct of the Claimant in pursuing this claim is wholly unreasonable and vexatious. As such, I am keeping a note of my wasted time/costs in dealing with this matter.
    21 The court is invited to strike out the claim, due to no cause of action nor prospects of success.
    22 The facts and information in this defence are true and the Defendant is not liable for the sum claimed, nor any sum at all.


    I believe that facts contained in this Defence Statement are true.


    Can you please have a look and tell me what I have got wrong.
    Thank you
    Last edited by faith_f; 16-03-2017 at 9:04 AM. Reason: spelling
Page 1
    • Coupon-mad
    • By Coupon-mad 15th Mar 17, 11:14 AM
    • 45,770 Posts
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    Coupon-mad
    • #2
    • 15th Mar 17, 11:14 AM
    • #2
    • 15th Mar 17, 11:14 AM
    Have you also posted this in a reply on your own thread? That's the best way to do it as we can then remind ourselves of the background.

    Or, if you have no new thread here yet, copy your opening summary post that I know I've seen on pepipoo (I am SchoolRunMum over there). That will help people see what it is all about.
    PRIVATE PCN in England/Wales? DON'T PAY BUT DO NOT IGNORE IT

    Click on the trail, top of this page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    DON'T read old advice to ignore, unless in Scotland/NI.

    • DoaM
    • By DoaM 15th Mar 17, 11:38 AM
    • 2,221 Posts
    • 2,221 Thanks
    DoaM
    • #3
    • 15th Mar 17, 11:38 AM
    • #3
    • 15th Mar 17, 11:38 AM
    OP first posted on the Motoring board. I suggested they contact a board guide to get it moved here, NOT to duplicate post here! (That's classed as spamming by the way, per forum rules).
    Diary of a madman
    Walk the line again today
    Entries of confusion
    Dear diary, I'm here to stay
    • faith_f
    • By faith_f 15th Mar 17, 9:50 PM
    • 8 Posts
    • 0 Thanks
    faith_f
    • #4
    • 15th Mar 17, 9:50 PM
    • #4
    • 15th Mar 17, 9:50 PM
    I am sorry guys, I have got it messed up, but all these is new for me and I have been doing it through my mobile, as my laptop is dead
    I have posted at the wrong board at first and then copy pasted here.
    I do apologise for my ignorance.
    However, I still need your help.
    Couple of months ago I had a parking ticket charge from PCM. I was ignoring these letters, untill I got letter before claim from Gladstones. As Gan's recommendation (from pepipoo forum) I have send a reply back on the 29th of December, 2016. On the 27th of February, 2017 I have received Claim Form. I have done the acknowledgment and now you can see my defense above.
    So, yes, is there anything else, that I can add or something to remove or correct?
    Thank you
    • Coupon-mad
    • By Coupon-mad 15th Mar 17, 10:02 PM
    • 45,770 Posts
    • 58,730 Thanks
    Coupon-mad
    • #5
    • 15th Mar 17, 10:02 PM
    • #5
    • 15th Mar 17, 10:02 PM
    It's fine, you are here now and on pepipoo so we will help you through.

    However, on pepipoo I re-wrote this for you because it's not good English:

    the Driver HAS NOT PARKED. THE DRIVER HAD TO STOP TEMPORARILY TO ASSIST A MEDICAL INCIDENT, SUFFERED BY DISABLE CHILD IN THE CAR.
    Did you not notice I re-wrote this already for you on the other forum? And I got rid of the capitals, so why are we being shown the first draft not the second one? I've already significantly rewritten parts of your defence, I remember it well.
    PRIVATE PCN in England/Wales? DON'T PAY BUT DO NOT IGNORE IT

    Click on the trail, top of this page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    DON'T read old advice to ignore, unless in Scotland/NI.

    • faith_f
    • By faith_f 16th Mar 17, 8:24 AM
    • 8 Posts
    • 0 Thanks
    faith_f
    • #6
    • 16th Mar 17, 8:24 AM
    • #6
    • 16th Mar 17, 8:24 AM
    Yes, I have change it. I must have copy-pasted the wrong one.
    Tnx
    Last edited by faith_f; 16-03-2017 at 9:07 AM.
    • Coupon-mad
    • By Coupon-mad 16th Mar 17, 8:14 PM
    • 45,770 Posts
    • 58,730 Thanks
    Coupon-mad
    • #7
    • 16th Mar 17, 8:14 PM
    • #7
    • 16th Mar 17, 8:14 PM
    Can we see the right one? I don't want to have to do this twice when I've already made suggestions on wording a week or more ago, on pepipoo.

    I seem to recall already advising other changes on pepipoo as well, none of which have been changed, such as I recall advising you to remove this:

    In their evidence, PCM have stick to that the Driver have parked in a manner whereby it agreed to pay a charge, as the signage in the area is clear and informs motorist of the restrictions the parking is managed under and that enforcement action will be taken for parking in breach of the restrictions.
    PRIVATE PCN in England/Wales? DON'T PAY BUT DO NOT IGNORE IT

    Click on the trail, top of this page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    DON'T read old advice to ignore, unless in Scotland/NI.

    • Gooston
    • By Gooston 17th Mar 17, 10:06 AM
    • 46 Posts
    • 43 Thanks
    Gooston
    • #8
    • 17th Mar 17, 10:06 AM
    • #8
    • 17th Mar 17, 10:06 AM
    When is your court date, faith_f? Goodluck with this.
    • faith_f
    • By faith_f 18th Mar 17, 2:03 PM
    • 8 Posts
    • 0 Thanks
    faith_f
    • #9
    • 18th Mar 17, 2:03 PM
    • #9
    • 18th Mar 17, 2:03 PM
    I am posting the update of the defense. I have add some more things.
    Coupon-mad, many thanks.
    1 I am the Defendant, .........., DOB, and reside at ......... and it is admitted that I was the driver of the vehicle on the day of this event.
    2 The identity of the driver of the vehicle on the date in question has not been ascertained.
    3 The Claimant did not identify the Driver.
    4 The Defendant has no liability, as they are the Keeper of the vehicle and the Claimant must rely upon the strict provision of the Protection of Freedoms Act 2012 in order to hold the defendant responsible for the driver’s allege breach.

    5 I deny any liability to the Claimant whatsoever on the following basis:

    a) Insufficient signage: The PCN was issued on a poorly signed road, where the car had to pull over. The Driver was completely unaware that it is not allowed to park for more that 20 minutes, because of the insufficient signage. I refer to the IPC Code of Practice, Part E, highlighting that entrance signs are necessary- there were none, at that time.
    b) There were no signs at all to highlight that the Driver was not allowed to stay longer than 20 minutes.
    c) There were no entrance signs at all to show that drivers were entering an area of 'parking enforcement' or 'private land'. The road was not marked as a no-stopping zone nor transparently signed as a permit-holders or 'managed' site, as their COP requires.
    d) The only sign was attached to high and the text too small for a driver to see while is in the vehicle, meaning it is not obvious for the motorist , where there were other equally unremarkable building company signs. There was nothing to suggest that one sign could relate to parking on the roadway where the kerb was unmarked. There was no clearway sign nor red lines/hatched lines to communicate 'no stopping' and certainly nothing was seen about permits or how to obtain one, or the charge itself. The IPC Code of practice also gives an example of what the sign should look like. There was no sufficient signage at the site. There was no "P" drawing attention to rules about parking.
    e) The signage was insufficient and illegible, meaning that the Driver did not enter into any agreement about pulling over. I have to state, that the Driver merely stopped temporarily to assist a medical incident, suffered by disabled child in the car. The Driver was completely unaware of any terms disallowing this temporary stop, due to insufficient signage. No PCN was placed on the windscreen; the charge was instead issued by post after remote photos were taken of an occupied car without any attempt to talk to the Driver and alert the Driver to move on if there was any issue.. This breaches Part B, section 13.1 of the Code of Practice, referring to professionalism.
    f) The Claimant did not comply with the Part B, section 15 of the Code of Practice regarding grace periods. The photographic evidence submitted by PCM are date and time stamped. It shows the vehicle at 11:58 from the rear back. It then shows the vehicle again from the back at 12:19. I refer to case Vehicle Services LTD vs Ibbotson (2012), in which it is agreed that the Claimant was responsible for mitigating the losses to the landowner. The parking operative had every opportunity to tell the Driver in person that they needed to move the car, but failed to do so.
    6 The Defendant denies that the Driver would have agreed to pay the original demand of certain amount to agree to the alleged contract had the terms and conditions of the contract been properly displayed and accessible.

    7 The IAS is not considered an independent appeals system due to the Assessors' names remaining secret and well-published concerns over a conflict of interest. The IAS is a trading name of the IPC who are owned by the same people as the Claimant's Solicitors, Gladstones, who are now bringing this claim. Given this, I do not accept its dismissal of my appeal. Furthermore, PCM submitted false evidence that was accepted by this corrupt system without question.
    I am not willing to accept the decision of the IAS adjudicator who dismissed the appeal, for the reasons stated above.
    8 The Defendant would like to point out, that this car park can be fully distinguished from the details, facts, and location in the Beavis case ( Parking Eye Ltd v Beavis [2015] UKSC 67 ). Absent any offer or agreement on a charge, the Beavis case does not assist the claimant and in fact supports this defense. Further, there is no ‘legitimate interest’ served by immediate ticketing of a car on arrival, with no attempt to mitigate loss or draw terms to the attention of drivers, or allow any period of grace to obtain any permit or even read the signs. Whilst the Claimant withheld any photos of the signs on site, the Defendant contends these are illegible with terms hidden in small print, unlike the ‘clear and prominent’ signs which create a contract Mr. Beavis was ‘bound to have seen’.
    9 The Claimant has not complied with the pre-court protocol. The Particulars of Claim contains no details and fails to establish a cause of action which would enable the Defendant to prepare a specific defense. It just states “parking charges” which does not give any indication of on what basis the claim is brought. There is no information regarding why the charge arose, what the original charge was, what the alleged contract was nor anything which could be considered a fair exchange of information. The defendant therefore asks that the court orders the case to be struck out for want of a detailed course of action and/or for the claim as having no prospect of success.

    10 The claimant failed to include a copy of their written contract nor any detail or reason for - nor clear particulars pertaining to - this claim (Practice Directions 16 7.3(1) and 7C 1.4(3A) refer).

    11 On the 20th September 2016 another relevant poorly pleaded private parking charge claim by Gladstones was struck out by District Judge Cross of St. Albans Court without a hearing due to their “roboclaim” particulars being incoherent, failing to comply with CPR 16.4. and “ providing no facts that could give rise to any apparent claim in law”. The Particulars of Claim (POC) do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how any terms were breached. Indeed the POC are not clear and concise as is required by CPR 16.4 1(a) and CPR 1.4. It just vaguely states “parking charges” 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', so I have had to cover all eventualities and this has denied me a fair chance to defend this in an informed way. The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no diligence, no scrutiny of details nor even checking for a true cause of action. HMCS has identified over 1000 similar sparse claims. I believe the term for such conduct of ‘roboclaims’ which is against the public interest, unfair on unrepresented consumers and 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. On the basis of the above, I request the court strike out the claim.

    12 The Supreme Court Judges in the Beavis case held that a COP is effectively 'regulation' for the private parking industry, full compliance with which is both expected and binding upon any parking.

    13 No terms were seen because the car was ticketed before the Driver even set foot out of the car. It was given no fair chance to read any terms at all, so the elements of a contract and agreement on any (unknown) charge are absent. Where terms on a parking sign are not seen/known, then there can be no contract. I rely upon the case of Vine v London Borough of Waltham Forest; CA 5 APR 2000, a case won by the consumer on appeal where the Judges also found that clear entrance signs are expected operator.

    14 Any ‘charge’ or terms on signage on the day was not seen but even if the court believes signs were displayed, the terms were in such small print as to be illegible, contrary to the Consumer Rights Act 2015.

    15 I submit that the IAS decision should be disregarded; it is ostensibly described as an appeal service, yet the Assessors' names remain secret. No figures or reports are published by the IAS but the publication 'Parking Review' reported that only 20% of appeals were upheld (compared to POPLA where 50% have consistently been upheld since its inception in 2012). There is no scrutiny board, unlike POPLA. The IAS decisions in the public domain blatantly disregard recognised standards of law or justice.

    16 The IAS is a trading name of the IPC, whose Directors are Will Hurley and John Davies. These Directors, having overseen my IAS appeal being unfairly refused, have now filed this claim because they are also the directors of Gladstones solicitors. It is submitted that this chain of events is founded upon a conflict of interest and operates in breach of the CPUTRs and is contrary to good faith.
    .

    17 Even if the court is minded to accept that a sign was visible, the wording on the sign was prohibitive. Unlike in the Beavis case, the Claimant offered no license to park if ‘unauthorised’. A purported license to stop without a permit, in exchange for payment of a ‘charge’ on the one hand, cannot be offered when that same conduct is, on the other hand, expressly prohibited in the signage wording. This does not create any possible contract.

    18 It is submitted that (apart from properly incurred court fees) any added solicitors fees are simply numbers made up out of thin air, and are an attempt at double recovery by the Claimant, which would not be recoverable in any event.

    19 The Claimant is not the landowner and suffers no loss, whatsoever as a result of a vehicle parking at the location in question. It is submitted that the Claimant is merely an agent acting ‘on behalf of’ the landowner who would be the only proper claimant. Strict proof is required of a chain of contracts leading from the landowner to this Claimant, to allow them the right to form contracts and to sue in their name. I have the reasonable belief that they do not have the authority to issue charges on this land in their own name and that they have no right to bring action regarding this claim.

    20 Even if this is produced, it is submitted that there is no contract offered to drivers not displaying a permit, so alleged 'unauthorised' parking (denied) can only be an event falling under the tort of trespass.

    21 As was confirmed in the Beavis case, Parking Eye could not have claimed any sum at all for trespass, whereby only a party in possession of title in the land could claim nominal damages suffered (and there were none in this material case).

    22 I refer to case Vehicle Services Ltd vs Ibbotson (2012) in which it was agreed that a private parking firm was responsible for mitigating any loss. The parking operative had every opportunity to tell the Driver in person to move on, but failed to do so.

    23 It is submitted that the conduct of the Claimant in pursuing this claim is wholly unreasonable and vexatious. As such, I am keeping a note of my wasted time/costs in dealing with this matter.

    24 The court is invited to strike out the claim, due to no cause of action nor prospects of success.

    25 The facts and information in this defense are true and the Defendant is not liable for the sum claimed, nor any sum at all.


    I believe that facts contained in this Defense Statement are true.
    • faith_f
    • By faith_f 18th Mar 17, 2:04 PM
    • 8 Posts
    • 0 Thanks
    faith_f
    I still haven't got a court date.
    • faith_f
    • By faith_f 21st Mar 17, 9:51 AM
    • 8 Posts
    • 0 Thanks
    faith_f
    Hi there,
    I hope that someone will have a look at this, as I have to send it next week.
    Thank you
    • Pauloipam
    • By Pauloipam 21st Mar 17, 11:07 AM
    • 17 Posts
    • 0 Thanks
    Pauloipam
    Sorry to interrupt but can someone give me the email I should use to complain a APOCA PCN? Thank you
    • Coupon-mad
    • By Coupon-mad 21st Mar 17, 2:10 PM
    • 45,770 Posts
    • 58,730 Thanks
    Coupon-mad
    Your defence looks fine to submit, so print it out, sign and date and post it to the CCBC at Northampton.

    Sorry to interrupt but can someone give me the email I should use to complain a APOCA PCN?
    If you are appealing a PCN you appeal using the email or online form stated on the PCN.
    PRIVATE PCN in England/Wales? DON'T PAY BUT DO NOT IGNORE IT

    Click on the trail, top of this page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    DON'T read old advice to ignore, unless in Scotland/NI.

    • faith_f
    • By faith_f 22nd Mar 17, 9:52 AM
    • 8 Posts
    • 0 Thanks
    faith_f
    Thank you Coupon-mad
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