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PCN from G24 Ltd

pould
pould Posts: 252 Forumite
Part of the Furniture 100 Posts Photogenic Name Dropper
edited 27 August 2015 at 3:43PM in Parking tickets, fines & parking
Hi folks,

I've received a PCN from G24 Ltd and have written the below letter in response. I think I'm pretty well on top of it, but any extra advice warmly welcomed.

Thanks,

Peter+

Letter Follows

I have received a communication from you which arrived on the 26th of August 2015 claiming a breach of contract between the driver of the vehicle registered XXXXXXX of which I am the registered keeper.
At this point I accept no liability and do not accept any breach of contract. I do not admit being the driver of the vehicle at the time in question.
In order to proceed in this matter, please address the following issues.
i) The alleged breach of contract occurred on the 11th of August 2015. The Parking Charge Notice to Keeper was delivered through my front door on Wednesday the 26th of August 2015 by the Royal Mail. This is a period of FIFTEEN DAYS. The Protection of Freedom Act 2012, Schedule 4, Paragraph 9(5) states that the Notice to Keeper must be delivered WITHIN FOURTEEN DAYS of the alleged breach of contract.
Please provide me with a proof of date of posting. Please note, I will not accept as sufficient evidence an internal date of issue – you must provide me with clear documentary evidence that the Notice to Keeper was handed over to your specified agents for delivery on or before the 23rd of August 2015 in order for me to accept a reasonable presumption of delivery two working days after postage.
ii) You state in your Notice to Keeper that the property on which the vehicle was parked belongs not to G24 Limited but rather to your client. Therefore, in order to pursue this matter please provide for me:
a. The full legal title of your client
b. Evidence that your client holds claim and title deed to the specific place where the vehicle XXXXXXX was allegedly parked. Please note, this must be either the original title deed to the land OR a certified copy of the title deed. I will not accept a photocopy as necessary proof. If you require any of this documentation to be returned to you please provide sufficient paid postage and packing material for its return.
c. Evidence that a contract exists between you and your client in this matter of establishing a contract for parking on your land. Please note, this must be either the original contract IN ITS ENTIRITY OR a certified copy of the original contract IN ITS ENTIRITY. I will not accept a photocopy as necessary proof. If you require any of this documentation to be returned to you please provide sufficient paid postage and packing material for its return.
iii) Please note in regard to ii(b) above, reasonable evidence will need to be submitted that the vehicle registered XXXXXXX was actually parked on your property, not simply that it passed through the entrance to your property and exited from your property whilst actually being parked on a third party’s property.
iv) Please outline the costs involved in calculating the charge being demanded under the breach of contract (£100). Where a claim for loss of revenue connected to lack of ability for customers of your client to park at their store is to be made, please demonstrate that for the time in question – 10:48:06 11 August 2015 to 12:04:47 11 August 2015 – there were no other parking spaces available on this site and that therefore such a loss was actual.
v) Please provide documentary evidence of how you have acquired my personal details as the registered keeper of this vehicle. Where a submission to the DVLA has been made, please provide evidence of the submission and your legal right to make such a submission.
Please also note the following.
vi) Where any further demand for money is made from myself as the registered keeper of XXXXXXX for this alleged breach of contract WITHOUT first providing the reasonable evidence of the existence of a contract as requested above in points (i), (ii) and (iii), I shall consider such a demand for money HARASSMENT as defined in Section 1 of the Protection from Harassment Act 1997 and shall contact the Police accordingly.
vii) Where any further demand for money is made from myself as the registered keeper of XXXXXXX for this alleged breach of contract WITHOUT first providing the reasonable assurances in sections (iv) and (v) above, a repeat of this letter will be issued. I reserve the right to charge G24 Ltd the cost of £25 per letter issued. Your delivery of a letter to me without the material requested in sections (iv) and (v) will be considered an acceptance of these terms.
Sincerely,
«134567

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