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SCS Law - CP Plus Ltd LBC letter

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Comments

  • Coupon-mad
    Coupon-mad Posts: 155,731 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Ah yes! Sorry, I was assuming Gladstones but SCS are no better. Yes please show us your draft.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Hello all - this might be a bit wooly but its a first pass. I do want to reply - I know Bargepole you told me not to bother...
    Why? It makes no difference what you say in your response, and they probably won't even bother reading it. If they are going to issue a claim, they will do so anyway
    .

    and I am confident you are right and bow to your experience but they stated they had sent me all the additional detail and evidence I had requested but all I received was a single piece of paper - it kinda feels like I am being set up for a fall, so I want to level this point with them at least.


    Dear Sir or Madam


    I have today received your letter dated 22nd May 2017

    Despite continued reasonable requests for information regarding the allegations made by your client this not been forthcoming, to this end you have not provided sufficient detail to allow me to make any decisions on how to proceed.

    In this letter you state ‘Please find attached copies of the parking charge notices, letters sent to you previously and photographic evidence in relation to the proposed claim’ ; To be clear and for the avoidance of any doubt, this letter arrived as a single sheet of paper with no additional details supplied as stated. Instead you have chosen to respond with continued unfounded unsubstantiated allegations with no additional detail added – this demonstrates a conduct of non-compliance with the Practice Direction – Pre Action Conduct and protocols.

    Quite simply I do not understand your position and I am unable to make decisions about how to proceed given the level of detail you have currently offered.


    Furthermore this is an example of a continued failure to comply with schedule 4 of the Protection of Freedoms act 2012, as I have not yet, despite my many requests received a Notice to Keeper.

    I must remind you of the 'overriding objective' when I once more request the details to support your clients allegations. Please instruct your client to provide me with strict proof of copies of all documentation and all correspondence relating to these allegations, for each alleged contravention; this should include all Notice to Keeper’s issued together with proof of dates of postage for each correspondence sent by your client including the windscreen notices if indeed any were attached to the vehicle.

    I require copies of all photos taken on the dates in question, including all pictures taken of the vehicle and all pictures taken (on each occasion) of any adjacent signage. At this stage I do not know where in the hospital these allegations refer to, and as such am unable to make any judgement on the validity or otherwise of the charges.

    These are fair requests to enable me to even begin to consider my position in relation to these allegations and in turn to understand if indeed I need to formulate a defence.





    Yours Faithfully
  • Coupon-mad
    Coupon-mad Posts: 155,731 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    If they are going to issue a claim, they will do so anyway
    I agree with bargepole, because they will proceed anyway, but on the other hand you are right to fire back that response because this is a series of written exchanges that you can use as part of your defence. It is only reasonable that you tell them in writing that you received no enclosures at all, so you can show the Judge later how reasonable you were, compared to them, at this pre-court stage.

    Email your responses if you can. Better than wasting stamps/letters/postage on this industry of greed.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Do you think this is good to go pretty much as is ?
  • Umkomaas
    Umkomaas Posts: 43,788 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Just a little bit of tidying up.
    Despite continued reasonable requests for information regarding the allegations made by your client this has not been forthcoming, to this end you have not provided sufficient detail to allow me to make any decisions on how to proceed.
    Missing word.
    sent to you previously and photographic evidence in relation to the proposed claim’ ; To be
    A full stop after 'claim', not a semi-colon.
    all correspondence relating to these allegations, have been sent for each alleged contravention
    this should include all Notice to Keeper’s
    Notices to Keeper.
    These are [STRIKE]fair[/STRIKE] reasonable requests to enable me to even begin to consider my position
    Please note, we are not a legal advice forum. I personally don't get involved in critiquing court case Defences/Witness Statements, so unable to help on that front. Please don't ask. .

    I provide only my personal opinion, it is not a legal opinion, it is simply a personal one. I am not a lawyer.

    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.

    Private Parking Firms - Killing the High Street
  • Thanks Umkomaas - top notch corrections - when you've been sitting with your nose pressed against it for hours you miss these things.. :-)
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