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Sip/gladstones draft defence -urgent help required
Anita86
Posts: 9 Forumite
Hi all,
Thanks for taking the time to read this post. I've made a massive booboo and miscalculated the 28 days after AoS, so need to submit a Defence by Wednesday.
The brief details regarding the claim are as follows:
Sorry if I have been too brief with the info, I'm rushing to get this posted but also from what I've read it seemed a typical Gladstone case, with the only difference being the ticket was found to be upside down. However, would that not really be the crux of the argument anyway?
Keeper's used MSF, Parking Prankster, BMPA and Pepipo for all correspondence but is now struggling with defence.
Grateful for any feedback received.
I am XXXXXXX defendant in this matter. It is admitted only that the Defendant was the authorised registered keeper of vehicle XXXXXXX at the time of the alleged incident.
I deny liability for the entirety of the claim, and all allegations implied in pre-action correspondence, based on the following.
1. The Claimant’s Particulars of Claim disclose no legal cause of action to give rise to any debt and do not comply with CPR Part 16 and Practice Direction 16 7.5.
The Particulars of Claim are vague and insufficient and do not disclose an adequate statement of facts proceeding the alleged cause of action.
The particulars of claim states only ‘parking charges’. No particulars are offered in relation to the nature of the agreement, the method the Claimant calculated any outstanding sums due, how they became due or any other matters necessary to substantiate the Claimants claim. The defendant cannot see how this could be considered a fair exchange of information. Due to this the defendant doesn’t consider the particulars of claim to be valid, therefore the defendant invites the court to strike out the claim as the Claimant has no basis for success.!
2. The Claimant has not complied with pre-court protocol and has acted unreasonable
There was no compliant ‘Letter before Claim’ under the Practice Direction. A Letter before Claim was sent to the Defendant; however, this Letter before Claim didn’t comply with the Practice Direction and provided insufficient information. The defendant responded to this LBC on 25/4/2017 and requested copies of the parking notice, evidence of the alleged action of the driver in accordance with the Over-riding objective, evidence of signage terms and evidence of the Claimants right to bring this claim.. The Claimants solicitors acknowledged only part of this request, providing non-timestamped photographs of vehicle XXXXXXX, with all other requests for information ignored. Therefore the Defendant holds a reasonable belief that the claimants solicitors do not possess this information and issued the claim without any due diligence or inspection of this individual case. Withholding evidence and the basis for a claim made against the Defendant, despite this being requested, goes against the SRA code and is contrary to the over riding objective in the pre action protocol.
Furthermore, the original Letter before Claim was missing the following information:
-The cause for action on which the claim was made. The LBC referenced ‘parking charges’ but that in and of itself isn’t a basis for a justifiable claim.
-A clear and detailed summary of the facts on which the claim is based. The original letter fails to provide any detail or evidence around the circumstances surrounding theses charges and why these are owed.
The defendant refers to the practise direction section on non-compliance and sanction, there can be no justifiable excuse for the Claimant’s failure to follow the Pre-action conduct, especially when the claim was issued by the Claimants Solicitors.
3. The Claimant has given no indication of the nature of the alleged charge in the Particulars of Claim. The Claimant has therefore disclosed no cause of action.
4. The website for payment of the parking notice is in the name of IP Car Parks Limited, not the Claimant. The Defendant has the reasonable belief that the Claimant does not manage the car park and puts the Claimant to proof that there is an innocent reason for the contradiction.
5. The identity of the driver of the vehicle on the date in question has yet to be ascertained.
The Claimant did not identify the driver.
The Defendant has no liability, as they are the Keeper of the vehicle and the Claimant must rely upon the strict provisions of the Protection of Freedoms Act 2012 in order to hold the defendant responsible for the drivers alleged breach.
6. It is denied the Defendant entered into a contract with the Claimant.
The signage on-site is not clear, prominent or legible as per Parking Eye v Beavis. It is inadequate to form a contract. The charge is buried in the small print and is an unfair term. The site in question also features signage breaches as per the BPA signage regulations. The entrance to the site is confusing. At neither the address/street name cited on the PCN nor the coordinates for the car park as stated by the Claimant, are clear and prominent terms on display. The Claimant in this case has displayed several distracting signs at various entrance points into the car park, which is not compliant.
In addition, the signage does not contain an obligation as to how to ‘display’ the ticket, therefore there was no breach of any ‘relevant obligation’ or ‘relevant contract’ as required under Schedule 4 of POFA. The terms are not clear, prominent and legible as per Parking Eye v Beavis and 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. This site does not offer free parking, nor is there any comparable ‘legitimate interest’ nor complex contractual arrangement to disengage the penalty rule, as ParkingEye did in the unique case heard by the Supreme Court in 2015. And whilst the Claimant has withheld any photos of the signs on site, the Defendant does contend these are illegible with terms hidden in small print, unlike ‘clear and prominent’ signs which created a contract Mr Beavis was ‘bound to have seen’.
7.The Claimants increasingly demanding letters failed to evidence any contravention.
The Claimant sent threatening and misleading demands which stated failure to pay the charge would result in enforcement action and an increased charge. No figure for additional charge was agreed nor could it have formed part of the alleged contract because no such indemnity costs were quantified on the signs. Terms cannot be added on later with figures seemingly produced out of nowhere.
8. The Defendant has reasonable belief that the claimant didn’t pay their legal representatives £50.00 to prepare the deficient claim that is quite clearly a template with no case specific input.
And so the Defendant does not belief the Claimant has incurred £50 costs to pursue an alleged £100 debt.
Notwithstanding the defendants belief, the costs are in any case unrecoverable.
The Claimant describes the charge of £500 “legal representative’s costs” not “contractual costs”.. CPR21.14 does not permit these to be recovered in Small Claims Court.
9. The Claimant has at no time provided an explanation as to how the charge has been calculated, the conduct that gave rise to it or why he amount increased from £100 to £160. This appears to be an unqualified additional cost and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.
The Protections of Freedom Act Para 4(5) states that the maximum sum that may be recovered from te keeper is the charge stated on the Notice to Keeper.
10.The Particulars of Claim contains no details and fails to establish case of action which would enable the Defendant to prepare specific defence. Therefore, as an unrepresented litigant-in-person I respectfully ask that I be permitted to amend and or supplement this interim defence as may be required following a fuller disclosure of the Claimant’s case.
11. The signage on-site is not clear, prominent or legible as per Parking Eye v Beavis. It is inadequate to form a contract. The charge is buried in the small print and is an unfair term. The site in question also features signage breaches as per the BPA signage regulations. The entrance to the site is confusing. At neither the address/street name cited on the PCN nor the coordinates for the car park as stated by the Claimant, are clear and prominent terms on display. The Claimant in this case has displayed several distracting signs at various entrance points into the car park, which is not compliant.
In addition, the signage does not contain an obligation as to how to ‘display’ the ticket, therefore there was no breach of any ‘relevant obligation’ or ‘relevant contract’ as required under Schedule 4 of POFA. The terms are not clear, prominent and legible as per Parking Eye v Beavis and 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. This site does not offer free parking, nor is there any comparable ‘legitimate interest’ nor complex contractual arrangement to disengage the penalty rule, as ParkingEye did in the unique case heard by the Supreme Court in 2015. And whilst the Claimant has withheld any photos of the signs on site, the Defendant does contend these are illegible with terms hidden in small print, unlike ‘clear and prominent’ signs which creaeted a contract Mr Beavis was ‘bound to have seen’.
10. The Claimant sent threatening and misleading demands which stated failure to pay the charge would result in enforcement action and an increased charge. No figure for additional charge was agreed nor could it have formed part of the alleged contraact because no such indemnity costs were quantified on the signs. Terms cnnot be added on later with figures seemingly produced out of nowhere.
12. The Defendant has reasonable belief that the claimant didn’t pay their legal representatives £50.00 to prepare the deficient claim that is quite clearly a template with no case specific input.
And so the Defendant does not belief the Claimant has incurred £50 costs to pursue an alleged £100 debt.
Notwithstanding the defendants belief, the coasts are in any case unrecoverable.
The Claimant describes the charge of £500 “legal representative’s costs” not “contractual costs”.. CPR21.14 does not permit these to be recovered in Small Claims Court.
13. The Claimant has at no time provided an explanation as to how the charge has been calculated, the conduct that gave rise to it or why he amount increased from £100 to £160. This appears to be an unqualified additional cost and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.
The Protections of Freedom Act Para 4(5) states that the maximum sum that may be recovered from te keeper is the charge stated on the Notice to Keeper.
The Particulars of Claim contains no details and fails to establish case of action which would enable the Defendant to prepare specific defence. Therefore, as an unrepresented litigant-in-person I respectfully ask that I be permitted to amend and or supplement this interim defence as may be required following a fuller disclosure of the Claimant’s case.
Sorry if the format is all crazy, it's hard to see how it will look when typing frantically into the little text box.
Thanks in advance everyone
Thanks for taking the time to read this post. I've made a massive booboo and miscalculated the 28 days after AoS, so need to submit a Defence by Wednesday.
The brief details regarding the claim are as follows:
- Driver purchased valid ticket, transpired it was placed upside down.
- NTK arrived within required time, citing no ticket displayed.
- Keeper appealed sending copy of ticket along with template appeal as per the NEWBIES forum.
- Obviously the following was standard Gladstones procedure. A few letters hiking charge and threatening legal action.
Sorry if I have been too brief with the info, I'm rushing to get this posted but also from what I've read it seemed a typical Gladstone case, with the only difference being the ticket was found to be upside down. However, would that not really be the crux of the argument anyway?
Keeper's used MSF, Parking Prankster, BMPA and Pepipo for all correspondence but is now struggling with defence.
Grateful for any feedback received.
I am XXXXXXX defendant in this matter. It is admitted only that the Defendant was the authorised registered keeper of vehicle XXXXXXX at the time of the alleged incident.
I deny liability for the entirety of the claim, and all allegations implied in pre-action correspondence, based on the following.
1. The Claimant’s Particulars of Claim disclose no legal cause of action to give rise to any debt and do not comply with CPR Part 16 and Practice Direction 16 7.5.
The Particulars of Claim are vague and insufficient and do not disclose an adequate statement of facts proceeding the alleged cause of action.
The particulars of claim states only ‘parking charges’. No particulars are offered in relation to the nature of the agreement, the method the Claimant calculated any outstanding sums due, how they became due or any other matters necessary to substantiate the Claimants claim. The defendant cannot see how this could be considered a fair exchange of information. Due to this the defendant doesn’t consider the particulars of claim to be valid, therefore the defendant invites the court to strike out the claim as the Claimant has no basis for success.!
2. The Claimant has not complied with pre-court protocol and has acted unreasonable
There was no compliant ‘Letter before Claim’ under the Practice Direction. A Letter before Claim was sent to the Defendant; however, this Letter before Claim didn’t comply with the Practice Direction and provided insufficient information. The defendant responded to this LBC on 25/4/2017 and requested copies of the parking notice, evidence of the alleged action of the driver in accordance with the Over-riding objective, evidence of signage terms and evidence of the Claimants right to bring this claim.. The Claimants solicitors acknowledged only part of this request, providing non-timestamped photographs of vehicle XXXXXXX, with all other requests for information ignored. Therefore the Defendant holds a reasonable belief that the claimants solicitors do not possess this information and issued the claim without any due diligence or inspection of this individual case. Withholding evidence and the basis for a claim made against the Defendant, despite this being requested, goes against the SRA code and is contrary to the over riding objective in the pre action protocol.
Furthermore, the original Letter before Claim was missing the following information:
-The cause for action on which the claim was made. The LBC referenced ‘parking charges’ but that in and of itself isn’t a basis for a justifiable claim.
-A clear and detailed summary of the facts on which the claim is based. The original letter fails to provide any detail or evidence around the circumstances surrounding theses charges and why these are owed.
The defendant refers to the practise direction section on non-compliance and sanction, there can be no justifiable excuse for the Claimant’s failure to follow the Pre-action conduct, especially when the claim was issued by the Claimants Solicitors.
3. The Claimant has given no indication of the nature of the alleged charge in the Particulars of Claim. The Claimant has therefore disclosed no cause of action.
4. The website for payment of the parking notice is in the name of IP Car Parks Limited, not the Claimant. The Defendant has the reasonable belief that the Claimant does not manage the car park and puts the Claimant to proof that there is an innocent reason for the contradiction.
5. The identity of the driver of the vehicle on the date in question has yet to be ascertained.
The Claimant did not identify the driver.
The Defendant has no liability, as they are the Keeper of the vehicle and the Claimant must rely upon the strict provisions of the Protection of Freedoms Act 2012 in order to hold the defendant responsible for the drivers alleged breach.
6. It is denied the Defendant entered into a contract with the Claimant.
The signage on-site is not clear, prominent or legible as per Parking Eye v Beavis. It is inadequate to form a contract. The charge is buried in the small print and is an unfair term. The site in question also features signage breaches as per the BPA signage regulations. The entrance to the site is confusing. At neither the address/street name cited on the PCN nor the coordinates for the car park as stated by the Claimant, are clear and prominent terms on display. The Claimant in this case has displayed several distracting signs at various entrance points into the car park, which is not compliant.
In addition, the signage does not contain an obligation as to how to ‘display’ the ticket, therefore there was no breach of any ‘relevant obligation’ or ‘relevant contract’ as required under Schedule 4 of POFA. The terms are not clear, prominent and legible as per Parking Eye v Beavis and 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. This site does not offer free parking, nor is there any comparable ‘legitimate interest’ nor complex contractual arrangement to disengage the penalty rule, as ParkingEye did in the unique case heard by the Supreme Court in 2015. And whilst the Claimant has withheld any photos of the signs on site, the Defendant does contend these are illegible with terms hidden in small print, unlike ‘clear and prominent’ signs which created a contract Mr Beavis was ‘bound to have seen’.
7.The Claimants increasingly demanding letters failed to evidence any contravention.
The Claimant sent threatening and misleading demands which stated failure to pay the charge would result in enforcement action and an increased charge. No figure for additional charge was agreed nor could it have formed part of the alleged contract because no such indemnity costs were quantified on the signs. Terms cannot be added on later with figures seemingly produced out of nowhere.
8. The Defendant has reasonable belief that the claimant didn’t pay their legal representatives £50.00 to prepare the deficient claim that is quite clearly a template with no case specific input.
And so the Defendant does not belief the Claimant has incurred £50 costs to pursue an alleged £100 debt.
Notwithstanding the defendants belief, the costs are in any case unrecoverable.
The Claimant describes the charge of £500 “legal representative’s costs” not “contractual costs”.. CPR21.14 does not permit these to be recovered in Small Claims Court.
9. The Claimant has at no time provided an explanation as to how the charge has been calculated, the conduct that gave rise to it or why he amount increased from £100 to £160. This appears to be an unqualified additional cost and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.
The Protections of Freedom Act Para 4(5) states that the maximum sum that may be recovered from te keeper is the charge stated on the Notice to Keeper.
10.The Particulars of Claim contains no details and fails to establish case of action which would enable the Defendant to prepare specific defence. Therefore, as an unrepresented litigant-in-person I respectfully ask that I be permitted to amend and or supplement this interim defence as may be required following a fuller disclosure of the Claimant’s case.
11. The signage on-site is not clear, prominent or legible as per Parking Eye v Beavis. It is inadequate to form a contract. The charge is buried in the small print and is an unfair term. The site in question also features signage breaches as per the BPA signage regulations. The entrance to the site is confusing. At neither the address/street name cited on the PCN nor the coordinates for the car park as stated by the Claimant, are clear and prominent terms on display. The Claimant in this case has displayed several distracting signs at various entrance points into the car park, which is not compliant.
In addition, the signage does not contain an obligation as to how to ‘display’ the ticket, therefore there was no breach of any ‘relevant obligation’ or ‘relevant contract’ as required under Schedule 4 of POFA. The terms are not clear, prominent and legible as per Parking Eye v Beavis and 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. This site does not offer free parking, nor is there any comparable ‘legitimate interest’ nor complex contractual arrangement to disengage the penalty rule, as ParkingEye did in the unique case heard by the Supreme Court in 2015. And whilst the Claimant has withheld any photos of the signs on site, the Defendant does contend these are illegible with terms hidden in small print, unlike ‘clear and prominent’ signs which creaeted a contract Mr Beavis was ‘bound to have seen’.
10. The Claimant sent threatening and misleading demands which stated failure to pay the charge would result in enforcement action and an increased charge. No figure for additional charge was agreed nor could it have formed part of the alleged contraact because no such indemnity costs were quantified on the signs. Terms cnnot be added on later with figures seemingly produced out of nowhere.
12. The Defendant has reasonable belief that the claimant didn’t pay their legal representatives £50.00 to prepare the deficient claim that is quite clearly a template with no case specific input.
And so the Defendant does not belief the Claimant has incurred £50 costs to pursue an alleged £100 debt.
Notwithstanding the defendants belief, the coasts are in any case unrecoverable.
The Claimant describes the charge of £500 “legal representative’s costs” not “contractual costs”.. CPR21.14 does not permit these to be recovered in Small Claims Court.
13. The Claimant has at no time provided an explanation as to how the charge has been calculated, the conduct that gave rise to it or why he amount increased from £100 to £160. This appears to be an unqualified additional cost and an attempt at double recovery, which the POFA Schedule 4 specifically disallows.
The Protections of Freedom Act Para 4(5) states that the maximum sum that may be recovered from te keeper is the charge stated on the Notice to Keeper.
The Particulars of Claim contains no details and fails to establish case of action which would enable the Defendant to prepare specific defence. Therefore, as an unrepresented litigant-in-person I respectfully ask that I be permitted to amend and or supplement this interim defence as may be required following a fuller disclosure of the Claimant’s case.
Sorry if the format is all crazy, it's hard to see how it will look when typing frantically into the little text box.
Thanks in advance everyone
0
Comments
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You can't be sure you placed the ticket upside down.... A draught coming through the vents or someone leaning on your car could have caused it to flip over.
In your appeal did you state that you placed the ticket upside down?
They deliberately make the tickets light and flimsy so exactly this will happen and they can charge an unsuspecting motorist an outlandish amount for something they had no control over.
It's far more likely that your placed the ticket the right way up and it was later flipped over through no fault of your own, in which case any alleged contact may be unenforceable and they would have no case.
Have a read of this thread:
https://forums.moneysavingexpert.com/discussion/57157020 -
All that info provided and you have contrived not to name the PPC trying to rob you!
The defence guru's will need this info in order to help with your lastminute.com defence. Provide this and sit tight - one of the amazing forumites will be along shortly with feedback for you.0 -
Thanks Molts and Lamilad.
Sorry, the 'Sip' in the post title is SIP Parking Ltd, or SIP Car Parks Ltd.
The keeper identified themselves as keeper only and confirmed that a valid ticket was purchased and displayed. No mention was made as to how the driver placed the ticket or how it came to be upside down. The fact the ticket is was upside down hasn't been mentioned by either party, but the non timestamped photos do show an upside down ticket in the windscreen of the keepers vehicle. Gladstones state 'As evident from the photographs you didn't display a ticket in accordance with the terms..' However, the terms make no mention as to how a ticket should be displayed.This point was mentioned in the defence, but not sure if I should have gone into more detail.
Thanks for the link Lamilad, will check it out now.
0 -
We’ve got something similar going on.. failure to display..!
The ticket they say was not displayed in the areas noted on the ticket, but was clearly visible to anyone looking in the car..that is their argument against ours..
We have clear photos which can be legibly read by anyone should they have wanted to read it,
We have been issued photos of the front and both sides, the camera clearly being positioned or angled acutely to support the claim that the ticket could not be seen.
The photo of the drivers seating area and cockpit was taken from the position of the rear doors to hide the tickets position amongs the steering assembly and is a completely opposite angle of that taken from the other side..
We are facing the same threats too which I keep encouraging.
The courts must see that many of these petty arguments they become sick to death of them..
I know what I’d do if I were the judge.. ban the lot of them.. and tell the customers to pay an attendant at the gate upon entry.. no arguments pay as you come in, all day...simples..
I may point out the obvious here but if they want to have proper means for debating incorrectly placed tickets they should provide the sticky adhesive backed ones which don’t come off the glass, or blow over from the vacuum of your door.
The nature of these tickets permit them to create such grounds for imposing such wrongdoing.
The fact also remains that if you have paid and hold a ticket to prove it, so why heckel somebody who pays their way.
If you were pulled to the side in a shop for stealing, and you proved that you’d paid for it, I’m sure there would be discretionary refund or vouchers to the disgruntled party.
With these parking companies they have the cheek of charging you and then exploiting your custom after profiteering from you.
If you’ve paid, you’ve paid..and anyone with any common sense will know that you owe indeed nothing.
And if anything: the parking company should be thankful for a paying customer..0 -
Post #26 of the linked case is where I suggested some wording re the truth behind a ticket flipping over.
Stop accepting their version of events (i.e. you did NOT place the ticket upside down, that's ludicrous - no-one would!).
You do realise clampers used to rock cars to dislodge permits, before clamping became illegal?
Have another think over how this could have occurred and take no blame, defend this robustly, as if it's a scam (oh, wait!).
Bucko78 you will need to start your own thread but your input does confirm how common this is.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 THREAD0 -
I'm also a little confused about when my defence is due. I thought it was 28 days from the date of issue which was 6.9.17. However, I read on another thread that you have an additional 5 days from then. Please can someone confirm, there isn't a deadline or any indication when I log onto MCOL.
Thanks y'all.0 -
Coupan-mad - I've refrained from mentioning anything at all about the ticket being upside down - is that wrong? I kind of thought it that was mentioned I would be qute vehement in my confusion as to how that could have occurred? Obviously noone in their right mind would purchase a ticket just to intentionally place it upside down,or is the onus on me to spell that out for the Judge/preempt that entirely. How does it work at court - do I get a chance to speak, do I only get to address what the claimants have in their claim?
Bucko78 - good luck with your case. Hopefully we'll both get results in our favour 0 -
Thanks Anita, stay strong, keep your chin up and don’t worry..
I’ve had these tickets before for numerous reasons.. all which were extremely petty just like your case..I’ve not yet paid one.. my cavalier attitude towards these parasites will reign on..
It’s a joke that the government are letting the good people of this country become overwhelmed with grief and distress for doing nothing more than trying to go about their daily business..
All the best0 -
I've refrained from mentioning anything at all about the ticket being upside down - is that wrong? I kind of thought it that was mentioned I would be quite vehement in my confusion as to how that could have occurred?
That's the wrong approach, IMHO. You need to rebut assertions or they are deemed accepted. Say nothing and you appear to concur that 'As evident from the photographs you didn't display a ticket in accordance with the terms..'
That's why I pointed you to post #26 of the thread linked by Lamilad. Be robust, paint another picture on the balance of probabilities, that tells it your way. That's why I wrote that bit for claxtome, to turn the assertion around, and you and Bucko78 need to paint the same alternative picture of whose fault the fluttering ticket really is.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 THREAD0
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