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Court Papers here - Defence Help Please!
crxvt
Posts: 28 Forumite
Hello Users!
Massive thank you to all the posters on this forum and would appreciate some advice and help for my situation.
I have completed the AOS, albeit a little late however I have 3 weeks to set up my defence with your help!
First issue: I have ignored all letters received since 2016, be it from JD Parking, or Gladstone. I made the mistake of not coming on the forums earlier, I also ignored the LBC letter from Gladstone, and now I have been issued court letters from County Court Business Centre.
My first question is, should I still send Gladstone a response to the LBC letter?
Some additional background which may help:
Claimant is JD PARKING
GLADSTONES acting as JD PARKING legal representatives
The car park in question is based in Leeds – Leodis Court
The car park has barriers however are always open
I am certain that I did not receive a PCN on my windscreen and it was just sent through the post however I can not remember for sure.
I have pictures available of from the area it was parked if it helps!?
HOW DID WE GET TO THIS
I parked in a business park by the name of Leodis court in Leeds, I genuinely did not see the signage when I parked in there and did not see any signs when entering the car park. I am extremely sure that the fine was NOT left on my windscreen and I only received them through the post back in 2016. Where I was parked there were no yellow lines or anything to suggest that I could not park there. The building where the sign is on, has chains and poles around the edges. I parked outside these edges I had no idea that these were the buildings property too. Can send pics if makes things easier. I have 2 fines few days apart that I am being charged for!
So here is my first EVER draft at any kind of defence! This is a collaboration of several other peoples defences. Apologies for the mistakes in advance!!
Preliminary
1.0 The PCN was issued on a poorly signed area, the Vehicle was parked on the curb that was not inside the area marked out by pole and chains. I was completely unaware that the site was 'private land' or being enforced by any restrictive terms, due to insufficient signage. I refer to the IPC Code of Practice (CoP) Part E, highlighting that adequate and clear entrance signs are required.
1.1There 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.
1.2 The only sign was attached to the building. There was nothing to suggest that one sign could relate to parking where my vehicle was located as the building has its marked territory via poles and chains. There was no clearway sign nor red lines/hatched lines to communicate permit requirement or how to obtain one, or the charge itself.
1.3The 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).
1.4The 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. I have asked questions in the form of a Part 18 request but have not received any response.
2. The Claimant has failed to comply with the requirements of Civil Procedure Rule 16.4. Its sparse Particulars do not disclose any cause of action which could give rise to a claim, and their single-page Letter Before Claim was no more than an aggressive demand, designed to intimidate and mislead the defendant, rather than narrow the issues or provide any specific detail.
2.1. The Claimant has failed to set out the basis of the claim - trespass or contractual breach? It has not specified how the sum sought represents any fee, charge, costs or damages incurred - nor evidenced that any contract existed or was breached - hence the Defendant is having to attempt to cover all possibilities, with no fair opportunity to make an informed response.
2.1.1. The Claimant's solicitors have sent no relevant details, copies of letters, facts or evidence.
2.1.1.1 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 thousands of similar poorly pleaded claims.
2.2 The Defendant believes the term for such conduct is ‘robo-claims’ which is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers. 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.
2.2.1 The Particulars of Claim fail to refer to the material terms of any contract and neither comply with the CPR 16 in respect of statements of case, nor the relevant practice direction in respect of claims formed by contract or conduct.
In further support of there being a want of cause of action:
2.4 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 operator.
2.4.1Any ‘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.
2.4.2 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.
ParkingEye Ltd v Beavis is distinguished
3. ParkingEye Ltd v Beavis [2015] UKSC 67 is fully distinguished from this claim, due to the completely different facts, including but not limited to:
i) There was no parking licence or offer, no consideration followed and there was no contract capable of being breached.
ii) The Claimant did not follow the effectively binding IPC Code of Practice.
iii) The sum claimed is extortionate, and the predatory business model is punitive and unconscionable.
iv) The Claimant has no standing or authority from the landowner.
v) There is no comparable legitimate interest or commercial justification to disengage the penalty rule.
vi) The driver has not been identified and nor can the Claimant rely on the POFA Schedule 4
Vii) the Trade Body Code of Practice regarding Grace Periods has been breached.
Background - no contract
4.0 No indication was provided as evidence to support the Claimant's contractual authority to operate at this specific location. The Defendant avers that the business model utilised at this site is predatory, punitive, unauthorised by the landowner and operates contrary to the IPC Code of Practice.
4.1 It is averred that the Claimant is not the landowner and therefore lacks any cause of action. If it is alleged that a trespass had occurred then the remedy available for that tort (which is denied) is in the gift of the landowner alone, to seek damages.
4.2 It was confirmed by the Supreme Court that ParkingEye Ltd could only recover the £85 parking charge which more than covered all costs of the automated business model of a parking firm and was heavily weighted for profit. It was held that a parking firm not in possession could not recover any sum at all in damages, but the Supreme Court were willing to impose a penalty as allowable only in the unique context of that particular retail site of commercial value. In that case, the signs were 'very prominent' and clear - both upon entry to the site and throughout - with the parking charge in the largest lettering with a free parking licence being offered and accepted under contract, giving rise to a sum being payable by patrons who overstayed.
Absence of 'registered keeper liability'
5. The Claimant has provided no evidence (in pre-action correspondence or otherwise) to identify the driver. The balance of probabilities is not tipped in the Claimant's favour, given the fact that more than one person drives this car. The Defendant avers that the Claimant is therefore limited to pursuing the Defendant in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 ("the POFA").
5.1 If seeking to rely on the keeper liability provisions of Schedule 4 of the POFA, the Claimant must demonstrate that:
5.1.1. there was a !!!8220;relevant obligation!!!8221;; either by way of a breach of contract, trespass or other tort; and
5.1.2. that this Claimant has established itself as the offeror and creditor; and
5.1.3. that it has followed the required deadlines and wording as described in the Act to transfer liability from the driver to the registered keeper. It is not admitted that the Claimant has complied with the relevant statutory requirements.
5.2. To the extent that the Claimant may seek to allege that any such presumption do exist, the Defendant expressly denies that there is any presumption in law (whether in statute or otherwise) that the keeper is the driver. Further, the Defendant denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of Parliament, they would have made such requirements part of the POFA, which makes no such provision.
The sum claimed is a penalty
6. The Claimant has at no time provided an explanation how the ‘PARKING CHARGE REF ’ has been calculated, or how the amount has been inflated from the initial 2 x £60 to now £300+. This is a completely exorbitant charge for an alleged overstay in this car park of around four minutes.
6.1. Schedule 4 of the POFA, Paragraph 4(5), states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper (a document which the Defendant avers was never received, but cannot have exceeded £90, if the Claimant is relying upon the sign in the photograph provided). The clear intention of Parliament was that parking charges on private land be capped at the (already inflated to include profit) sum on the Notices, with double recovery being specifically disallowed.
6.2. The Defendant has the reasonable belief that the Claimant has not incurred such exorbitant costs to pursue an alleged £300+ debt. Notwithstanding the Defendant's belief, the costs are in any case not recoverable. No indemnity costs or damages have been incurred, nor were any debt collection 'fees' paid by this Claimant, and nor were such sums specified in prominent lettering on any sign at the point of the driver parking. It is averred that the sum claimed is invented out of thin air as part of the Claimant's solicitors' robo-claim model.
Wholly unreasonable and vexatious claim
7. It is submitted that the conduct of the Claimant in operating a predatory model for profit, and intimidating the Defendant with misleading threats in the pre-action stage before pursuing this claim, is wholly unreasonable and vexatious.
7.1. As such, the Defendant is keeping careful note of all wasted time/costs in dealing with this matter and should the case continue to trial (or in the event of the Claimant filing a Notice of Discontinuance) the Defendant will seek further costs on an indemnity basis, pursuant to Civil Procedure Rule 27.14(2)(g).
8. In the alternative, when Directions are given, the Defendant asks that there is an order for sequential service of witness evidence (rather than exchange) because it is expected that the Claimant will use its witness statement to provide the sort of detail which should have been disclosed much earlier, and the Defendant should have the opportunity to consider it, prior to serving evidence and witness statements in support of this defence.
I confirm that the above facts and statements are true to the best of my knowledge and recollection.
Signed:
Date:
***
***This was amended from a one recently found on the site***
Massive thank you to all the posters on this forum and would appreciate some advice and help for my situation.
I have completed the AOS, albeit a little late however I have 3 weeks to set up my defence with your help!
First issue: I have ignored all letters received since 2016, be it from JD Parking, or Gladstone. I made the mistake of not coming on the forums earlier, I also ignored the LBC letter from Gladstone, and now I have been issued court letters from County Court Business Centre.
My first question is, should I still send Gladstone a response to the LBC letter?
Some additional background which may help:
Claimant is JD PARKING
GLADSTONES acting as JD PARKING legal representatives
The car park in question is based in Leeds – Leodis Court
The car park has barriers however are always open
I am certain that I did not receive a PCN on my windscreen and it was just sent through the post however I can not remember for sure.
I have pictures available of from the area it was parked if it helps!?
HOW DID WE GET TO THIS
I parked in a business park by the name of Leodis court in Leeds, I genuinely did not see the signage when I parked in there and did not see any signs when entering the car park. I am extremely sure that the fine was NOT left on my windscreen and I only received them through the post back in 2016. Where I was parked there were no yellow lines or anything to suggest that I could not park there. The building where the sign is on, has chains and poles around the edges. I parked outside these edges I had no idea that these were the buildings property too. Can send pics if makes things easier. I have 2 fines few days apart that I am being charged for!
So here is my first EVER draft at any kind of defence! This is a collaboration of several other peoples defences. Apologies for the mistakes in advance!!
Preliminary
1.0 The PCN was issued on a poorly signed area, the Vehicle was parked on the curb that was not inside the area marked out by pole and chains. I was completely unaware that the site was 'private land' or being enforced by any restrictive terms, due to insufficient signage. I refer to the IPC Code of Practice (CoP) Part E, highlighting that adequate and clear entrance signs are required.
1.1There 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.
1.2 The only sign was attached to the building. There was nothing to suggest that one sign could relate to parking where my vehicle was located as the building has its marked territory via poles and chains. There was no clearway sign nor red lines/hatched lines to communicate permit requirement or how to obtain one, or the charge itself.
1.3The 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).
1.4The 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. I have asked questions in the form of a Part 18 request but have not received any response.
2. The Claimant has failed to comply with the requirements of Civil Procedure Rule 16.4. Its sparse Particulars do not disclose any cause of action which could give rise to a claim, and their single-page Letter Before Claim was no more than an aggressive demand, designed to intimidate and mislead the defendant, rather than narrow the issues or provide any specific detail.
2.1. The Claimant has failed to set out the basis of the claim - trespass or contractual breach? It has not specified how the sum sought represents any fee, charge, costs or damages incurred - nor evidenced that any contract existed or was breached - hence the Defendant is having to attempt to cover all possibilities, with no fair opportunity to make an informed response.
2.1.1. The Claimant's solicitors have sent no relevant details, copies of letters, facts or evidence.
2.1.1.1 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 thousands of similar poorly pleaded claims.
2.2 The Defendant believes the term for such conduct is ‘robo-claims’ which is against the public interest, demonstrates a disregard for the dignity of the court and is unfair on unrepresented consumers. 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.
2.2.1 The Particulars of Claim fail to refer to the material terms of any contract and neither comply with the CPR 16 in respect of statements of case, nor the relevant practice direction in respect of claims formed by contract or conduct.
In further support of there being a want of cause of action:
2.4 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 operator.
2.4.1Any ‘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.
2.4.2 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.
ParkingEye Ltd v Beavis is distinguished
3. ParkingEye Ltd v Beavis [2015] UKSC 67 is fully distinguished from this claim, due to the completely different facts, including but not limited to:
i) There was no parking licence or offer, no consideration followed and there was no contract capable of being breached.
ii) The Claimant did not follow the effectively binding IPC Code of Practice.
iii) The sum claimed is extortionate, and the predatory business model is punitive and unconscionable.
iv) The Claimant has no standing or authority from the landowner.
v) There is no comparable legitimate interest or commercial justification to disengage the penalty rule.
vi) The driver has not been identified and nor can the Claimant rely on the POFA Schedule 4
Vii) the Trade Body Code of Practice regarding Grace Periods has been breached.
Background - no contract
4.0 No indication was provided as evidence to support the Claimant's contractual authority to operate at this specific location. The Defendant avers that the business model utilised at this site is predatory, punitive, unauthorised by the landowner and operates contrary to the IPC Code of Practice.
4.1 It is averred that the Claimant is not the landowner and therefore lacks any cause of action. If it is alleged that a trespass had occurred then the remedy available for that tort (which is denied) is in the gift of the landowner alone, to seek damages.
4.2 It was confirmed by the Supreme Court that ParkingEye Ltd could only recover the £85 parking charge which more than covered all costs of the automated business model of a parking firm and was heavily weighted for profit. It was held that a parking firm not in possession could not recover any sum at all in damages, but the Supreme Court were willing to impose a penalty as allowable only in the unique context of that particular retail site of commercial value. In that case, the signs were 'very prominent' and clear - both upon entry to the site and throughout - with the parking charge in the largest lettering with a free parking licence being offered and accepted under contract, giving rise to a sum being payable by patrons who overstayed.
Absence of 'registered keeper liability'
5. The Claimant has provided no evidence (in pre-action correspondence or otherwise) to identify the driver. The balance of probabilities is not tipped in the Claimant's favour, given the fact that more than one person drives this car. The Defendant avers that the Claimant is therefore limited to pursuing the Defendant in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 ("the POFA").
5.1 If seeking to rely on the keeper liability provisions of Schedule 4 of the POFA, the Claimant must demonstrate that:
5.1.1. there was a !!!8220;relevant obligation!!!8221;; either by way of a breach of contract, trespass or other tort; and
5.1.2. that this Claimant has established itself as the offeror and creditor; and
5.1.3. that it has followed the required deadlines and wording as described in the Act to transfer liability from the driver to the registered keeper. It is not admitted that the Claimant has complied with the relevant statutory requirements.
5.2. To the extent that the Claimant may seek to allege that any such presumption do exist, the Defendant expressly denies that there is any presumption in law (whether in statute or otherwise) that the keeper is the driver. Further, the Defendant denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of Parliament, they would have made such requirements part of the POFA, which makes no such provision.
The sum claimed is a penalty
6. The Claimant has at no time provided an explanation how the ‘PARKING CHARGE REF ’ has been calculated, or how the amount has been inflated from the initial 2 x £60 to now £300+. This is a completely exorbitant charge for an alleged overstay in this car park of around four minutes.
6.1. Schedule 4 of the POFA, Paragraph 4(5), states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper (a document which the Defendant avers was never received, but cannot have exceeded £90, if the Claimant is relying upon the sign in the photograph provided). The clear intention of Parliament was that parking charges on private land be capped at the (already inflated to include profit) sum on the Notices, with double recovery being specifically disallowed.
6.2. The Defendant has the reasonable belief that the Claimant has not incurred such exorbitant costs to pursue an alleged £300+ debt. Notwithstanding the Defendant's belief, the costs are in any case not recoverable. No indemnity costs or damages have been incurred, nor were any debt collection 'fees' paid by this Claimant, and nor were such sums specified in prominent lettering on any sign at the point of the driver parking. It is averred that the sum claimed is invented out of thin air as part of the Claimant's solicitors' robo-claim model.
Wholly unreasonable and vexatious claim
7. It is submitted that the conduct of the Claimant in operating a predatory model for profit, and intimidating the Defendant with misleading threats in the pre-action stage before pursuing this claim, is wholly unreasonable and vexatious.
7.1. As such, the Defendant is keeping careful note of all wasted time/costs in dealing with this matter and should the case continue to trial (or in the event of the Claimant filing a Notice of Discontinuance) the Defendant will seek further costs on an indemnity basis, pursuant to Civil Procedure Rule 27.14(2)(g).
8. In the alternative, when Directions are given, the Defendant asks that there is an order for sequential service of witness evidence (rather than exchange) because it is expected that the Claimant will use its witness statement to provide the sort of detail which should have been disclosed much earlier, and the Defendant should have the opportunity to consider it, prior to serving evidence and witness statements in support of this defence.
I confirm that the above facts and statements are true to the best of my knowledge and recollection.
Signed:
Date:
***
***This was amended from a one recently found on the site***
0
Comments
-
So you ignore the paperwork up until now. Did you take any pics of the place to underpin your claim of poor signage?
If you visited said business park were you there to see someone?This is a system account and does not represent a real person. To contact the Forum Team email forumteam@moneysavingexpert.com0 -
What is the Date of Issue on your Claim Form?0
-
if the driver has not been revealed , edit post #1 accordingly , to what the DRIVER did (no "ME , MYSELF & I")0
-
No.My first question is, should I still send Gladstone a response to the LBC letter?
I would say this heading should instead, be 'Background':PreliminaryPRIVATE '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 -
IamEmanresu wrote: »So you ignore the paperwork up until now. Did you take any pics of the place to underpin your claim of poor signage?
If you visited said business park were you there to see someone?
The answer to this is yes unfortunatley hence the position i am in!0 -
Apologies for the late reply, probably not the best time to take a holiday!
in response to the questions:
Date of Issue is 5 September 2018. I believe I need to have posted my defence by 5th October after submitting the AOS.
I have made the amendments.. would appreciate guidance on my defence.
These pictures have been taken in the last week.
I must admit I have just noticed the big sign where it says at the bottom 'Parking for tenants and Visitors Only'
The sign on the building is quite high up and i would say its about A2 size.
I have marked where my car was parked!
0 -
please see marked area where I was parked.0 -
You have up to 33 days from issue, but don't push it that close.I believe I need to have posted my defence by 5th October after submitting the AOS.
That signage is almost non-existent! You don't need your pics at defence stage, however.
That draft defence is a waffly and generic one. I'd be spending the time reading the other defence examples in the NEWBIES thread. Only yesterday I added two very concise defence links there, to ones written by bargepole which are less than half the words you;ve used and are about lack of clear signs.
Have a look and try to improve the clarity of the defence & remove the waffle.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 -
please see marked area where I was parked.
So you were there visiting one of the companies on that estate, according to a previous post on this thread?
The sign says 'Parking for Tenants & Visitors Only', so if you were a visitor, you were entitled to park there, and didn't breach any terms.
I suggest you get rid of the torrent of irrelevant waffle that you've put in your draft defence, and concentrate on the facts. There's no point trying to hide behind terms such as 'the keeper' and 'the driver' if you were driving, that will just make you appear evasive in front of a Judge.
I have been providing assistance, including Lay Representation at Court hearings (current score: won 57, lost 14), to defendants in parking cases for over 5 years. I have an LLB (Hons) degree, and have a Graduate Diploma in Civil Litigation from CILEx. However, any advice given on these forums by me is NOT formal legal advice, and I accept no liability for its accuracy.0 -
With a Claim Issue Date of 5th September, and having done the AoS in a timely manner, you have until 4pm on Monday 8th October 2018 to file your Defence.
That's that's still over a week away, but don't leave it to the very last minute.
When you are happy with the content, your Defence should be filed via email as described here:
1) Print your Defence.
2) Sign it and date it.
3) Scan the signed document back in and save it as a pdf.
4) Send that pdf as an email attachment to CCBCAQ@Justice.gov.uk
5) Just put the claim number and the word Defence in the email title, and in the body of the email something like 'Please find my Defence attached'.
6) Log into MCOL after a few days to see if the Claim is marked "defended". If not chase the CCBC until it is.
7) Wait for the Directions Questionnaire and then re-read post #2 of the NEWBIES thread to find out what to do with it.0
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