UKCPM IAS Appeal ?

jonnyfriendly · 28 October 2019 at 8:34PM

Hi
Could someone have a look at my reply to Gladstone's request for information (see above) and hopefully give me some feedback. I'm unsure with the legal language.
Thanks in advance
J

Your Reference:

Dear Gladstones
Thank you for your emailed letter dated xxxxxxx and your request for
clarification of my position regarding PCN charge xxxxxx
As previously stated on the submission of the Pre-action protocol reply form.
I dispute the debt because the UKCPM claim is unreasonable, disproportionate and does not follow legal protocol.

To clarify
Extra charges
I dispute the extra charges of £60 added to the original PCN. I content that they are disproportionate and not legal. I refer you to ParkingEye v Beavis, 2015. (paragraph’s 98 and 198)

Unloading
I contend that as I was unloading I was not parked. See Jopson, 2016. I was not causing an obstruction.
See attached image of nearby sign offering 30mins free
See image of my own sign left clearly visible inside drivers window to inform any warden of the situation and of my whereabouts.
This sign is clearly visible on your own pictures. I attach a close up image for your information.

According to pictures provided by UKCPM, the attendant arrived at 16.02 and issued a ticket on or before 16.11. A maximum of 9mins. spent in the area. No attempt was made to contact me and no attention paid to unloading time.
See previous attached image and your own records.
I contend that the attendant did not act reasonably within the context of the unloading time to fully check the circumstances.

Signage
I suggest that there was inadequate signage around the hatched area, previously used for many years for student/staff parking.
The map of signs provided by CPM indicates a general sign adjacent to where I parked.
This sign was not in place on the date of the alleged offence and must have been added later.
See attached image