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Parking at the Gym - VCS Defence Help
SachinD
Posts: 12 Forumite
Hi,
I have read the newbies thread and threads and havent found an exact match to what I need and just getting a bit lost with all the information
Long Story Short I receiced a Parking fine of £60 (Now £185) for Overstay at my Gym Car Park which also used by other shops for Maximum of 2 hours back in March . Being a Gym Member you get to park for 3 as long as you have put your details in the tablet at the gym. Now I have been a member there for 2 years and the gym were not very helpful at the time but said nothing will happen as they have similar issues with other members and I have parked longer than 2 hours on lots of occasion without any issues.
I informed VCS of this and they rejected all my appeals ( I have admited Ii was the driver, my first mistake) and a few weeks back I received an MCOL as didnt think I would receive this as had been over 6 weeks since I submited to VCS my last appeal.
I did the AOS abd I went straight to my Gym saying I want this escalulated which was to Head Office. I gave them all the details of the fine including the Court Claim which they said they will chase up and get resolved. Having left this with them and I chased a few times with my gym manger, the person whos looking into this has been away and now the deadline for submitting is today (again my mistake for not chasing quicker). The gym manager has made an offer that if I have to pay he will conpensate by offering a years free gym membership which is slightly more than the fine.
I'm just looking if someone just give me a little help with the wording of a Dence draft I have found from another thread and put bits in that i could use below to submit.
IN THE COUNTY COURT
CLAIM No: xxxxxxxxxx
BETWEEN:
VCS LTD (Claimant)
-and-
xxxxxxxxxxxx (Defendant)
________________________________________
DEFENCE
________________________________________
1. The Defendant is the registered keeper of the vehicle in question. The Claim relates to an alleged debt arising from the driver's alleged breach of contract, which is denied. It is further denied that there was any agreement to pay the Claimant a punitive £60 'parking charge notice' (PCN) for the lawful conduct described below.
2. The allegation appears to be that the 'Parked for longer than the Maximum Period Permitted ' based on images by their ANPR camera at the entrance and exit to the site. This is merely an image of the vehicle in transit and is no evidence of 'No Auth' or not being a patron of the facility.
3. The facts are that the vehicle, registration XXXXX, is permitted to park at LOCATION through an agreement with COMPANY NAME for a Maximum of 3 Hours and the landlord via COMPANY MANAGEMENT NAME.
4 . The Defendant has already proved patronage as COMPANY NAME and has been a member for two years, on two occasions and it is the Claimant's own failure, to acknowldge this fact.
4. The Claim Form issued on xx March 2019 by VCS Ltd was not correctly filed under The Practice Direction as it was not signed by a legal person but signed by “VCS Limited” which is the Claimant’s Legal Representative. The claim does not have a valid signature and is not a statement of truth. Practice Direction 22 requires that a statement of case and truth on behalf of a company must be signed by a person holding a senior position and that person or office must state the position held. If the party is legally represented, the legal representative must sign the statement of truth in their own name and not that of their firm or employer.
5. The Claimant has not complied with pre-court protocol (as outlined in the new Pre-Action Protocol for Debt Claims, 1 October 2017) and as an example as to why this prevents a full defence being filed at this time, a parking charge can be for trespass, breach of contract or a contractual charge. All these are treated differently in law and require a different defence. The wording of any contract will naturally be a key element in this matter, and a copy of the alleged contract has never been provided to the Defendant.
6. It is denied that the Defendant, or any driver of the vehicle, entered into any contractual agreement with the Claimant, whether express, implied, or by conduct.
7. The alleged breach, according to VCS Ltd, is in contravention of terms and conditions. Visitors were expected to input their Vehicle Registration Number into a touchscreen system which was not displayed anywhere on the small sparse signs within the car park. The signs in this car park are not at all prominent, clear or legible from all parking spaces or upon entering the car park and there is insufficient notice of the sum of the parking charge itself. Other signs in this car park are sporadically placed and not clearly visible, especially in the evening when it's dark with no sufficient lighting. It is therefore very much possible to park and not be able to see any clear signage which complies with BPA requirements.
10. It is contended that the Claimant failed to alert regular local visitors to an onerous change and unexpected obligation to use an iPad, or risk £100 penalty. The Claimant is put to strict proof, with the bar being set by Denning LJ in J Spurling Ltd v Bradshaw [1956] in the well-known 'Red Hand Rule' where hidden/unknown terms were held to be unenforceable: ''Some clauses which I have seen would need to be printed in red ink...with a red hand pointing to it before the notice could be held to be sufficient.''
11. The Claimant is put to strict proof that it has sufficient interest in the land or that there are specific terms in its contract to bring an action on its own behalf. As a third party agent, the Claimant may not pursue any charge, unless specifically authorised by the principal. The Defendant has the reasonable belief that the Claimant does not have the authority to issue charges on this land in their own name, and that they have no right to bring any action regarding this claim.
12. . Even if the Claimant is able to produce such a landowner contract, it is averred that there can be no legitimate interest arguable by the Claimant in this case. When - all too often at this location – VCS Ltd unfairly harvest the data of a registered keeper to charge a genuine patron, any commercial justification in the form of landowner support for such unfair ticketing is de facto absent.
13. Further, there was no overstay nor any mischief to deter, nor was there any misuse of a valuable parking space by the Defendant, whose car was parked in good faith, not in contravention nor causing an obstruction, and was certainly not 'unauthorised'. With no 'legitimate interest' excuse for charging this unconscionable sum given the above facts, this Claimant's claim is reduced to an unrecoverable penalty and must fail.
14. This case is fully distinguished in all respects from ParkingEye Ltd v Beavis [2015] UKSC 67. That Supreme Court decision sets a high bar for parking firms, not a blanket precedent, and the Beavis case essentially turned on a 'complex' and compelling legitimate interest and very clear notices, where the terms were held not to involve any lack of good faith or 'concealed pitfall or trap'. Completely unlike the instant case.
15. In addition, there can be no cause of action in a parking charge case without a 'relevant obligation' and/or 'relevant contract' (the Protection of Freedoms Act 2012, Schedule 4 refers).
16. This Claimant uses ANPR camera systems to process data but fails to comply with the Information Commissioner's 'Data Protection Code of Practice for Surveillance Cameras and Personal Information' (the ICO Code). This is both a specific Data Protection and BPA Code of Practice breach. The Supreme Court Judges in Beavis held that a Code of Practice is effectively 'regulation' for this blatantly rogue industry, full compliance with which is both mandatory and binding upon any parking operator.
17. The ICO Code applies to all ANPR systems, and states that the private sector is required to follow it, in order to meet its legal obligations as a data processor. Members of the BPA are required to comply fully with the Data Protection Act (DPA) and all ICO rules and guidelines, as a pre-requisite of being able to use the DVLA KADOE system and in order to enforce parking charges on private land. At this location, the Claimant has failed on all counts and the data gathered about patrons of the site is unconscionable and excessive, given the lack of transparency about the risk of a charge for failing to do something that the driver never knew was a requirement.
18. These are specific breaches of the Consumer Protection from Unfair Trading Regulations 2008 and transgress the tests of fairness and transparency of consumer contracts, as set out in the Consumer Rights Act 2015 (this relatively untested legislation was enacted after the final hearing in Beavis and not actively considered in that case). As such, this claim must fail.
19. This claim inflates the total charges in a clear attempt at double recovery. The Defendant trusts that the presiding Judge will recognise this wholly unreasonable conduct as a gross abuse of process. It was held in the Supreme Court in Beavis (where £85 was claimed, and no more) that a private parking charge already includes a very significant and high percentage in profit and more than covers the costs of running an automated regime of template letters. Thus, there can be no 'costs' to pile on top of any parking charge claim.
20. In addition to the original penalty, the Claimants have artificially inflated the value of the Claim by adding purported legal costs and fines of £100, which have not actually been incurred by the Claimant. VCS Ltd have not expended any such sum in this case, given that they have a Legal Team with salaried in-house Solicitors and this firm whose main business is supposed to be parking 'management' as a service provision, files tens of thousands of similar 'cut & paste' robo-claims per annum. No genuine legal costs arise, per case, and their in-house Solicitors cannot possibly be believed to be paid in the millions per annum for their services.
21. The added 'legal' cost is in fact an artificially invented figure, which represents a cynical attempt to circumvent the Small Claims costs rules and achieve double recovery. According to Ladak v DRC Locums UKEAT/0488/13/LA, a Claimant can only recover the direct and provable costs of the time spent by legally qualified staff on actually preparing the claim and/or the cost of obtaining advice for that specific claim, in a legal capacity.
22. Many informed Court Court Judges have disallowed all added parking firm 'costs' in County courts, such as these cases, struck out in recent months without a hearing, due solely to the pretence of adding 'damages' blatantly made up out of thin air.
(a) In Claim number F0DP163T on 11th July 2019, District Judge Grand sitting at the County Court at Southampton, struck out a overly inflated (over the £100 maximum Trade Body and POFA 2012 ceiling) parking firm claim without a hearing for that reason.
(b) In Claim number F0DP201T on 10th June 2019, District Judge Taylor echoed an earlier General Judgment or Order of DJ Grand, who on 21st February 2019 sitting at the Newport (IOW) County Court, had struck out a parking firm claim. These include a BPA member serial Claimant (Britannia, using BW Legal's robo-claim model) and an IPC member serial Claimant (UKCPM, using Gladstones' robo-claim model) where the abuse is inherent in the business model.
23. The Defendant has the reasonable belief that the Claimant has not incurred £XXXXXXXXXXX costs due to the aforementioned reasons to pursue an alleged £60 debt.. The Protection of Freedoms Act 2012, in Schedule 4, Para 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper, in this case £100, as per the Defendants terms.
24. In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no diligence, no scrutiny of details nor even checking for a true cause of action. The Claimant's vexatious conduct from the outset has been intimidating, misleading and indeed mendacious in terms of the added costs alleged.
25. There are several options available within the Courts' case management powers to prevent vexatious litigants pursuing a wide range of individuals for matters which are near-identical, with meritless claims and artificially inflated costs. The Defendant is of the view that private parking firms operate as vexatious litigants and that relief from sanctions should be refused.
26. The Court is invited to make an Order of its own initiative under management powers pursuant to Civil Procedure Rules 3.4., dismissing this claim in its entirety as the claim discloses no cause of action, is without merit and no real prospect to defend and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14 on the indemnity basis, taking judicial note of the wholly unreasonable conduct of this Claimant, not least due to the abuse of process in repeatedly attempting to claim fanciful costs which they are not entitled to recover.
Any help on the above would be really appreciated, Thanks
I have read the newbies thread and threads and havent found an exact match to what I need and just getting a bit lost with all the information
Long Story Short I receiced a Parking fine of £60 (Now £185) for Overstay at my Gym Car Park which also used by other shops for Maximum of 2 hours back in March . Being a Gym Member you get to park for 3 as long as you have put your details in the tablet at the gym. Now I have been a member there for 2 years and the gym were not very helpful at the time but said nothing will happen as they have similar issues with other members and I have parked longer than 2 hours on lots of occasion without any issues.
I informed VCS of this and they rejected all my appeals ( I have admited Ii was the driver, my first mistake) and a few weeks back I received an MCOL as didnt think I would receive this as had been over 6 weeks since I submited to VCS my last appeal.
I did the AOS abd I went straight to my Gym saying I want this escalulated which was to Head Office. I gave them all the details of the fine including the Court Claim which they said they will chase up and get resolved. Having left this with them and I chased a few times with my gym manger, the person whos looking into this has been away and now the deadline for submitting is today (again my mistake for not chasing quicker). The gym manager has made an offer that if I have to pay he will conpensate by offering a years free gym membership which is slightly more than the fine.
I'm just looking if someone just give me a little help with the wording of a Dence draft I have found from another thread and put bits in that i could use below to submit.
IN THE COUNTY COURT
CLAIM No: xxxxxxxxxx
BETWEEN:
VCS LTD (Claimant)
-and-
xxxxxxxxxxxx (Defendant)
________________________________________
DEFENCE
________________________________________
1. The Defendant is the registered keeper of the vehicle in question. The Claim relates to an alleged debt arising from the driver's alleged breach of contract, which is denied. It is further denied that there was any agreement to pay the Claimant a punitive £60 'parking charge notice' (PCN) for the lawful conduct described below.
2. The allegation appears to be that the 'Parked for longer than the Maximum Period Permitted ' based on images by their ANPR camera at the entrance and exit to the site. This is merely an image of the vehicle in transit and is no evidence of 'No Auth' or not being a patron of the facility.
3. The facts are that the vehicle, registration XXXXX, is permitted to park at LOCATION through an agreement with COMPANY NAME for a Maximum of 3 Hours and the landlord via COMPANY MANAGEMENT NAME.
4 . The Defendant has already proved patronage as COMPANY NAME and has been a member for two years, on two occasions and it is the Claimant's own failure, to acknowldge this fact.
4. The Claim Form issued on xx March 2019 by VCS Ltd was not correctly filed under The Practice Direction as it was not signed by a legal person but signed by “VCS Limited” which is the Claimant’s Legal Representative. The claim does not have a valid signature and is not a statement of truth. Practice Direction 22 requires that a statement of case and truth on behalf of a company must be signed by a person holding a senior position and that person or office must state the position held. If the party is legally represented, the legal representative must sign the statement of truth in their own name and not that of their firm or employer.
5. The Claimant has not complied with pre-court protocol (as outlined in the new Pre-Action Protocol for Debt Claims, 1 October 2017) and as an example as to why this prevents a full defence being filed at this time, a parking charge can be for trespass, breach of contract or a contractual charge. All these are treated differently in law and require a different defence. The wording of any contract will naturally be a key element in this matter, and a copy of the alleged contract has never been provided to the Defendant.
6. It is denied that the Defendant, or any driver of the vehicle, entered into any contractual agreement with the Claimant, whether express, implied, or by conduct.
7. The alleged breach, according to VCS Ltd, is in contravention of terms and conditions. Visitors were expected to input their Vehicle Registration Number into a touchscreen system which was not displayed anywhere on the small sparse signs within the car park. The signs in this car park are not at all prominent, clear or legible from all parking spaces or upon entering the car park and there is insufficient notice of the sum of the parking charge itself. Other signs in this car park are sporadically placed and not clearly visible, especially in the evening when it's dark with no sufficient lighting. It is therefore very much possible to park and not be able to see any clear signage which complies with BPA requirements.
10. It is contended that the Claimant failed to alert regular local visitors to an onerous change and unexpected obligation to use an iPad, or risk £100 penalty. The Claimant is put to strict proof, with the bar being set by Denning LJ in J Spurling Ltd v Bradshaw [1956] in the well-known 'Red Hand Rule' where hidden/unknown terms were held to be unenforceable: ''Some clauses which I have seen would need to be printed in red ink...with a red hand pointing to it before the notice could be held to be sufficient.''
11. The Claimant is put to strict proof that it has sufficient interest in the land or that there are specific terms in its contract to bring an action on its own behalf. As a third party agent, the Claimant may not pursue any charge, unless specifically authorised by the principal. The Defendant has the reasonable belief that the Claimant does not have the authority to issue charges on this land in their own name, and that they have no right to bring any action regarding this claim.
12. . Even if the Claimant is able to produce such a landowner contract, it is averred that there can be no legitimate interest arguable by the Claimant in this case. When - all too often at this location – VCS Ltd unfairly harvest the data of a registered keeper to charge a genuine patron, any commercial justification in the form of landowner support for such unfair ticketing is de facto absent.
13. Further, there was no overstay nor any mischief to deter, nor was there any misuse of a valuable parking space by the Defendant, whose car was parked in good faith, not in contravention nor causing an obstruction, and was certainly not 'unauthorised'. With no 'legitimate interest' excuse for charging this unconscionable sum given the above facts, this Claimant's claim is reduced to an unrecoverable penalty and must fail.
14. This case is fully distinguished in all respects from ParkingEye Ltd v Beavis [2015] UKSC 67. That Supreme Court decision sets a high bar for parking firms, not a blanket precedent, and the Beavis case essentially turned on a 'complex' and compelling legitimate interest and very clear notices, where the terms were held not to involve any lack of good faith or 'concealed pitfall or trap'. Completely unlike the instant case.
15. In addition, there can be no cause of action in a parking charge case without a 'relevant obligation' and/or 'relevant contract' (the Protection of Freedoms Act 2012, Schedule 4 refers).
16. This Claimant uses ANPR camera systems to process data but fails to comply with the Information Commissioner's 'Data Protection Code of Practice for Surveillance Cameras and Personal Information' (the ICO Code). This is both a specific Data Protection and BPA Code of Practice breach. The Supreme Court Judges in Beavis held that a Code of Practice is effectively 'regulation' for this blatantly rogue industry, full compliance with which is both mandatory and binding upon any parking operator.
17. The ICO Code applies to all ANPR systems, and states that the private sector is required to follow it, in order to meet its legal obligations as a data processor. Members of the BPA are required to comply fully with the Data Protection Act (DPA) and all ICO rules and guidelines, as a pre-requisite of being able to use the DVLA KADOE system and in order to enforce parking charges on private land. At this location, the Claimant has failed on all counts and the data gathered about patrons of the site is unconscionable and excessive, given the lack of transparency about the risk of a charge for failing to do something that the driver never knew was a requirement.
18. These are specific breaches of the Consumer Protection from Unfair Trading Regulations 2008 and transgress the tests of fairness and transparency of consumer contracts, as set out in the Consumer Rights Act 2015 (this relatively untested legislation was enacted after the final hearing in Beavis and not actively considered in that case). As such, this claim must fail.
19. This claim inflates the total charges in a clear attempt at double recovery. The Defendant trusts that the presiding Judge will recognise this wholly unreasonable conduct as a gross abuse of process. It was held in the Supreme Court in Beavis (where £85 was claimed, and no more) that a private parking charge already includes a very significant and high percentage in profit and more than covers the costs of running an automated regime of template letters. Thus, there can be no 'costs' to pile on top of any parking charge claim.
20. In addition to the original penalty, the Claimants have artificially inflated the value of the Claim by adding purported legal costs and fines of £100, which have not actually been incurred by the Claimant. VCS Ltd have not expended any such sum in this case, given that they have a Legal Team with salaried in-house Solicitors and this firm whose main business is supposed to be parking 'management' as a service provision, files tens of thousands of similar 'cut & paste' robo-claims per annum. No genuine legal costs arise, per case, and their in-house Solicitors cannot possibly be believed to be paid in the millions per annum for their services.
21. The added 'legal' cost is in fact an artificially invented figure, which represents a cynical attempt to circumvent the Small Claims costs rules and achieve double recovery. According to Ladak v DRC Locums UKEAT/0488/13/LA, a Claimant can only recover the direct and provable costs of the time spent by legally qualified staff on actually preparing the claim and/or the cost of obtaining advice for that specific claim, in a legal capacity.
22. Many informed Court Court Judges have disallowed all added parking firm 'costs' in County courts, such as these cases, struck out in recent months without a hearing, due solely to the pretence of adding 'damages' blatantly made up out of thin air.
(a) In Claim number F0DP163T on 11th July 2019, District Judge Grand sitting at the County Court at Southampton, struck out a overly inflated (over the £100 maximum Trade Body and POFA 2012 ceiling) parking firm claim without a hearing for that reason.
(b) In Claim number F0DP201T on 10th June 2019, District Judge Taylor echoed an earlier General Judgment or Order of DJ Grand, who on 21st February 2019 sitting at the Newport (IOW) County Court, had struck out a parking firm claim. These include a BPA member serial Claimant (Britannia, using BW Legal's robo-claim model) and an IPC member serial Claimant (UKCPM, using Gladstones' robo-claim model) where the abuse is inherent in the business model.
23. The Defendant has the reasonable belief that the Claimant has not incurred £XXXXXXXXXXX costs due to the aforementioned reasons to pursue an alleged £60 debt.. The Protection of Freedoms Act 2012, in Schedule 4, Para 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper, in this case £100, as per the Defendants terms.
24. In summary, the Claimant's particulars disclose no legal basis for the sum claimed and it is the Defendant's position that the poorly pleaded claim discloses no cause of action and no liability in law for any sum at all. The Claimant’s solicitors are known to be a serial issuer of generic claims similar to this one, with no diligence, no scrutiny of details nor even checking for a true cause of action. The Claimant's vexatious conduct from the outset has been intimidating, misleading and indeed mendacious in terms of the added costs alleged.
25. There are several options available within the Courts' case management powers to prevent vexatious litigants pursuing a wide range of individuals for matters which are near-identical, with meritless claims and artificially inflated costs. The Defendant is of the view that private parking firms operate as vexatious litigants and that relief from sanctions should be refused.
26. The Court is invited to make an Order of its own initiative under management powers pursuant to Civil Procedure Rules 3.4., dismissing this claim in its entirety as the claim discloses no cause of action, is without merit and no real prospect to defend and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14 on the indemnity basis, taking judicial note of the wholly unreasonable conduct of this Claimant, not least due to the abuse of process in repeatedly attempting to claim fanciful costs which they are not entitled to recover.
Any help on the above would be really appreciated, Thanks
0
Comments
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I would also add that they failed the CRA 2015 because they offer you nothing in the alleged parking contract , you had permission to park from the gym where you have a contract as a paid up member, therefore no consideration equals no contract from VCS
I would also get a WS from the gym manager to include with your own WS at that stage too ( not needed for the defence stage )
Are you sure the original PCN was £60 , and not £100 reduced to £60 for early payment ?
Also, your deadline cannot be today, a Sunday, nor tomorrow which is a bank holiday
What is the issue date on the claim form ??0 -
I would also add that they failed the CRA 2015 because they offer you nothing in the alleged parking contract , you had permission to park from the gym where you have a contract as a paid up member, therefore no consideration equals no contract from VCS - Thanks will Add this
I would also get a WS from the gym manager to include with your own WS at that stage too ( not needed for the defence stage ) - He has agreed to Come to court if neccessary so I dont think this would be an issue
Are you sure the original PCN was £60 , and not £100 reduced to £60 for early payment ? - Yes your right need to change this
Also, your deadline cannot be today, a Sunday, nor tomorrow which is a bank holiday -
What is the issue date on the claim form ?? - 23/07/20190 -
You still need his WS in writing , even if he attends , great to get both , statement and attendance
I doubt that they added £100 to the charge for the PCN
More likely that the PCN was £100 and they added £60 debt collectors fee plus £25 CCBC fee
I make your deadline day 4pm on 27 August 2019 , which is 33 days from the issue date plus adding today and tomorrow on as well because it cannot be a Sunday nor a Bank holiday0 -
A decent offer, usually gyms are decidedly unhelpful to their paying membership.The gym manager has made an offer that if I have to pay he will conpensate by offering a years free gym membership which is slightly more than the fine.
Why not get an email from the manager saying that the gym does not wish for any member/customer to be sued by VCS and that your case is against those wishes. You can add that to your eventual Witness Statement (about 2 months away) and hope that it will help sway the Judge in your direction, meaning VCS get what they deserve from suing you - £0.00!
But you've still got a nice 'backstop' (oops, perhaps shouldn't mention that, gets politicians all of a lather!
). 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 Street0 -
I make your deadline day 4pm on 29 August 2019 , which is 33 days from the issue date - Thanks I kept think ing it was today for some reason
I will keep also chasing up with the Gym Magager and submit this before Thursday0 -
A decent offer, usually gyms are decidedly unhelpful to their paying membership.
Why not get an email from the manager saying that the gym does not wish for any member/customer to be sued by VCS and that your case is against those wishes. You can add that to your eventual Witness Statement (about 2 months away) and hope that it will help sway the Judge in your direction, meaning VCS get what they deserve from suing you - £0.00!
But you've still got a nice 'backstop' (oops, perhaps shouldn't mention that, gets politicians all of a lather!).
Yeah the staff were not that helpful originally as I used to mainly go in the evening so there was no Manager there.
Im sure he was would be happy to write that and to get something from headoffice for me if required.
Yep worst case is I have to pay but will get ot back through my membership0 -
Hi , I edited my post due to a typo in calculating from your issue dateI make your deadline day 4pm on 29 August 2019 , which is 33 days from the issue date - Thanks I kept think ing it was today for some reason
I will keep also chasing up with the Gym Magager and submit this before Thursday
It's actually 4 pm on Tuesday the 27th, I was hoping that I had edited it in time before you saw it, so Tuesday not Thursday , it's never a Sunday as the CCBC is closed, but 33 days was today as you surmised, the bank holiday has stretched it even further0 -
Yes, Redx is right with your target date.
With a Claim Issue Date of 23rd July, and having done the Acknowledgement of Service in a timely manner, you have until 4pm on Tuesday 27th August 2019 to file your Defence.
That's just two days away.
When you are happy with the content, your Defence should be filed via email as suggested here:-
Print your Defence.
- Sign it and date it.
- Scan the signed document back in and save it as a pdf.
- Send that pdf as an email attachment to CCBCAQ@Justice.gov.uk
- 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'.
- Log into MCOL after a few days to see if the Claim is marked "defence received". If not chase the CCBC until it is.
- Do not be surprised to receive an early copy of the Claimant's Directions Questionnaire, they are just trying to keep you under pressure.
- Wait for your DQ from the CCBC, or download one from the internet, and then re-read post #2 of [URL="https://forums.moneysavingexpert.com/discussion/4816822NEWBIES FAQ sticky thread[/URL] to find out exactly what to do with it.
0 - Sign it and date it.
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Just checking - what is the full name of the claimant on the claim form.0
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1505grandad wrote: »Just checking - what is the full name of the claimant on the claim form.
Simon Renshaw-Smith0
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