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New PCN NTK from UKPC, they have photos

Hi Guys,

So my last attempt to fight these tickets went to court, so i really want to play this one better and try and tackle it on the first instance.

I have a NTK from UKPC that includes photographs.

Is the first line of attack to send this defence from the Newbies thread, as they have included photos which means its mostly irrelevent... in which case is there any other way to approach?

Re PCN number:

I dispute your 'parking charge', as the keeper of the vehicle. I deny any liability or contractual agreement and I will be making a formal complaint about your predatory conduct to your client landowner and to my MP.

There will be no admissions as to who was driving and no assumptions can be drawn. Since your PCN is a vague template, I require ALL photos taken and an explanation of the allegation and your evidence, i.e.:

- If the allegation concerns a PDT machine, the data supplied in response to this appeal must include the record of payments made - showing partial VRNs - and an explanation of the reason for the PCN, because your Notice does not explain it.

- If the allegation involves an alleged overstay of minutes, your evidence must include the actual grace period agreed by the landowner. If you fail to evidence the actual grace period that applies at this site or suggest that only one period applies, this will be disregarded as an attempt to mislead. In the absence of evidence, it will be reasonably taken to be a minimum of twenty minutes (ten on arrival and ten after parking time) in accordance with the official BPA article by Kelvin Reynolds about 'observation periods' on arrival being additional and separate to a 'grace period' at the end.

- in all cases, you must include a close up actual photograph of the sign you contend was at the location on the material date.

Formal note:
Should you later pursue this charge by way of litigation, note that service of any legal documents by email is expressly disallowed and you are not entitled to assume that the data in this dispute/appeal remains the current address for service in the future.

Yours faithfully,

Comments

  • waamo
    waamo Posts: 10,298 Forumite
    10,000 Posts Seventh Anniversary Name Dropper
    It's not irrelevant. They see it and recognise it flagging you up as a difficult target.

    Have you complained to the landowner?
  • Umkomaas
    Umkomaas Posts: 43,862 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Is the first line of attack to send this defence from the Newbies thread, as they have included photos which means its mostly irrelevent... in which case is there any other way to approach?
    If there was any better way to approach, it would be templated in the sticky.

    If you have a better way, show us your draft please.
    Please note, we are not a legal advice forum. I personally don't get involved in critiquing court case Defences/Witness Statements, so unable to help on that front. Please don't ask. .

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

    Give a man a fish, and you feed him for a day; show him how to catch fish, and you feed him for a lifetime.

    Private Parking Firms - Killing the High Street
  • 1505grandad
    1505grandad Posts: 4,047 Forumite
    Part of the Furniture 1,000 Posts Name Dropper
    " I require ALL photos taken " - are you sure you have received ALL the photos held by them?.
  • Got out of this one! Thanks people!
  • Coupon-mad
    Coupon-mad Posts: 155,731 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Great, so are you confirming that the template appeal worked again, with no edits?

    :)
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Umkomaas
    Umkomaas Posts: 43,862 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Got out of this one! Thanks people!

    How? Can you give us a bit more of a clue?

    Well done anyway!
    Please note, we are not a legal advice forum. I personally don't get involved in critiquing court case Defences/Witness Statements, so unable to help on that front. Please don't ask. .

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

    Give a man a fish, and you feed him for a day; show him how to catch fish, and you feed him for a lifetime.

    Private Parking Firms - Killing the High Street
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