Operator under IPC code failing to address appeal points

goroaming

Thanks CM,
I'll experiment with a database thing and let you know how I get on but the problem you identify does make it difficult.
Today I got a "Letter before claim" for the first PCN. I'll presumably get another similar letter for the second PCN in a weeks time or so. Do I need to respond again immediately about the issue of "combining two claims" every time they send me anything to do with individual PCN's? I only sent the first letter telling them to combine the claims yesterday.
Thanks in advance.

Coupon-mad

Yes, send the response about combining two claims, in both cases.

goroaming

Hi all,
I basically sent the letter as described above but I had ignored the rest of it thinking it was just part of their sham process to get exhorted fees out of me. Then I saw that there was a form to fill in that I've scanned and attached. It has an option to fill in the form saying that I do not owe the alleged debt. Should I complete it and send it back to them or is that simply playing their game? They ask for full details about why I don't owe any alleged debt but are they just trying to find out my arguments/case against them to prepare better to fight me? Should I engage in this form? Links to the jpg's are here:





Thanks for any responses in advance.

MothballsWallet

I've rotated the images round 90 degrees so they're more readable.





These could be the PPC "fishing" for more details about your personal finances as well, but what do others think?

Is this the standard PPC "give us your info" baloney sausage expected at this point?

KeithP

Those are standard reply forms that are always sent out with a Letter of Claim.

Ignore them, but do respond to the LoC as described in post #2 of the NEWBIES thread if you haven't already done so.

Coupon-mad

I saw that there was a form to fill in that I've scanned and attached. It has an option to fill in the form saying that I do not owe the alleged debt. Should I complete it and send it back to them

No. The NEWBIES thread tells you about this and NOT filling in these forms.

goroaming

Dear all,
I've recieved the next "letter before claim" from VCS and I have cobbled together a response pressing them to consoldate two claims into one as you have advised me to do.

*************************letter starts*************************
Your Ref: Letter before claim
Your Ref: Final Demand Letter for PCN2 dated December 19
My Ref:

Dear Sir or Madam,
I am writing to you in relation to the PCN charges you have claimed against me as the keeper of vehicle car registration namely PCN1 and PCN2.
I do not recognise the legitimacy of any of these claims as detailed in a written submission to you in relation to this matter. I do not accept that any contract to make the payment that you are requesting exists.
I would like to draw your attention to your obligations in relation to the consolidation of similar claims as detailed below:
The issuing of separate claims, by the same Claimant and for essentially the same cause of action, is an abuse of the civil litigation process. The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case. In the event that similar matters proceed to claim issue, they must be particularised as a single claim and not as multiple separate cases, otherwise (as an extreme analogy) a builder purportedly owed money by an individual customer, could file a separate claim for each brick laid.

The facts of these cases are duplicated in every respect: Claimant, Defendant, location, parking charge breach allegation, and added unrecoverable 'debt collection' and/or 'legal' costs for each case,
In my previous letter to you dated Early Jan I pointed out you were pursuing two claims separately, unnecessarily and in contravention to the established case law quoted above. I expressly requested you to consolidate those cases and to respond in writing confirming that you had done so. By issuing a letter before claim separately for PCN2 is a clear attempt to pervert the correct court processes and exaggerate the unfounded and contested claim for damages you have made in each “letter before claim”. If you continue to pursue this course of action and do not consolidate both cases I will consider my option to pursue damages against you for vexatious and unsupportable claims that have been exaggerated to inflate costs to me and which clearly fall into the category of “double charging”.
Please confirm in writing by date two weeks from now that you will consolidate both claims into one prior to issuing any legal proceedings.

*********************************letter ends******************************

Any comments or suggestions for improvements gratefully accepted.