I know, You've heard it all before. More CCJ angst

Coupon-mad

Looks ok, a bit short so maybe others can add more.

so the correspondence from both CEL and the courts went and are probably continuing to go to my old address.

Send them a data rectification notice (GDPR) stating your new address and to erase the old one, and ask CEL by email, if they will CONSENT to the set aside as it appears to meet the requirements of a mandatory set aside due to failure to make adequate checks before filing a claim to an old address they got from the DVLA xx months/years ago.

If CEL will consent then the court fee is £100 instead of £255, so worth pushing them by email first and giving them even days to respond promptly, give the fault lay with them for an improperly served claim by making an assumption about fairly old address data.

Greenwich2019

Thank You so much Coupon Mad,
I have sent that as a letter today.........to give them 7 days to consent before I make my application for set aside.
I could not locate an email address on their "website". Is there one that people know about? 
Thanks again.

nosferatu1001

Draft order - your 7 is not right. This draft order is what you want the COURT to ORDER *at the hearing*. Obviously *at the hearing* is too late to consolidate the hearings.... as i told, covering letter, and make it part of the notes section of the N244. 
You have not mentioned CPR 13.2 or CPR13.3. I specifically directed you to them. Have you read them to understand why it is imperative that you do so?

Greenwich2019

Coupon-mad said:

Looks ok, a bit short so maybe others can add more.

so the correspondence from both CEL and the courts went and are probably continuing to go to my old address.

Send them a data rectification notice (GDPR) stating your new address and to erase the old one, and ask CEL by email, if they will CONSENT to the set aside as it appears to meet the requirements of a mandatory set aside due to failure to make adequate checks before filing a claim to an old address they got from the DVLA xx months/years ago.

If CEL will consent then the court fee is £100 instead of £255, so worth pushing them by email first and giving them even days to respond promptly, give the fault lay with them for an improperly served claim by making an assumption about fairly old address data.

So..............haven't heard anything back from CEL regarding the above letter (GDPR request and Request to agree to a set aside) so am now back to applying for a set aside with hearing for both of these tickets. Again, my problem is that I do not know where these offences are alleged to have taken place, I just know when and that I have 2 CCJ's.
I totally get where nosferatu1001 is coming from in that my draft order is not right and I am going to start all over again. I have no legal background in these matters and my question still stands.........how can I form a defence against the tickets when I do not know the location of the car park or what the offences actually relate to? I suppose I will just have to use a generic defence that the signage is misleading not clear and mention CPR13.2 & CPR13.3 in that defence but to be honest I do not really understand what these are myself.
I would be more than happy to pay for advice on these matters but the £1500 quoted by the solicitor I contacted seemed outrageous when all he was going to do is contact the company to ask if they would agree to a set aside.....something I have managed to do myself thanks to Coupon-mad and through research on this website.
Anyway, many thanks to all to date, I am back on this today and will try to put something together if the forum/group would not mind me copy and pasting it here so people can see how NOT to do it
I will keep updating as this goes along in the hope that it will be useful for others.

nosferatu1001

erm, hang on
Youre only *now* applying for a set aside? Your deadline to do so, arguably, has already expired. You were not supposed to wait 18 days!!! to see if you got a response. You ha da total of 3 weeks from when you FIRST discovered the CCJ. 
Your "problem" is now you have to explain why you did not act PROMPTLY in filing for a set aside. As this is a requirement on YOU to do so, you better explain it REALLY well.
Your defence problem - you have already been told or you will have found this SAME advice on multiple threads
You
Guess
Thats it. That is ALL you can do. You point out that this is LIKELY to be for a parking charge and as you have NO documents at all, you have formed a defence based on.... INCLUDING the almost certainly included £60 add on nonsense. 
Also - you must be *precise*
CPR13.2 & CPR13.3 are NOT mentioned in the defence. I never said to mention them in the defence. They go in the WITNESS STATEMENT, because the WS is where you set out yor *grounds* for set aside, and 13.2 and 13.3 are the *grounds* under which  you are looking for a set aside. They are not tricky to read
- 13.2 is the form was never served. Every CCJ set aside thread covers this
- 13.3 is you have a good chance of defending the claim. Every CCJ set aside thread covers this

THREE DOCUMENTS YOU MUST PRODUCE
- set aside draft order. Thats easy. Copy and paste. 6 point draft order.
- WS. Easy. WHY you should get a set aside. How you were contactable at your new address (and you prove it by showing ....) etc
- defence to the underlying claim. EASY. Because you dont know anything at all, you jut create the most generic defence along the lines of:
- no POFA compliance (if the driver was never identified, im not going to check, you know this)
- poor signs
- no land holder authority
- amount claimed is in excess of wha tthe CRA, POFA and the Beavis rulings allow.

Greenwich2019

Very decent of you. I really do appreciate it. This is now my priority.

nosferatu1001

Good! 
You will need to, in your WS, explain why you delayed
- if you are going down the 13.2 route, ie failed service - and i think you are - there is a technical, backed up by court argument that failing to serve means the time to acknowledge has *never* ended - this is because you have to acknowledge within a certain time of being served. No service, the clock doesnt start ticking. Henrik77 i think posted about this. As such the default judgement was never lawful and so *must* be set aside. 
- So you dont rely solely on this, state you are a consumer and you had given the claimant chance to agree to set aside with consent, to minimise costs on both parties as well as saving the court th etime needed for a hearing, as the claimant failed to ensure the claim was served to the last known good address. Thats why you didnt immediately apply. 
You will need to produce a concise, easy to follow ws. no rambling. no mixing up issues. Clear. Concise. Well written. That is NOT something that takes an hour to do . 

Greenwich2019

Yes, definitely appreciate your comments about it not taking an hour!! Believe it or not, having not received a response to the Agree to a Set Aside letter I sent to CEL I have been doing work on this  following what you said by reading through etc. It does, however make much more sense to me now I have your list. I have adapted what I have written re. the draft order and witness statements and made it much more personal to me. I was honestly hoping CEL would get in touch as I have been struggling a bit healthwise recently and could well do without this! Alas they are not the best! 
I haven't started the defence bit yet but I will attach what I have as a PDF and if you think it works I will run with that. I will then make a start on my defence this evening and try to get something up by tomorrow.

Many thanks for all your help with this. 

Le_Kirk

In your 6-point draft order, just leave the dates as XX/XX/2020, the rest of it seems to be OK - I cannot speak to the sequence of events as only you know that is but if it is accurate then should be OK.  One question not answered is why you did not update your V5C when you moved OR you did but it fell through the cracks at DVLA OR there was a timing issue between advising DVLA and the PPC obtaining your data.

Greenwich2019

Yes,
Good point. The reason was that between selling the flat Dec 17 and selling the car March 18 I sent the docs in but as I didn't get them back and was selling the car anyway I didn't chase it up.
Thanks for the input. Would you suggest adding that to the witness statement?