County Court Letter – Defence against Gladstones (UKCPM)

Coupon-mad

this particular Claimant UK CAR PARK MANAGEMENT LIMITED House lists their company number as 07383860 .  

What happened to the word 'Companies'?

Also how can you say this when in 1.1. you didn't say you were not the driver (and you must not lie).
Of course you had knowledge of the PCN and letters; you told us you received them so why have you left this in, you can't write something under a statement of truth that isn't true, and it's your task to put the facts right for your own case:

16.  The Defendant is not driver of this vehicle and has no knowledge of any parking charge notice (‘PCN’) or letters.

1505grandad

Also:-
"However, this Claimant is claiming a global sum of £176.18."

I believe the global sum is £170  -  interest is not to be included

D_P_Dance

CM said Nine times out of ten these tickets are scams, so consider complaining to your MP, it can cause the scammer extra costs and work, and has been known to get the charge cancelled.

Parliament is well aware of the MO of these private parking companies, many of whom are former clampers, and on 15th March 2019 a Bill was enacted to curb the excesses of these shysters. Codes of Practice are being drawn up, an independent appeals service will be set up, and access to the DVLA's date base more rigorously policed, persistent offenders denied access to the DVLA database and unable to operate.

Hopefully, when life gets back to normal, it will become impossible for those scammers who are left to continue their vile trade, but until this is done you should still complain to your MP, citing the new legislation.

http://www.legislation.gov.uk/ukpga/2019/8/contents/enacted

Just as the clampers were finally closed down, so hopefully will many of these Private Parking Companies.

I also intend to shortly provide a template counter-claim and encourage people to make a punt at £35 (to claim up to £300) or £60 (to try to claim up to £1000), to try to overburden the robo-claim solicitors and catch PPCs out so they don't defend the counterclaim in time.

I fully endorse everything possibe that can be done to make ife difficult for these bottyom feeding law firms, her is another way.

Le_Kirk

Just check when you print it, that paragraph 5 comes out as Appendix B ) and not Appendix .  It is because the new forum platform reads "B )" without a space between "B" and ")" as a smiley.

zeljko

Coupon-mad said:

this particular Claimant UK CAR PARK MANAGEMENT LIMITED House lists their company number as 07383860 .  

What happened to the word 'Companies'?

Also how can you say this when in 1.1. you didn't say you were not the driver (and you must not lie).
Of course you had knowledge of the PCN and letters; you told us you received them so why have you left this in, you can't write something under a statement of truth that isn't true, and it's your task to put the facts right for your own case:

16.  The Defendant is not driver of this vehicle and has no knowledge of any parking charge notice (‘PCN’) or letters.

Hi,

very good spotted. I have put missing word 'Companies'.

From begging of this ticket saga I never disclose who was a driver. When NTK arrived I have challenge as the KEEPER.

I have respond online and post using template below:

Can I still keep statement "you were not the driver"?

For this:

Of course you had knowledge of the PCN and letters; you told us you received them so why have you left this in, you can't write something under a statement of truth that isn't true, and it's your task to put the facts right for your own case:

I will remove as per your suggestion. Should I remove pint #16 or keep it like this:

1.      The Defendant is not driver of this vehicle. It is not established thus far, whether the car was parked, or just stopped momentarily and caught by predatory ticketing.  It is not accepted that the location included prominent signs giving ‘adequate notice’ of the onerous parking charge.

Thank you for help.

zeljko

1505grandad said:

Also:-
"However, this Claimant is claiming a global sum of £176.18."

I believe the global sum is £170  -  interest is not to be included

Hi,
please check below claim form, should be £160 or £176.18?

zeljko

Le_Kirk said:

Just check when you print it, that paragraph 5 comes out as Appendix B ) and not Appendix .  It is because the new forum platform reads "B )" without a space between "B" and ")" as a smiley.

Hi,
Good point I will be careful about this, print preview showing ok for now:
 

Le_Kirk

zeljko said:

1505grandad said:

Also:-
"However, this Claimant is claiming a global sum of £176.18."
I believe the global sum is £170  -  interest is not to be included

Hi,
please check below claim form, should be £160 or £176.18?

Below are part of the instructions from the post that Coupon-mad wrote about using this defence.  From here you can see that the global amount is a whole number i.e. £160.

Everything shown in red is something that needs editing by you and changing to black font once you've done it - even the £160 if your case seeks £182.      DO NOT ADD THE COURT CLAIM AND LEGAL FEES TO THAT SUM - THE OBJECTION IS TO THE 'ADMIN/CONTRACTUAL COSTS' ONLY. 
YOUR FIGURE NEAR THE START WILL BE A WHOLE NUMBER.  USUALLY £160 (REMOVE THE BOLD).

zeljko

Le_Kirk said:

zeljko said:

1505grandad said:

Also:-
"However, this Claimant is claiming a global sum of £176.18."
I believe the global sum is £170  -  interest is not to be included

Hi,
please check below claim form, should be £160 or £176.18?

Below are part of the instructions from the post that Coupon-mad wrote about using this defence.  From here you can see that the global amount is a whole number i.e. £160.

Everything shown in red is something that needs editing by you and changing to black font once you've done it - even the £160 if your case seeks £182.      DO NOT ADD THE COURT CLAIM AND LEGAL FEES TO THAT SUM - THE OBJECTION IS TO THE 'ADMIN/CONTRACTUAL COSTS' ONLY. 
YOUR FIGURE NEAR THE START WILL BE A WHOLE NUMBER.  USUALLY £160 (REMOVE THE BOLD)

Great that is clear now, I will put £160.

1505grandad

As per the thread by C-m:-

"Start a new discussion about your own case if you haven't already and show us your draft defence based on this one, if the PPC has included in the Particulars of Claim on the left of the Claim Form, that they have added 'contractual costs' or damages - usually £60 or £70 - that takes the alleged 'debt' over £100."

Without the benefit of the claim form I thought there was only a small amount of interest - so the global amount is as already stated above £160.