Claim for 5 PCNs

lowryder

Hello,

In the last two months, I received a letter from DCBLegal. It read that I am liable for 5 PCNs - 100GBP each + 60GBP admin costs for each. 800GBP in total. Following your threads, I understand that this is 'abuse of process' as the admin costs cannot be created out of thin air.
I have then received a claim form of the sum aforementioned + interest.
After reading this forum, I have completed the AOS and now I have to submit my defence through the CCBQ email and not through the www.moneyclaim.gov.uk website. Just to be sure; after I submit my defence by EMAIL following the instructions in the thread there is nothing else that I need to do on the website, right?

My understanding is that I need to follow your template and modify points 2 and 3 with my own facts and keep the rest intact (obvs. modify the claimant/defendant name etc).

Below you have what I have written so far. I would immensely appreciate it if you can critique what's below.

2.       It is admitted that the Defendant was the registered keeper of the vehicle in question but liability is denied. 

3.       The defendant recognizes the car park in question, and it is admitted that the Defendant has parked there multiples times over the last three years. However, the Defendant shares his car with his partner and brother, and they have also parked in the respective car park numerous times. Therefore, it is hard for the Defendant to recognize whether he is liable for all, if any of the PCNs issued to vehicle [VRN HIDDEN]. The Defendant has been made aware of these PCNs by the aggressive ‘debt recovery’ mails he received from DCB Legal on behalf of First Parking LLP, but has felt harassed, especially knowing that he had always paid and has always been in good faith.

KeithP

What is the Issue Date on your County Court Claim Form?

Upon what date did you file an Acknowledgment of Service?
Your MCOL Claim History will have the definitive answer to that.

Coupon-mad

Depends when the NTKs were issued, but just to add, a few years ago F1rst didn't use the POFA 2012 wording and could not hold a registered keeper liable.

lowryder

Issue date is 23rd October. I believe today is my last day, right?
First PCN was issued on Apr 2019, so I think that's when I received my first NTK

Your acknowledgment of service was submitted on 28/10/2020 at 23:18

Your acknowledgment of service was received on 29/10/2020 at 08:08

Coupon-mad

I think you have to get the defence in by tomorrow at the latest but KeithP might be along soon to confirm.

lowryder

I am ready to send it! Just wanted to double-check that the text I’ve written is fine.

D_P_Dance

Have you complained to your MP?  Sometimes  PPCs cancel if an MP weighs in.

Fruitcake

Have you checked to see if any of the NTKs were PoFA compliant? If they are not, then perhaps that should be included in your defence.

lowryder

The only problem is that I just did a SAR last Friday... so I have no clue about how the letters look...

Coupon-mad

Like all the other exact same cases you just add a line putting them to strict proof of POFA 2012 compliance. Easy.

lowryder

Already submitted. Should I try to resend it ? Where do I add this? In paragraph 3 ?
Something like this?
The defendant requests strict proof of POFA 2012 compliance.