County Court Claim - QDR Solicitors (NSGL Parking LTD)

Rosht

Hello,
I need some guidance please if anyone can help.
I got a parking ticket even though I paid for my ticket. £5 for 4 hours. The reason for PCN: Pay and Display ticket incorrectly displayed. (what does this mean ?)
I have gone through the noobies thread and seen quite a few defense examples. I do struggle to understand most of these defenses as they are written in legal talk. If someone knows a defense similar to my case I would be most grateful. 
Issue date of claim form: 4th of May
I have completed the moneyclaim form, ticking the box for the extra 14 days. So I believe I have until June 6th to submit my defence. 
Should I request SARs now or is it too late?
Many thanks

Rosht

Also it says: 
 "The Parking charge notice was posted to you as it was not possible to attach a notice to your vehicle at the time and has not been paid."
Does this not contradict the statement that says "The Pay and Display ticket was incorrectly displayed".  As to me, this means I displayed a ticket but incorrectly.

D_P_Dance

It does seems to be contradictory.  Have you read the Newbies?  Have you complained yo your MP?

Rosht

D_P_Dance said:

It does seems to be contradictory.  Have you read the Newbies?  Have you complained yo your MP?

I haven't complained to my MP. I have read through the newbies thread and understand the process, but I am struggling with the defence letter that I need to write, any guidance or help would be much appreciated.

Le_Kirk

Never too late to submit a SAR - (note it is not a SARS, you wouldn't want that!)  Any data from that request will be useful for you at witness statement (WS) stage.  Did you find the standard defence template, one of the first five announcements on the front page of the forum?  You only need to adjust paragraphs 2 & 3 of that template.
Seems like you have a typical "fluttering ticket" scenario.  Search the forum for those words and read other posters defences.

Rosht

Le_Kirk said:

Never too late to submit a SAR - (note it is not a SARS, you wouldn't want that!)  Any data from that request will be useful for you at witness statement (WS) stage.  Did you find the standard defence template, one of the first five announcements on the front page of the forum?  You only need to adjust paragraphs 2 & 3 of that template.
Seems like you have a typical "fluttering ticket" scenario.  Search the forum for those words and read other posters defences.

Thanks Le Kirk
I have found the standard defence template. That makes it much easier thank you
 Im finding it hard to know what to write for paragraph 3, as I am not sure what they mean by "Pay and display ticket incorrectly displayed".
Should I just assume it was a fluttering ticket ?
I do not think it was adhesive, or I would of stuck it to my window but I do not have the ticket anymore, so can't check if the ticket was adhesive or if it had a serial number on the back.
Issue is the place is 1 hour away from me (Lulworth Cove, 2 hours total drive just to take some pictures.
The signage is really bad at this place as well, i remember having to ask someone if I had to pay for parking cause I was not sure.

Redx

Signage and extra charges are covered already in that defence template

If the parking was fully paid for , easy so

Don't worry about what incorrectly displayed means , if it was on the dashboard or on the inside of the windscreen , say so , or it it blew off , it's a fluttering ticket , nor fit for purpose , so outline the facts in 3 , don't worry about what the claimant says , it's ambiguous to confuse everyone

As long as the parking was paid for , the allegation is trivial , de minimis

Post the issue date from the CCBC claim form below

Ensure that you have emailed a SAR to the DPO at the claimant PPC , if not done already , attaching a copy of the claim form as proof of I D under the GDPR law to obtain all your data

A landowner complaint , plan A , is also a good Idea , ALWAYS is

Rosht

Thanks Redx
So I should be emailing and asking this email adress for the SAR: dpo@nsgl.co.uk? I had previously emailed admin@nsglparking.co.uk requesting it and without the claim form attached.

Issue date of County Court Claim form: 4th May 2021 

So is what I have written below enough facts, and that is all I need to edit from the template except for filling in my claim references and signing it?

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

3.       The Defendant purchased a valid parking ticket for the period the vehicle in question was parked at the location. The claimant is not clear on what they mean by the defendants ticket being incorrectly displayed. Given the non-adhesive nature of the ticket, it could not be securely fixed to the window, therefore the defendant placed the ticket correctly on the dashboard. 

Rosht

I have received the SAR
it reminded me that the girl I was seeing at the time offered and purchased the ticket on her debit card. She possibly got the car registration wrong, I am not sure I checked or knew it needed a reg, but looking at the pictures the machine looks to have a full keyboard. She is back in Russia now.
I have therefore updated my 2 and 3 defence to include this, is this okay?
2.       It is admitted that the Defendant was the registered keeper and driver of the vehicle in question but liability is denied. 

3. The Defendant was on his second date with a female who he had met the week previously. As he drove them both from Bournemouth to Lulworth, she offered to purchase the parking ticket for the period the vehicle in question was parked at the location. Given the non-adhesive nature of the ticket, it could not be securely fixed to the window, therefore the defendant placed the ticket correctly on the dashboard.  The defendant requested a Subject Access Request (SAR) to understand what the claimant meant by “Pay and display ticket incorrectly displayed". The pictures they have provided clearly show the ticket on display on the dashboard. The defendant has repeatedly asked in what way is the ticket is incorrectly displayed but is getting no response to this question.

Redx

personally , I dont think all the background info should be included, just say the defendant and girlfriend , no one cares how many dates you went on or if you are still together (save it for the WS in a few months time) - just set the scene , concisely

at the end, suggest that the paper ticket is not fit for purpose and the claim is without merit and is de minimis

beamerguy

OH DEAR, QDR again ??

QDR are an offshoot of disgraced solicitors, WRIGHT HASSALL.

Why are they disgraced ?  When the BPA failed to pay London Councils for their appeals service, some bright spark at the BPA decided to offer the job to Wright Hassall who started calling themselves Wright Hassall POPLA  AKA WHOPLA

WHOPLA would reject appeals and then tried to sue people for non payment.
WHAT A SCAM ???
The BPA realised how stupid they were and WHOPLA was history

COMPANIES HOUSE INFO FOR WRIGHT HASSALL
https://find-and-update.company-information.service.gov.uk/company/OC315843/officers
COMPANY DIRECTOR = JOHN DORMER

COMPANIES HOUSE INFO FOR QDR
https://find-and-update.company-information.service.gov.uk/company/07561541/officers
COMPANY DIRECTOR = JOHN DORMER

And QDR are scamming you for a fake £60 ...... 

It is difficult to understand why a once respected legal firm decides to enter the scam industry and degrade themselves to such a low life
Don't get confused ... you are involved in a scam which your MP should be involved with and certainly the main stream media