County Court Claim - QDR Solicitors (NSGL Parking LTD)

Rosht

Redx said:

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

Okay I will update it to be less personal
Why are we saying that the paper ticket is not fit for purpose? 
Is this better?

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's girlfriend purchased 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. The paper ticket is not fit for purpose and the claim is without merit and is de minimis.

Rosht

beamerguy said:

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

COMPANY DIRECTOR = JOHN DORMER

COMPANIES HOUSE INFO FOR QDR

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

Thanks Beamerguy, (it is my 2 series that they are after )
I know I have read a lot about what they do and it is not good. Hopefully my defence is good enough, not done this before.
The total is now £247 with the added court fees, was £172 before.

Redx

Rosht said:

Redx said:

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

Okay I will update it to be less personal
Why are we saying that the paper ticket is not fit for purpose? 
Is this better?

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's girlfriend purchased 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. The paper ticket is not fit for purpose and the claim is without merit and is de minimis because the full tariff was paid and the ticket was displayed.

seems ok but wait for other comments in case it can be improved

IMHO the ticket is not fit for purpose because you can do nothing with it apart from placing it on a dashboard , which was done

if the claimant wants it to be stuck to the windscreen or whatever then it should be foolproof and easy to do, like peeling off a part of it , like a sticking plaster, to reveal adhesive etc, with clear and specific instructions on what to do and where to place it

so if all you could do with the ticket was what you did, in a reasonable manner , then your actions are appropriate

I have added the part in bold

KeithP

Rosht said:

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

I am going to assume that you filed an Acknowledgment of Service some time after 7th May and before 24th May. Please confirm that.
Anything different may affect your Defence filing deadline.

With a Claim Issue Date of 4th May, and having filed an Acknowledgment of Service in a timely manner, you have until 4pm on Monday 7th June 2021 to file your Defence.

That's almost two weeks away. Plenty of time to produce a Defence, but please don't leave it to the last minute.

To create a Defence, and then file a Defence by email, look at the second post in the NEWBIES thread.

Don't miss the deadline for filing a Defence.

Le_Kirk

Rosht said:

Redx said:

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

Okay I will update it to be less personal
Why are we saying that the paper ticket is not fit for purpose? 
Is this better?

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's girlfriend A passenger in the car purchased 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.  In order to narrow the issues, the defendant requested submitted 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. The paper ticket is not fit for purpose and the claim is without merit and is de minimis.

Some suggestions for you.  You do not need to repeat facts.  Looking at the ticket rotated and enlarged, there does not seem to be a space where a VRM would be printed.

Rosht

KeithP said:

Rosht said:

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

I am going to assume that you filed an Acknowledgment of Service some time after 7th May and before 24th May. Please confirm that.
Anything different may affect your Defence filing deadline.

With a Claim Issue Date of 4th May, and having filed an Acknowledgment of Service in a timely manner, you have until 4pm on Monday 7th June 2021 to file your Defence.

That's almost two weeks away. Plenty of time to produce a Defence, but please don't leave it to the last minute.

To create a Defence, and then file a Defence by email, look at the second post in the NEWBIES thread.

Don't miss the deadline for filing a Defence.

Yes I did do the Acknowledgment of Service about a week after I received it the Claim, thanks for the heads up . 

Rosht

Le_Kirk said:

Rosht said:

Redx said:

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

Okay I will update it to be less personal
Why are we saying that the paper ticket is not fit for purpose? 
Is this better?

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's girlfriend A passenger in the car purchased 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.  In order to narrow the issues, the defendant requested submitted 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. The paper ticket is not fit for purpose and the claim is without merit and is de minimis.

Some suggestions for you.  You do not need to repeat facts.  Looking at the ticket rotated and enlarged, there does not seem to be a space where a VRM would be printed.

Thanks Le Kirk, I have made the updates below.

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

3. 3. A passenger in the car purchased 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.  In order to narrow the issues, the defendant submitted 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 displayed on the dashboard. The paper ticket is not fit for purpose and the claim is without merit and is de minimis because the full tariff was paid and the ticket was displayed.

So I think I am quite happy with this now. I will be sending my defense on Monday, any other tips are welcome. Thanks all for your help.

Am I right to follow this:
https://forums.moneysavingexpert.com/discussion/6108153/suggested-template-defence-to-adapt-for-all-parking-charge-cases-where-they-add-false-admin-costs/p1

And not to use the online system, but to send it via email?

Coupon-mad

Yes, as it says - and it tells you that there are other steps after that, as well.

Le_Kirk

So I think I am quite happy with this now. I will be sending my defense on Monday, any other tips are welcome. Thanks all for your help.

I hope you will be sending your defence not defense - it looks like you have your keyboard/PC/phone set to US spelling.

Rosht

Le_Kirk said:

So I think I am quite happy with this now. I will be sending my defense on Monday, any other tips are welcome. Thanks all for your help.

I hope you will be sending your defence not defense - it looks like you have your keyboard/PC/phone set to US spelling.

Thanks Le kirk, I double checked everywhere and thankfully it was only on this forum i made that mistake 
I recieved the auto response email and then also a letter by post acknowledging they had received my defence, but i haven't receieved anything since then, such as the questionaire i was expecting, going by the newbie / process posts.
It says the claimant must contact the court within 28 days after receiving my defence, after which the claim will be stayed.
Should i download the questionaire myself and send it as it mentions in the newbie post, is there beneifit in doing so?
Any other advice is welcome, many thanks for all your help