Yet another UKPC / DCB Legal LTD - WS Bundle

aphex007

patient_dream said:

aphex007 said:

 

I have a date stamped photo of a UKPC sign from the private land dated Dec 2017 which states the following:

“Unpaid Parking Charges will be passed to our debt recovery agent at which point an additional charge of £60 will apply”

A date stamped picture in 2017 ???

Considering the dream world of the BPA had not invented the debt collection charge in the code of practice your ticket relates to, why would UKPC add this ... ?

This is more like another timestamp fraud by UKPC

My bad patient_dream when I said date stamped photo I meant my own photo that a took myself of a UKPC sign in December 2017 after the event.  However there is indeed an actual "date stamped" 2017 UKPC photo (that I received from the SAR) but the photo is so bad it is impossible to read any of the smaller text even when zoomed in!  But you can tell by the formatting of the text it is the same sign.

aphex007

Coupon-mad said:

Please put the spelling of 'kerb' right for the English noun,  as your version is an horrific Americanism that made me stop reading!  I really did stop there, always do...

Add a word here:

unmarked roadway leading into the car park.  

Now corrected and thanks!

patient_dream

aphex007 said:

patient_dream said:

aphex007 said:

 

I have a date stamped photo of a UKPC sign from the private land dated Dec 2017 which states the following:

“Unpaid Parking Charges will be passed to our debt recovery agent at which point an additional charge of £60 will apply”

A date stamped picture in 2017 ???

Considering the dream world of the BPA had not invented the debt collection charge in the code of practice your ticket relates to, why would UKPC add this ... ?

This is more like another timestamp fraud by UKPC

My bad patient_dream when I said date stamped photo I meant my own photo that a took myself of a UKPC sign in December 2017 after the event.  However there is indeed an actual "date stamped" 2017 UKPC photo (that I received from the SAR) but the photo is so bad it is impossible to read any of the smaller text even when zoomed in!  But you can tell by the formatting of the text it is the same sign.

OK, no such thing as debt collection relating to your ticket. As said the BPA had not invented this scam yet

Can you post the picture UKPC sent you

Coupon-mad

I would be using UKPC's own crappy 2017 photo at WS and evidence stage and not your clearer one.

aphex007

UKPC photo:

Redx

That is how I usually see them , and cannot read them from below , or afar 😁😁

Coupon-mad

Perfect evidence for you.

Le_Kirk

Where is paragraph 2?  In paragraph 4 you seem to be repeating what you say.  Do you mean that "after receiving the PCN/NTK the defendant carried out research on foot and discovered that........."  Same comment about paragraph 5.

6.  The Claimants sparse signage on other adjoining roads or roundabouts is placed at such a high height that the Defendant did not see them whilst driving.......

Further to this even Even if the signage was at the correct height for visibility, they are it is placed sideways and not front facing in the direction of travel on the road [whilst the Defendant drives too or from their place of work], therefore the Defendant would still have been unable to read the Claimants signage and thus the defendant did not enter into any contract and was not bound by any contractual terms.

7.  It is the Defendant’s position that this amounts to serial predatory ticketing of employees and visitors of the companies located at this location.  The Claimant is put to strict proof that, at the time of the parking event that the signage was evident, correct and clearly visible on this road in question

Also check that the signage points do not conflict or duplicate the signage points already in the template.  Look out for this (courtesy of @1505grandad who first pointed it out): -

7.  The Claimant ..............  He was not taken by either party to Somerfield in point #5 above and in any event

..... and change #5 to the correct number after you have renumbered your whole defence.

patient_dream

aphex007 said:

UKPC photo:

Are you happy that this picture is from the same car park ?

If that is what they rely on, make sure you take a magnifier with you so the judge can read it

aphex007

Le_Kirk said:

Where is paragraph 2?  In paragraph 4 you seem to be repeating what you say.  Do you mean that "after receiving the PCN/NTK the defendant carried out research on foot and discovered that........."  Same comment about paragraph 5.

6.  The Claimants sparse signage on other adjoining roads or roundabouts is placed at such a high height that the Defendant did not see them whilst driving.......

Further to this even Even if the signage was at the correct height for visibility, they are it is placed sideways and not front facing in the direction of travel on the road [whilst the Defendant drives too or from their place of work], therefore the Defendant would still have been unable to read the Claimants signage and thus the defendant did not enter into any contract and was not bound by any contractual terms.

7.  It is the Defendant’s position that this amounts to serial predatory ticketing of employees and visitors of the companies located at this location.  The Claimant is put to strict proof that, at the time of the parking event that the signage was evident, correct and clearly visible on this road in question

Also check that the signage points do not conflict or duplicate the signage points already in the template.  Look out for this (courtesy of @1505grandad who first pointed it out): -

7.  The Claimant ..............  He was not taken by either party to Somerfield in point #5 above and in any event

..... and change #5 to the correct number after you have renumbered your whole defence.

@Le_Kirk
Missing paragraph 2 now inserted!  You are quite correct it was research after the event for #4 and #5.  I have edited and added the extra text in bold and striked through the, to be removed text.  I have stuck with the word "confirmed" though instead of discovered as it's more definitive.

Yes noted about changing the template 7. point #5 reference.  I will check if there is duplicate signage points in the template as well.

Thank you very much for the help