UKPC Finally filed claim.

Boat_to_Bolivia

Have you posted it here?

If not, do so and get some feedback from the experts.

forgotmyname

Curious whether to go into the POPLA appeal details if I don't have the outdated photo's UKPC provided.

Would that be a waste of space?

Thanks.

Coupon-mad

Yes - waste of time - and you don't want to do that because you are using the defence by @Johny86 that says the POC are incoherent.

Also, I've never seen a paragraph 3 of a defence here that's in bullet points!  Show us one?  All the cases I see every day, show us a fairly full facts summary, not bullet points.

As seen in the defence you are advised to copy (Johny86).  Should take you half an hour.

forgotmyname

Sorry badly worded again, but shorter explanations and not a detailed war and peace.  I have hacked it down to the

bare essentials....

Johny86   =  Para2 apples here...

And Para 4 ->

Para 3...

--------------

The driver was a customer of the McDonald’s establishment on the day in question where upon entering the car park in the first instance could not find a suitable space in which to park.

The driver drove around and exited the site several times before finding a suitable disabled parking space within the car park. Having driven
around and exited the car park several times the actual time parked on the site is far less than claimed.

The claimant sent 4 identical PCN’s on the same day which we assume was their camera system picking up the car entering and exiting.

--------------

Should I mention the sign near the exit is often facing different directions ( shown on google images )

Thanks..

Umkomaas

POPLA appeal was unfair and unjust, UKPC provided signage photographs that predated the McDonald’s refurbishment. Photographs of
signage on the building that are no longer there and signage on a wall that was demolished some 3 years prior to the parking event.   

Unless they are using the same photos for their court claim, I'd say this is irrelevant. In fact, in light of your loss at POPLA, it might just cause a judge to consider UKPC's claim justifiable.  You can't second-guess a judge. 

forgotmyname

Removed thanks.

What about the 4 tickets received, is that worth mentioning?    Rewording?

Fruitcake

Four identical PCNs all with the same PCN number seems unreasonable to me and an attempt to intimidate. Definitely mention it in my opinion.

Please show us your paras 2 - 4 for comment.

forgotmyname

Para 2 and 4 unchanged from Johny86


-----------------------------------------------------
2. It is admitted that on the material date the Defendant was the registered keeper of the vehicle in question, but liability is denied.

4. The Defendant avers that the Claimant failed to serve a Notice to Keeper compliant with the Protection of Freedoms Act 2012. Consequently,
the claimant cannot transfer liability for this charge to the Defendant as keeper of the vehicle.

------------------------------------------------------

I don't think it was to intimidate they all arrived on the same day, the keeper was away from home for over a month and these were all
bundled in an elastic band when she got home with several others which were singles and not bundled.

Parking event middle of Dec 18, and she did not arrive home until almost the end of January so she had a few of these.
UKPC so they have the  (42 days) wording.  Coupon-mad said Par.4 covered that.

Coupon-mad

Looks all good now.

forgotmyname

Thank's that is what I meant about short   (although bullet points was a poor choice of words) but my
first attemp was getting on for pages and said little more than those few lines but in minute details
which may have been a hinderance rather than a help.

Just hoping their printer is working so I can send them the document to sign and scan back in. A 6 hour
drive could be costly although I would rather do that than giving UKPC money they are not entitled to.

I will post the entire thing just in case I have missed anything.  Not to check the actual text but that all sections
are complete.

Thank you all.