'left site' UKPC nonsense - check my defence

Umkomaas

To get some confidence in your position, go to the UKPC website as if to pay your PCN (obviously don't!) where you should then be able to see all the photos they have of the parking event.  Bet there won't be any of the driver leaving the site (whatever they mean by the very loose term 'site'!).

Coupon-mad

It is alleged that the keeper of vehicle xxxx RDZ breached terms of parking signage by leaving the shopping park. 

No it isn't alleged, not in the claim.

Please don't do their job for them and fill in gaps that are not in the POC.

It is recommended that you use the defence by @Johny86 and just change paras 2, 3 and 4.  Like everyone else in every DCBLegal /UKPC thread since February, this claim does not make any specific allegation about leaving the site, hence you need the extra paras 5 -11 in Johny's thread.

Physiobro

Coupon-mad said:

It is alleged that the keeper of vehicle xxxx RDZ breached terms of parking signage by leaving the shopping park. 

No it isn't.

Don't do their job for them and fill in gaps that are not in the POC.

That's why you use the defence by @Johny86 and just change paras 2, 3 and 4.

Like everyone else in every DCBLegal /UKPC thread since February, this claim does not make any specific allegation about leaving the site, hence you need the extra paras 5 -11 in Johny's thread.

The POC makes reference to the PCN and number though which does say about leaving site? Surely the original PCN (which I have via SAR) would then be used as evidence of the breach of terms? 

B789

Physiobro said:
The POC makes reference to the PCN and number though which does say about leaving site? Surely the original PCN (which I have via SAR) would then be used as evidence of the breach of terms? 

You don't know that. You are assuming too much. Your Defence is answering the particulars on the Claim. Knowing how bad they are from DCB Legal, you just need to do as you are advised. Everyone else is out of step but you?

As in this example Defence, just edit your paras 2, 3 & 4:

https://www.dropbox.com/s/66hosld75llha3j/2023_defence.pdf?dl=0

Physiobro

B789 said:

Physiobro said:
The POC makes reference to the PCN and number though which does say about leaving site? Surely the original PCN (which I have via SAR) would then be used as evidence of the breach of terms? 

Everyone else is out of step but you?

As in this example Defence, just edit your paras 2, 3 & 4:

https://www.dropbox.com/s/66hosld75llha3j/2023_defence.pdf?dl=0

"Everyone else is out of step but you?" - such passive aggression on this forum. Not suggesting this at all I'm asking for opinions and critique on what I've written but clearly anything outside of copy and pasting someone else's defence is unacceptable 

I keep getting redirected to the newbies thread or the same template defence which I have read and have already copied. The bits I have put on here ARE my attempt at editing paras 2, 3 & 4. I didn't post the rest of the template defence as has been recommended countless times. I'll stop posting now for fear of getting redirected and told the same thing again. 

Thanks for everyones help to now 

B789

You are getting constructive criticism but being thin-skinned is not going to help you. We post advice/critique/suggestions hundreds of times a day, every day, assisting hundreds of cases a week. It is done in our spare time and some of the volunteers/experts are offering advice that would cost you hundreds of pounds an hour from a solicitor who wouldn't know a fraction of what this scam industry is up to and how to tackle it.

So, please don't just give up because you think a short or terse reply to something you posted is meant as a rebuke or admonishment. It is probably so because it would appear to everyone providing you with advice/critique/suggestions that you are not understanding that advice.

Coupon-mad

"Everyone else is out of step but you?" - such passive aggression on this forum. Not suggesting this at all I'm asking for opinions and critique on what I've written but clearly anything outside of copy and pasting someone else's defence is unacceptable 

I keep getting redirected to the newbies thread or the same template defence which I have read and have already copied. The bits I have put on here ARE my attempt at editing paras 2, 3 & 4. I didn't post the rest of the template defence as has been recommended countless times. I'll stop posting now for fear of getting redirected and told the same thing again. 

Thanks for everyones help to now 

Please stick around, @Physiobro - there are more stages to face and we want to help.

The defence is yours to draft as you see fit but we do now recommend you don't respond in detail to allegations not specified in the POC, which is why we strongly recommend adding paras 5 - 11 from Johny86's defence.

Judges have stuck out a few DCBLegal claims for incoherent POC so it is worth not filling in the gaps for them at this early stage. You might get a strike out when the initial allocating Judge at your local court takes a look at your remarks about the POC and agrees. 

The template defence already denies breach of any term, so that base is covered for you and at WS stage you can expand on the detail.

Then DCBLegal will discontinue as they always do.

Physiobro

Added bits from Johny's defence and sent defence now with much more brief paragraph 2. Basically said I was keeper and don't recall specific events from the day. All else as per the template and Johny's defence