QDR Formal Letter of Claim

Castle

No reference to the byelaws or in fact any other statue under which the "penalties" have been issued.

Coupon-mad

I agree with @Grizebeck you will need a bespoke defence, not the template.

I have a contact who saw this and said:

"This is my local station and is definitely a byelaws location. Let me know if I can be of any assistance."

He acts as lay rep at hearings (like me, he's not a lawyer, so the Defendant has to attend too but the lay rep speaks).  He would be very useful to assist you and he posts here so maybe he'll stop by.

Your defence needs thought.

When did you do the AOS?

Johnersh

If we're saying that this is subject to byelaw and the criminal justice system, then the AOS possibly would've been a neat solution - a jurisdiction challenge.

As it is, the o/p may wish to plead that

1. the POC are inadequate failing to identify any contract date under which the proceedings are brought or details of breaches or entitlement to damages such that a detailed defence cannot yet be prepared. (They appear to have avoided using that word, aware that there is no private parking contract here under which they bring the claim)

2. If, which is unclear from the pleading, the claimants claim relates to railway land then xx law applies and the county court is not the appropriate forum to hear the claim and in any event is not brought within time, such that the court is invited to strike out.
(Oddly they do reference byelaws in the pre-action correspondence, which suggests they know full well the applicable law here)

3. Probably best to deny entitlement to interest on damages or in the form pleaded or at all.

If there is the suggestion a claim is intentionally brought being opaque as to the law and out of time, that may well be complaint worthy. It's potentially misleading to a consumer and to the court. It's signed off by quite a senior solicitor too.

Coupon-mad

SRA complaint worthy?  

An SRA investigation should put Askews off getting into bed with the parking industry.

Grizebeck

yes you have missed the boat on the challenging jurisdiction issue although that would have required an initial fee by you
@Johnersh however this is what i would do in this case is apply for summary judgment.  If you do it before its gets tracked then employ a solicitor and you will be able to claim the costs as its not a tracked matter
Or if it goes on to track then apply for summary judgment 
@Coupon-mad @bargepole not something that is done often on here but here it would certainly be a good gamble

Coupon-mad

Where is the best place to send the above and the rest of my defence? Direct to Saba, the court or somewhere else?

The CNBC.

Make sure you email your defence as the Template Defence states/explains (and that you get the CNBC's weird auto-receipt talking about delays).

Similar case here:

https://forums.moneysavingexpert.com/discussion/6491089/saba-park-claim-form