Bristol Airport NTK - 104) Stopping to Pick-Up/Drop Off In a Restricted Zone

Fruitcake

You could also add in your response to DCB Ltd that the first duty of a solicitor is to the court, not to their client.
"VCS has previously lied to me in correspondence stating that their employer, Bristol Airport Ltd consider byelaws at the material location to be obsolete. This is not true as has been established in writing by The Right Honourable John Penrose MP. It has also been established that this is not the first time VCS Ltd has spouted this untruth. Again, I will provide proof of this, and that VCS were aware over a year ago that this claim about byelaws is not true, and is therefore proof of VCS's attempts at serial deception.

DCB Ltd should censure their client, VCS Ltd, for making untrue statements (that will be produced as evidence of your client's lies and attempts to mislead motorists), and DCB Ltd should censure themselves for spouting falsehoods about land ownership."

Please do follow up with a complaint to the SRA.

RRTechie

Thanks everyone...

I will be sending the following email in response to DCB Legal's reply to my reply to their LoC...

Dear DCB Legal Ltd,

I write in response to your correspondence received by email dated ***.

     As you are or should be aware, Vehicle Control Services Ltd (VCS Ltd) are not the landowner of Bristol Airport, nor do they have a contract with or flowing from the landowner of Bristol Airport. G (Graeme) Gamble is not the COO of the Landowner (Ontario Teacher's Pension Plan) of Bristol Airport but is the COO of the sub-contractor employed by the landowner. These statements are false and I will be reporting DCB Legal Limited to the Solicitors Regulatory Authority for making these false statements.

VCS Ltd has previously lied to me in correspondence stating that their employer, Bristol Airport Ltd consider byelaws at the material location to be obsolete. This is not true as has been established in writing by The Right Honourable John Penrose MP. It has also been established that this is not the first time VCS Ltd has spouted this untruth. Again, I will provide proof of this, and that VCS Ltd were aware over a year ago that this claim about byelaws is not true, and is therefore proof of VCS's attempts at serial deception.

DCB Legal Ltd should censure their client, VCS Ltd, for making untrue statements (that will be produced as evidence of your client's lies and attempts to mislead motorists), and DCB Legal Ltd should censure themselves for spouting falsehoods about land ownership.

VCS Ltd have failed to provide a copy of the contract with or flowing from the landowner to the registered keeper of the vehicle. Without such a contract, the keeper can never be held liable.

The map of the area outlined in red does not match the location where the alleged event occurred. 

There are no traffic lights shown within the area marked in red where the alleged event allegedly occurred.

The map does not show where the alleged event occurred.

VCS Ltd have failed to show photos of the vehicle allegedly parked within the red outline on the map of where the alleged event occurred.

The photos provided by VCS Ltd do not show the vehicle was within the area marked in red.

Based on the circumstances provided, I am willing to settle the matter. I  would be agreeable to your offer of payment of £120.00 to conclude the matter. For clarity, this relates to both PCNs: ***, ***.

My bank details are,  Sort Code **-**-**, A/C No ***. Payment of £120 to this account within 7 (seven) days of the date of receipt of this notice, which is presumed by law to be two working days from the date of issue will result in an end to this matter. 

If payment is not received within this timeframe, your client should be prepared to lose in court at which point I will seek ordinary costs plus costs for unreasonable behaviour.

For the avoidance of doubt, airport byelaws apply at the material location meaning that the registered keeper can never be held liable for this spurious and inflated charge.

The driver has not been identified, and in any case, they cannot be held liable for actions of a passenger whilst the vehicle was lawfully stopped as require by airport byelaws at a traffic light controlled pedestrian crossing whilst said lights were set to red.

Yours sincerely,

***

Coupon-mad

Typo here:

"stopped as require by airport byelaws"

should be 

stopped as required and specifically allowed by airport byelaws

RRTechie

Coupon-mad said:

Typo here:

"stopped as require by airport byelaws"

should be 

stopped as required and specifically allowed by airport byelaws

Thank you...I have made the change and will send tomorrow.

Fruitcake

It should be Teachers' not Teacher's.

RRTechie

Thank you everyone for your help...Reply now sent.

Imnotpaying

"3. The Operator is authorised by the Landowner to undertaker Parking Management, Control and Enforcement at the site by a contract dated 07th October 2019."
Glad to know the Landowner has a funeral provision contract with the operator..... 

RRTechie

Update:

- Received Claim Form and have implemented the great AoS process in the Newbies section to submit my Acceptance of Service (AoS).

- My deadline for submitting defence is 24/08/2024.

Onwards and upwards and Right Up 'Em!

KeithP

What is the Issue Date on your Claim Form?
Upon what date did you file an Acknowledgment of Service?

RRTechie

Issue Date: 22/07

AoS: Today 31/07