Help needed regarding claim forms (N1SDT) from UKCPM/Gladstone solicitors
Hello, this is the first time I am going through this process and the resources available here have proved to be extremely helpful and informative (thank you everyone!).
Quick summary: I live as a tenant, with a marked (with flat number) parking spot in underground fob-accessed car park. Have been living here/parking car since mid-2021. Parking permit was given by letting agency, which I have kept on the dashboard of the car.
Received multiple PCNs earlier this year that permit was not visible (car was parked in correct bay). The permit is placed (not stuck) on the dashboard and sometimes (rarely) gets moved when the window is opened and there is a draught. I see it fallen on the sear and put it back in place. Not sure if this was one of those instances as the pictures in the PCN were poor quality. I ignored the PCNs and the following letters from Gladstone Solicitors, and have now received two claim forms for breaches on the same day.
Claim 1 issue date: 15/December/2023
Claim 2 issue date: 19/December/2023
Solicitors: Gladstone Solicitors
What I have done so far.
- Read the NEWBIES thread to understand the steps involved.
- Completed AoS on MCOL for both claims on 31/December/2023 (AoS received on 2/January/2024 as per MCOL website for both claims). MCOL will be used a read-only from now.
- I have started preparing my defence based on the Template Defence provided.
1. While the claim form issue dates are 15th and 19th of December, I did not receive the letters in my post till 30th December. Now this could be due to the holiday season, but also due to well-advertised delays at the local post office, which have been going on for past few months. Does this effect my timeline, and do I need to say something about this in my defence statement?
2. I am pasting redacted versions of both claims. Could you please confirm that the POC does not state the actual breach, and I can use wording from relevant posts with in my defence?
3. Where do I ask for both claims to be amalgamated, on the defence template or a separate cover letter? Could someone please direct me to relevant post/thread on this. I tried searching the forum for ‘two claims? abuse of process consolidated’, but only found other threads being asked to look for the same.
4. I have checked my AST, and nowhere it mentions needing a parking permit or any mention of parking whatsoever. Is this something I can include in my defence, if it would help?
5. I do not own the vehicle in question anymore. I was the registered keeper when the alleged breach happened. Does this change anything, or is this something I need to include in the defence?
Would appreciate any further help or advice, I know I have to modify paras 2 and 3 from the template, but if there is anything specific I should include based on the above, please let me know.
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