MET Parking Services Southgate Park

BigBeardyBaz

Hi, first time posting here.
I am have issues with MET Parking Service, Southgate Park dating back to September 2020.
I ignored the all letters as the original PCN letter arrived about 8 or more weeks after the PCN. Unfortunately I can’t find the original letter which stated “Sorry it’s taken so long to locate you”.
Before Christmas I received a Claim Form N1SDT,  I disagreed with the claim and got an extension until 28/01/24.
On 10/01/24 I received a Notice of Proposed Allocation to the Small Claims Track N149A.
Two things I’d like advice with please.
What to put on the from from Part C?
Can I use BigMacNoFinesPlease defence of the letter being over 14 working days if a cannot give the exact date? Is there a way or requesting a copy of all correspondence from MET and it’s bogus debt collection agencies?

Fruitcake

Please show us the particulars of claim on the claim form, with all personal details redacted.

Please clarify what you mean by "as the original PCN letter arrived about 8 or more weeks after the PCN" because it doesn't make sense. Do you mean a NTD was left on the vehicle, then a NTK posted to the keeper at a later date?

Is the vehicle privately owned, or is it a hire/lease vehicle?

Where did the alleged event occur? It may have cropped up here before.
What happened when you complained to the landowner and your MP. That is always Plan A an it is never too late to do so.

You were asked on the other thread to tell us the issue date on the claim form, but don't appear to have done so.

When you say you were given an extension, do you mean you completed the AoS, and if so, upon what date?

There is no reason why you can't say the NTK was delivered too late for keeper liability to apply, even if you can't be sure. You then put the claimant to strict proof that the contrary is true.

Presumably you know not to reveal or hint at the driver's identity in any correspondence, or on here. No me, myself, nor I. The driver did this. The keeper got an NTK.

BigBeardyBaz

The alleged PCN is for the 1st Sept 2020 but the notification letter arrived many weeks later. The even stated “sorry it’s taken so long to find your address “ or word to those effect.
The vehicle is privately owned.
it was a Southgate Park, been mentioned many many times here.
I wrote to my MP, but he was told by MET parking service, that the car park is clearly marked as two separate car parks, which is not the case.
I information is in my original post above isn’t it?
What exactly do you need the photo of? The front side of the Claim Form?

BigBeardyBaz

There was no ticket on the windscreen, I have only received the letter as I’m the registered keeper 

KeithP

You still haven't told us the Issue Date on your Claim Form.
But now that you state "On 10/01/24 I received a Notice of Proposed Allocation to the Small Claims Track", I'm no longer interested in the Claim Issue Date, as it looks like you have already filed a Defence.

Can you please show us word for word what you filed as a Defence - blotting out personal detail of course.

BigBeardyBaz

Apologies for not posting the date.
I will send over the defence tomorrow. 

Can the defence be added to?

KeithP

BigBeardyBaz said:

Can the defence be added to?

No - well not without paying a hugely disproportionate fee.

BigBeardyBaz

Defence

The date of contravention on the PCN is 01 September 2020. The PCN
was not received with 14 days of the alleged PCN. According to
POFA paragraph 4, sub-paragraph (5), “The relevant period for the
purposes of sub-paragraph (4) is the period of 14 days beginning
with the day after that on which the specified period of parking
ended. In this case, the PCN was therefore “given” more than 14
days after the “relevant period” had started. As the PCN was not
given within 14 days, the keeper cannot be held liable.
The defendant avers that the parking signage at the site in
question was wholly inadequate, misleading and confusing, and no
consideration flowed between the driver and the claimant. The
inadequacy of the signage on this site has been widely reported in
he media and therefore cannot, reasonably, be construed as having
created a contractual relationship between the claimant and the
driver.

Coupon-mad

That's a very basic defence.

Sad to see you didn't come here and find us earlier & use the Template Defence.

Anyway, if this is a DCB Legal claim, the good news is they will discontinue if you do a better WS bundle before they have to pay the hearing fee. A good WS sees them run away.

Read the 'KNOW WHAT HAPPENS WHEN' section of the 2nd post of the NEWBIES thread now, to see what to expect & find the exemplar WS links.

BigBeardyBaz

Yes you live a learn, I will ask her first in future.
WS bundle?

Coupon-mad

I signposted what to read.  Please go there first!  We do this in our own time - no Mods here - and we can't be explaining basic acronyms piecemeal in every thread or we'd drown. This is why I created the Newbies thread a decade ago.