PS24 LTD, Gladstones court claim, WS stage 2025

azqw204

I have received a claim from the county court with Gladstones as the claimant following my ignorance of all letters from debt collector's etc.

I followed all of the various threads posted here and used the wording from here:
https://forums.moneysavingexpert.com/discussion/6108153/suggested-template-defence-to-adapt-for-all-parking-charge-cases-where-they-add-false-admin-costs/p1

It says in the thread that I'm okay to ask for feedback here so I just wanted advice on my paragraph for defence, the rest is all the default wording copied and pasted.

These are my paragraph's 2 and 3:

2. The facts in this defence com............However, it is admitted that the Defendant was the registered keeper but not the driver at that time.

3. The alleged parking breach occurred on 21st and 22nd of June in 2023. On the date of 20 June 2023, the defendant and their family had boarded a flight to Antalya in Turkey. They returned from vacation on 24th June 2023. The defendant was not in the country during that time and, to the defendant’s knowledge, vehicle in question was parked outside the family home. The defendant does not recognise the mentioned car park, the area or the town in which the alleged parking breach occurred. The defendant has never used this car park and they are unsure why it would appear that their car has been parked in the Salford area at all. Further to this, no letters have been received regarding the alleged PCN’s by the defendant before the claim form. Please find the enclosed boarding passes as proof.

The total amount of the claim is: £353.98

Received on 21 January - I have already acknowledged using the online service as instructed.

The remaining paragraphs 1, and 4 - 30 are the same as the default wording in the thread above.

Please can I have someone's feedback on the above. Thanks in advance

Etccarmageddon

What exactly have you received from Gladstone's? 

IE the document type ?   Letter before claim?  Or something else?

KeithP

azqw204 said:

I have received a claim from the county court with Gladstones as the claimant...
Received on 21 January - I have already acknowledged using the online service as instructed.

You tell us you received the Claim on 21st January, but what is the Issue Date on your Claim Form?

Upon what date did you file an Acknowledgment of Service?
Your MCOL Claim History will have the definitive answer to that.

Not_A_Hope

I have received a claim from the county court with Gladstones as the claimant

Gladstones are not the claimant. They are the money grabbing solicitors acting on behalf of the actual PPC claimant. Who is the claimant?

Further to this, no letters have been received regarding the alleged PCN’s by the defendant before the claim form.

If you did not receive the original NTK or reminders it is likely your V5C logbook for the vehicle has a former address. You need to check and update this with the DVLA. Gladstones have probably done a 29p search to find your current address. You can submit a SAR to the claimant and this should provide more information of the alleged event including photos of the vehicle. You can then check whether it looks anything like yours. A well known fault with ANPR cameras is they often get registration number wrong. They don’t actually take photos of the VRM. Just a computerised guess from a digital image.

azqw204

Etccarmageddon said:

What exactly have you received from Gladstone's? 

IE the document type ?   Letter before claim?  Or something else?

I have received the claim form, from the country court with the claimant Parking Solutions 24 Ltd. the acting solicitor is Gladstones, sorry for the confusion.

azqw204

KeithP said:

azqw204 said:

I have received a claim from the county court with Gladstones as the claimant...
Received on 21 January - I have already acknowledged using the online service as instructed.

You tell us you received the Claim on 21st January, but what is the Issue Date on your Claim Form?

Upon what date did you file an Acknowledgment of Service?
Your MCOL Claim History will have the definitive answer to that.

Apologies, the claim is dated the 21st January. I received it on 26th January. I submitted my Acknowledgement Of Service on 30 January 2024.

Hope this helps

azqw204

Not_A_Hope said:

I have received a claim from the county court with Gladstones as the claimant

Gladstones are not the claimant. They are the money grabbing solicitors acting on behalf of the actual PPC claimant. Who is the claimant?

Further to this, no letters have been received regarding the alleged PCN’s by the defendant before the claim form.

If you did not receive the original NTK or reminders it is likely your V5C logbook for the vehicle has a former address. You need to check and update this with the DVLA. Gladstones have probably done a 29p search to find your current address. You can submit a SAR to the claimant and this should provide more information of the alleged event including photos of the vehicle. You can then check whether it looks anything like yours. A well known fault with ANPR cameras is they often get registration number wrong. They don’t actually take photos of the VRM. Just a computerised guess from a digital image.

Sorry for the confusion here.

You are correct. Gladstones are the money-grabbling acting solicitors. The claimant is Parking Solutions 24 Ltd.

The logbook is still addressed to my parent's address but that's because I haven't changed any of my paperwork over. There may have been letters from UCS if I remember correctly that said 'Final demand for payment' and if unpaid they'll instruct their solicitor to start court proceedings. But that's it. 

I will submit a subject access request at some point today to get the photos of the vehicle etc. 

Other than that, is the wording okay?

Le_Kirk

azqw204 said:

3. The alleged parking breach occurred on 21st and 22nd of June in 2023. On the date of 20 June 2023, the defendant and their family had boarded a flight to Antalya in Turkey. They returned from vacation on 24th June 2023. The defendant was not in the country during that time and, to the defendant’s knowledge, vehicle in question was parked outside the family home. The defendant does not recognise the mentioned car park, the area or the town in which the alleged parking breach occurred. The defendant has never used this car park and they are unsure why it would appear that their car has been parked in the Salford area at all. Further to this, no letters have been received regarding the alleged PCN’s by the defendant before the claim form. Please find the enclosed boarding passes as proof.  At witness statement stage, the defendant will provide copies of boarding passes as proof of being out of the country.

No evidence goes with a defence, that come later at witness statement stage, otherwise I would say you have a cast  iron defence if you can prove your car was at your home (when the time comes at WS stage!)  Adjust as above.

azqw204

Le_Kirk said:

azqw204 said:

3. The alleged parking breach occurred on 21st and 22nd of June in 2023. On the date of 20 June 2023, the defendant and their family had boarded a flight to Antalya in Turkey. They returned from vacation on 24th June 2023. The defendant was not in the country during that time and, to the defendant’s knowledge, vehicle in question was parked outside the family home. The defendant does not recognise the mentioned car park, the area or the town in which the alleged parking breach occurred. The defendant has never used this car park and they are unsure why it would appear that their car has been parked in the Salford area at all. Further to this, no letters have been received regarding the alleged PCN’s by the defendant before the claim form. Please find the enclosed boarding passes as proof.  At witness statement stage, the defendant will provide copies of boarding passes as proof of being out of the country.

No evidence goes with a defence, that come later at witness statement stage, otherwise I would say you have a cast  iron defence if you can prove your car was at your home (when the time comes at WS stage!)  Adjust as above.

Thank you for this! Really appreciated

KeithP

azqw204 said:

KeithP said:

azqw204 said:

I have received a claim from the county court with Gladstones as the claimant...
Received on 21 January - I have already acknowledged using the online service as instructed.

You tell us you received the Claim on 21st January, but what is the Issue Date on your Claim Form?

Upon what date did you file an Acknowledgment of Service?
Your MCOL Claim History will have the definitive answer to that.

Apologies, the claim is dated the 21st January. I received it on 26th January. I submitted my Acknowledgement Of Service on 30 January 2024.

Hope this helps

With a Claim Issue Date of 21st January, and having filed an Acknowledgment of Service in a timely manner, you have until 4pm on Friday 23rd February 2024 to file your Defence.

That's over three weeks away. Plenty of time to produce a Defence but please don't leave it to the last minute.

To create a Defence, and then file a Defence by email, look at the second post in the NEWBIES thread.

Don't miss the deadline for filing a Defence.

Do not try and file a Defence via the MoneyClaimOnline website. Once an Acknowledgment of Service has been filed, the MCOL website should be treated as 'read only'.

Coupon-mad

azqw204 said:

Not_A_Hope said:

I have received a claim from the county court with Gladstones as the claimant

Gladstones are not the claimant. They are the money grabbing solicitors acting on behalf of the actual PPC claimant. Who is the claimant?

Further to this, no letters have been received regarding the alleged PCN’s by the defendant before the claim form.

If you did not receive the original NTK or reminders it is likely your V5C logbook for the vehicle has a former address. You need to check and update this with the DVLA. Gladstones have probably done a 29p search to find your current address. You can submit a SAR to the claimant and this should provide more information of the alleged event including photos of the vehicle. You can then check whether it looks anything like yours. A well known fault with ANPR cameras is they often get registration number wrong. They don’t actually take photos of the VRM. Just a computerised guess from a digital image.

Sorry for the confusion here.

You are correct. Gladstones are the money-grabbling acting solicitors. The claimant is Parking Solutions 24 Ltd.

The logbook is still addressed to my parent's address but that's because I haven't changed any of my paperwork over. There may have been letters from UCS if I remember correctly that said 'Final demand for payment' and if unpaid they'll instruct their solicitor to start court proceedings. But that's it. 

I will submit a subject access request at some point today to get the photos of the vehicle etc. 

Other than that, is the wording okay?

No you won't - a SAR IS NOT ADVISED. 

Better to defend using theTemplate Defence.  Show us the Particulars of Claim on the left.