CCJ from Civil Enforcement Ltd - advice please

Emmanat

Hello again,

As many of you with experience with these matters probably predicted, it’s been radio silence from CEL, so I’m getting ready to send the N244 form, along with a witness statement and draft order.

Would it be possible for someone to review the drafts I’ve put together of the witness statement and order below please (I’ll put them in separate posts)?

I also have a few questions and I would be grateful if someone could also point me in the right direction on these as well. As before, any assistance is greatly appreciated!

• Unlike other scenarios I’ve read through on this forum, the CCJ obtained against me is still relatively fresh (I found out through a letter from CEL at the beginning of the month that it was obtained in April). As I’m unsure on when the actual claim was meant to be served, am I still safe in using the ‘more than 4 months have passed’ argument in relation to the claim having expired?

• In terms of the claim form being served at my old address, I haven’t seen the actual form and from speaking to CNBC, CEL seem to be claiming that it was served at my current address (although the man I spoke to didn’t seem 100% sure and couldn’t tell me the date that it was supposedly served). What I’ve seen is the PCN details on the CEL website which contain my old address to this day. Am I still safe in arguing that I believe the form wasn’t served at my current address?

• I’m planning on attaching the following exhibits, will this be enough?

  01 – Letter from CEL informing me that the CCJ had been obtained

  02 – Screenshot of PCN details on CEL website with my old address details

  03 – Particulars of claim sent to me by the court

  04 – Copy of mortgage agreement proving current address

  05 – Email receipt showing parking payment of £1 to cover the duration of my stay

  06 – Screenshot of phone and pay booking terms for the location in question showing that a £1 payment covers you for 2 hours

• If I’m currently not working (left my old job on the 10th April), should I be applying for help with fees?

Emmanat

Draft Witness Statement:

Civil Enforcement Limited

V

Mr XXXXXXX

 

Case number  

XXXXXXX

WITNESS STATEMENT  

I, XXXX, of XXXX , will say as follows:  

1.     I am the Defendant in this matter and I make this witness statement in support of my application to set aside the County Court Judgment (CCJ) entered against me on XX/XX/XXXX, in default due to a defective service of Claim.  

2.     I was not aware of the claim made against me until I received a letter from the Claimant’s legal team on XX/XX/XXXX advising that the Claimant had obtained a default CCJ against me, relating to an alleged parking event in October 2021 (SEE EXHIBIT XX-01)

3.     The Claimant has an old address at which I no longer reside on file and I believe that this is where the Claimant served the claim which is a clear breach of both the CPRs and the industry Code of Practice (SEE EXHIBIT XX-02). These facts and issues are explained further, below. 

4.     The Claimant had a duty to take reasonable steps to check for the correct address, in accordance with the IPC Code of Practice 22.1 and CPR 6.9, as more than 12 months have passed since the PCN on XXXX and the CCJ on XXXX.  

5.     I have not received any claim form or detailed particulars of the claim regarding this matter until I became aware as per paragraph 2 above.  

6.     Whilst I am unsure which date the claim was issued, it has been more than four months since the CCJ was issued, during which time I have not been aware of the claim or the CCJ. As per CPR 7.5, the claim should now be dismissed.  

7.     I believe that I have a strong defence to the claim and that it is without merit as I have evidence, in the form of an email receipt, to demonstrate that I made a valid payment for parking on the date in question which covered the duration of my stay (SEE EXHIBIT XX-05).

8.     Should it not be dismissed despite the wealth of case law below that supports the claim being dismissed at the set aside hearing, I should (at the very least) have the opportunity to defend it properly.  My application relies upon the 'mandatory set aside' rule in CPR 13.2 (in the alternative, 13.3).  

9.     I have set out the grounds for my application in the attached draft order.  

THE CLAIMANT FAILED TO SERVE THE CLAIM  

10.  I understand that the Claimant obtained a Default Judgment against me as the Defendant on XXXXXXX. I am aware that the Claimant is Civil Enforcement Limited and that the assumed claim is in respect of an unpaid Parking Charge Notice.  

11.  CPR 6.9 stipulates that an "Individual" should be served at their "Usual or last known residence."  As I have not had any correspondence in relation to this matter, other than the brief case details emailed to me on 10/05/2024 from the courts, I am unsure of the specific dates that the claim was made. Nonetheless, it is clear that the Claimant, having obtained a previous address from the DVLA and having received no response, did not perform the requisite "reasonable diligence" required to find my correct address to serve the claim form in. Had reasonable diligence been taken, my personal details are found in multiple public sources, such as DVLA, HMRC. The claimant did not have any contact with the defendant, and thus should have considered they had obtained incorrect details. It appears that the claimant continued to issue correspondence to the incorrect address intentionally, in line with the concerns raised by the government regarding this abhorrent industry (Relevant case law cited below in paragraphs 23 - 30).  

12.  The claim form was not served at my current address, thus I was not aware of the Default Judgment until I received the letter mentioned in paragraph 2 on XX/XX/XXXX. This is a breach of CPR 13.2 (a) as the claim form was never served to my current address. Due to this, the judgement was wrongly entered as I was unable to submit an acknowledgement of service in the absence of notification of the case (CPR 13.3).  

13.  The address on that the Claimant has on file is Address A I moved from this address to my current address at Address B in July 2021. In support of this, I can provide a copy of my mortgage agreement showing my updated address. (SEE EXHIBIT XX-04)  

14.  According to publicly available information, my circumstances are far from unique. The industry’s persistent failure to use correct and current addresses of results is an unnecessary burden for individuals and the justice system across the country.  

 

THE INTERNATIONAL PARKING COMMUNITY CODE WAS NOT FOLLOWED  

15.  International Parking Community (IPC) Code of Practice which requires a soft trace to be undertaken was not followed. The IPC Code of Practice 2019 - Version 7, November 2019, clause 22.1 states;  

16.  Operators must take reasonable steps to ensure that the motorist’s details are still correct if 12 months have passed from the Parking Event before issuing court proceedings”  

 

 

DVLA ADDRESS DATA MAY NOT BE RELIABLE  

17.  DVLA data is provided for a single (very limited) reason, so a parking operator can invite the registered keeper to name the driver or pay the invoice or inform the registered keeper they will be liable if not, and notify of appeal rights.  

18.  The system, called 'KADOE' (Keeper On Date of Event), is a brief 'snapshot in time' address to enable a parking firm to send a Notice to the registered keeper. Operators are only allowed to ask the DVLA once, hence the code of practice requires reasonable steps are taken to check address details are current before litigation. Even if a motorist later updates a VC5 logbook with a new address (or if the DVLA fails to process a change in a timely manner, which is reportedly common) a parking operator will not know, nor be able to find that out.  

19.  There is no safe presumption that a DVLA vehicle address is a valid address where a Defendant can be served. The KADOE address is not provided as a 'court claim service address' and should not be relied upon, as it is only an address where the vehicle was kept at a historical point in time (which may not be where the keeper lives; it is where the car was 'kept').  

20.  Considering the above, I was unable to defend this claim. I believe that the Default Judgment against me was issued incorrectly and thus should be set aside, and I ask the Court to kindly consider the reimbursement of the fee of £303 from the claimant should this request be successful.  

21.  There is a wealth of case law making reference to the failures of parking companies to correctly ascertain the addresses of defendants. Of note:  

22.  In Collier v Williams [2006] 1 WLR 1945 (CA) LJ Dyson said  

23.  "What state of mind in the server is connoted by the words "last known"? … As we have said, there is an important distinction between belief and knowledge. It is a distinction particularly well understood in the criminal law, but elsewhere too. The draftsman of the rules deliberately chose the word "known". In our view, knowledge in this context refers to the serving party's actual knowledge or what might be called his constructive knowledge, i.e. knowledge which he could have acquired exercising reasonable diligence. We arrive at this conclusion on the basis of what we understand the words to mean. We do not believe that there are any policy reasons which require us to give the words a strained or unusual meaning. The risk of satellite litigation is inherent in whatever interpretation is adopted. It is true that a defendant who has not in fact received the claim form should have no difficulty in setting aside a default judgment. But it is not desirable that defendants should be put to the trouble and expense of making applications to set aside default judgments."  

24.  The same sentiment was echoed by:  

25.  HHJ Hacon in MB Garden Buildings Ltd v Mark Burton Construction Ltd & Anor [2014] EWHC 431 (IPEC) (28 February 2014)  

26.  HHJ Behrens in Broadside Colours And Chemicals Ltd, Re (No 2) [2012] EWHC 195 (Ch) (20 February 2012)  

27.  In Broadside Colours And Chemicals Ltd, Re (No 2) [2012] EWHC 195 (Ch) (20 February 2012) it would appear that obtaining the information from a source that an individual is required by law to keep updated is adequate knowledge. However, I would submit that it is incumbent to have recent knowledge and not outdated knowledge as HHJ Hacon put it in MB Garden Buildings Ltd v Mark Burton Construction Ltd & Anor [2014] EWHC 431 (IPEC) (28 February 2014)   

28.  As it was put in Dubai Financial Group Llc v National Private Air Transport Services Company (National Air Services) Ltd [2016] EWCA Civ 71 (09 February 2016) by LJ McCombe  

29.  “If a defendant has never become under a valid obligation to acknowledge service, either as specified under the rules or by order of the court, I do not see how it can be that a judgment can be entered against him in default of such acknowledgment. He is simply not in default at all."  

Emmanat

THE CLAIM HAS EXPIRED UNSERVED

I HEREBY CHALLENGE THE JURISDICTION OF THE COURT TO HEAR IT NOW (EFFECTIVELY THAT WOULD MEAN DISPENSING WITH SERVICE). THERE ARE NO EXCEPTIONAL CIRCUMSTANCES TO SUPPORT THE VERY LIMITED COURT DISCRETION TO RETROSPECTIVELY VALIDATE DEFECTIVE SERVICE BY RESURRECTING AN EXPIRED AND UNSERVED (AND HOPELESS) CLAIM.

30. Service of the claim form on an old address constitutes defective service and the claim has expired unserved.   The Claimant currently has no claim because it was not properly served within 4 months and is time barred.

31. Continuing an expired unserved claim more than 4 months after it was raised (but never properly served) is impossible under any rule of law or practice (CPR 7.5).  

32. The Claimant is wholly responsible for failing to serve the claim correctly within the 4 months (as required by CPR 7.5) and as a result this claim has expired unserved. 

33. The Claimant should not be given extra opportunities to waste the Court’s time after failing to follow pre-action protocols for debt claims, breaching the IPC code of practice and the CPRs about taking 'reasonable steps' (CPR 6.9) to check a Defendant's address.  

34. If the Claimant believes they still have a claim then filing afresh is the only way forward. The Claimant may send a ‘Letter Before Claim’ to the right address, this time following the pre-action protocol for debt claims. The court is reminded that this Defendant has received nothing to build any defence on. No claim form and no detailed particulars of the claim have ever been received at the Defendant’s current address.  

35. This claim should be struck out as more than 4 months have passed (CPR 7.5 refers) from issue of proceedings [date] and service of the claim was defective (i.e. it was never served).  

36. A Court's discretionary power to validate a defectively served claim is very limited, and only applies where there is ‘good reason’ for the court to exercise the power so conferred.  There is no ‘good reason’ to retrospectively validate the claimants’ service under Rule 6.15.  Further, whilst Rule 6.16 does create a power for a court to dispense with service of the claim form, this only applies in 'exceptional circumstances' and this does not apply in my case.

37. Tests were established by Lord Sumption’s analysis in Barton v Wright Hassall LLP [2018] 1 WLR 1119 and I have answered those questions in respect of my own case below:

38. Did the claimant take reasonable steps to effect service in accordance with the rules?

39. In my case, no.  An old DVLA address obtained months or years earlier is not a reliable address for service.  Indeed the DVLA do not sell 'keeper data' with any warranty that it can be used or relied upon for service of court papers to a motorist; it is merely a snapshot in time of where a vehicle was once registered.

40. Addresses change frequently and the parking industry and DVLA know this; hence the International Parking Community's Code of Practice requires steps to be taken to ascertain any new address prior to litigation. Parking operators are not allowed to rely upon DVLA data for litigation purposes and must undertake a Credit Reference Agency 'soft trace' before issuing a claim.

41. Were the defendants aware of the contents of the claim form at the time when the time for service expired?

42. In my case, no. I have only just received the particulars from the CNBC (requested in May 2024 – SEE EXHIBIT XX-03) and I knew nothing about any outstanding parking charge.

43. What, if any, prejudice would the defendants suffer by the retrospective validation of a non-compliant service of the claim form, bearing in mind what the defendants knew about its contents?

44. The above answer is repeated. It would cause huge detriment for me to have to spend time and money to defend a meritless parking charge when I made a valid payment for parking on the date in question which covered the duration of my stay.

THE CLAIM IS WITHOUT MERIT

45. The particulars of the claim allege a breach of contract terms and conditions for parking at [LOCATION] on XX/XX/XXXX for 1 hour and 28 minutes (17:33pm to 19:00pm) (SEE EXHIBIT XX-03)

46. The advertised parking rates for this location are £1 for 2 hours or £2 for 5 hours (SEE EXHIBIT XX-06)

47. EXHIBIT XX-05 is a receipt confirming a payment of £1 was made at 17:36:20pm, meaning a valid parking payment was actually made for the duration of the stay and a PCN should not have been issued in the first place

48. It is noted that the email receipt shows a finished time of parking at 18:00:00, however, as it is extremely unlikely that the £1 payment was for a duration of 23 minutes and 40 seconds, there appear to be two possible reasons for this (none of which imply any failure on my part to comply with the terms and conditions of parking):

a. Payments for parking were no longer required after 18:00:00pm; or

b. An error in the recording of the parking duration

49. In any case, the original PCN should not have been issued and the claim is invalid

FURTHER RELEVANT CASE LAW ON EXPIRED UNSERVED CLAIMS

50. There are several authorities, including the judgment in Boxwood [2021] EWHC 947 (TCC), which are reminders of the strictness of the requirements of CPR 7.6 and how difficult it is to use other parts of the Civil Procedure Rules to rectify a failure to serve the claim form within the requisite period: “A claimant is not entitled to rely on the wide, general powers under CPR 3.10 or CPR 3.9 to circumvent the specific conditions set out in CPR 7.6 (3) for extending the period for service of a claim form.”  

51. In the judgment of Deputy Master Marsh in Croke & Anor v National Westminster Bank Plc & Ors [2022] EWHC 1367 (Ch), the claimant was one day late in properly serving the Particulars of Claim to the Defendant and the claimant’s application for relief from sanctions was refused. In section 65 of the transcript of the trial, Deputy Master Marsh stated, “The defendants were entitled to know within the four month period specified in the CPR whether a claim had been made against them and to be able to understand that claim. [...] Unless an extension of time is granted, the claim will cease to have any validity and will be struck out."  

52. In Piepenbrock-v-Associated News Limited [2020] EWHC 1708 (QB), the High Court refused the Claimant’s application for a retrospective extension of time to serve a Claim Form after the Claimant failed to demonstrate they took all reasonable steps to serve the Claim form in the period of its validity.  

53. “Ultimately, the problem was that the Claimant had made no attempt to serve in accordance with the rules. [...] Although I sympathise with the Claimant that the consequences for him of the error of not validly serving the Claim Form will be serious, there is nothing that really separates his case from many others who have made similar mistakes when attempting to serve a Claim Form. [...] I am afraid, in this case, the responsibility for the failure validly to serve the Claim Form rests solely with the Claimant’s side [...]   

54. In light of my conclusions above, having refused the applications made under CPR 7.6, 6.15 and 6.16, there is not a residual self-standing power available under CPR 3.9 to relieve the claimant of the “sanction” that, as a result of his failure to validly to serve the Claim Form during its period of validity, it has now lapsed. The term “sanction” is inapt because it would, in theory, be possible for the Claimant to issue and validly serve a fresh Claim Form. The obstacle standing in the way of a claim is not any sanction imposed by the Court but the fact that the limitation period for defamation and malicious falsehood has expired. [...]  

55. Finally, the Claimant seeks an order under CPR 3.10 remedying his error in not validly serving the Claim Form. The Defendants submit that CPR 3.10 cannot rescue the Claimant. This general provision does not enable the Court to do what CPR 7.6(3) forbids: Vinos -v- Marks & Spencer plc [2001] 3 All ER 784; [2001] CP Rep 12 [20]. [...]  

56. The Claim Form was not served during its period of validity. In consequence, the Court has no jurisdiction over the Claimant’s claim. It follows that I should also formally dismiss the Claimant’s application for summary judgment.”  

57. In Vinos v Marks & Spencer plc [2001] 3 All ER 784, the Court of Appeal considered whether any extension of time should be granted under CPR 7.6 in circumstances where the defendant had been notified of the issue of a claim form but the claim form had not been served within four months as required by CPR 7.5 and the application was made after expiry of that period. The court refused to grant relief on the basis that it did not have the power to do so.  

58. CPR 12.3(1) states that a claimant may obtain judgment in default of an acknowledgement of service only if at the date on which judgment is entered (a) the defendant has not filed an acknowledgement of service or a defence to the claim (or any part of the claim); and (b) the relevant time for doing so has expired. In this case, the claim form was not validly served in [month/year] due to failure to check for a current address (CPR 6.9 (3)), therefore the time limit for acknowledging service has not begun. As the time limit has not begun it cannot have expired. As the time limit has not expired the condition in CPR 12.3(1)(b) has not been satisfied. This results in a mandatory set aside (CPR 13.2). It follows that if a claim is set aside for failure to be served, then the claim cannot be resurrected and served again after 4 months has passed from the date of filing pursuant to CPR 7.5(1). This is on point with the court of appeal in Dubai Financial Group Llc v National Private Air Transport Services Company (National Air Services) Ltd [2016] EWCA Civ 71 (09 February 2016):  

59. “Moreover, I do not consider that the CPR presents an obstacle in the circumstances of this case to setting aside judgment. CPR 13.2 provides that the court must set aside a default judgment where any of the conditions in rule 12.3(1) and 12.3(3) was not satisfied. The latter provision does not apply, but the former is relevant. CPR 12.3(1) states that a claimant may obtain judgment in default of an acknowledgement of service only if (a) the defendant has not filed an acknowledgement of service or a defence and (b) the relevant time for doing so has expired (my italics). I accept Mr McLaren's argument that when an order for retrospective validation of an alternative method of service has been made pursuant to CPR 6.15(2) the relevant time for filing an acknowledgement of service is the period which the court must specify under CPR 6.15(4)(c). Where, as in this case, the court did not specify any such time there can be no relevant time which has expired for the purposes of CPR 12.3(1). If this analysis is correct the requirements of CPR 12.3(1)(b) have not been satisfied and so the court is obliged to set aside the default judgment pursuant to CPR 13.2(a).  

60. I do not see it as a draconian consequence that a judgment, obtained after deemed service has been effected without specifying a time for that service to be acknowledged, should be set aside as of right in such a case. I agree that CPR 13.2 specifies the circumstances in which a default judgment must be set aside and in my judgment one of those circumstances is when judgment is entered in default of an acknowledgement of service when "any of the conditions in rule 12.3(1) …was not satisfied". Here one such condition was not satisfied, namely the time for acknowledgement of service had not expired, because none had ever become applicable.  

61. This, to my mind, is not "playing technical games" (c.f. the passage from the Abela case, cited at paragraph 11 in the judgment of Longmore LJ). It is merely applying the principle that due process should be followed. If a defendant has never become under a valid obligation to acknowledge service, either as specified under the rules or by order of the court, I do not see how it can be that a judgment can be entered against him in default of such acknowledgement. He is simply not in default at all.”  

SET ASIDE APPLICATION WAS MADE PROMPTLY

62. I have responded to this matter promptly. I discovered a CCJ had been obtained against me after receiving a letter from the Claimant’s legal team at the beginning of May. On the 10th May 2024 I contacted the Civil National Business Centre to obtain relevant information relating to this default judgement. On the 13th May 2024 I wrote to Civil Enforcement Limited offering to jointly apply to set aside the judgment. Despite allowing them a reasonable amount of time to seek instructions from the claimant, no response was received so on the 28th May 2024, I have submitted my case in order to set-aside this judgement and fairly present my case  

63. Considering all of the above, I was unable to defend myself against this claim. I believe that the claim against me is without merit and the Default Judgement against me was issued incorrectly. Thus, the judgement should be set aside, the claim struck out, and I ask the Court to kindly consider the reimbursement of the fee of £303 from the claimant should this request be successful.  

Statement of truth:  

64. I believe that the facts stated in this Witness Statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.  

Signed:  Mr XXXXXXXX

 

Date: 28th May 2024

Emmanat

Draft Order:

CLAIM No: XXXXXXX
BETWEEN:
CIVIL ENFORCEMENT LIMITED (Claimant)
-- and --
XXXXXXX (Defendant)
______________________________________________
DRAFT ORDER
______________________________________________
IT IS ORDERED THAT:

 

UPON considering the application of the Defendant to set aside the Judgment by default entered on [date];

AND UPON reading the evidence in support of the application;

AND UPON the court taking note that the Claimant was not entitled to default judgment, having failed to serve on Defendant's usual residential address;

AND UPON more than 4 months having passed (CPR 7.5 refers) from issue of proceedings [date]

IT IS ORDERED:

1.      The Judgment by default entered against the Defendant on [date] is hereby set aside.

2.      The claim be struck out as more than 4 months has passed from issue of proceedings [date].

3.      Costs of the application be paid by the Claimant to the Defendant in the sum of £303.

1505grandad

An obvious observation  -  as posted in your comment on previous page:-

"The Claimant is a member of the British Parking Association (the ‘BPA’) and is bound by the BPA’s Code of Practice which gives voice to CPR 6.9(3) in the following terms:"

Coupon-mad

Yep. but your draft WS cites the IPC CoP, which is wrong.

am I still safe in using the ‘more than 4 months have passed’ argument in relation to the claim having expired?

No. Remove the stuff about the claim being expired.  And remove this from your Draft Order:

"AND UPON more than 4 months having passed (CPR 7.5 refers) from issue of proceedings [date]"

But you are safe to say the claim form was improperly served to an old address, therefore the Claimant is in breach of the BPA CoP and for the sake of the mere 28 pence 'soft trace' that the BPA CoP requires, the claim could and should have been properly served.

As such, CPR 13.2 applies (mandatory CCJ set aside) and the Claimants should be ordered to pay all the Defendant's costs.

When you ring up to pay the £303 fee, ask if you qualify for Help With Fees.

Emmanat

Thank you @Coupon-mad and @1505grandad, much appreciated.

I have made the following changes, please could you give them a once over to check I haven't missed anything?

Draft Order:

Removed "AND UPON more than 4 months having passed (CPR 7.5 refers) from issue of proceedings [date]"

Draft Witness Statement:

Removed paragraphs 4,5 and 6 and replaced with...

4. The Claimant had a duty to take reasonable steps to check for the correct address, in accordance with the British Parking Association (BPA) Code of Practice (CoP) 24.1c and CPR 6.9.  

5. As the claim form was improperly served to an old address, the Claimant is in breach of the BPA CoP and for the sake of the mere 28 pence 'soft trace' that the BPA CoP requires, the claim could and should have been properly served.

 6. As such, CPR 13.2 applies (mandatory CCJ set aside) and the Claimant should be ordered to pay all the Defendant's costs.

Removed paragraphs 15 and 16 and replaced with...

THE BRITISH PARKING ASSOCIATION CODE OF PRACTICE WAS NOT FOLLOWED 

15. The Claimant is a member of the British Parking Association (the ‘BPA’) and is bound by the BPA’s Code of Practice which gives voice to CPR 6.9(3) in the following terms:

16. 24.1c Before serving a Letter Before Claim and prior to the issue of proceedings, Operators must, if no responses have been received to the NTD/NTK/reminder letters, take reasonable endeavours to ensure that the contact details for the person you are writing to are correct.

Removed paragraphs 30-44

Removed paragraphs 50-61

Thanks in advance

Coupon-mad

Great stuff.

If the hearing is arranged more than 4 months from the court claim filing date (which I assume was March?) don't forget that you can & should then use all those paragraphs & case law, chuck it onto a sheet headed 'skeleton argument - the claim has expired unserved' and file & serve that like a silver bullet the week before your hearing, along with your costs list.

Emmanat

Coupon-mad said:

Great stuff.

If the hearing is arranged more than 4 months from the court claim filing date (which I assume was March?) don't forget that you can & should then use all those paragraphs & case law, chuck it onto a sheet headed 'skeleton argument - the claim has expired unserved' and file & serve that like a silver bullet the week before your hearing, along with your costs list.

I will do, thanks very much again for your help.

1505grandad

Some further obs:-

"11. Had reasonable diligence been taken, my personal details are found in multiple public sources, such as DVLA, HMRC."
Yet in para 17 you state:-

"DVLA ADDRESS DATA MAY NOT BE RELIABLE  

17.  DVLA data is provided for a single (very limited) reason,....."

"13.  The address on that the Claimant has on file is....."  -  word not required

There are several incorrect spellings of "Judgment" which include a middle "e"  -  control + F (judgement" in box) will find them.