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2x CCJ's - Civil Enforcement Limited - Private Parking Violation

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  • RedOrchid
    RedOrchid Posts: 100 Forumite
    10 Posts Name Dropper
    Hi everyone, have drafted my response email to their crappy robotic reply: 

    "To whom it may concern,

    I am deeply saddened that your reply did not answer any of my questions, nor was it helpful to resolve this situation. 

    I hereby demand that the address you have on file is removed from all PCN's. I have moved to 3 different addresses since you've allegedly obtained my details from the DVLA which I find very hard to believe that an address from 2021 came up as my last known address before you moved forward with the two CCJ's in December 2023. You can update my address on file to "LA VIE EN ROSE, LA LA LAND, WARDROBE 6". 

    It is also demanded that you cancel all outstanding PCN's as you have failed to include all of them in a single claim. I would invite you to read the following, which explains the reason behind my demand:

    "17.      The Claimant has issued a further claim, number XXXX, against the Defendant on an earlier date, and with substantially identical particulars, for the same cause of action. The issuing of two separate claims, by the same Claimant and for essentially the same cause of action, is an abuse of the civil litigation process. The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case."

    I hereby invite CEL to re-read my initial email and take into consideration this reply, I have allowed CEL to produce a reply to this matter by the 25th of June 2024 and it would be wise to stop this matter before it reaches the court. 

    It is my intention to apply to set aside both CCJ's against me, on the 25th June 2024. The basis for my application will be based on (but not limited to) a poorly pleaded Particulars of Claim and will enter a claim for all fees and costs due to unreasonable conduct, the clear breach of the BPA CoP by not conducting a soft trace and instead, deliberately bunging in claims to an old unreliable DVLA car address.

    Yours sincerely,
    RedOrchid"
  • LDast
    LDast Posts: 2,496 Forumite
    1,000 Posts Photogenic Name Dropper
    edited 16 June 2024 at 12:40PM
    Please, please, please... do not use ChatGPT or any other AI to author that response. It has all the hallmarks of having been generated by AI or a Nigerian Prince in exile with a fortune that they want to give you.

    You need to take out things like "saddened" and "hereby" for starters. What is this: "I hereby invite CEL to re-read my initial email and take into consideration this reply, I have allowed CEL to produce a reply to this matter by the 25th of June 2024 and it would be wise to stop this matter before it reaches the court."?

    If English is not your first language, I forgive you. If it is...
  • RedOrchid
    RedOrchid Posts: 100 Forumite
    10 Posts Name Dropper
    Hi @LDast

    Thanks for your input, I didn't use Chat GPT to create my response email but I did try to tone the email to match the way I initially wrote to CEL, which was an email template from a solicitor, I thought it'd be odd if all of a sudden I became more informal. 

    And you're spot on, I am Brazilian and English is actually my 3rd language, although I have lived in the UK for the past 12 years  :) 

    How about this?

    "To whom it may concern,

    Your reply did not answer any of my questions, nor was it helpful to resolve this situation. 

    I demand that the address you have on file is removed from all PCN's. I have moved to 3 different addresses since you've allegedly obtained my details from the DVLA which I find very hard to believe that an address from 2021 came up as my last known address before you moved forward with the two CCJ's in December 2023. You can update my address on file to "LA VIE EN ROSE, LA LA LAND, WARDROBE 6". 

    I demand that you cancel all outstanding PCN's as you have failed to include all of them in a single claim. I invite you to read the following, which explains the reason behind my demand:

    "17.      The Claimant has issued a further claim, number XXXX, against the Defendant on an earlier date, and with substantially identical particulars, for the same cause of action. The issuing of two separate claims, by the same Claimant and for essentially the same cause of action, is an abuse of the civil litigation process. The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case."

    I suggest you go through my initial email and take into consideration this reply. As mentioned in my previous email to yourselves, I expect a reply to this matter by the 25th of June 2024. It would be wise to stop this matter before it reaches the court. 

    It is my intention to apply to set aside both CCJ's against me, on the 25th June 2024. The basis for my application will be based on (but not limited to) a poorly pleaded Particulars of Claim and will enter a claim for all fees and costs due to unreasonable conduct, the clear breach of the BPA CoP by not conducting a soft trace and instead, deliberately bunging in claims to an old unreliable DVLA car address.

    Yours sincerely,
    RedOrchid"
  • LDast
    LDast Posts: 2,496 Forumite
    1,000 Posts Photogenic Name Dropper
    You are forgiven.  ;)

    You must tell them to erase, not "remove" your previous addresses. You also have to tell that they must, not "can" update your address on file and that it is the only address they must use as an address for service.
  • Coupon-mad
    Coupon-mad Posts: 152,611 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Oooh I have a visitor from Brazil here right now. Constantly impressed by the good English of those people we help here who have a different first language.

    Remove this (not needed and a bit rambling):

    "which I find very hard to believe that an address from 2021 came up as my last known address before you moved forward with the two CCJ's in December 2023."
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • RedOrchid
    RedOrchid Posts: 100 Forumite
    10 Posts Name Dropper
    Thank you both, yea it's no easy feat to juggle all these languages, my brain is unfortunately no longer replenishing its cells, from here-on it's bleak  :D.

    Ok, draft with the suggestions incorporated, if all is fine I will shoot this across to CEL: 

    To whom it may concern,

    Your reply did not answer any of my questions, nor was it helpful to resolve this situation. 

    I demand that the address you have on file is erased from all PCN's. I have moved to 3 different addresses since you've allegedly obtained my details from the DVLA. You must update my address on file to "RETRACTED". This is the only address you must use for service.

    I demand that you cancel all outstanding PCN's as you have failed to include all of them in a single claim. I invite you to read the following, which explains the reason behind my demand:

    "17.      The Claimant has issued a further claim, number XXXX, against the Defendant on an earlier date, and with substantially identical particulars, for the same cause of action. The issuing of two separate claims, by the same Claimant and for essentially the same cause of action, is an abuse of the civil litigation process. The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case."

    I suggest you go through my initial email and take into consideration this reply. As mentioned in my previous email to yourselves, I expect a reply to this matter by the 25th of June 2024. It would be wise to stop this matter before it reaches the court. 

    It is my intention to apply to set aside both CCJ's against me, on the 25th June 2024. The basis for my application will be based on (but not limited to) a poorly pleaded Particulars of Claim and will enter a claim for all fees and costs due to unreasonable conduct, the clear breach of the BPA CoP by not conducting a soft trace and instead, deliberately bunging in claims to an old unreliable DVLA car address.

    Yours sincerely,


  • Coupon-mad
    Coupon-mad Posts: 152,611 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    And change this:

    "demand that you cancel all outstanding PCN's as you have failed to include all of them in a single claim. I invite you to read the following, which explains the reason behind my demand:
    "17.      The Claimant has issued a further claim, number XXXX, against the Defendant on an earlier date, and with substantially identical particulars, for the same cause of action. The issuing of two separate claims, by the same Claimant and for essentially the same cause of action, is an abuse of the civil litigation process. The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case."

    I suggest you go through my initial email and take into consideration this reply. As mentioned in my previous email to yourselves, I expect a reply to this matter by the 25th of June 2024. It would be wise to stop this matter before it reaches the court. "

    To this:


    You have no case to support any new claims, so you must now cancel all outstanding PCNs.  It is clear that Civil Enforcement has already filed two near-duplicate (and hugely exaggerated) claims and failed to include all charges/sums in a single claim.

    The issuing of two separate claims by the same Claimant and for essentially the same cause of action, would be (and is already) an abuse of the civil litigation process.

    The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case.

    As mentioned in my previous email to yourselves, I expect a reply to this matter by the 25th June 2024 after which I will apply to set aside both CCJs and have both claims struck out, with your firm being liable for both £303 application fees plus my attendance costs.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • RedOrchid
    RedOrchid Posts: 100 Forumite
    10 Posts Name Dropper
    Okay, re-tweaked it a little as to not duplicate the last paragraph I originally had in there, here's the latest:

    "To whom it may concern,

    Your reply did not answer any of my questions, nor was it helpful to resolve this situation. 

    I demand that the address you have on file is erased from all PCN's. I have moved to 3 different addresses since you've allegedly obtained my details from the DVLA. You must update my address on file to "RETRACTED". This is the only address you must use for service.

    You have no case to support any new claims, so you must now cancel all outstanding PCNs.  It is clear that Civil Enforcement has already filed two near-duplicate (and hugely exaggerated) claims and failed to include all charges/sums in a single claim.

    The issuing of two separate claims by the same Claimant and for essentially the same cause of action, would be (and is already) an abuse of the civil litigation process.

    The long-established case law in Henderson -v- Henderson [1843] 67 ER 313, and more recent authorities, establishes the principle that when a matter becomes the subject of litigation, the parties are required to advance their whole case.

    As mentioned in my previous email to yourselves, I expect a reply to this matter by the 25th June 2024 after which I will apply to set aside both CCJs and have both claims struck out, with your firm being liable for both £303 application fees plus my attendance costs, based on (but not limited to) a poorly pleaded Particulars of Claim and will enter a claim for all fees and costs due to unreasonable conduct, the clear breach of the BPA CoP by not conducting a soft trace and instead, deliberately bunging in claims to an old unreliable DVLA car address.

    Yours sincerely,"
  • Coupon-mad
    Coupon-mad Posts: 152,611 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Change "To whom it may concern,"

    to

    Dear Sirs
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • RedOrchid
    RedOrchid Posts: 100 Forumite
    10 Posts Name Dropper
    All done, will send it across in the next half hour if there are no objections :) 
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