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UKPC Licence plate error

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  • TBrown302818
    TBrown302818 Posts: 84 Forumite
    Second Anniversary 10 Posts Name Dropper
    Thanks. Assuming there are no corrections to be made on my defence - yay

    I more wanted to have it confirmed that I had posted the correct 30+ paragraph defence with the appropriate links. 
  • Coupon-mad
    Coupon-mad Posts: 152,071 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 22 May at 3:30PM

    The defence looks fine for that claim, once the rest of the template is re-numbered. Don't show us!

    Just follow the first 12 steps in the Template Defence thread from now on.
    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
  • TBrown302818
    TBrown302818 Posts: 84 Forumite
    Second Anniversary 10 Posts Name Dropper

    The defence looks fine for that claim, once the rest of the template is re-numbered. Don't show us!

    Just follow the first 12 steps in the Template Defence thread from now on.
    @Coupon-mad
    Oh wise one. On the 30+ paragraph defence it refers to '. {if you have a DCB Legal Claim you can copy the new 'Regarding the POC...' paragraph 3 from the thread by @shahib_02

    When I looked it up, paragraph 3 states: 'Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. No PCN was "issued on 20/03/2023" (the date of the alleged visit).  Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations.

    So my questions are:
    1. Have I found the correct @shahib_02 paragraph 3?
    2. Can I use it or would you advise sticking with what I have (and renumber the rest of the defence)?

    Many thanks

  • TBrown302818
    TBrown302818 Posts: 84 Forumite
    Second Anniversary 10 Posts Name Dropper
    Also! I have just seen that my point 8 states:
    1. In the alternative, the defendant was not the driver, and the Claimant has failed to comply with the strict requirements of the Protection of Freedoms Act (POFA) 2012 Schedule 4 to hold me liable as keeper.
    I was the driver but they have not established that. If you recall, when I appealed they asked me for the drivers details which I did not provide.

    So can I change this point to something (insert legal ways of saying it) that they did not establish the driver (within the timeframe or ever) then went straight to keeper liability

  • Le_Kirk
    Le_Kirk Posts: 24,602 Forumite
    Part of the Furniture 10,000 Posts Photogenic Name Dropper
    @Coupon-mad
    Oh wise one. On the 30+ paragraph defence it refers to '. {if you have a DCB Legal Claim you can copy the new 'Regarding the POC...' paragraph 3 from the thread by @shahib_02

    When I looked it up, paragraph 3 states: 'Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. No PCN was "issued on 20/03/2023" (the date of the alleged visit).  Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations.

    So my questions are:
    1. Have I found the correct @shahib_02 paragraph 3?
    2. Can I use it or would you advise sticking with what I have (and renumber the rest of the defence)?
    The claimant started changing their POC to read contravention date rather than issue date, so you need to check your POC to see which version you have.  @Coupon-mad has recently offered @fig_tree29 as a replacement for @shahib_02
  • Coupon-mad
    Coupon-mad Posts: 152,071 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 27 May at 2:42PM
    Yep, I removed reference to shahib's case and provide an alternative link in the Template Defence over the past few days.
    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
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