UKPC Licence plate error

TBrown302818

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

TBrown302818 said:

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.

TBrown302818

Coupon-mad said:

TBrown302818 said:

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

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

TBrown302818 said:

@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

Yep, I removed reference to shahib's case and provide an alternative link in the Template Defence over the past few days.

TBrown302818

Hey guys 

So I got back from trip to find this letter in my postbox. 

The deadline has passed. Last step I went through was mediation in which I declined to pay a penny as I already paid to park and there was a single digit error on the ticket which should have caused cancellation at my appeal of the ticket.

I got a number of calls from dcbls automatic dialer which had me on hold in excess of 45 minutes sometimes, so it got to the point where I would just hang up when they called me.

This has obviously now progressed so just wanted to know best course of action as I've not found another case on the forum in this position. 


Many thanks for the guidance. 

kryten3000

This instructs the Claimant to send their Directions Questionnaire to the court by the date shown, not you.