Euro Car Parks / DCB Legal – 2025 Defence to Old Debt Claim

Coupon-mad

Why not just search the forum for that letter instead of copying it here? We've seen it hundreds and hundreds of times and every thread already says what to do to report the VAT concern to HMRC.

Canon7601

Hi everyone, 

Just preparing my defence and wanted to see if I could get some feedback on my ending for para 2 and paragraph 3. I would be grateful if you could take a look.

 (...)2. The facts in this defence come from the Defendant's own knowledge and honest belief.  Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to "state all facts necessary for the purpose of formulating a complete cause of action". The Defendant is unable, on the basis of the POC, to understand with certainty what case, allegation(s) and what heads of cost are being pursued, making it difficult to respond. However, the vehicle is recognised, and it is admitted that the Defendant was the registered keeper. The Defendant is unable to confirm who was driving on the date in question."

Will this weaken my defence altogether? 

The rest I copied and pasted exactly as advised- from paras 4 to 30. 

3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The Defendant does not accept that a contravention occurred on 25/09/2020, as alleged.  Whilst the Defendant is the registered keeper, the Defendant is unable to recall who was driving on the day in question, due to the time elapsed. No admission is made as to the identity of the driver. Paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of clear, prominent, and legible signage.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever.

3.1 Due to the length of time, the Defendant has no recollection of the day in question. The Defendant parked in that carpark on several occasions in the past late in the evenings and was unaware of parking restrictions in place. The Defendant had not noticed any ‘Prominent’ signage close to where the vehicle was parked, showing the terms and conditions for use. Any small or obscure signs present would not have been visible or sufficient to alert a motorist, leading to an unawareness of any parking restrictions.

Thank you.

Gr1pr

Looks OK to me but wait for other replies if you have time 

As for paragraph 2, the defence template does include an ending for victims who can't remember or recall the details 

Your defence should rebut the POC,  not your problem if they issued a claim years later 

Chances are that they will discontinue anyway in several months time 

Canon7601

Thank you, re-edited for the correct ending. I still have some days until submission, so I have time to change it if something needs changing.

Gr1pr

Your thread title needs changing,  to something more suitable,  like

ECP DCB Legal court claim 2025  ( or something similar and more useful for the case stages  )

1505grandad

Para 3.1  -  " The Defendant had not noticed any ‘Prominent’ signage close to where the vehicle was parked, showing the terms and conditions for use."

Should the above be included in view of the following in para 2:-

"The Defendant is unable to confirm who was driving on the date in question."

Coupon-mad

3.1 makes no sense if you genuinely don't know who was driving. Remove it.

Canon7601

Hello, does anyone know how long after DCBL sends their email about settling and their own direct questions questionaire do I receive my CNBC form? Thank you.

Le_Kirk

That is down to how long the CNBC take.  Keep checking your status page on MCOL and when you see that CNBC have posted a DQ to you, you can download one and complete it.

Canon7601

Hi everyone,

I’d appreciate your advice on this situation.

I submitted my N180 Directions Questionnaire on time (both filed to the court and served to the claimant). The version I sent was signed on my iPad (checked twice), but I’ve now been told by the CNBC:

“Your directions questionnaire was not signed, therefore it may not be considered as a valid document if the case goes to a court hearing. Please sign the form and return to us as soon as possible.”

It seems the signature layer I used didn’t display in all PDF viewers. I have now re-saved the document with the signature embedded/flattened so it’s visible everywhere and have sent this corrected version to the court. (I also received the mediation details, so they progressed.)

However, I’ve checked MCOL and it now shows the submission date as the date I re-sent the second version — which makes it look like I didn’t submit it on time in the first place.

My questions:

1.  Will this signature display issue cause any problems for me later on, given that I originally met the deadline but they couldn’t see the signature on their system?Would they think I missed the deadline?

2. Should I provide proof that my original (signed) version was sent before the deadline?When I open the document on my MacBook it shows signed, when I do it on my phone it shows unsigned. Could I use this as proof?

Thanks in advance for any guidance.