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Parking Control Management - Claim defence (Successful)

245

Comments

  • Gr1pr
    Gr1pr Posts: 12,982 Forumite
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    2. The Defendant draws to the attention of the allocating Judge that there is now two persuasive Appeal judgments

    Should be 

    2. The Defendant draws to the attention of the allocating Judge that there is are now two persuasive Appeal judgments
  • massop
    massop Posts: 57 Forumite
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    Bad grammar on my part, see below fixed

    Preliminary matter: The claim should be struck out

     

    2. The Defendant draws to the attention of the allocating Judge that there are now two persuasive Appeal judgments to support striking out the claim (in these exact circumstances of typically poorly pleaded private parking claims, and the extant PoC seen here are far worse than the one seen on Appeal).  The Defendant believes that dismissing this meritless claim is the correct course, with the Overriding Objective in mind.  Bulk litigators (legal firms) should know better than to make little or no attempt to comply with the Practice Direction.  By continuing to plead cases with generic auto-fill unspecific wording, private parking firms should not be surprised when courts strike out their claims based in the following persuasive authority.


  • Coupon-mad
    Coupon-mad Posts: 160,814 Forumite
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    Good stuff.  
    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
  • massop
    massop Posts: 57 Forumite
    Seventh Anniversary 10 Posts Name Dropper Combo Breaker
    edited 21 November 2024 at 12:37PM
    Excellent,

    ill update my original post to help newcomers fight similar cases. ill get this sent off tomorrow probably. And of course ill update this thread on the progress of the case

    Where can I find the images for the "Car Park Management Service Ltd v Akande (Ref. K0DP5J30)" case?

    I have looked int he template & newbie threads but cant find it. 
  • Le_Kirk
    Le_Kirk Posts: 26,174 Forumite
    Part of the Furniture 10,000 Posts Photogenic Name Dropper
    massop said:
    Excellent,

    ill update my original post to help newcomers fight similar cases. ill get this sent off tomorrow probably. And of course ill update this thread on the progress of the case

    Where can I find the images for the "Car Park Management Service Ltd v Akande (Ref. K0DP5J30)" case?

    I have looked int he template & newbie threads but cant find it. 
    Go to my profile @Le_Kirk and then look on my threads; it is called Judgments Link
  • massop
    massop Posts: 57 Forumite
    Seventh Anniversary 10 Posts Name Dropper Combo Breaker
    Perfect, this is really helpful.

    For anyone else looking for that thread you can find it HERE
  • massop
    massop Posts: 57 Forumite
    Seventh Anniversary 10 Posts Name Dropper Combo Breaker
    edited 17 December 2024 at 5:46PM
    Just got the N180 form for this, I have filled it out and will send to DQ.CNBC@justice.gov.uk shortly.

    The form is very different from the answers to the guide HERE.

    So I have attached my answers (and removed any personal information) to help anyone else wanting to fill in the updated sheet.

    MY TEMPLATE N180 RESPONSE

    Also I downloaded the pdf of the N180 form HERE



  • KeithP
    KeithP Posts: 41,296 Forumite
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    massop said:
    Just got the N180 form for this, I have filled it out and will send to CNBC@justice.gov.uk shortly.
    Why not instead send it to the email address listed in that checklist you were following when you filed a Defence?

    Remembering of course to send a copy to the Claimant.
  • massop
    massop Posts: 57 Forumite
    Seventh Anniversary 10 Posts Name Dropper Combo Breaker
    edited 17 December 2024 at 7:02PM
    KeithP said:
    massop said:
    Just got the N180 form for this, I have filled it out and will send to CNBC@justice.gov.uk shortly.
    Why not instead send it to the email address listed in that checklist you were following when you filed a Defence?

    Remembering of course to send a copy to the Claimant.
    Good catch, that was a typo on my part, I have modified my post to reflect the correct email so other users do not get confused.

    Correct email is DQ.CNBC@justice.gov.uk

    PCM are using Moorside Legal Services LTD for legal representation, so I will also CC them on the email using from their own website - 
    help@moorsidelegal.co.uk
  • Coupon-mad
    Coupon-mad Posts: 160,814 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    massop said:
    Just got the N180 form for this, I have filled it out and will send to DQ.CNBC@justice.gov.uk shortly.

    The form is very different from the answers to the guide HERE.

    Yes, it would be different because as you can see, that link is old.

    Which is why the NEWBIES thread (which provides that link because it still has some uses) catches it by covering the new questions too and begs people not to ask.
    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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