submitting defence to a UKPC claim

Coupon-mad

I didn't mean look at UKPC ones. That's not what I advised. I'm saying: copy a recent one denying each numbered point in these template POC.

You only needed to look at some DCB Legal claim threads. Loads of Euro Car Parks ones that are exactly right, denying each numbered point in the POC. Copy that style.

Please stop looking for UKPC cases.

ih8ukpc

Thank you for clarifying this.

I have now added the following:

3.6 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 27/05/24" (the date of the visit).  Whilst the Defendant was the keeper and driver, the rest of 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.

I have also corrected the IPC error.

Finally I have added the bold line into para 2:

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 Claimant is seeking interest, however does not state under which contract or terms.   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 and driver.

Coupon-mad

Perfect. Much better response to allegations.  

ih8ukpc

Urgent! 

Hi guys, I navigated my way through to the N180 stage where I submitted my form back in January. I’ve been away on holiday over the last week and have just found a letter from the court dated 13th feb, stating that I have failed to submit the questionnaire and I have 7 days to submit it. 

I have 100% sent it back in January and received an automated response. This is the email I sent. 

ih8ukpc

This I the letter

KeithP

Just send it again. You still have six days to do so.

Angel1947

I was driving my neighbours car on29th January as I am a named driver and she received a parking fine. We found the parking ticket and sent it with a letter and copy of fine on 4th February. She has since received a further letter stating she has to pay £100. On the website it says my letter is under appeal investigation. Should she pay or wait

KeithP

@angel1947, you really need to start your own thread about your problem.
Trying to progress the two different issues of two different people in a single thread can only lead to confusion.

ih8ukpc

Hi

I have received a CCJ regarding the above, I am a little bewildered to be frank. Having sent the directions questionnaire a second time in February, I have not had any response back and now there is a CCJ on my file.

What has happened and what do I do?

Nellymoser

Looks to be a CNBC admin error happens a lot.

See yesterday's thread
https://forums.moneysavingexpert.com/discussion/comment/81443715/#Comment_81443715