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Letter of claim from DCB legal LTD

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  • jellybaby25
    jellybaby25 Posts: 11 Forumite
    10 Posts Name Dropper

    The facts known to the Defendant:

    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 and driver.

    3. 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 28/12/2022" (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.

  • jellybaby25
    jellybaby25 Posts: 11 Forumite
    10 Posts Name Dropper
    I have copied and pasted everything else in the 30 paragraph template defence. I just need to sign and then email. 
  • Coupon-mad
    Coupon-mad Posts: 152,548 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Yep, all good now.
    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
  • jellybaby25
    jellybaby25 Posts: 11 Forumite
    10 Posts Name Dropper
    Just a quick update, I have the mediation call next Thursday. Is it worth mentioning that I’ve already given them over £300? Or shall I just offer zero and leave any defence details until court? 
  • Gr1pr
    Gr1pr Posts: 8,714 Forumite
    1,000 Posts First Anniversary Photogenic Name Dropper
    edited 11 April at 8:13PM
    The latter should suffice for a 5 minute phone call 

    But, your defence has already been submitted and is already on file 

    Your WS + Exhibits bundle will possibly be required a few weeks before any future court hearing,  if they pay the fee
  • Coupon-mad
    Coupon-mad Posts: 152,548 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Just a quick update, I have the mediation call next Thursday. Is it worth mentioning that I’ve already given them over £300? 
    No. That makes you sound like someone who could be persuaded to make offers.
    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
  • jellybaby25
    jellybaby25 Posts: 11 Forumite
    10 Posts Name Dropper
    I received an email today from DCB legal to say the claim has been discontinued. Thank you so much for your help :) 
  • Gr1pr
    Gr1pr Posts: 8,714 Forumite
    1,000 Posts First Anniversary Photogenic Name Dropper
    I received an email today from DCB legal to say the claim has been discontinued. Thank you so much for your help :) 
    Excellent news 

    Please post a redacted picture of the attached N279 NoD document so that @Umkomaas can add your case to his thread of shame,  thank you
  • Castle
    Castle Posts: 4,840 Forumite
    Part of the Furniture 1,000 Posts Name Dropper
    I received an email today from DCB legal to say the claim has been discontinued. Thank you so much for your help :) 
    Well done; please can you post up a copy of the N279.
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