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No it's not too late because your application is under CPR 13.2 (mandatory set aside) however some judges wouldn't be impressed with this significant delay.
Also I have no time this week to even look at your WS. I haven't read it (sorry). If it doesn't major on VCS v Carr then search the forum for newer ones posted this Summer on CCJ threads. Change results to show NEWEST.PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
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Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD0
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