Had Letter of Claim and emailed them from newbies thread - What do I do to their response?

DJEmmey

Hello, so this is the first thread I'm making as I feel like I've looked at so many threads and the newbie thread excessively now and I don't know what to do. for the past like 6 months I've had letters about a parking charge 5.5 years ago, which they stopped sending me letters for after a while initially. They recently started sending letters again and sent me a letter of claim. I sent them the template email asking for 30 days to be on hold, etc. This is the email I've received in response. What do i do now? and please don't just say read the newbies thread. I've read it so many times.

Email response below

"Dear *removed name*,    

We write in response to your correspondence received in our office on 3rd April 2025.  

The sum added is a contribution to the actual costs incurred by our Client as a result of your non-payment. Our Client’s employees have spent time and material attempting to recover the debt. This is not our Client’s usual business and the resources could have been better spent in other areas of the business. Had you of paid as per the Contract, there would have been no need for recovery action so the amount due would not have increased. 

Please note, the HMRC ‘VAT Supply and Consideration manual’ (VATSC06140), which was last updated on 02 September 2020, confirmed that Parking Charges fall out of the scope of VAT.  

As per your request, your file will remain on hold for 30 days from the date of this email. After which, payment of the outstanding balance of £120.00 will be due. Failure to make payment will result in a Claim being issued against you without any further reference.  

Payment can be made via bank transfer to our designated client account: - 

*REMOVED BANK DETAILS*

You must quote the correct case reference (*CASEREFERENCE*)) when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred. 

Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to make payment over the telephone or online at

Kind Regards, 

"

DJEmmey

Bearing in mind, the original parking charge was november 2019.

Coupon-mad

When you get replies from such idiots please don't post them here like they are new & different!

Search the forum for some unusual words from the reply instead. Such as the VAT acronym...

Which PPC?

Which location? What happened?

Coupon-mad

DJEmmey said:

Bearing in mind, the original parking charge was november 2019.

Please answer the questions so we can help. Or come back if you get a claim form.

DJEmmey

I got a claim form and im now just doing my defence but don't really know what to put. the only bits I've changed on the template is this:

It was 5.5 years ago, this is with DCB Legal now and under G24 Limited.

Can't really remember what happened due to the time passed, Any information would be really helpful @Coupon-mad

"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 13/12/2019, as alleged.  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 £120 on private land) and there were no damages incurred whatsoever.

3.1 The Defendant has no specific recollection of the events of 13/12/2019 due to the passage of time. However, the Defendant has frequently parked in the Colchester Retail Park, Sheepen Road – while shopping, and was not aware of any parking restrictions in place. To the best of the Defendant’s knowledge and usual practice, no prominent signage was visible near the location where the vehicle would have been parked, and any small signage present would not have been sufficient to alert a motorist to the terms and conditions of parking. Furthermore, the Defendant submitted an appeal over five and a half years ago but did not receive a response."

Gr1pr

Seems OK, but where is your paragraph 2 with a suitable ending   ?

Presumably G24 via DCB Legal   ?

What is the issue date from the top right of the claim form   ?

Have you completed the AOS online yet  ?

Post a redacted picture of the POC on the lower left of the claim form after hiding the VRM details first 

DJEmmey

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 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. Multiple persons drive the vehicle and the Defendant does not know who was driving the vehicle on this particular date five and a half years ago."

Yes G24 Via DCB Legal
issue date is 29th may and I already acknowleged it on 3rd June.

Ive attached the asked for photo.

Gr1pr

OK, so all good so far,  so post those 3 draft paragraphs below and wait for further guidance 

DJEmmey

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. Multiple persons drive the vehicle and the Defendant does not know who was driving the vehicle on this particular date five and a half years ago.

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 13/12/2019, as alleged.  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 £120 on private land) and there were no damages incurred whatsoever.

3.1 The Defendant has no specific recollection of the events of 13/12/2019 due to the passage of time. However, the Defendant has frequently parked in the Colchester Retail Park, Sheepen Road – while shopping, and was not aware of any parking restrictions in place. To the best of the Defendant’s knowledge and usual practice, no prominent signage was visible near the location where the vehicle would have been parked, and any small signage present would not have been sufficient to alert a motorist to the terms and conditions of parking. Furthermore, the Defendant submitted an appeal over five and a half years ago but did not receive a response.

Coupon-mad

All good.

This will be discontinued by Christmas. 

DJEmmey

Coupon-mad said:

All good.

This will be discontinued by Christmas. 

perfect thank you!