Parking Control Management UK limited - Moorside Legal - Letter of Claim - Advice

brucewayne59

Hi everyone,

First of all, thank you to all who contribute to this forum — the guidance here is invaluable.

I created my account back in October as I anticipated eventually receiving a Letter of Claim, and now I have. It's from Moorside Legal on behalf of Parking Control Management (UK) Ltd.

The letter is quite vague. It includes "Annex 1" and a reply form. There’s also a “Schedule of Parking Charge Notices” section, which lists just one entry. Under "Details," it says: “Parked outside of the confines of a marked bay – High Point Village.”

I've read the NEWBIES thread multiple times, as well as other threads similar to my situation. Based on that, I’ve drafted the following response. I'd really appreciate any feedback — is this too much, too little, or in need of correction?
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Dear Moorside Legal,

I refer to your recent Letter of Claim dated [insert date].

The alleged debt is disputed, and any court proceedings will be vigorously defended.

I note that the amount being claimed has been significantly inflated — a practice that has been widely criticised as unfair and excessive.

I have the following questions and formal requests, which fall squarely within my rights under the Pre-Action Protocol for Debt Claims. You are required to respond substantively to these points before any proceedings may be initiated:

1. Debt Recovery Charge
   Am I to understand that the additional £70 represents what you describe as a “debt recovery” fee? If so:

   • Is this figure net or inclusive of VAT?

   • If inclusive, please explain why I am being asked to pay your client’s VAT.

2. Basis of the Principal Sum
   With regard to the original PCN amount:

   • Is this sum being claimed as damages, or as consideration for parking?

3. Details of the Alleged Contravention
   Your letter vaguely alleges that the vehicle was “parked outside of the confines of a marked bay at High Point Village.”
   Please clarify:

   • The precise nature of the alleged breach,

   • The exact location within the site,

   • The evidence relied upon, including photographs and site diagrams,

   • The specific terms and conditions said to have been breached.

4. Documents Requested Under Civil Procedure Rules
   In accordance with Paragraph 3 and Paragraph 6(c) of the Civil Procedure Rules, Pre-Action Conduct and Protocols, I formally request that you provide:

   • A copy of the written contract or agreement authorising your client to issue parking charges at the site.

   • A breakdown of the administrative charges and how the total debt has been calculated.

   • A copy of any notice of assignment, or legal documentation confirming the alleged debt was assigned or transferred to your organisation (if applicable).

5. Late Delivery of Previous Correspondence
   I have received two letters from your organisation to date. In both cases, they were delivered more than two weeks after the date printed on the letter. This is wholly unacceptable for correspondence of such seriousness and undermines the ability to respond within proper timeframes. Such delays are poor practice and may also be raised in any defence, if necessary.

These requests are both reasonable and necessary for me to understand the legal basis of your claim and to formulate a complete response. If you fail to respond adequately or ignore these pre-action requirements, I will ask the court to consider a stay or strike-out of any proceedings on the grounds of procedural non-compliance.

I look forward to your reply.

Yours faithfully,

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Background of the Alleged Contravention

For context: the driver briefly stopped in a bay to drop someone off at the station. The entire stop lasted less than a minute. During this time, the rear wheels were slightly over the line into the bay behind — but not enough to block or inconvenience any other vehicle.

Several photos were taken, but all from behind the vehicle — none from the front. It appears the person taking the photos did not have time to capture the front before the vehicle drove off. In one of the images, the passenger can be seen stepping out of the car, and the driver is visibly still inside.

It’s also worth noting that the individual taking the photos may have caused more of an obstruction by their positioning than the vehicle itself did during the very brief stop.

No PCN was placed on the vehicle at the time, and we only became aware of this issue months later when contacted by Trace Debt Recovery — by which point it was too late to appeal.

I’ve also tried to contact the landowner to complain but I’ve been unable to find a working email address or contact details associated with High Point Village.

Any thoughts, corrections, or suggestions are very welcome. I’ve got around a week before I plan to send this.

Thanks again!

Gr1pr

A well known trap site,  scores of previous posts about it 

Missing paperwork is usually due to not updating the dvla database with an address change promptly 

The standard response to an LoC is to use the response template in the second post in the newbies sticky thread in announcements,  no changes,  no additions,  no subtractions or deletions,  so template only 

Hence why most people wont read a draft here,  its unnecessary