DCB Legal G24 Limited Claim

webbo87

My partner has received a HM Courts & Tribunal Service letter for a parking fine with the contravention date of 06/01/2020, so over 5 year ago now. With the help of this forum I have found the template for the defence response and have amended paragraphs 2 and 3 as instructed, please could someone just double check my amendments are ok before I email submit the defence please. 

The issued date of letter was 29 May 2025 and I have completed the AoS on the MCOL website on the 03 June 2025.

Below are my paragraphs 2 and 3, thanks for you help in advance.

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. The Defendant does not accept that a contravention occurred on 06/01/2020, 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 £170 on private land) and there were no damages incurred whatsoever. 
 
3.1 Due to the length of time since the alleged parking offence, the Defendant has no recollection of the day in question. The Defendant has parked in this car park many times while shopping with evidence of transactions available to submit when required. The Defendant was unaware of parking restrictions in place. The Defendant had not noticed any ‘Prominent’ signage close to where the vehicle was parked, showing the terms and conditions for use. The small signage was not suitable to alert a motorist, leading to an unawareness of any parking restrictions. 

Gr1pr

Its not a fine,  or a Parking offence,  so never use those words in these cases,  paragraph 3 mentions alleged contravention,  so use that wording  in 3.1

Coupon-mad

Looks good. Nice research of the forum!

This is what we like to see from a first post. Do show us the POC though.

webbo87

Thanks for the responses and advice, here is the POC. With the changes made as recommended by Gr1pr is this ok to submit the defence? Thanks.


[Image removed by Forum Team]

Coupon-mad

Yes that's a good paragraph to add within the 30 para Template Defence, as long as your partner (Defendant) was driving. Are they sure?

Your POC showed your VRM so I have redacted that data:
 

KeithP

webbo87 said:

The issued date of letter was 29 May 2025 and I have completed the AoS on the MCOL website on the 03 June 2025.

With a Claim Issue Date of 29th May and having filed an Acknowledgment of Service('AOS') in a timely manner, you have until 4pm on Tuesday 1st July 2025 to file a Defence.

That's nearly four weeks away. Plenty of time to produce a Defence, but please don't leave it to the last minute.

To create a Defence, and then file a Defence by email, look at the second post in the NEWBIES thread.

Don't miss the deadline for filing a Defence.

Do not try and file a Defence via the MoneyClaimOnline website. Once an AOS has been filed, the MCOL website should be treated as 'read only'.