DCB LEGAL cp plus/groupnexus court claim

Coupon-mad

It's not a counterclaim. Those are your costs which you will see the defence already covers at the conclusion.

standup369

thanks for your help in getting this to this stage. is this the standard next step?  so I now just wait and see if they reply or potentially contact me direct as implied

Coupon-mad

Yep - normal. See the first 12 steps in the Template Defence thread.

standup369

DCB legal ltd are proceeding with the claim and i have to file a n180 directions questionnaire asap as i've left it late in the day - will it impact me is a day or so late? can i email a response in or does it have to be paper? do i agree smalls claims is the correct track ? do i request the defendants home courts is the location? do dcb legal ltd tend to go all the way to a hearing?

Gr1pr

Download the N180 pdf document from the government website,  fill it in and save it,  email the saved document as an attachment to your email and add the claim reference number to it, email it to the DQ email address in the 8 steps and CC the lawyers too, today 

The instructions are in announcements,  top of the forum,  step 3

Check out the discontinuations thread by Umkomaas to see their modus operandi, nearly 650 and rising 

standup369

IMG_20260309_122553 redact.jpg

IMG_20260309_122600 redact.jpg

hi, Groupnexus claim has been allocated to the small claims track for Bristol court (see redacted attached images)

Summary: its a inflated claim for costs for no payment of car park fees at a m4 services area. the company have tried to bully and intimidate me on their basis that there was a contract entered into (which i dispute and i'm clear i did not have full information provided to consider a consensual agreement or that i consented in anyway)

I need to submit a witness statement by "no later than" fri 20th March so would love any pointers on helpful content to cover as never done this before.It does not define the length or detail of the document (not hugely helpful)

does this mean I can do so on the day of 20th March? or do i need to do so by 19th March

It also says on page 2 that the applicant only has 3 days to reply (ie that that weekend following) and by the 4pm on the mon 23rd to submit their own statement and pay a court fee of £27, so i'm guessing that short window over a weekend is positive dimension for me and they may not proceed as such a short window of time to submit a statement or assess if worthwhile as I recall that a previous forum post said groupnexus frequently do not go the distance on such false claims

can you submit video evidence within a small claim

i recently visited the same services and shot video evidence / I noticed that when you enter the service station "land" all you see signage wise on the slip road entrance is a blue road sign words "end of motorway regulations" , there is no information offered up after passing this point that you have entered private land with assumed contractual terms attached

you have whilst driving at significant speed to slow down post motorway have 6 seconds to read complex signage on a bend - technically a impossibility). its also impossible to go back and read the complex signage as its on a busy slip road with incoming traffic

thanks in advance for any help offered

Many thanks

Coupon-mad

Group Nexus / DCB Legal claims never proceed past the hearing fee due date.

i recently visited the same services and shot video evidence / I noticed that when you enter the service station "land" all you see signage wise on the slip road entrance is a blue road sign words "end of motorway regulations" , there is no information offered up after passing this point that you have entered private land with assumed contractual terms attached

can you submit video evidence within a small claim?

Yes.

But this is a simple stage and your WS will prod DCB Legal to email the Notice of Discontinuance.

Show that NoD here and on Umkomaas' thread when it arrives please as we are counting them for Government evidence.

Copy & adapt the recent WS by @Horizon_Dawn which is a simple one responding to the claim, citing HHJ Moloney in Beavis and it has Mazur v Speechlys.

The latter case law is massive and is being appealed but currently it means that your Claim Form in 2025 should never have been filed by Sarah Ensall because she's unqualified. She's not a solicitor.

A WS citing that case pushes through a NoD, as happened in the Horizon_Dawn thread! Bring it home please!

😃

standup369

feedback sought on this please

I,__________, of __________, of am the Defendant in this matter. The facts below are true to the best of my belief and this account has been prepared based upon my own knowledge.

1.2I am a litigant in person with no formal legal training. I have done my best to present my evidence clearly, and I respectfully ask the court to take this into account.

2.Preliminary Matter: The Claim should be Struck Out

2.1The recent High Court judgment in Mazur and Stuart v Charles Russell Speechlys LLP [2025] EWHC 2341(KB) underlines that supervision does not transform an unauthorised employee into anauthorised litigator. Only those who personally hold the necessary authorisation may conduct litigation

.2.2 The Claim Form in this case was signed by Sarah Ensall, who does not appear on the SRA register as a solicitor for DCB Legal. I aver that the Particulars of Claim (POC) were verified by a person not authorised to conduct litigation.I attach 3 letters of evidence signed by Sarah Ensall dated, ____________, ____________, and____________. They are signed “Sarah Ensall, Head of BulkLitigation, DCB Legal Ltd”

2.3Furthermore, the POC fail to comply with CPR 16.4 and 16PD3. I rely upon the persuasive appeal authorities of CivilEnforcement Limited v Chan (E7GM9W44) and CarPark Management Service Ltd v Akande (K0DP5J30).In both cases, generic, "auto-fill" POCs were held to be defective and this applies to my case  

3.Facts and Sequence of Events

1. I was the registered keeper and driver of the vehicle on the date of the alleged claim. The claim is made that by entering private land that does not clearly identify that it is private land I willing consented into entered into a contract for free parking for 2hours. This is Denied, disputed fully and has been done so since the outset of the claimant's claim. I was not aware on this date that I had entered “Private land” as there is no clear signage stating this that would be seen whilst walking from a parked car to the service building.My submitted video evidence of 18th Feb 2026 makes it clear this lived experience of no clear “ you are entering private land” signage present when entering______________.
2. New Appeal Form Submission PCN No.__________________VRM__________________Was Driver?YesSite__________________Email Address__________________Name of Appellant__________________Reason for AppealOtherFollow up QuestionsNo of Documents attached0Further Information_____________________ (redacted for forum purposes but I asked them to provide evidence of a contract, which they have not done)Submitted on__________________
3. It is claimed by the claimant that £181.12 is reasonable to claim for32 minutes of alleged “parking”
4. On the material date, I visited _________________ services driving eastwards from the direction of ______________l (where at that timeI lived) . I attach video evidence filmed on 18th Feb2026, the video evidence filmed 216calendar days after the alleged “breach” is provided without commentary BUT to illustrate the factual evidence of the speed at which a driver is travelling when entering the services means it is technically impossible to read a complex signage whilst driving a fast moving vehicle.
5. The video evidence of 18th Feb 2026 evidences the whilst driving in inside lane of the m_ before you enter the slip road for the services, you see a large approx 3m x 1 metres rectangular Blue sign to the left of the road, with a bridge just behind it stating“___________ services” and a white rectangle within the brandname “Moto” on it,There is nothing on this sign saying “you are about to enter private land”
6. The video evidence of 18th Feb 2026 evidences that once a driver has indicated left to turn off the motorway to rest (as per national driving guidelines) that they pass on the left hand side of motorway slip road entrance to the “services”, a large blue rectangular sign (approx 2 metres width by 1 m height) that states“end of motorway regulations” this is easy to read and process information wise whilst travelling at significant speed.
7. The video evidence of 18th Feb 2026 evidences no signage follows after this signage to inform you that “you are now on private land” (as it common when encountering private land) or what or if new regulations exist after passing the blue signage of“end of motorway regulations”.
8. The video evidence show that then as you are faced with the driving task of turning left whilst decreasing in speed, you have 6 seconds to slow your car, make the correct driving adjustments to take the corner safely . It appears to be the case of the Claimant that they expect you to read and enter consensually into a complex contract whilst driving a car at around 40mph. The video evidence of 18th Feb 2026 evidences there is some signage at the bend on the right hand side of the bend of the road, and the video shows that you have 2 seconds to read it whilst driving a moving vehicle, this signage is situated on a grass verge by a fast moving road, the video shows that there is no public path to walk down to read it afterwards as likely this would endanger other drivers entering the service area. the video shows it would be unsafe to seek to walk to this area after parking to read in full . I still have not read the sign or entered into a consensually agreed contract. The video evidences in real time that it is impossible to read what is on this sign at the point of leaving the motorway to enter the public highway area of the “services”
9. one of the false claims made in the POC 3 of the claim which states”reason: vehicle remained on private property in breach of the prominently displayed terms and conditions”.
10. The video evidence of 18th Feb 2026 also shows that once safely parked, when you walk from the car park into the to the services (which takes around ½ a minute) you also see no bold,clear signage telling you “you are now on private land” as you walk into the services building . The video evidence of 18th Feb 2026 that is it very easy to walk into the services area without any advance notice that you are on private land

4.Lack of Contract and Distinction from Beavis

4.1In ParkingEyeLtd v Beavis [2015] UKSC 67,the Supreme Court held that "adequate notice" of terms is essential. My case is the video evidence shows adequate notice is not provided or offered at all during the driver entrance whilst driving or in the 30 second walk into the service area.

1. Here,the signage was a "concealed pitfall or trap". Per Vinev London Borough of Waltham Forest [2000] EWCA Civ 106,a driver cannot be bound by terms they had no reasonable opportunity to see.
2. A letter from CPPlus dated _____________ implies the claimant believes I have an an account with them. This is a false claim.“as previously advised, a further fee of £70 has been applied to your account to cover additional administration costs” and the case should be struck out on this basis

5.Unlawful Inflation and Abuse of Process

1. 5.1The Claimant seeks £181.12 for the alleged PCN. Schedule 4paragraph 4(5) of the Protection of Freedoms Act 2012 (POFA) limits keeper liability to the amount of the unpaid parking charge only.The claimed amount of £----- divided by ---- (the minutes claimed parked) means the claimant claims that their total fee for additional parking is £5.66 per minute.

1. The addition of arbitrary "debt fees" is an attempt at double recovery. I rely on ParkingEyev Somerfield Stores [2011] EWHC 4023(QB),where HHJ Hegarty held that inflating a PCN with admin costs "would appear to be penal". I attach evidence that in a letter dated______ from CPPlus limited on _______ “as previously advised, a further fee of £70 has been applied to your account to cover additional administration costs”
2. Email correspondence with the claimant pre - claim has been a challenge as it comes across like you are dealing with an automated, possiblyAI generated auto fill system as I attach evidence of 2 emails with no name attached and signed “Yours faithfully,CP Plus Ltd”(further proof this is a automated Bulk litigation system process).On insert date _________ unknown person or AI technology alleges“Clear signs at the entrance of this site and throughout inform drivers of the requirement to pay for parking in excess of the free2 hour period, and it is not possible to access any part of the premises without passing multiple signs. Your representations are not considered a mitigating circumstance for appeal.We confirm theCharge was issued under Schedule 4 of the Protection of FreedomsAct 2012. As no driver details have been provided, we are holding the registered keeper of the vehicle liable.In light of this, on this occasion, your representations have been carefully considered and rejected.We can confirm that we will hold the Charge at the current rate of £60 fora further 14 days from the date of this correspondence. If no payment is received within this period, and no further appeal toPOPLA is made, the Charge will escalate and further costs may be added”. So at this early stage of the “the alleged claim” in email correspondence with a unknown person representing “CP PlusLtd” I can evidence the alleged parking fee claimed was £60 for32 minutes . “as previously advised, a further fee of £70 has been applied to your account to cover additional administration costs”. I have not created an account with CP Plus and on this basis the claim should be struck out as well as the basis being that the addition of arbitrary "debt fees" evidenced is an attempt at double recovery

6.Conclusion

6.1I respectfully request the Court dismiss the claim on the grounds of unauthorised litigation, defective POCs and attempts at double recovery debt fees, and a complete lack of clear private land signage for visiting member of the public , looking to rest and be in a fit state to drive safely on a public highway.

Statement of Truth

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement ina document verified by a statement of truth without an honest belief in its truth.  

Coupon-mad

You need to add Chan and Akande as exhibits.

I'd remove 1, 2 and 3 under 3.Facts and Sequence of Events which are unnecessary & repetition.

'Private land' isn't something special or rare so tone down that argument. Obviously you were on private land! EVERY car park that's not Council-owned is private land (you park on private land most days: every time you shop at a retail park, visit a hotel, church, pub or petrol station, or motorway services, whatever). It's no big deal not seeing a sign with those two words on.

Also remove this (below) because they aren't charging you by the minute and these sums don't add up anyway (can't be over a fiver a minute for staying for say, 160 minutes or whatever your time was):

"The claimed amount of £----- divided by ---- (the minutes claimed parked) means the claimant claims that their total fee for additional parking is £5.66 per minute."

Remove the phrase 'abuse of process'.

And add a paragraph somewhere about putting them to proof of landowner authority.

And add a point that the DFT rules on Motorway Services require a MINIMUM free two hours parking, not total stay on site in moving traffic, which is what this ANPR firm has set up. That breaches the DFT MSA rules (Google them and quote them).

Remove this:

"

1. Email correspondence with the claimant pre - claim has been a challenge as it comes across like you are dealing with an automated, possiblyAI generated auto fill system as I attach evidence of 2 emails with no name attached and signed “Yours faithfully,CP Plus Ltd”(further proof this is a automated Bulk litigation system process).On insert date _________ unknown person or AI technology alleges“Clear signs at the entrance of this site and throughout inform drivers of the requirement to pay for parking in excess of the free2 hour period, and it is not possible to access any part of the premises without passing multiple signs. Your representations are not considered a mitigating circumstance for appeal.We confirm theCharge was issued under Schedule 4 of the Protection of FreedomsAct 2012. As no driver details have been provided, we are holding the registered keeper of the vehicle liable.In light of this, on this occasion, your representations have been carefully considered and rejected.We can confirm that we will hold the Charge at the current rate of £60 fora further 14 days from the date of this correspondence. If no payment is received within this period, and no further appeal toPOPLA is made, the Charge will escalate and further costs may be added”. So at this early stage of the “the alleged claim” in email correspondence with a unknown person representing “CP PlusLtd” I can evidence the alleged parking fee claimed was £60 for32 minutes . “as previously advised, a further fee of £70 has been applied to your account to cover additional administration costs”. I have not created an account with CP Plus and on this basis the claim should be struck out as well as the basis being that the addition of arbitrary "debt fees" evidenced is an attempt at double recovery"

Instead of that, in its place add the words about HHJ Moloney's judgment in Beavis. Pretty sure they are in the WS by @Horizon_Dawn but if not, those words are in the Template Defence now. Copy that bit and link to HHJ Moloney's Beavis judgment.

How long were you there? An extra 32 minutes?

Did you use the petrol station?

Did you have your ongoing health issues in 2024 that meant you needed more time?

Le_Kirk

I was the registered keeper and driver of the vehicle on the date of the alleged claim. The claim is made that by entering private land that does not clearly identify that it is private land I willing willingly consented into and entered into a contract for free parking for 2 hours. 

My submitted video evidence of 18th Feb 2026 makes it clear this lived experience of no clear “you are entering private land” signage present when entering______________

What does this lived experience mean?

Change as above