CIVIL ENFORCEMENT LTD - Court Claim (CEL: S. Wilson)

justcause

Coupon-mad said:

justcause said:

Defence submitted today. I’ll update once I have some news. 

But not news about things already covered by the first 8 steps please.

  

I wrote those steps to inform people but also to protect our time, by stopping endless posts telling us about the bog standard (fully expected) letters and DQ form, mediation phone call and the tedious S Wilson early template witness statement (there's a thread about that...).

See you back here in Summer 2026. 

Yes I’ve read those steps. I’ll only update if I get a discontinuation. 

justcause

Good afternoon folks. Update, I have a court hearing 4th Sept & need to file my witness statement by 19th August (not stated on the letter). CEL sent me a letter offering a reduced price (£130) to settle otherwise they will go after the full amount in court. I tried to find out from HMCTS if they have paid the court fee which was due by 7th August but they have no record of it either way, so not much help (I thought if they haven't then claim would be struck off/out and save me doing the WS)

I have not received the WS from CEL yet, so can't counter based on that.

My WS & defence would revolve around based on what I understand from the forum is:

No keeper liability - if you are relying on a 'no keeper liability' argument, include a URL to Schedule 4 of the POFA and also exhibit the transcripts of Excel v Smith and VCS v Edward (search the forum!).

The Claim form did not specify the term breached. -  If the Claim form did not specify the term breached, include the strike out orders shown here in a link to CEL v Chan and similar case 'strike out' Judgments from all over the English courts:

Am I going along the right lines?

ChirpyChicken

CEL wont pay the hearing

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/81525991#Comment_81525991

Don't forget the above kind offer.

But why do you think the NTK was non-POFA? You showed it to us earlier, on page 1 and it has the POFA wording and was posted in time. And Creative Car Parks are the same stable as Civil enforcement. 

So none of what you are thinking about is relevant.

Your WS is more about the story of what happened.

Your sequentially numbered exhibits will include that pic of the tablet on a table with the back of it to the door/window and no sign alerting people to remember to use it before they leave, nor warning of the risk of a parking charge if you don't, or if you make a VRM typo (yes, I know Costa made an effort to later put up a handwritten sign but that's due to complaints and isn't from CEL and doesn't warn about any of the above):

And the usual section about no landowner authority for CEL to litigate in their name.

Plus the usual other exhibits in the long list that I carefully collated (in the second post of the NEWBIES thread) that nobody ever seems to read…