UKPS LTD Particulars of Claim court action

ChirpyChicken

No.
Your defence. Word for Word

dabachi_scents23

ChirpyChicken said:

No.
Your defence. Word for Word

I've posted above 

ChirpyChicken

dabachi_scents23 said:

ChirpyChicken said:

No.
Your defence. Word for Word

I've posted above 

No you didnt that couldn't have been the defence you logged with the court.
Please post up the defence you logged directly with the court.
Word for Word please.

dabachi_scents23

ChirpyChicken said:

dabachi_scents23 said:

ChirpyChicken said:

No.
Your defence. Word for Word

I've posted above 

No you didnt that couldn't have been the defence you logged with the court.
Please post up the defence you logged directly with the court.
Word for Word please.

No, it was my appeal to UKPS.

I can't provide word for word for the defence to the court as it was handwritten and posted back, so I now have no access to it, but it was something very similar to the following (based on my chat GPT search at the time using the defence template on the newbies thread) 

"I was not the driver of the vehicle at the time of the alleged incident and I denyany liability. The Claimant has not identified the driver, nor have they complied with the strict requirements of Schedule 4 of the Protection of Freedoms Act 2012 (POFA) to hold the registered keeper liable. The Notice to Keeper (NTK) issued by the Claimant does not comply with POFA 2012 in both form and content, and was served outside of the prescribed timeframe. As such, the Claimant has no legal basis to pursue me as keeper.

I request that the claim be struck out on these grounds"

ChirpyChicken

Thats not bad at all if as you say not the driver and non pofa 

Coupon-mad

However, the OP will now have a chance to improve it, if Moorside comply with the order.

dabachi_scents23

Coupon-mad said:

However, the OP will mow have a chance to improve it, if Moorside comply with the order.

If they do comply with the order, what can I expect? How would I improve my defence? 

Coupon-mad

You can then use the template defence.

Le_Kirk

dabachi_scents23 said:

Letter attached! Please do advise on if there is anything I need to be aware of? How would they potentially amend the Particualrs of Claim? My defence is that no NTK was issued, and that I deny liability as I wasn't the driver, and almost 7 years later would not be able to name the driver. 

Thank you, I have saved it ready for when the outcome is posted.

ChirpyChicken

Coupon-mad said:

You can then use the template defence.

Personally i wouldn't bother. 
If they were not the driver and it is 100%  a non pofa pcn their defence is succinct and to the point.
I dont see any need to add extra stuff in to what is a decent defence and strong case.