ECP/DCB Legal paragraph 3 help - is this draft enough?

lemonfresh

Hi, so I've got a court summons, read everything so just after a bit of help for the template. It was for overstaying in a car park that serviced Wynsors shoe shop and The Big Charity Shop:

3. The defendant has used Wynsors shoe shop for many years and had no reason to believe they would be billed for using the car park and had never noticed any signage informing them of possible fines. The defendant’s partner was still having trouble walking due to a hospitalising bout of pneumonia the previous winter and needed to rest often. Defendant can provide proof of hospitalisation and also bank statement proving they made two purchases at the Big Charity Shop, serviced by the same car park, and bank statement from partner’s account proving purchase made at Wynsors.

Defendant previously appealed and was turned down.

Is that any good? We were there for 40 minutes over the allowed hour in two shops but they were quite large and we were quite slow and hadn’t been anywhere in a while. I didn’t notice any signs, having gone back there many months ago (and confirmed by Google maps) they are there but all seem mainly lumped in one area, all easily missed whilst walking along, especially with kids.  Is there anything worth missing out or adding? Thanks

lemonfresh

Here's the POC

Gr1pr

Definitely NOT a summons,  just an MCOL claim from the CNBC in Northampton 

Not a fine either,  so you dont want that word in there, it was a private parking charge notice,  a pcn , an invoice 

Presumably its a retail park or shopping centre if there is more than one business there, so the shops are likely to be tenants,  not landowners

Post a redacted picture of the POC from the lower left of the claim form below after hiding the VRM details first 

What is the issue date from the top right of the claim form   ?

What date was your AOS completed   ?

This recent thread is similar so please study it,  especially the replies 

https://forums.moneysavingexpert.com/discussion/6620864/please-help-with-my-defence-statement-draft-paragraph-3/p1

Coupon-mad

Everyone (hundreds of posters in the first half of 2025 alone) with a single PCN claim from DCB Legal, have easily beaten it. DCB Legal will discontinue by the New Year.

No hearing, no costs, nowt scary.

And if you want to be part of the push to change things in future, it's very important that people like you tell the Government that:

a) you have no faith in POPLA or the IAS and that there must be the SINGLE APPEALS SERVICE that the Parking (Code of Practice) Act 2019 *almost* promised. As long as it is independent and impartial (and only ONE appeals service, not two involved in a race to the bottom) that will give a real option to resolve disputed cases out of court.

b).  THAT THE ENRICHMENT OF 'DEBT RECOVERY FEES' MUST BE COMPLETELY BANNED. DISPUTED CASES ARE NOT SOLVED BY DEMANDING MORE MONEY AND OFFERING A 'PAYMENT PLAN'!

c). Tell them about your experience and the complete and utter waste of court resources caused on a grand scale by DCB Legal,

Responses are invited to the Consultation now:

https://forums.moneysavingexpert.com/discussion/6617396/parking-code-of-practice-consultation-8-weeks-from-11th-july-2025/p1

Do it this month pleeease! We will discuss it on that thread next week if you want ideas.