Group Nexus, DCB Legal court claim 2025, the driver parked in a disabled bay

evasivedavid

Signed by a David John Croot... no mention of S.E anywhere front or back of this letter.... 

Coupon-mad

Ok no worries. He's a solicitor, so nothing to see there. Use the template defence.

evasivedavid

Gr1pr said:

As above,  all you had to do is check the initials of the person who signed the claim form and compare

I dont know who signed it so I dont know if you need an extra paragraph regarding the recent Mazur decision,  or not

I won't check a defence that has say 10 to 12 paragraphs,  because I refuse to do a comparison with the template to see what YOU have changed or added or removed  ( we dont need to see any paragraphs that you left alone   )

Its your job to show us your homework,  not that of coupon mad 

so the letter was signed by a socilicitor, therefore just the folloiwng has been added/ammended on the template:

2. The allegation(s) and heads of cost are vague and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. This also makes retrieving material documents/evidence difficult, which is highly prejudicial. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant has little recollection of events, save as set out below and to admit that they were the registered keeper and driver.

3. The Defendant notes that the Parking Charge Notice was issued outside of the statutory 14-day window prescribed by the Protection of Freedoms Act 2012 for keeper liability. The alleged event occurred on 25/01/2025, yet no communication was received before 14/02/2025. This delay extinguishes any keeper liability under POFA. Further, the location’s bay markings and lines were unclear, the signage was inadequate, and no terms and conditions sign was visible from the position of parking, meaning no clear contract could be formed.

8. The Parking (Code of Practice) Act will curb rogue conduct by operators and their debt recovery agents (DRAs). The Government recently launched a Public Consultation considered likely to bring in a ban on DRA fees, which a 2022 Minister called ‘extorting money from motorists’. They have identified in July 2025: 'profit being made by DRAs is significantly higher than ... by parking operators' and 'the high profits may be indicative of these firms having too much control over the market, thereby indicating that there is a market failure'.

1505grandad

You have admitted being the driver so POFA is not relevant.

evasivedavid

1505grandad said:

You have admitted being the driver so POFA is not relevant.

Sorry, I forgot to upload updated version....

2: The allegation(s) and heads of cost are vague and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. This also makes retrieving material documents/evidence difficult, which is highly prejudicial. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant has little recollection of events, save as set out below, and admits only to being the registered keeper.

3. The Defendant notes that the Parking Charge Notice was issued outside of the statutory 14-day window prescribed by the Protection of Freedoms Act 2012 for keeper liability. The alleged event occurred on 25/01/2025, yet no communication was received before 14/02/2025. This delay extinguishes any keeper liability under POFA. Further, the location’s bay markings and lines were unclear, the signage was inadequate, and no terms and conditions sign was visible from the position of parking, meaning no clear contract could be formed.

8. The Parking (Code of Practice) Act will curb rogue conduct by operators and their debt recovery agents (DRAs). The Government recently launched a Public Consultation considered likely to bring in a ban on DRA fees, which a 2022 Minister called ‘extorting money from motorists’. They have identified in July 2025: 'profit being made by DRAs is significantly higher than ... by parking operators' and 'the high profits may be indicative of these firms having too much control over the market, thereby indicating that there is a market failure'.

Gr1pr

Was it an actual solicitor  ? With the initials DC  ?  Or a non solicitor with the initials SE  ?

evasivedavid

Gr1pr said:

Was it an actual solicitor  ? With the initials DC  ?  Or a non solicitor with the initials SE  ?

I uploaded the picture above... it says "David John Croot, Claimant's legal representative as defined by CPR 2.3 (1)"...

Gr1pr

OK, then forget about the Mazur angle,  your current draft seems OK but wait for more comments unless your deadline is imminent 

evasivedavid

Gr1pr said:

OK, then forget about the Mazur angle,  your current draft seems OK but wait for more comments unless your deadline is imminent 

okay mate, thanks. No, not imminent, I only acknwledged last week so I've around 3 weeks yet...

Coupon-mad

I don't understand why you are showing us para 8? Is it changed?