DCB legal ltd solicitors court claim letter

Alius

Hi everyone,
Hope you can help me out with writing a defense regarding parking fine.

I will post a letter shortly after.
Long story short : original parking fines probably were delivered to old address.
 
I updated v5 document and then i received Solicitors threatening letters to my new  address.

So i have no idea how i breached their terms of contract as all i can see car was at B&Q car park which is free to use, but because i was moving houses my father ore went that day maybe free times to buy renovation stuff that day,30 12 24, New year Eve.
And i moved houses next day on 1st of January ,( i know ,it sounds sad)

I denied for being a driver ,admit as being a keeper 

I followed your thread and filled acknowledge of service already.

By the way , English is my second language so hopefully it doesn't make things too complicated for me

Alius

My letter received from scammers

Coupon-mad

Oh good, they don't state the breach so just use the template defence with the special para 3 linked in it for claims with no specified breach. Very easy one.

They'll discontinue it in the end. No hearing.

Alius

With regards to the POC in question, two recent persuasive appeal judgments in Civil Enforcement Limited v Chan (Ref. E7GM9W44) and Car Park Management Service Ltd v Akande (Ref. K0DP5J30) would indicate the POC fails to comply with Civil Procedure Rule 16.4(1)(e) and Practice Direction Part 16.7.5. On the 15th August 2023, in the Chan case, HHJ Murch held: 'the particulars of the claim as filed and served did not set out the conduct which amounted to the breach in reliance upon which the claimant would be able to bring a claim for breach of contract'. The same is true in this case and the Defendant trusts that the Court should strike out the extant claim, using its powers pursuant to CPR 3.4. The second recent persuasive appeal judgment also held that typical private parking case POC (like this) fail to comply with Part 16. On the 10 May 2024, in CPMS v Akande, HHJ Evans held: 'Particulars of Claim have to set out the basic facts upon which a party relies in order to prove his or her claim'."

Alius

Is this the para 3 you referred i should use?

Coupon-mad

Yep. Easy innit?!

Alius

Thank you for your help.

So just to clarify myself.

I used template of 10 para but this para 3 u referred?

Alius

Sorry let me rephrase my previous comment.

So for my defence i use a template of 10 para found in newbies thread and as 3rd para I'm using the one you referred?

Le_Kirk

With an issue date of 12/09/25 and having completed the AoS in a timely manner

your defence deadline date is 4.00 p.m. on 15/10/25

Alius

Aos done ,defence left of which i am struggling a bit