Gladstones LBC: Draft Response for Review

bigf00t

Hi all,

I’ve received a Letter Before Claim from Gladstones Solicitors on behalf of Premier Parking Enforcement Ltd (dated 8th September 2025).

The alleged issue is that my car was not fully within a bay. However, there were large containers and other obstructions directly opposite the bay, which narrowed the roadway. To allow other vehicles to pass safely, the car had to be positioned so that it encroached into the space behind. There was already a car in that bay and I parked as close to it as possible. It seems they later thatched out that bay so nobody parks in it but the containers and obstructions were still there, last I checked. 

I’ve drafted a reply letter (based on the NEWBIES thread guidance). Could you please check it for me and let me know if any improvements are needed?

Here’s my draft:

Dear Sirs,

I write in response to your Letter Before Claim dated 8th September 2025.

1. Debt Denied

I deny any debt to your client, Premier Parking Enforcement Ltd.

2. Request for Information

Please provide the following documents and evidence that you intend to rely upon in court, as required under the Pre-Action Protocol for Debt Claims:

A full copy of the contract between your client and the landowner authorising the issue of parking charge notices.

Copies of all photographs taken of the vehicle, and a site plan showing the position of all signage. Please also include photographs of the roadway directly opposite the bay in question.

Evidence of compliance with the IPC Code of Practice.

A detailed breakdown of how the parking charge was calculated and justified.

A detailed breakdown of the £70 “debt recovery” costs added to the original charge, which are clearly an attempt at double recovery and are not recoverable in law (see Excel v Wilkinson [2020]).

Until this information is supplied, the claim is not properly particularised.

3. Reason for Dispute

The vehicle was parked in a bay where large containers and other obstructions had been placed directly opposite, narrowing the roadway. To allow other vehicles to pass safely in front of the bay, the car had to be positioned in such a way that it slightly encroached into the adjacent space to the rear. This was a matter of necessity and safety, and likely a direct result of your client’s poor management of the site.

It is notable that your client’s photographs do not show the obstructions opposite the bay. Full disclosure of the site layout and contemporaneous images is therefore required.

Your client’s rigid enforcement under these circumstances is unreasonable and contrary to the principle of fairness required under the Consumer Rights Act 2015.

4. Seeking Debt Advice

I am seeking debt advice and therefore require this matter to be put on hold for 30 days as per the Pre-Action Protocol for Debt Claims.

5. Future Conduct

Please confirm whether your client intends to proceed to a fully pleaded claim once the above information is supplied. Should proceedings be issued without proper compliance with the Protocol, I will seek an immediate stay and costs.

Yours faithfully,

Thanks for any advice.

bigf00t

Any help? 

Coupon-mad

That's not the LBC response in the NEWBIES thread. 

bigf00t

You're right, I didn't actually understand the one in the NEWBIES thread or the other one linked to in that thread. I don't understand why I'd need to confirm/delete my address and I don't know what perpensity to zero means. So I cobbled stuff together from other letters I found. You don't like it? 

Gr1pr

bigf00t said:

You're right,

 I didn't actually understand the one in the NEWBIES thread or the other one linked to in that thread.

 I don't understand why I'd need to confirm/delete my address and I don't know what perpensity to zero means.

 So I cobbled stuff together from other letters I found. You don't like it? 

Irrelevant,  this is litigation where legal speak is involved and you are not a trained lawyer,  hence why there is an approved template 

The reason is to confirm the current address for the service of papers,  the future court claim for example,  it doesn't have to be your address,  but a valid UK address you have access to in order to obtain the paperwork promptly. That way it doesn't go to an old or incorrect address,  which we see every week on here,

Its a data protection right under GDPR, plus something that claimants and solicitors are expected to do ( it doesn't matter if they are already using the correct address,  it's making sure that they use the correct address,  regardless of where previous paperwork went,  which means less future hassle for the victim,  you

Cobbling stuff is usually worse than a multiple person approach to an approved template etc

If you have ever bought a house or done probate,  you would probably not understand a lot of these legal matters, so following the advice of experienced people is usually the best option,  or employ a lawyer like the opposition did

DIY projects might get the job done but there is nothing better than getting a professional in,  including opinions 

After being involved in these matters for over a decade,  if I were in your position I would be using the template approach,  including the LoC response and also the template defence too ( suitably adapted   )

But its your legal case,  so your choice  ( might not matter at the LoC response stage,  but extremely important in the future stages, please note that 99% of the volunteers here wont bother to read a DIY (  or cobbled together   )  defence. Our trademark reply is bin it and use the free template defence 

bigf00t

OK, I think I understand. I should just reply to Gladstones with the below template? I don't need to add anything about my particular situation?

Dear Sirs,

Your ref: [insert reference number]

Proposed legal proceedings

Claimant: [insert name of parking company]

I refer to your letter of claim.

I confirm that my address for service for the time being is as follows, and any older address must be erased from your records:

[Insert correct address here]

You should revert to your client because the 'propensity to pay' score in my case is zero, so any claim is hopeless and a waste of the court fee (whether 'fronted' by your firm or not). Move on to weaker victims.

The alleged 'debt' is disputed and any court proceedings will be vigorously defended.

Yours faithfully,

Coupon-mad

Yep. You can google 'propensity to pay' if you want to understand the phrase better, in terms of debt collection.