DCBL Legal claim

Gr1pr

They can certainly try,  but I think that Smart Parking will refuse to cancel 

Le_Kirk

With an issue date of 22/10/25 and providing you complete(d) the AoS after 27/10/25 and before 10/11/25 your defence deadline date is 4.00 p.m. on 24/11/25

Wilkstar147

How does this look for paragraph 3 and also the extra paragraph relating to pofa2012.

3. The defendant does not recall being the driver at the alleged time of the breach and was not issued with a PC. The defendant also notes that any signage at the location is unclear or not prominent enough to bring terms to the attention of a driver. No detailed evidence of a breach has been provided by the Claimant. 

4. Further, regarding the Particulars of Claim paragraph 4, research has proved that this Claimant has never used the POFA 2012 and has never been able to hold registered keepers liable. This is important because the solicitor signatory of the statement of truth on this claim is knowingly or negligently misleading the court by citing that law. Despite tens of thousands of boilerplate claims from DCB Legal causing inflated default CCJs this year – as they have reportedly filed a ‘job lot’ of template bulk claims for this Claimant, all repeating the untruth about the POFA 2012 – Smart Parking has no cause of action against any registered keeper 

Le_Kirk

You write that you were not the driver or don't recall being the driver but your knowledge of the signs is remarkably clear!  Maybe you need to say something like "following receipt of the PCN, the defendant carried out research (on foot) and noted that any signage at the location was unclear or not prominent enough to bring terms to the attention of a driver"

Wilkstar147

Thanks, I have reworded as below.

3. The defendant does not recall being the driver at the alleged time of the breach and was not issued with a PC. After carrying out research (on foot) the defendant also notes that any signage at the location is unclear or not prominent enough to bring terms to the attention of a driver. No detailed evidence of a breach has been provided by the Claimant. 

Wilkstar147

Would this be ok for the para 3 + added paragraph?

3. The defendant does not recall being the driver at the alleged time of the breach and was not issued with a PC. After carrying out research (on foot) the defendant also notes that any signage at the location is unclear or not prominent enough to bring terms to the attention of a driver. No detailed evidence of a breach has been provided by the Claimant.

4. Further, regarding the Particulars of Claim paragraph 4, research has proved that this Claimant has never used the POFA 2012 and has never been able to hold registered keepers liable. This is important because the solicitor signatory of the statement of truth on this claim is knowingly or negligently misleading the court by citing that law. Despite tens of thousands of boilerplate claims from DCB Legal causing inflated default CCJs this year – as they have reportedly filed a ‘job lot’ of template bulk claims for this Claimant, all repeating the untruth about the POFA 2012 – Smart Parking has no cause of action against any registered keeper 

All advice is appreciated. Thanks

Gr1pr

PCN, not PC ( Read what LeKirk said  )

Wilkstar147

Amended, thanks. 

3. The defendant does not recall being the driver at the alleged time of the breach and was not issued with a PCN. After carrying out research (on foot) the defendant also notes that any signage at the location is unclear or not prominent enough to bring terms to the attention of a driver. No detailed evidence of a breach has been provided by the Claimant.

4. Further, regarding the Particulars of Claim paragraph 4, research has proved that this Claimant has never used the POFA 2012 and has never been able to hold registered keepers liable. This is important because the solicitor signatory of the statement of truth on this claim is knowingly or negligently misleading the court by citing that law. Despite tens of thousands of boilerplate claims from DCB Legal causing inflated default CCJs this year – as they have reportedly filed a ‘job lot’ of template bulk claims for this Claimant, all repeating the untruth about the POFA 2012 – Smart Parking has no cause of action against any registered keeper 

Gr1pr

The POC core breach is allegedly UNAUTHORISED PARKING 

I suggest that you refute that allegation in paragraph 3, by adding a sentence or two rebutting the allegation 

Wilkstar147

Do you think this would be ok,

3. The defendant does not recall being the driver at the alleged time of the breach and was not issued with a PCN. After carrying out research (on foot) the defendant also notes that any signage at the location is unclear or not prominent enough to bring terms to the attention of a driver. It is also alleged that the ‘vehicle was not authorised to use the car park’ but there is no evidence of ‘No Authorisation’ or not being a patron at the facility. No detailed evidence of a breach has been provided by the Claimant.