DCB Legal - BaySentry - Defense Para 3

yorks_lass17

Hello,  

I have read as much information here as I can but I still need a bit of help on drafting Para 3 of my Defense.  

I had 2 notices from BaySentry and then a letter from DCB Legal. I did not respond. I have a claim form issue date 6 Jan 2026 (date of service is then 11 Jan 2026) and I have logged onto MCOL and submitted the AoS acknowledged on 21 Jan 2026. I believe I have until 25 Jan 2026 to submit my defense? 
 
What happened – I had a knee injury which meant I couldn’t commute by train to work as usual, but I had a meeting that I had to go in for, so I drove to my office in Leeds and parked at the closest car park I could. I did not see the signs which said the car park didn’t open until 9.30am. There were no barriers and there were lots of other cars parked there already. In the rain, I hobbled to the paystation to pay and it didn’t accept payment. I then tried to pay on an app and it also would not take my payment. At the time I thought they must be not working so I proceeded to my office. From the Particulars of Claim, the Reason: Vehicle parked Out of Allowed Hours. 

But the car park was open! Lots of other cars were there. I arrived at 9.13, why wouldn’t the pay machine let me pay from 9.30am?  
 
Please can you help me write my defense Para 3?

3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The Defendant does not accept that a contravention occurred on 17/09/2025, as alleged.  Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever. 
 
3.1 The Defendant on the day in question pulled into an open car park in Leed City Centre. The car park was open and with no barriers, and a number other cars were parked in the same location. The Defendant had a knee injury and her mobility was reduced, but needed to attend her place of employment, nearby for an important meeting. When the Defendant proceeded to the pay station, it was not in working order. The Defendent also tried to pay for parking on an app, which was also not functioning. The Defendant was unaware of parking restrictions in place. The Defendant had not noticed any ‘Prominent’ signage close to where the vehicle was parked, showing the terms and conditions for use. The Defendant maintains that if Vehicle was parked Outside of Allowed Hours, why was the car park open and full of other vehicles. The Claimants must have their parking machines in working order.

Thank you in advance for any and all help! (I've never done anything like this before).

Kate

Coupon-mad

I believe I have until 25 Jan 2026 to submit my defense?

There is no 's' in defence and your deadline date is wrong too. You have much longer. Others will reply in the morning!

yorks_lass17

sorry, I'm originally American, I spell everything wrong...organizing my colors etc etc. Phew, good to know I have a bit longer! My husband is very stressed about this!

ChirpyChicken

tell him to relax 

James_Poisson

Was this Whitehall Road Leeds?

If so the car park is closed to entry between 6:30 AM to 9:30AM I am sure the landowner have their reasons, maybe to stop over night parking, other vehicles on site mean nothing to your case and may be white listed.

However in your case you were parked outside of hours you could not pay so no contract was offered so they cannot charge you anything it was in fact trespass.

A two bit parking scammer cannot charge you for trespass.

Le_Kirk

yorks_lass17 said:

I have read as much information here as I can but I still need a bit of help on drafting Para 3 of my Defense Defence.   

I had 2 notices from BaySentry and then a letter from DCB Legal. I did not respond. I have a claim form issue date 6 Jan 2026 (date of service is then 11 Jan 2026) and I have logged onto MCOL and submitted the AoS acknowledged on 21 Jan 2026. I believe I have until 25 Jan 2026 to submit my defense defence?

With an issue date of 06/01/26 and having completed the AoS in a timely manner your defence deadline date is 4.00 p.m. on 09/02/26

Gr1pr

With an issue date of 6th January  and the AOS completed,  the deadline for the defendant to submit their defence is 4pm on Monday 9th February 

Add ,and driver  , to the end of your paragraph 2

Paragraph 3 is ok

I would remove your 3.1, too much information,  save it for any future WS

If you are adding an extra paragraph point,  it should be about,  no offer,  no consideration,  no parking contract,  plus frustration of contract due to their machines and app not accepting payment when the defendant tried to pay

Clearly you were classed as a trespasser, as mentioned above,  but the parking company cannot enforce against trespassers 

yorks_lass17

@James_Poisson, Yes indeed it was that car park. 

Trespassing...interesting. A fully dressed up car park with pay stations basically inviting trespassers. 
Wow. 

Gr1pr
"Add ,and driver  , to the end of your paragraph"
I don't understand this part...I'm just going to submit Para3 and omit 3.1 (as you say, save for Witness Statement).
I haven't included a para2 in this message (because I intend to copy/paste it from the guidance notes)
Can you clarify that for me?

I'm submitting this on MCOL, correct? Or do I need to email it?
I was unclear on this point from the threads as it seems like it may have changed?

Is there any benefit to waiting closer to the 9th February date, or should I just submit it now?

Thank you again for all this assistance...I felt so overwhelmed and my husband was really pushing me to pay and just be done with it...and I just knew that it wasn't right.
 

Coupon-mad

You are putting in all 10 paragraphs and adding to para 2 what I tell people to add. 

Gr1pr

10 paragraphs,  with your paragraph 3 and the additional 2 word ending to paragraph 2, simples

Copy and paste it into the defence box on MCOL,  save,  submit,  done

No paperwork,  no email  either 

No real benefit in waiting,  if its good to go, get it saved and submitted 

I dont think that you should be looking for any input from your other half, because he doesn't understand it like we do, it's your name on the claim form, nobody else's,  trust us. ! ( he will thank us later this year. )

yorks_lass17

Hello again, I have received the N180 form DCB Legal by email on Mon 23 Feb? I see it is just a copy for my records. What do I do now? Am I now waiting for someone to contact me regarding mediation?

I can't seem to find that part of the thread in the newbies?
Thank you in advance for your help! (feeling anxious about this again!)

Thank you.