Letter Before Claim - UPE

LSP18 · 21 May at 5:17PM

Hi all,

I'm looking for some guidance on a Letter Before Claim received by a relative that they have asked me to assist with.

It pertains to a location which has had quite a few threads on but none seem to have gone as far as a LBC. They received a windscreen PCN, time 19:33, claiming driver or passenger left the site.

I have added links to the original NtK, LBC and some of the photos they provided as evidence.

They do not know who the driver or passenger (a teenager) was, no appeal was made to UPE or IPC, and a request for more information was made as with the evidence provided it wasn't evident that a contravention had occurred.

Below is also a draft response to the LBC.

Thanks in advance.

To UPE,

This is a response in light of your Letter Before Claim.

The alleged debt is denied in its entirety, and will be vigorously defended.

Your letter fails to provide sufficient particulars to properly understand the basis of the claim. In particular, the allegation that the driver and/or passenger “left the premises” is vague and unsupported.

No clarification of the alleged contravention was provided despite previous requests.

Please confirm whether you are relying upon Schedule 4 of the Protection of Freedoms Act 2012 in order to hold the registered keeper liable for this charge.

The additional £70 is denied. It is an unjustified attempt at double recovery and is routinely disallowed in court.

Yours faithfully,

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