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Letter Before Claim - UKPPO

191012141518

Comments

  • Elmo111
    Elmo111 Posts: 76 Forumite
    Evening/Morning all,

    Please take a look at my fourth draft, with amendments suggested by IamEmanresu and Coupon-Mad.

    I've put some additional information in place, specifically at points 5, 6, 10.5, 12 and 15.

    **********

    IN THE COUNTY COURT
    Claim No.: XXXXXXXX

    Between

    UK PARKING PATROL OFFICE LTD
    (Claimant)

    -and-


    XXXXX
    (Defendant)

    ___________________________________________________________________________

    DEFENCE
    ___________________________________________________________________________

    Preliminary

    1. The Defendant denies receiving correspondence from the Claimant regarding any of the alleged parking contraventions. In pre-action communication, UKPPO Ltd states that 24 letters were sent to the Defendant's address acquired from the DVLA for strictly limited purpose of ‘enquiring who was driving’.

    2. It is with distress that I note that the Claimants amount of letters sent, is approximately twice as many demands than the unwarranted demands which bombarded the consumer victim in the case of Ferguson v British Gas Trading Ltd [2009] EWCA Civ 46, where the company's course of conduct amounted to unlawful harassment contrary to the Protection from Harassment Act 1997 and they were liable to pay the defendant over £10,000 in compensation.

    Background

    3. It is admitted that on the material dates, the Defendant's vehicle was parked at the location stated.

    4. It is admitted that at all material times the Defendant is the registered keeper of the vehicle which is the subject of these proceedings.

    5. The Defendant has sufficient evidence which shows the continued disdain and negligent attitude of the landlord, UrbanBubble, who merely appointed the Claimant to act on behalf of the landowner.
    5.1. The Claimant has failed to supply a copy of the contract demonstrating their ability to issue charges on this land.
    5.2. The Claimant is put to proof that it has sufficient interest in the land or that there are specific terms in its contract to bring an action on its own behalf. As a third party agent, the Claimant may not pursue any charge.
    5.3. The Defendant put the Claimant to strict proof for full disclosure of the contract with UrbanBubble, and what steps were taken in advance of enforcement to take account of the primacy of contract of existing residents and to avoid unconscionable ticketing of genuine residents/their visitors, rather than a genuine aim to deter trespassers.

    6. No driver of the vehicle reported finding a windscreen PCN. After correspondence from the landowner regarding CCTV footage, this is unavailable due to only 4 weeks footage being on file at any one time.
    6.1. The Defendant researched online about a phenomenon known as ‘ghost ticketing’, in which a private car park attendant would remove an affixed PCN before the driver has returned to the vehicle. One missing PCN could be seen as a prank, but for four parking charge notices to have never been seen by the driver, suggests something different.
    6.2. The Claimant supplied pictures of the PCN(s) attached to the vehicle, but photos are not enough because they form part of a typical ‘ghost ticketing’ rogue operation.
    6.3. There is evidence in the form of a DVLA FOI that UKPPO use self-ticketers. The FOI showed that not all UKPPO's ticketers had been trained and had signed that they abided by the BPA (or IPC) Code of Practice.


    7. The Claimant failed to issue a Notice to Keeper (NTK) for the alleged infringement. This is not in accordance with the requirements of The Protection of Freedom Act 2012 (POFA). Under schedule 4, paragraph 4 of the POFA, an operator can only establish the right to recover any unpaid parking charges from the keeper of a vehicle if certain conditions are met as stated in paragraphs 5, 6, 11 & 12. UK Parking Patrol have failed to fulfil the conditions which state that the keeper must be served with a compliant NTK in accordance with paragraph 9, which stipulates a mandatory timeline and wording:-

    The notice must be given by; (a) handing it to the keeper, or leaving it at a current address for service for the keeper, within the relevant period; or (b) Sending it by post to a current address for service for the keeper so that it is delivered to that address within the relevant period.

    7.1. Paragraph 5.2 of the October 2017 pre-action protocol, which UK Parking Patrol Office Ltd, states that in our pre-action communications:-

    If the debtor requests a document or information, the creditor must:- (a) provide the document or information; or (b) explain why the document or information is unavailable, within 30 days of receipt of the request.

    7.2. UK Parking Patrol Office Ltd could not supply the defendant with a copy of a compliant NTK and (b) did not explain why the requested NTK is unavailable. Instead, UK Parking Patrol Ltd decided to continually evade providing the defendant with a copy of the required documents, vital to their case.

    8. The claimant failed to include a copy of their written contract with any correspondence as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice B1.1 which says;
    If you operate parking management activities on land which is not owned by you, you must supply us with written authority from the land owner sufficient to establish you as the ‘Creditor’; within the meaning of the Protection of Freedoms Act 2012 (where applicable) and in any event to establish you as a person who is able to recover parking charges. There is no prescribed form for such agreement and it need not necessarily be as part of a contract but it must include the express ability for an operator to recover parking charges on the landowner’s behalf or provide sufficient right to occupy the land in question so that charges can be recovered by the operator directly. This applies whether or not you intend to use the keeper liability provisions;

    8.1. The claimant provided an example ‘contractual notice’, that was not a picture directly from the event of each parking offence, but instead an out-of-date PDF, titled ‘Parking Patrol july2013’, which states at the bottom of the document, “Non-payment will result in additional charges which will be added to the value of the charge and for which the driver will be liable on an indemnity basis.”

    9. The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed the particulars of claim are not clear and concise as is required by CPR 16.4 1(a).

    10. The claimant has not provided enough details in the particulars of claim to file a full defence; no dates, the reason for each PCN or whether the vehicle was parked on the roadway or car park.
    10.1. The Claimant has stated that 4 ‘parking charges’ were incurred.
    10.2. The Claimant has given no indication of the nature of the alleged charge in the Particulars of Claim. The Claimant has therefore disclosed no cause of action.
    10.3. The Particulars of Claim contains no details and fails to establish a cause of action which would enable the Defendant to prepare a specific defence. It simply states ‘parking charges’; which does not give any indication of on what basis the claim is brought.
    10.4. It was only during pre-action communication that information regarding why the charge arose, what the initial charge was, what the alleged contract was and anything which could be considered a fair exchange of information. The Particulars of Claim are incompetent in disclosing no cause of action.
    10.5. The Particulars of Claim are deficient in establishing whether the claim is brought in trespass. If the driver on the date of the event was considered to be a trespasser if not allowed to park there, then only the landowner can pursue a case under the tort of trespass not this Claimant, and as the Supreme Court in the Beavis vs ParkingEye (2015) [2015] UKSC 67 case confirmed, such a matter would be limited to the landowner themselves claiming for a nominal sum.

    11. The Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. The Defendant avers that the Claimant is therefore limited to pursuing the keeper in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 ("POFA")

    11.1. Before seeking to rely on the keeper liability provisions of Schedule 4 POFA the Claimant must demonstrate that:
    11.1.1. There was a ‘relevant obligation’; either by way of a breach of contract, trespass or other tort; and
    11.1.2. That it has followed the required deadlines and wording as described in the Act to transfer liability from the driver to the registered keeper. It is not admitted that the Claimant has complied with the relevant statutory requirements.
    11.2. To the extent that the Claimant may seek to allege that any such presumption exist, the Defendant expressly denies that there is any presumption in law (whether in statute or otherwise) that the keeper is the driver.

    12. For the Claimant to utilise The Interpretations Act of 1978, proof of postings must be given to the Defendant. UKPPO were unable to supply proof of postings for the NTK(s), nor even true copies showing the address utilised for the NTK. In pre-action communications, proof of a ‘reminder notice’ was seen, but as such, this is not a compliant NTK variant.
    12.1. The ‘reminder notice’ received was a ‘digital’ document, not a scanned copy of the document supposedly duly sent, leading to a possibility of the contents of the document being altered in an attempt to thwart the chance of the Defendant holding a strong case, before being supplied as evidence.

    13. It is denied that the Claimant has any entitlement to the sums sought and it is denied that interest is applicable on the total sums claimed by the Claimant, which bear no relation to the maximum sum potentially able to be recovered from a registered keeper, as set out in the POFA, namely the sum stated in the Notice to Keeper.

    14. Further, the Defendant denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of parliament, they would have made such requirements part of POFA, which makes no such provision. In the alternative, an amendment could have been made to s.172 of the Road Traffic Act 1988. The 1988 Act continues to oblige the identification of drivers only in strictly limited circumstances, where a criminal offence has been committed. Those provisions do not apply to this matter.

    15. The sparse Particulars of Claim creates confusion around the contravention(s) and contains no details enabling the defendant to prepare a defence.

    16. UK Parking Patrol Office Ltd have failed to adhere to POFA 2012 and should chase the appropriate party.

    17. The Court is invited to dismiss the Claim, and to allow such Defendant’s costs as are permissible under Civil Procedure Rule 27.14.


    I believe the facts stated in this Defence Statement are true.


    ………………………………………………………. ………………………
    (Defendant) (Date)

    **********

    Thanks again for your continued support!
  • Coupon-mad
    Coupon-mad Posts: 130,606
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    edited 30 May 2018 at 1:32AM
    3. It is admitted that on the material dates, the Defendant's vehicle was parked at the location stated.

    I would remove the above or adapt it, because you had NO PCN and NO NTK, and the first you knew of this was recently. So you cannot be sure the above is true on those dates last year, and I would say more at this early stage in your defence.

    I would suggest the following but I may have some details wrong about your situation, so you must adapt it to suit:
    3. It is neither admitted nor denied that on the material dates, the Defendant's vehicle was parked at the location. The Defendant is a resident and does have full authorisation to park at home, so any 'contravention' is denied. However, the car is insured for more than one driver and it is impossible to be sure now in 2018, whether the car was there on four unremarkable dates almost a year ago, or indeed, who parked it at the purported times.

    3.1. The Defendant has seen the Claimant's photographs but suggests the court should treat those images with scepticism, given the following facts which are expanded upon later in my defence:

    (a) they purport to show the vehicle with windscreen PCNs attached that never materialised in reality, and

    (b) parking firms (including IPC members) have in recent years been caught issuing PCNs, taking a photo, then removing them, and

    (c) parking firms who are supposedly 'legitimate' AOS members have been caught and investigated for altering times and/or dates on their handheld cameras, showing how easy it is to falsify such photo evidence, and

    (d) this Claimant is known to use 'self-ticketing' where the person with the camera has an incentive to issue predatory PCNs for personal monetary gain (a 'bounty' per paid PCN) and is not an employee. Such a person is unlikely to have training and knowledge of the Trade Body Code of Practice or any applicable law, including but not limited to: the Data Protection Act, the Consumer Rights Act 2015, the Equality Act 2010, the Protection of Freedoms Act 2012 (Schedule 4) and the Consumer Protection from Unfair Trading Regulations 2008, and

    (e) The Defendant avers there was a lack of due diligence and there were insufficient checks and balances by the Claimant at this location, and that any PCNs were not properly issued. The Trade Body (IPC) Code of Practice from 2017 states:
    ''4.2 Self-ticketing practices are considered the same as sub-contractors, so if you enforce parking charges issued by a self-ticketing site, you are responsible for ensuring they keep to the Code in its entirety.
    17. Incentive Schemes
    17.1 You may use incentive schemes to motivate your staff and improve productivity. However, you may not use an incentive scheme which focusses solely on the volume of parking charges issued without introducing sufficient checks and balances so as to ensure that operatives do not issue Parking Charges where they should not.
    17.2 To avoid simply encouraging the issue of a high volume of parking charges notices, operators should employ schemes which encourage a high standard of work.
    17.3 Where incentive schemes are employed, Operators should keep in mind that it is they that are ultimately responsible for improperly issued Parking Charges and that there may be ramifications should members of their staff (or self-ticketers) issue parking charges fraudulently''.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
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  • Elmo111
    Elmo111 Posts: 76 Forumite
    Coupon-mad wrote: »
    I would remove the above or adapt it, because you had NO PCN and NO NTK, and the first you knew of this was recently. So you cannot be sure the above is true on those dates last year, and I would say more at this early stage in your defence.

    I would suggest the following but I may have some details wrong about your situation, so you must adapt it to suit:

    That looks like a good alteration Coupon-Mad, thanks!

    There is a few bits that I need to change, but otherwise the majority of it seems pretty spot on. If I used section 3, would I need to adapt para 6 accordingly, or could I effectively leave it in place?
  • Coupon-mad
    Coupon-mad Posts: 130,606
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    I think you could remove 6.2 and 6.3 in the defence. Point #6 is punchier and more thought provoking for a switched-on Judge, if it concludes:
    but for four parking charge notices to have never been seen by the driver, suggests something different.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top of this/any page where it says:
    Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Elmo111
    Elmo111 Posts: 76 Forumite
    edited 31 May 2018 at 9:47PM
    Coupon-mad wrote: »
    I think you could remove 6.2 and 6.3 in the defence. Point #6 is punchier and more thought provoking for a switched-on Judge, if it concludes:

    Cool - I've remove those, edited 3 as per your direction and the fifth draft is below!

    **********
    IN THE COUNTY COURT
    Claim No.: XXXXXXXX

    Between

    UK PARKING PATROL OFFICE LTD
    (Claimant)

    -and-


    XXXXX
    (Defendant)

    ___________________________________________________________________________

    DEFENCE
    ___________________________________________________________________________

    Preliminary

    1. The Defendant denies receiving correspondence from the Claimant regarding any of the alleged parking contraventions. In pre-action communication, UKPPO Ltd states that 24 letters were sent to the Defendant's address acquired from the DVLA for strictly limited purpose of !!!8216;enquiring who was driving!!!8217;.

    2. It is with distress that I note that the Claimants amount of letters sent, is approximately twice as many demands than the unwarranted demands which bombarded the consumer victim in the case of Ferguson v British Gas Trading Ltd [2009] EWCA Civ 46, where the company's course of conduct amounted to unlawful harassment contrary to the Protection from Harassment Act 1997 and they were liable to pay the defendant over £10,000 in compensation.

    Background

    3. It is neither admitted nor denied that on the material dates, the Defendant's vehicle was parked at the location. However, the car is insured for more than one driver and it is impossible to be sure now in 2018, whether the car was there on four unremarkable dates almost a year ago, or indeed, who parked it at the purported times.

    3.1. The Defendant has seen the Claimant's photographs but suggests the court should treat those images with scepticism, given the following facts which are expanded upon later in my defence:
    (a) they purport to show the vehicle with windscreen PCNs attached that never materialised in reality, and
    (b) parking firms (including IPC members) have in recent years been caught issuing PCNs, taking a photo, then removing them, and
    (c) parking firms who are supposedly 'legitimate' AOS members have been caught and investigated for altering times and/or dates on their handheld cameras, showing how easy it is to falsify such photo evidence, and
    (d) this Claimant is known to use 'self-ticketing' where the person with the camera has an incentive to issue predatory PCNs for personal monetary gain (a 'bounty' per paid PCN) and is not an employee. Such a person is unlikely to have training and knowledge of the Trade Body Code of Practice or any applicable law, including but not limited to: the Data Protection Act, the Consumer Rights Act 2015, the Equality Act 2010, the Protection of Freedoms Act 2012 (Schedule 4) and the Consumer Protection from Unfair Trading Regulations 2008, and
    (e) The Defendant avers there was a lack of due diligence and there were insufficient checks and balances by the Claimant at this location, and that any PCNs were not properly issued. The Trade Body (IPC) Code of Practice from 2017 states:
    ''4.2 Self-ticketing practices are considered the same as sub-contractors, so if you enforce parking charges issued by a self-ticketing site, you are responsible for ensuring they keep to the Code in its entirety.
    17. Incentive Schemes
    17.1 You may use incentive schemes to motivate your staff and improve productivity. However, you may not use an incentive scheme which focuses solely on the volume of parking charges issued without introducing sufficient checks and balances so as to ensure that operatives do not issue Parking Charges where they should not.
    17.2 To avoid simply encouraging the issue of a high volume of parking charges notices, operators should employ schemes which encourage a high standard of work.
    17.3 Where incentive schemes are employed, Operators should keep in mind that it if they that are ultimately responsible for improperly issued Parking Charges and that there may be ramifications should members of their staff (or self-ticketers) issue parking charges fraudulently''.


    4. It is admitted that at all material times the Defendant is the registered keeper of the vehicle which is the subject of these proceedings.

    5. The Defendant has sufficient evidence which shows the continued disdain and negligent attitude of the landlord, UrbanBubble, who merely appointed the Claimant to act on behalf of the landowner.
    5.1. The Claimant has failed to supply a copy of the contract demonstrating their ability to issue charges on this land.
    5.2. The Claimant is put to proof that it has sufficient interest in the land or that there are specific terms in its contract to bring an action on its own behalf. As a third party
    agent, the Claimant may not pursue any charge.
    5.3. The Defendant put the Claimant to strict proof for full disclosure of the contract with UrbanBubble, and what steps were taken in advance of enforcement to take account of the primacy of contract of existing residents and to avoid unconscionable ticketing of genuine residents/their visitors, rather than a genuine aim to deter trespassers.

    6. No driver of the vehicle reported finding a windscreen PCN. After correspondence from the landowner regarding CCTV footage, this is unavailable due to only 4 weeks footage being on file at any one time.
    6.1. The Defendant researched online about a phenomenon known as !!!8216;ghost ticketing!!!8217;, in which a private car park attendant would remove an affixed PCN before the driver has returned to the vehicle. One missing PCN could be seen as a prank, but for four parking charge notices to have never been seen by the driver, suggests something different.

    7. The Claimant failed to issue a Notice to Keeper (NTK) for the alleged infringement. This is not in accordance with the requirements of The Protection of Freedom Act 2012 (POFA). Under schedule 4, paragraph 4 of the POFA, an operator can only establish the right to recover any unpaid parking charges from the keeper of a vehicle if certain conditions are met as stated in paragraphs 5, 6, 11 & 12. UK Parking Patrol have failed to fulfil the conditions which state that the keeper must be served with a compliant NTK in accordance with paragraph 9, which stipulates a mandatory timeline and wording:-
    The notice must be given by; (a) handing it to the keeper, or leaving it at a current address for service for the keeper, within the relevant period; or (b) Sending it by post to a current address for service for the keeper so that it is delivered to that address within the relevant period.

    7.1. Paragraph 5.2 of the October 2017 pre-action protocol, which UK Parking Patrol Office Ltd, states that in our pre-action communications:-
    If the debtor requests a document or information, the creditor must:- (a) provide the document or information; or (b) explain why the document or information is unavailable, within 30 days of receipt of the request.

    7.2. UK Parking Patrol Office Ltd could not supply the defendant with a copy of a compliant NTK and (b) did not explain why the requested NTK is unavailable. Instead, UK Parking Patrol Ltd decided to continually evade providing the defendant with a copy of the required documents, vital to their case.

    8. The claimant failed to include a copy of their written contract with any correspondence as per Practice Direction 16 7.3(1) and Practice Direction 7C 1.4(3A). No indication is given as to the Claimants contractual authority to operate there as required by the Claimants Trade Association's Code of Practice B1.1 which says;
    If you operate parking management activities on land which is not owned by you, you must supply us with written authority from the land owner sufficient to establish you as the !!!8216;Creditor!!!8217;; within the meaning of the Protection of Freedoms Act 2012 (where applicable) and in any event to establish you as a person who is able to recover parking charges. There is no prescribed form for such agreement and it need not necessarily be as part of a contract but it must include the express ability for an operator to recover parking charges on the landowner!!!8217;s behalf or provide sufficient right to occupy the land in question so that charges can be recovered by the operator directly. This applies whether or not you intend to use the keeper liability provisions;

    8.1. The claimant provided an example !!!8216;contractual notice!!!8217;, that was not a picture directly from the event of each parking offence, but instead an out-of-date PDF, titled !!!8216;Parking Patrol july2013!!!8217;, which states at the bottom of the document, !!!8220;Non-payment will result in additional charges which will be added to the value of the charge and for which the driver will be liable on an indemnity basis.!!!8221;

    9. The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed the particulars of claim are not clear and concise as is required by CPR 16.4 1(a).

    10. The claimant has not provided enough details in the particulars of claim to file a full defence; no dates, the reason for each PCN or whether the vehicle was parked on the roadway or car park.
    10.1. The Claimant has stated that 4 !!!8216;parking charges!!!8217; were incurred.
    10.2. The Claimant has given no indication of the nature of the alleged charge in the Particulars of Claim. The Claimant has therefore disclosed no cause of action.
    10.3. The Particulars of Claim contains no details and fails to establish a cause of action which would enable the Defendant to prepare a specific defence. It simply states !!!8216;parking charges!!!8217;; which does not give any indication of on what basis the claim is brought.
    10.4. It was only during pre-action communication that information regarding why the charge arose, what the initial charge was, what the alleged contract was and anything which could be considered a fair exchange of information. The Particulars of Claim are incompetent in disclosing no cause of action.
    10.5. The Particulars of Claim are deficient in establishing whether the claim is brought in trespass. If the driver on the date of the event was considered to be a trespasser if not allowed to park there, then only the landowner can pursue a case under the tort of trespass not this Claimant, and as the Supreme Court in the Beavis vs ParkingEye (2015) [2015] UKSC 67 case confirmed, such a matter would be limited to the landowner themselves claiming for a nominal sum.

    11. The Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver. The Defendant avers that the Claimant is therefore limited to pursuing the keeper in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 ("POFA")

    11.1. Before seeking to rely on the keeper liability provisions of Schedule 4 POFA the Claimant must demonstrate that:
    11.1.1. There was a !!!8216;relevant obligation!!!8217;; either by way of a breach of contract, trespass or other tort; and
    11.1.2. That it has followed the required deadlines and wording as described in the Act to transfer liability from the driver to the registered keeper. It is not admitted that the Claimant has complied with the relevant statutory requirements.
    11.2. To the extent that the Claimant may seek to allege that any such presumption exist, the Defendant expressly denies that there is any presumption in law (whether in statute or otherwise) that the keeper is the driver.

    12. For the Claimant to utilise The Interpretations Act of 1978, proof of postings must be given to the Defendant. UKPPO were unable to supply proof of postings for the NTK(s), nor even true copies showing the address utilised for the NTK. In pre-action communications, proof of a !!!8216;reminder notice!!!8217; was seen, but as such, this is not a compliant NTK variant.
    12.1. The !!!8216;reminder notice!!!8217; received was a !!!8216;digital!!!8217; document, not a scanned copy of the document supposedly duly sent, leading to a possibility of the contents of the document being altered in an attempt to thwart the chance of the Defendant holding a strong case, before being supplied as evidence.

    13. It is denied that the Claimant has any entitlement to the sums sought and it is denied that interest is applicable on the total sums claimed by the Claimant, which bear no relation to the maximum sum potentially able to be recovered from a registered keeper, as set out in the POFA, namely the sum stated in the Notice to Keeper.

    14. The Court is invited to dismiss the Claim, and to allow such Defendant!!!8217;s costs as are permissible under Civil Procedure Rule 27.14.

    I believe the facts stated in this Defence Statement are true.


    (Defendant) (Date)


    **********

    Thanks for everything and thanks to everybody that's helped me this far - any further additions before I sign, seal and deliver? I'm wondering if I should sent first class tomorrow so I can make sure it's filed by 4pm on Monday like @KiethP said?
  • Coupon-mad
    Coupon-mad Posts: 130,606
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    I would remove #14, #15 and #16 which add nothing not already stated before, and are a bit mixed in terms of going back over a point made much higher up.
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top of this/any page where it says:
    Forum Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Elmo111
    Elmo111 Posts: 76 Forumite
    Coupon-mad wrote: »
    I would remove #14, #15 and #16 which add nothing not already stated before, and are a bit mixed in terms of going back over a point made much higher up.

    Edited 14, 15 and 16 out of the fifth draft. I did think that I was reiterating points not so eloquently, in those sections, so thank you for confirming.

    Do you think I should post first class tomorrow morning if all is well?
  • KeithP
    KeithP Posts: 37,427
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    Elmo111 wrote: »
    Do you think I should post first class tomorrow morning if all is well?
    Are you not going to email it, like everyone else does?
  • Elmo111
    Elmo111 Posts: 76 Forumite
    KeithP wrote: »
    Are you not going to email it, like everyone else does?

    Yes of course! To my understanding the rule of thumb here is to post to Northampton CC and email. :)
  • KeithP
    KeithP Posts: 37,427
    Name Dropper First Post First Anniversary
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    No need to post it as well.

    Email it as described here:

    Once you are satisfied with the content -
    1) print your Defence
    2) sign it
    3) scan the signed document back in and save as a pdf.
    4) send that pdf as an email attachment to CCBCAQ@Justice.gov.uk
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