CST Law/JD Parking letter before claim advice please

Dear Sir or Madam

I have received two Letters Before Claim from yourselves regarding vehicle XXX and parking charge notices from the claimant JD Parking Consultants Ltd. I have sent the claimant a subject access request and therefore require a restriction of data processing and for you to put both cases on hold.

I’m aware of the following parking charge notices:
[PCN details]

Please detail all parking charge notices which the claimant alleges are outstanding against me as registered keeper.

Please advise if you believe you have complied with the Protection Of Freedoms Act 2012 Schedule 4 for ‘keeper liability’. If you believe you have, then all claims must be consolidated into a single claim for all parking charge notices - to date, you have sent me two claims.

Please advise if the claimant is relying upon Protection Of Freedoms Act 2012 Schedule 4 for ‘keeper liability’ for all parking charge notices?

Please explain the additional £15 charge applied to each parking charge notice given that the costs of the operation and debt collection must already be covered by the parking charge itself as per the Parking Eye vs Beavis case in the Supreme Court.

Please provide photographs of any relevant signage on the date of issue for each parking charge notice and highlight where the £160 charge is mentioned and the additional £15 charge claimed for each parking charge notice required due to the Consumer Rights Act 2015 with my objective being to narrow the issues in the claim prior to court.

Yours faithfully
XXX