PCM & Gladstones want a revenge

Hi All

I received a new email from Gladstones for a new case which they sent a LBC in July and I replied to it as usual asking for more Information and with who they contracted and request a copy of their contract.
Below is there email and what I'm going to reply in red, could you please review and advise.

Good Afternoon mr. xxxx,

As per your request, no further action was taken between the dates specified (Thanks very much), however we apologise for our delay in responding (Your apologise is not acceptable as you put me under stress all of that period, costs will be claimed against your client).

Your references to cancelling of contract etc are unsubstantiated (I disagree),
please provide these letters / anything you deem relevant to your claim so that they may be reviewed ( check your company emails, correspondences to you & your client PCM it was sent several times and check PCNs photos it was in the cars wind screen).
In any event, such a contract and agreed sums are rejected (It’s too late now to reject as PCM already accepted that payment by their action long time ago. PCM accepted to pay me £500 for any PCN issued to any property related to me & that contract will be renew every time PCM do).

CPR 31.14 applies to those cases where litigation has began, as no claim has been issued on this case we trust you agree no prejudice has been suffered as a result. (Disagree as I suffered from stress and time waste occurred)

You may be aware of that your previous attempt to have the Judgment obtained against you set aside was dismissed, although in that instance you were being represented by a Solicitor. If you would like us to correspond with your legal advisor going forward please confirm this by return and we will contact them directly regarding this matter. (you should contact my Solicitor when he asked for information and cc to myself)

In previous cases your parking charges were appealed where you admitted to being the driver (disagree with the whole sentence, I never admitted I was the driver), although if this is not the case here then it is rejected our Client does not use POFA Schedule 4's guidelines when pursuing a keeper of the vehicle (disagree as your client PCM mentioned POFA 2012 Schedule 4 in his correspondences & you can’t go back now) .

We deny that the letter you have sent constitutes a draft claim form as you suggest. This is a letter before claim which is compliant with the pre-action protocol at the time of sending. Again we wish to remind you that no proceedings have been issued on this claim and therefore the pre-action protocol has not been breached - this correspondence is sent to clarify our Client's position and we invite you to expand upon our comments (disagree as you didn’t send any evidences requested by my previous letters).

If you would like to view images of the charge, these can be found at https://www.paymypcn-uk.co.uk. Your PCN Number (xxxx) and Vehicle Registration (xxxx) will be required to view the images. (that images doesn’t show your client contract with the landowner please sent prove that your client have a contract to provide a private park scheme in the land in question).

In terms of the pre-action protocol;

ADR options have been explored via our Client's appeal procedure, with a further appeal procedure being afforded should you wish to explore it. However, if you would like to enter negotiation we invite you to make an offer for our Client's consideration. (I deny any debt to your client PCM )

If a conclusion to this case cannot be drawn via this correspondence, our Client may elect to issue legal proceedings to facilitate the recovery of this debt.

We confirm however that any counterclaim will be robustly defended should it be necessary to do so - however you have not explained your case and why you do not believe yourself to be liable for this charge. You & your client have not explained their authority to run a private parking scheme, nor provide the contract with the landowner as requested and also didn’t named with who PCM have a contract to run such scheme in the land in question. I already explained my case and reasons why I do believe I’m not liable in all my correspondences to you & your client PCM, so no more explanation or data will be present to you, especially after your previous unreasonable behave in court case xxxx, up to you send all the requested documents including contract / chain of contract with the landowner authorise your client PCM to provide a private park scheme in xxxx.

We are aware of costs being awarded, but we finally must stress this matter has not reached a claim stage and invite your comments on the above (as per my comments above please apologise for your unreasonable behave and discontinue that case at this stage immediately).

In the event this is not received within 14 days from the date of this email, as mentioned above, legal proceedings may be issued to facilitate the recovery of this debt.

We look forward to hearing from you.

Kind Regards,