SCS-Law Letter Before Claim, Ukpc - Court Claim

This is a draft of my reply, I am re-using parts of the previous letter and I am pointing at the fact that their clients admit the non availability of motorcycle bay and motorcycle permits:

Dear Sirs,
In response to your email dated 06/12/2019, I firmly dispute the legal basis of your claim and the charges.
The signage is insufficient to form a contract.
Your clients admit clearly that there are no specific motorcycle parking bays or motorcycle parking permits available at either sites. Your clients confirm there is no possibility to obtain and display a permit for and on a motorcycle because it does not exist. Parking a motorcycle in a car bay displaying a valid permit does not make sense and it is in fact impossible.
I have been a resident in Latham Yard since 2014 and I can provide evidence.

As stated in previous correspondence, the sum sought is manifestly excessive and unsupported by the Supreme Court decision in ParkingEye Ltd v Beavis [2015] UKSC 67, has no 'deterrent value' given the facts, and the sum of £160 per event is unrecoverable and not an understandable ingredient of a parking regime with proper legitimate interests.
Should your client proceed with their baseless claim, I will be filing a defence which deals with the meritless claim in detail. In evidence at the later stages, I will be including the two statute laws and one binding case law that defeated BW Legal's barrister in the application they lost at Southampton County Court on 11.11.19, a decision that will surely debar any future 'parking firm' claim in that circuit at least, from trying to add 'costs' that are indisputably already absorbed in the parking charge itself.
Yours faithfully,

Any advice willl be appreciated. Thank you and have a great week!

I received this reply and I wonder if I should keep replying back or wait for the county court claim.
I don't have the knowledge to understand if they are in the wrong.
I made it clear that I dispute it as I don't believe I ever was in a contract with them.

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I write in response to your email dated 12 January 2020. I have now received my client's instructions.



The signage installed at both sites referred to "parking", it did not refer to cars or motorcycles exclusively. Therefore, parking at the site was subject to the terms and conditions which were breached on 4 separate occasions. It is immaterial whether the vehicle was a car or a motorcycle. In light of the terms and conditions being applicable to all vehicles, the contract was not frustrated or voidable as a result of 'impossibility'. As mentioned previously, motorcycles were required to display the same permit as a car.



The terms and conditions formed a valid offer to park at the site, which was subsequently deemed agreed to upon parking. Consideration was given upon the parking facilities being provided to you and subsequently being used. The contract is binding and you are being pursued for breach of the same.



My client's legitimate interest lies in the management of parking at the site and ensuring that motorists comply with the terms and conditions. As per my client's contracts of authority previously provided to you, my client was authorised to enforce the sums owed under the parking charge notices. The sums being pursued are not contrary to the Protections Freedoms 2012 and or/ any ruling by the Supreme Court. The sums being claimed are pursuant to the terms and conditions displayed on the signage installed at the sites.



In light of my client's position, it is apparent that no agreement is likely to be reached between the parties. As such, I have received instructions to issue county court proceedings to recover the sums owed after 14 days from the date of this email. Please treat this email as the required notice pursuant to paragraph 8.2 of the Pre-Action Protocol for Debt Claims.

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I replied today, the last of the 14th day, using the comments about pofa2012 and the terms and condition misuse.
I also copied the links above as a reference to Ukpc reputation and told them I am ready to see them in court and defend myself.
Thank you again for the help. I will update on progress.

At the same time I am appealing to Popla for one of their ticket which is not in SCSlaw hands yet, using the forum help. Those people keep me very busy.

SCSlaw is taking me to court after a one long year.
I have just acknowledged service and I have 28 days to file defence. I also, by error, selected that I intend to contest jurisdiction. I read in another thread that once I file defence, the intention of contesting jurisdiction will drop as it requires different follow up. I wrongly assumed it was to change the court location as it is far from me.

I have a few doubts on how a defence should really look like.
Shall I write to the court and dispute the claim, with the same points that were suggested for communication with the claimants? 
Shall I also attach all of the communication and other useful files like photos of unclear signage and what I have received from the SAR request?

scs law is also stating in the court claim that I have admitted being the driver during communication, which is a lie and they can not prove it as I believe was careful to identify myself as the keeper. I also received bailiff fake letters regarding a couple of notice that scslaw confirmed they were adding to the original claim but they didn't. Shall I add those details in defence?