Received a aLetter before court, please could you help with my response

A few months ago the driver parked at a private car park twice in a row and it was the drivers fault a bit as to why they didn't pay it.
They were in a rush for a job interview and ran to the ticket machine but it wasn't accepting card payment, even-though the card worked everywhere else that day, so the driver left it and ran to the interview, there was a second interview the next day and exactly the same thing happened. Could of payed by phone, however, was in too much in a rush to do so. The company parked at is National Car Parks (NPC). NPC sent a bunch of letters, which were ignored, I think, and they now have passed the debt onto BW Legal, who are threatening to take the keeper to county court for around £500 for both tickets. I think the form is saying only £320 has to be payed if it's before this gets taken to court. Do you think the keeper should just pay up front now or do you think they are charging an unreasonable amount? Do you think the keeper will pay less if taken to court. The keeper is also currently under a debt management plan. I have attached the letter they sent (they sent 2 of these).

Any help would be really appreciated, thanks.

FYI- I don't have any proof of trying to pay or that the card machine part wasn't working.

Dear Sirs,

Thank you for your letter of claim. This is regarding accounts

You have now sent a Letter Before Claim. However, your letter contains insufficient detail of the claim and fails to provide any photographic evidence. It does not even say what the cause of action is. Nor does it contain any mention of what evidence your client intends to rely on, or enclose copies of such evidence.

This action on the part of your client is a clear breach of its pre-action obligations set out in the Practice Direction - Pre-Action Conduct, with which as solicitors you must surely be familiar (and with which your client, a serial litigator of small claims, must also be familiar). As you (and your client) must know, the Practice Direction binds all potential litigants, whatever the size or type of the claim. Its express purpose is to assist parties in understanding the claim and their respective positions in relation to it, to enable parties to take stock of their positions and to negotiate a settlement, or at least narrow the issues, without incurring the costs of court proceedings or using up valuable court time.

Nobody, including your client, is immune from the requirements and obligations of the Practice Direction.

I require your client to comply with its obligations by sending me the following information/documents:

1. an explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of POFA 2012
4. what the details of the claim are (where it is claimed the car was parked, for how long, how the monies being claimed arose and have been calculated, what contractual breach (if any) is being claimed)
5. a copy of the contract with the landowner under which they assert authority to bring the claim
6. a copy of any alleged contract with the driver
7. a plan showing where any signs were displayed
8. details of the signs displayed (size of sign, size of font, height at which displayed)
9. If they have added anything on to the original charge, what that represents and how it has been calculated.

I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).

If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) !!!8211; Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13 ,15(b) and (c) and 16.

Until your client has complied with its obligations and provided this information, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.

Yours faithfully,