Gladstone LBC

So, I've had another letter from Gladstones which simply states "Please find enclosed the relevant evidence as requested" then goes on to demand payment within 14 days or legal proceedings will be issued. Their evidence enclosed consists of a few dodgy photos of the vehicle, nothing else.
My response to them is as follows:

Thank you for your letter of xxxxxx.

You state that you have enclosed “the relevant evidence as requested”, however I refer you to my letters of xxxxx and xxxxx in which I requested the following in order to narrow the issues and ascertain whether or not your client has any right to bring a claim:

1) All documents referred to in your letter of 13th July 2017 including but not limited to windscreen notices and Notices to Keeper.
2) Clear authority for your client to take legal action.
3) A relevant contract.

Once again you and your client have made no attempt to provide the requested documents, in clear breach of your clients pre-action obligations.

It seems clear to me that in blatant disregard for Practice Direction your intention is to deliberately withold sufficient information for me to understand the claim and consider my position thereby removing the possibility of resolution without court proceedings. I have afforded your client more than sufficient opportunity to avoid wasting the court's time and incur unnecessary costs, however rather than provide the requested information your client chooses to persist with threats of legal action. Should your client issue proceedings without the requested information I will bring your clients behaviour to the attention of the court and as stated in previous correspondence I will seek an immediate stay pursuant to paragraph 15 (b) of the practice direction.

In light of your persistent refusal to provide the requested information, or indeed any evidence to support your client’s claim I can only conclude that in fact there is no further evidence, your claims are unsubstantiated, and your correspondence is nothing more than a thinly veiled attempt by your client to obtain money to which they are not entitled through harassment and repeated threat of court action.

As stated in previous correspondence should your client proceed with a claim with no cause of action against me as registered keeper I will file a counter-claim for not less than £500 in compensation for distress caused by your unwarranted demands arising from misuse of the data your client obtained from the DVLA for one purpose, yet are now processing it for another purpose not covered by the KADOE regulations.

Furthermore, the continued threat of legal action is unwarranted and I intend to report your client to their governing body and you to the Solicitors Regulation Authority.

Either provide the requested information within 14 days or confirm that the Letter Before Claim is withdrawn. Should you fail to withdraw the LBC and/or pursue a baseless claim, as stated in my letter of xxxxx I intend to sue your client for the significant distress caused by their actions.

All letters exchanged will be used in evidence in court.

---

If anyone has any input feel free to comment.

Thanks CM. Its obvious to me now what their game is, and I'm not playing...😀

Quick update. I didn't bother applying for a stay, just filed a robust defence statement based on what I've picked up from the newbie thread.(https://www.dropbox.com/s/dh31dm534d62eps/DEFENCE%20Statement.docx?dl=0).
I was fighting two of these at the same time, and the court ordered that the two cases be heard together. The following day I had another letter from the court, both cases struck out "as disclosing no cause of action".
Antrim Mark 5, Gemini/Gladstones 0

I presume it's because many more people get bullied into paying up by these charlatans than fight them, unfortunately.
I know of several users of the same car park who paid the charge, despite being pointed in the direction of forums like this. My wife would have been one of them if I'd let her.