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  • FIRST POST
    • Searc
    • By Searc 13th Mar 18, 1:47 AM
    • 9Posts
    • 1Thanks
    Searc
    Parking & Property (IPC) -> Gladstones -> Court
    • #1
    • 13th Mar 18, 1:47 AM
    Parking & Property (IPC) -> Gladstones -> Court 13th Mar 18 at 1:47 AM
    I have read the newbies thread but it is my 1st PCN in UK so still learning legal staff and language.
    So any help would be appreciated!

    + 07.06.17 I found windscreen PCN from Parking & Property management, member of IPC. Reason is - Parking in no parking area. Parking charge 100.00
    It is issued on private road, it is even dosn't exist on Google map. The road is U-shape, 2 lines.

    + 12.07.17 Received NTK

    + 02.08.17 Posted complaint (appeal).
    I used IPC template from newbies thread and also added extra key points -

    ....
    Based on my research I believe what your Parking Charge Notice breaks IPC code of practice V6 of April 2017 Part E Schadule 1.
    The following information on the site is missing and likely the reason of breach of the IPC code of practice:

    a. No entrance sign from XXXX rd. about entering into private land.
    b. No sign around used car park space, which display the full terms and conditions.
    ....

    Admin - Please insert my photo!
    https://
    image.ibb.co/hjOmxn/new_board.jpg

    I think it supports my complaint regarding breach of the IPC code of practice.
    I errased parked cars where it was issued with PCN.
    Please note red arrow about 25 m behind the car - It is 1st signage location on the road. I considered it as a starting point where parking conditions apply.
    Please note another signage circuled in red - it is on oposite side of 1st signage and considered as the sign for residents car park.

    Also there is no photo in their evidences where my car and the sign is on the same photo. So basically my car could have been anywhere in the world, there is no link with their sign.

    + 8.08.17 Received appeal rejection letter as part of copied below.

    ... you vehicle was observed at the time the PCN was issued parked in no parking area. The photographic evidence supports the issue of the parking charge. Please reffer to photographic evidence ....
    which clearly shows vehicle in a no parking area.

    The signage on the site is clearly visible and information on signage informs the driver of the parking conditions at the location. Signage is prominent throughout the parking area.
    Signage location, size, content and font has been audited by IPC.

    It is the driver's responsibility, to check for signage, check the legality and obtain authorisation for parking before leaving their vehicle.

    It is not within out gift to provide details of our contract with the client without their express permission to do so.

    The charge is based on contract


    Also Parking & Property management offered to pay reduced rate 60.00 in 14 days timeframe

    I ignored it.

    + 10.11.17 Received Gladstones LBC
    ref. 1XXXXXXXX.
    amount due 160.00

    We are on behalf of the Claimant and we have been instructed to commence legal action against you to recover the amount due above, as you failed to settle the debts that are owing, or privide a valid reason for non-payment
    We understand that our client written to you to request payments but amount is still outstanding.

    The charge amount includes 60.00 claimed by our client for its time spent and resource facilitating the recovery of the charge.
    The amount is a pre-determinated and nominal contribution to our Client's losses as a direct result of your non-payment


    ....

    If you believe you vahe valid reason for non-payment, you are able to reply pursuant to Paragraph 4 of Pre-Action Protocol for Debt Claims under Civil Procedure rules 1998.
    Aversion of the Information sheet and reply form taken from PAP can be completed on our website. Alternatively you can request a paper version.

    we reffer you to Paragraf 2.1(c) of the PAP which obliges the parties to act reasonably and proportionatey.

    Please pay or reply within 30 days.

    .....


    + 07.12.17 Replied to Gladstones

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

    1. Whether they are pursuing me as driver or keeper. This question was already asked in my letter of 02.08.2017 and ignored by Parking and Property Management Ltd

    2. Photo evidences where my car parked and the sign is on the same photo.

    3. Provide me a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the IPC code of practice V6 part B, clause 1.1 “establishing yourself as the creditor”

    4. A site plan showing where any signs were displayed including location of entrance sign from XXXXX rd. about entering into private land to comply with IPC code of practice V6 of April 2017 Part E Schadule 1.

    5. Details of the signs displayed (size of sign, size of font, height at which displayed)

    6. Up-to-date statement of account for the debt

    7. Provide a printed copy of the Information Sheet and the Reply Form


    +22.01.18 Received reply from Gladstones (my comments are in brackets)

    1. You are pursuted as the driver of the vehilcle, you have failed to prove otherwise and as such it is safe to assume you were the driver of the vehicle on the date of the incendent

    2. Please find enclosed
    (Requested evidences where my car parked and the sign is on the same photo. They enclosed the same photos as before. No photo where my car parked and the sign is on the same photo)

    3. At this stage we are not obligated to provide a copy of the contract, our Client has the ability under this contract to issue charges at the site. In any event, your contract is with our Client direct and this is the primary contract.

    4. At this stage we are not obligated to provide a copy of the site plan, please see the enclosed photographs, sign can be seen in the vicinity
    (????) of your vehicle.

    5. This is irrelevant to the charge itself.
    (requested details of the signs displayed)

    6. This is irrelevant to the charge, the full amount can be seen above and consist of the original 100.00 charge and 60.00 incurred by our Client for having to 'chase' the debt and otherwise employ staff to do other than their smployment states.
    .
    7. Enclosed Information Sheet and the Reply Form


    + 20.02.18 Replied to Gladstones

    1. Please provide full details of a source what named me as a “driver of the vehicle” and how did your get personal data of the “driver”. This is request is issued in accordance with The Data Protection Act

    2. You are not provided a photo where the car parked and the sign is on the same picture. Your photo of a sign has no location coordinates and may be taken anywhere in this world.

    3. As a solicitor your are refused to provide me with the necessary information I requested in order to defend myself against the alleged debt as it advices in Paragraph 2.1 (A) of PAP. Also the manner of the reply can’t be considered as reasonable and proportionate in all dealings as it advices in Paragraph 2.1 (C) of PAP

    4. Site plan is requested because it is unclear where the photo of the sign is taken. As a solicitor your are refused to provide me with the necessary information I requested in order to defend myself against the alleged debt as it advices in Paragraph 2.1 (A) of PAP. Also the manner of the reply can’t be considered as reasonable and proportionate in all dealings as it advices in Paragraph 2.1 (C) of PAP

    5. Details of the signs displayed on site (size of sign, size of font, height at which displayed) are relevant information for drivers and to defend myself against the alleged debt.

    6. This is not a statement of account for the debt.

    7. Please provide details of Alternative Dispute Resolution (ADR) procedure in accordance to Paragraph 6 of PAP

    + 08.03.18 Received Court Claim Form

    Particulars of claim:
    The driver of the vehicle ... incurred the parking charge on 07.06.17 for breaching the terms of parking on the land at .........
    The defendant was driving the vehicle and/or is the Keeper of the vehicle and the claimant claims 160.00 for Parking charges / Damages and indeminity costs if applicable, together with interest of 8.18 pursuant to s69 of the County Court Act 1984 at 8% pa continuing to Judgment at 0.04 per day.

    Amount claimed 168.18
    Court fee 25.00
    Legal representative's cost 50.00
    Total amount 243.18

    Looking for defence advice in my particular situation.
    Have many questions and I will ask in following post.

    But first of all. What do you think, can I defence myself successful?
Page 1
    • waamo
    • By waamo 13th Mar 18, 1:52 AM
    • 3,185 Posts
    • 4,212 Thanks
    waamo
    • #2
    • 13th Mar 18, 1:52 AM
    • #2
    • 13th Mar 18, 1:52 AM
    FWIW I think you have a strong case. They have not established keeper Liability under POFA and it sounds as though the signage is nowhere near up to scratch.

    A decent defence should see this off.
    This space for hire.
    • The Deep
    • By The Deep 13th Mar 18, 8:05 AM
    • 9,203 Posts
    • 8,968 Thanks
    The Deep
    • #3
    • 13th Mar 18, 8:05 AM
    • #3
    • 13th Mar 18, 8:05 AM
    This is an entirely unregulated industry which is scamming the public with inflated claims for minor breaches of contracts for alleged parking offences.

    Parking Eye, CPM, Smart, and a smaller company have already been named and shamed, as has Gladstones Solicitors, and BW Legal, (these two law firms take hundreds of these cases to court each year). They nearly always lose) and have been reported to the regulatory authority by an M.P.

    The problem has become so rampant that MPs have agreed to enact a Bill to regulate these scammers. Watch the video of the Second Reading in the HofC recently.

    http://parliamentlive.tv/event/index/2f0384f2-eba5-4fff-ab07-cf24b6a22918?in=12:49:41

    and complain in the most robust terms to your MP. With a fair wind most of these companies may well be put out of business by Christmas.
    Last edited by The Deep; 13-03-2018 at 8:07 AM.
    You never know how far you can go until you go too far.
    • Le_Kirk
    • By Le_Kirk 13th Mar 18, 10:11 AM
    • 2,667 Posts
    • 1,527 Thanks
    Le_Kirk
    • #4
    • 13th Mar 18, 10:11 AM
    • #4
    • 13th Mar 18, 10:11 AM
    Here is your picture
    https://image.ibb.co/hjOmxn/new_board.jpg
    • nosferatu1001
    • By nosferatu1001 13th Mar 18, 12:50 PM
    • 2,464 Posts
    • 3,005 Thanks
    nosferatu1001
    • #5
    • 13th Mar 18, 12:50 PM
    • #5
    • 13th Mar 18, 12:50 PM
    Get that claim acknowledged NOW

    Yes, you can defend yourself. They are pursuing you as the driver, and not relying on POFA2012. As such if you CAN deny you were the driver, you do so in your defence. If you cannot you state you put them to strict proof that you are the driver, who could have been one of many individuals.
    • Searc
    • By Searc 14th Mar 18, 12:19 AM
    • 9 Posts
    • 1 Thanks
    Searc
    • #6
    • 14th Mar 18, 12:19 AM
    • #6
    • 14th Mar 18, 12:19 AM
    ...They have not established keeper Liability under POFA ....
    Originally posted by waamo
    Can you please explain what they missed?

    In the particulars of Claim they are saying "The defendant was driving the vehicle and/or is the Keeper of the vehicle"
    Looks like the court is happy to start judgment on this base.

    The response pack I received is from the court located 100s miles away.
    How to transfer hearing to my local court?

    I'm going to make the claim acknowledged now and use 28 days to write defence.
    • KeithP
    • By KeithP 14th Mar 18, 12:51 AM
    • 7,167 Posts
    • 6,647 Thanks
    KeithP
    • #7
    • 14th Mar 18, 12:51 AM
    • #7
    • 14th Mar 18, 12:51 AM
    Can you please explain what they missed?

    In the particulars of Claim they are saying "The defendant was driving the vehicle and/or is the Keeper of the vehicle"
    Looks like the court is happy to start judgment on this base.

    The response pack I received is from the court located 100s miles away.
    How to transfer hearing to my local court?

    I'm going to make the claim acknowledged now and use 28 days to write defence.
    Originally posted by Searc
    Your question about POFA and keeper liability is answered in post #1 of the NEWBIES FAQ sticky thread.

    Not sure what "the court is happy to start judgment on this base" means, but the court will listen to any claim from a claimant.

    The claim is sent from the County Court Business Centre in Northampton. Later in the process, if there is a case to be heard, the case will be transferred to your local court. See post #2 of the NEWBIES FAQ sticky thread for further details.

    Yes, having acknowledged service, you are right to be starting on your defence. Again, see post #2 of the NEWBIES FAQ sticky thread for how you might go about that.
    Last edited by KeithP; 14-03-2018 at 1:12 AM.
    .
    • Searc
    • By Searc 5th Apr 18, 12:09 AM
    • 9 Posts
    • 1 Thanks
    Searc
    • #8
    • 5th Apr 18, 12:09 AM
    • #8
    • 5th Apr 18, 12:09 AM
    Hello

    Going to submit my defence this week

    Also have a few question

    1. Counterclaim - there was another car parked next to my car at the same time and sticked with PCN.
    Its numberplate is visible on photo evidences provided by Parking & Property management.
    As a counterclaim - Can I invite the court to cancel another car PCN?

    2. Received NTK and letters are refer to Independent Parking Committee's Code of Practice.
    Meanwhile it was renamed to The International Parking Community in 2016 so it is The International Parking Community code of Practice now.
    Can I use this confusing issue in my defence somehow?

    Thanks again for advice
    • KeithP
    • By KeithP 5th Apr 18, 1:09 AM
    • 7,167 Posts
    • 6,647 Thanks
    KeithP
    • #9
    • 5th Apr 18, 1:09 AM
    • #9
    • 5th Apr 18, 1:09 AM
    1. No.

    2. You can mention it if you like, but it won't win anything.

    As Waamo has said, you already have two winning points.


    How is your Defence coming along?
    You received the Claim form on 8 March.
    What is the Date of Issue on the Claim Form?

    You must be very very close to your deadline for filing a Defence.
    Don't miss it.
    Last edited by KeithP; 05-04-2018 at 1:12 AM.
    .
    • Coupon-mad
    • By Coupon-mad 5th Apr 18, 1:32 AM
    • 57,393 Posts
    • 71,004 Thanks
    Coupon-mad
    What is the date on the Claim form, you only have a day or two to defend this now I think?

    So I have written a defence for you, as English is not your first language. Hope it makes sense to you; see below.


    You will need to read Pace v Lengyel and PCM v Bull, both here:

    http://www.parking-prankster.com/case-law.html

    http://www.parking-prankster.com/more-case-law.html

    and they will be included with your Witness Statement later, before the hearing date. Along with your photos showing the sparse signs, which do NOT go to the court yet.

    Only your defence goes now, by email to the CCBCAQ email address.


    As a counterclaim - Can I invite the court to cancel another car PCN?
    No, and I would NOT try a counter claim.

    Received NTK and letters are refer to Independent Parking Committee's Code of Practice.
    Meanwhile it was renamed to The International Parking Community in 2016 so it is The International Parking Community code of Practice now.
    Can I use this confusing issue in my defence somehow?
    No.


    a. No entrance sign from XXXX rd. about entering into private land.
    b. No sign around used car park space, which display the full terms and conditions.
    Your main defence will be the lack of signs; it looks like an unmarked public road.



    In the County Court Business Centre
    Claim Number: ___

    Between:

    Parking & Property Management Ltd (Claimant)

    v

    ___(defendant's name) (Defendant)

    DEFENCE


    Preliminary

    1. The Particulars of Claim lack specificity and are embarrassing. The Defendant is prejudiced and is unable to prepare a full and complete Defence. The Defendant reserves the right to seek from the Court permission to serve an Amended Defence should the Claimant add to or expand his Particulars at a later stage of these proceedings and/or to limit the Claimant only to the unevidenced allegations in the Particulars.

    2. The Particulars of Claim fail to refer to the material terms of any contract and neither comply with the CPR 16 in respect of statements of case, nor the relevant practice direction in respect of claims formed by contract or conduct. The Defendant further notes the Claimant's failure to fully engage in pre-action correspondence in accordance with the pre-action protocol and with the express aim of avoiding contested litigation. The Claimant failed to respond to the Defendant's letter dated 20th February, asking for more evidence, and merely proceeded to issue a claim.

    Background

    3) It is admitted that at all material times the Defendant is the registered keeper of the vehicle which is the subject of these proceedings.

    4) It is admitted that on the material date, the Defendant's vehicle was parked at the location stated.

    5) The Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver.

    5.1. The Defendant avers that the Claimant is therefore limited to pursuing the Defendant in these proceedings under the provisions set out by statute in the Protection of Freedoms Act 2012 (the 'POFA').

    5.2. Before seeking to rely on the keeper liability provisions of Schedule 4 of the POFA, a private parking operator must demonstrate that:

    5.2.1. there was a 'relevant obligation' and/or 'relevant contract' formed with the driver, and

    5.2.2. there was 'adequate notice' of the terms and the parking charge itself, on prominent signs in large lettering displayed clearly at the place where the car was parked, and at the entrance, and

    5.2.3. that it has followed the required deadlines and wording as described in the Act to transfer liability from the driver to the registered keeper. It is not admitted that the Claimant has complied with the relevant statutory requirements.

    5.3. To the extent that the Claimant may seek to allege that any such presumption exists, the Defendant expressly denies that there is any presumption in law (whether in statute or otherwise) that the keeper is the driver. Further, the Defendant denies that the vehicle keeper is obliged to name the driver to a private parking firm. Had this been the intention of parliament, they would have made such requirements part of POFA, which makes no such provision. In the alternative, an amendment could have been made to s.172 of the Road Traffic Act 1988. The 1988 Act continues to oblige the identification of drivers only in strictly limited circumstances, where a criminal offence has been committed. Those provisions do not apply to this matter.

    6) It is denied that any "parking charges, damages or indemnity costs" (whatever they might be) as stated on the Particulars of Claim are owed. The alleged debt is denied in its entirety.

    7) It is denied that the Claimant has standing to bring any claim in the absence of a contract that expressly permits the Claimant to do so, in addition to merely putting up parking signs and issuing letters on behalf of the true landowner. The Claimant is put to strict proof.

    7.1. It is not admitted that the Claimant has contractual or other lawful authority to make contracts, specifically by offering parking to non-permit holders at this location, and/or to bring proceedings against the Defendant. The Claimant is put to strict proof.


    Failure to set out clearly, or offer parking terms to non-permit holders

    8) The Defendant relies upon ParkingEye Ltd v Barry Beavis (2015) UKSC 67 insofar as the Court were willing to consider the imposition of a penalty in the context of a site of commercial value and where the signage regarding the penalties imposed for any breach of parking terms were clear - both upon entry to the site and throughout.

    9) The Defendant avers that the parking signage in this matter was inadequate and no consideration flowed between the driver and the Claimant.

    9.1.1. At the time of the material events the signage was deficient in number, distribution, wording and lighting to reasonably convey a contractual obligation;

    9.1.2. The signage did not comply with the requirements of the Code of Practice of the International Parking Community's ("IPC") Accredited Operators Scheme, an organisation to which the Claimant was a signatory; and

    9.1.3. The signage contained particularly onerous terms not sufficiently drawn to the attention of the driver, as set out in the leading judgment of Denning MR in J Spurling v Bradshaw [1956] EWCA Civ 3

    9.2. In this case neither the Claimant, nor their principal, the landowner, is offering anything to motorists who do not have a permit. The Defendant avers that the sign - in fact, not seen by the driver due to hidden placement and lack of lines - creates a prohibition against parking on the roadway without a permit. The notices cannot, therefore, reasonably be construed as having created a contractual relationship between the Claimant and the Driver.

    9.2.1. The above point was tested in the County Court at High Wycombe, in the case of Parking Control Management (UK) Ltd v Bull & 2 Others (B4GF26K6, 21 April 2016), where District Judge Glen dismissed all three claims, stating in his judgment that: ''All this is essentially saying is you must not trespass on the roadway. If you do we are giving ourselves, and we are dressing it up in the form of a contract, the right to charge you a sum of money which really would be damages for trespass, assuming of course that the claimant had any interest in the land in order to proceed in trespass.''

    9.3. Even if the Court finds that a non-permit holder should have seen a sign and was a trespasser, this is a matter of tort whereby (as confirmed in the Beavis case and also by the 2012 Guidance Notes relating to Section 56/Schedule 4 of the POFA) only the landowner themselves would be potentially able to pursue damages. In Beavis, this was because ParkingEye Ltd were not in possession and thus unable to pursue damages, one of the same difficulties this Claimant faces, yet they lack the 'legitimate interest/commercial justification'reasoning that disengaged the penalty rule for ParkingEye, given the unusual and case-specific facts in the Beavis case.

    10) This operation at this location is predatory, with hidden/small signage designed not to be seen, in order to penalise unsuspecting drivers rather than offer a clear contract to park at a price. The charge is unconscionable and unfair in this context, with ParkingEye v Beavis fully distinguished.

    11) The concept of the fairness of a contract must be considered in every case (Consumer Rights Act 2015) and was considered by District Judge Iyer in Pace Recovery v Lengyel, case C7GF6E3R, on 24 May 2017. The Judge held that 'the concept of fairness requires the parking firm to comply with the requirements of the relevant code of practice' which the parking operator had not; the same difficulty this Claimant faces.

    11.1. The transcript of the decision in Pace v Lengyel will be provided to the Court, since it is on all fours with this case in several other respects too, including:

    i. the Judge's findings that the Claimant could not make contracts with drivers, and

    ii. that there was no contract possible with a non-permit holder in any case, so any purported contract was invalid under the doctrine of impossibility of performance, and

    iii. the signage was inadequate, and

    iv. such a claim against a non-permit holder might have been more properly phrased in trespass, but that was not the Claimant's case and they were not the party in possession of the land.

    12) It is denied that the Claimant has any entitlement to the sums sought and it is denied that interest is applicable on the total sums claimed by the Claimant, which bear no relation to the maximum sum potentially able to be recovered from a registered keeper, as set out in the POFA, namely the sum stated in the Notice to Keeper.

    13) The Defendant denies the claim in its entirety, voiding any liability to the Claimant for all amounts due to the aforementioned reasons. The Defendant asks that the court gives consideration to exercise its discretion to order the case to be struck out under CPR Rule 3.4, for want of a detailed cause of action and/or for the claim having no realistic prospects of success.

    14) If the court is not minded to make such an order, then when Directions are given, the Defendant asks that there is an order for sequential service of witness evidence (rather than exchange) because it is expected that the Claimant will use its witness statement to provide the sort of detail which should have been disclosed much earlier, and the Defendant should have the opportunity to consider it, prior to serving evidence and witness statements in support of this defence.

    I confirm that the above facts and statements are true to the best of my knowledge and recollection.


    Signed...........................


    Date
    .....................
    Last edited by Coupon-mad; 05-04-2018 at 1:36 AM.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Searc
    • By Searc 5th Apr 18, 10:35 PM
    • 9 Posts
    • 1 Thanks
    Searc
    Thanks for responses!

    Will follow all you advised.

    The date of the issue is 6th of March so last day is 8th of Aprill but I'm going to email the defence tomorrow.

    It took some time for research and communication with local area Highways engineer to find exactly the point on a map/plan where the road is split between adopted highway and private land. So found the part of the road I parked does not form part of the public highway.

    I also visited the site and found the road recently marked with double yellow line all way through.

    The draft above is much better when one I composed so will use it.

    I only deleted
    "5) The Claimant has provided no evidence (in pre-action correspondence or otherwise) that the Defendant was the driver."
    and flowing 5.1 to 5.3
    as It is unfortunately not the case

    Many thanks again
    • KeithP
    • By KeithP 5th Apr 18, 11:02 PM
    • 7,167 Posts
    • 6,647 Thanks
    KeithP
    Where's their evidence that the keeper is the driver?

    As far as I can see that is only suggested in Gladstones' letter of 22 January:
    1. You are pursuted as the driver of the vehilcle, you have failed to prove otherwise and as such it is safe to assume you were the driver of the vehicle on the date of the incendent
    That is certainly very far removed from being evidence.
    It certainly is not safe for them to make that assumption.
    .
    • Searc
    • By Searc 6th Apr 18, 12:22 AM
    • 9 Posts
    • 1 Thanks
    Searc
    It is on the photo, I left my phone number under windscreen as usualy when on call
    • Coupon-mad
    • By Coupon-mad 6th Apr 18, 12:23 AM
    • 57,393 Posts
    • 71,004 Thanks
    Coupon-mad
    How does that ID you (the Defendant) as the driver?
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • KeithP
    • By KeithP 6th Apr 18, 12:24 AM
    • 7,167 Posts
    • 6,647 Thanks
    KeithP
    It is on the photo, I left my phone number under windscreen as usualy when on call
    Originally posted by Searc
    Oh, the phone number of an occupant of the car you mean?
    .
    • Searc
    • By Searc 6th Apr 18, 7:50 PM
    • 9 Posts
    • 1 Thanks
    Searc
    Oh, the phone number of an occupant of the car you mean?
    Originally posted by KeithP
    Well I understand but it couldn't be anybody else driving the car to do my job there... Don't want to get a trouble in a court about.
    I believe defence based on lack of signs is strong enough
    • Coupon-mad
    • By Coupon-mad 6th Apr 18, 7:54 PM
    • 57,393 Posts
    • 71,004 Thanks
    Coupon-mad
    OK, yes I can see that signage is your best point so use the defence I gave you, admit you were the driver, like this:

    4) It is admitted that on the material date, the Defendant parked the vehicle at the location stated.
    PRIVATE PCN? DON'T PAY BUT DO NOT IGNORE IT TWO Clicks needed for advice:
    Top of the page: Home>>Forums>Household & Travel>Motoring>Parking Tickets, Fines & Parking - read the 'NEWBIES' FAQS thread!
    Advice to ignore is WRONG, unless in Scotland/NI.

    • Searc
    • By Searc 7th Apr 18, 1:21 AM
    • 9 Posts
    • 1 Thanks
    Searc
    Thanks, corrected #4 in my defence as above

    Only your defence goes now, by email to the CCBCAQ email address.
    Emailed both defence and signed N9B
    • Searc
    • By Searc 12th Apr 18, 10:54 PM
    • 9 Posts
    • 1 Thanks
    Searc
    Just a quick update.

    Received letter from County Court with acknowledge receipt of my defence.

    Received letter from Gladstones with their Client's completed Directions Questionnaire.

    As usually they want hearing venue to be Claimant's home court - if defendant does not consent )
    and to hear the case on the papers only.

    Hope will receive my Directions Questionnaire soon. I know how to fill it properly )
    • nosferatu1001
    • By nosferatu1001 13th Apr 18, 10:45 AM
    • 2,464 Posts
    • 3,005 Thanks
    nosferatu1001
    Check MCOL. Tells you when sent
    Or just download yoru own N180, and add the usual covering letter.
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  • It's the start of mini MSE's half term. In order to be the best daddy possible, Im stopping work and going off line? https://t.co/kwjvtd75YU

  • RT @shellsince1982: @MartinSLewis thanx to your email I have just saved myself £222 by taking a SIM only deal for £7.50 a month and keeping?

  • Today's Friday twitter poll: An important question, building on yesterday's important discussions: Which is the best bit of the pizza...

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