Your browser isn't supported
It looks like you're using an old web browser. To get the most out of the site and to ensure guides display correctly, we suggest upgrading your browser now. Download the latest:

Welcome to the MSE Forums

We're home to a fantastic community of MoneySavers but anyone can post. Please exercise caution & report spam, illegal, offensive or libellous posts/messages: click "report" or email forumteam@.

Search
  • FIRST POST
    • rimbats
    • By rimbats 15th Apr 18, 6:34 PM
    • 5Posts
    • 8Thanks
    rimbats
    Witness Statement help against Mil Collections
    • #1
    • 15th Apr 18, 6:34 PM
    Witness Statement help against Mil Collections 15th Apr 18 at 6:34 PM
    I have received a hearing date at my local county court and I now need to write a witness statement by the 27th of April. If there's anyone that could help me as I have no idea what is meant to be in the witness statement. My Defence was from someone else's on this thread whose situation was similar.

    IN THE COUNTY COURT

    CLAIM No: ***************

    BETWEEN:

    MIL COLLECTIONS LTD (Claimant)

    -and-

    ************ (Defendant)

    DEFENCE STATEMENT


    It is admitted that the Defendant is the registered keeper of the vehicle in question.
    1.!The Defendant denies any liability whatsoever to the Claimant for all of the following reasons, any one of which is fatal to the Claimant’s case:

    i)!The Claimant has no valid assignment of debt in the form of a signed Deed of Assignment pursuant to s136 of the Law of Property Act 1925. Absent of such evidence, the Claimant has no cause of action. The Debt Sold Under Agreement of Assignment Letter (Annexure A) and Letter Before Action copies (Annexure B) are unsigned with the same barcode header, which may indicate both were produced by the Claimant.

    ii)!The Claimant has no interest in any purported original contract and it is submitted that the Deed of Assignment is champertous.

    iii)!The Claimant’s original claim form does not contain a signature that meets the requirements of the Civil Procedure Rules Part 22 and Practice Direction 22 which state a statement of truth must ‘where a document is to be verified on behalf of a company or other corporation…be signed by a person holding a senior position in the company or corporation.’!In the Particulars of Claim the Claimant's statement of truth has not been signed/verified and cannot be relied upon.

    iv)!The Defendant has never owed any debt to the Operator (Llawnroc Parking Services Limited) to be assigned. If a debt had existed, it would be due to the Landowner (RNAS CULDROSE) not the operator, nor the Claimant.

    v)!The Defendant’s right to park is by virtue of a tenancy agreement with the Landowner. As such even if it could be proven the Defendant was the driver of the vehicle at the time of the alleged infringement, the Operator had no capacity to offer a contract with the Defendant. Nor was the Operator able to unilaterally alter the contract between the Defendant and Landowner, by restricting the right to park.

    2.!The Defendant neither confirms nor denies being the driver of the alleged offence. It is therefore for the Claimant to provide proof that this is the case and that keeper liability has been established by the issue of compliant documents, in accordance with Schedule 4 of the Protection of Freedom Act 2012.

    3.!The Claimant has no right to assert that the Defendant is liable based on ‘reasonable assumption’. Parking and Traffic Appeals Service (PATAS) and Parking On Private Land Appeals (POPLA) Lead Adjudicator and Barrister, Henry Michael Greenslade, clarified that with regards to keeper liability,!'there is no ‘reasonable presumption’ in law that the registered keeper of a vehicle is the driver and operators should never suggest anything of the sort' (p.12 POPLA Annual Report 2015).

    4.!The Claimant has provided no evidence that there was a valid assignment of debt and as such is put to strict proof that a Deed of Assignment signed by the original creditor, pursuant to section 136 of the Law of Property Act 1925 exists. Absent of such evidence the Claimant has no locus in this matter.!

    5.!If a valid Deed of Assignment were to exist, the Claimant has no interest in, or privy to any purported original contract and it is submitted that the Deed of Assignment is champertous. The sole purpose is to enable the Claimant to instigate legal proceedings, which is a chose in action, and on that basis the Claim should be struck out by the Court, as was the case in!MIL!Collections v Stephen Bowker, B1QZ7N32, Oldham CC 15/01/2016.!

    6.!The Claimant is to put to proof that the Operator had sufficient interest in the land or that there were specific terms in the contract between the Landowner and Operator to entitle the Operator to bring an action on its own behalf as required in the British Parking Association’s Legislation Guidance to Operators.

    7.!Case law in recent years suggests without such proof the Claimant has no locus standi to initiate legal proceedings.ParkingEye Ltd. v Sharma, 3QT62646, Brentford CC,!23/10/2013!examined the contract between the Landowner and Claimant and dismissed the Claimant’s case as the Claimant had no ownership of, or proprietary interest in, the land. It followed that the Claimant, acting as an agent, had no locus standi to bring court proceedings in its own name.

    8.!The Claimant has not disclosed whether its case is one of breach of contract or breach of license.

    9.If a breach of contract is being alleged, the Defendant submits there was no valid contract between the Operator and the Defendant. The only contract in existence is between the Landowner and the Defendant in the form of a tenancy agreement. Of which the Royal Navy have denied ever allowing permission for Llawnroc Parking Services Limited to give residents parking tickets.!

    10. The tenancy agreement places a number of restrictions on residents who park their vehicles on the premises. The displaying of a permit is not one of the restrictions contained within the agreement.!

    11. Having spoken to the Landowner at the time of receiving correspondence from the Operator pertaining to the need to display a permit, the Defendant was assured his right to park had not been further restricted and he was able to continue to park without displaying a permit as his vehicle details were kept by the Landowner and could be identified as belonging to a tenant of the premises.!

    12. The tenancy agreement is not able to be unilaterally altered by the Operator. Additional restrictions on parking must be made by a party to the original contract not a third party. In Pace Recovery and Storage v Mr N, C6GF14F0, Croydon CC, 16/09/2016 this was reaffirmed by District Judge Coonan who dismissed the claim and refused leave to appeal. In Link Parking v Ms P, C7GF50J7 Wrexham CC, 02/11/2016 it was also held that the Operator could not override the tenant's right to park by requiring a permit to park.


    13. The Operator erected signage at the premises following the issuing of permits which attempted to form a contract with motorists (Annexure C). However, given the advice the Defendant had received from the Landowner as well as the Landowner’s signage at the premises stating ‘MOD PROPERTY’ (Annexure D), the Defendant has the reasonable belief that the Operator’s intention was not to offer a genuine contract to residents but was to deter non-residents by attempting to enforce a penalty. The Defendant refers the court to Civil Enforcement Ltd v McCafferty, 3YK50188, Luton CC, 21/02/2014 which was decided by Mr Recorder Gibson QC in almost identical words.!

    14. It is submitted the Operator’s management of the site was to enforce the Landowner’s restriction to stop non-residents from utilising the parking facilities not to target residents exercising their right to park in the residential car park.

    15. Furthermore, in the event the Operator’s signage did constitute a contract, the primacy of the Defendant’s contract with the Landowner in the form of a tenancy agreement would render this void. As stated in paragraph 12, the contract between Landowner and the Defendant is not able to be unilaterally altered. In Jopson v Homeguard, 9GF0A9E, Oxford CC, 29/06/2016 on appeal it was found the parking management company could not override the tenant's right to temporarily stop near the building entrance for loading/unloading.

    16. If the Claimant is basing the claim on a breach of a licence, as opposed to breach of contract, the offence would be one of trespass and could only be pursued by the land-owner.!

    17. If the court finds a contract existed between the Operator and the motorist, the provision requiring payment of £100 within 28 days is an unenforceable penalty clause.!

    18. Further and alternatively, the provision requiring payment of £100 is unenforceable as an unfair term contrary to the Consumer Rights Act 2015 unless it is found the charge is a pre-estimate of loss or there is commercial justification. In ParkingEye v Beavis [2015] UKSC 67, 04/11/2015, the Supreme Court found that £85 was not a genuine pre-estimate of loss in as there was no direct loss to the parking management company. It is submitted that the Claimant or Operator would find it difficult to provide commercial justification for charging residents hundreds of pounds a year to park outside their premises.

    19. The Defendant further disputes that the Claimant has incurred £50 in ‘Administration and!Collection!fees’ as stated in the Particulars of Claim. The Defendant draws the Court’s attention to the judgment in Vehicle Control Services Ltd. v Ibbotson, 1SE09849 S!!!!horpe CC, 16/05/2012 which stated that only the costs directly resulting from the alleged parking infringement may be included in the claim, and not an arbitrary proportion of normal business costs. The Claimant is to put to proof a breakdown of the ‘Administrative and!Collection!fees’ referred to in the Particulars of Claim.!

    20. The charges represent a breach of the well-known and well-established principle of promissory estoppel. In this case the Defendant has relied upon a promise made by his landlord (the Landowner) that his right to park in the residential car-park is not effected by the Operator’s management of the car-parking facilities. The reliance on this promise by the Defendant was to his detriment.

    21. The charges also represent a breach of the well-known and well-established principle that 'a grantor shall not derogate from his grant'. Landholders cannot allow or promise a right to park to a tenant on the one hand, and then subsequently take away this permission or promise, by allowing a third party to disallow and/or seek to charge for the permitted action by a tenant.

    22. The above has been confirmed in case law. In Saeed v Plustrade Limited [2001] EWCA Civ 2011, a tenant was granted a right in common with others to park on such part of the forecourt as might from time to time be specified by the Landholder. The Landholder later proposed to reduce the availability of parking and to charge those who wished to park. On appeal it was held the Landholder was only entitled to change the location of spaces, not to reduce their number, nor to unreasonably restrict parking previously offered, nor to charge for it. Such restrictions would interfere with easements enjoyed under the lease.

    23. Given the above points, the Court is invited to strike out the claim as having no prospect of success. It is submitted that this is a vexatious litigant, merely buying sets of photographs from parking firms for as little as £1, with the aim of inflating any damages for this Claimant's own profit. This claimant is wantonly and officiously intermeddling in cases where they have no prior interest; this is frivolous litigation with no evidence nor any particulars that could give rise to a claim in law.!

    24. If the court chooses not to strike out the claim, the Defendant invites the court to order the Operator to be added as a party to the claim.!

    25. I believe the facts stated in this defence are true.


    **/**/**



    MR *************
Page 1
    • Quentin
    • By Quentin 15th Apr 18, 6:46 PM
    • 35,623 Posts
    • 19,852 Thanks
    Quentin
    • #2
    • 15th Apr 18, 6:46 PM
    • #2
    • 15th Apr 18, 6:46 PM
    The newbies faq thread near the top of the forum includes advice on a WS - see#2 of the FAQ
    • Castle
    • By Castle 15th Apr 18, 6:48 PM
    • 1,715 Posts
    • 2,311 Thanks
    Castle
    • #3
    • 15th Apr 18, 6:48 PM
    • #3
    • 15th Apr 18, 6:48 PM
    Have you read this; same PPC:-
    http://parking-prankster.blogspot.co.uk/2018/04/mil-collections-750-awarded-against.html
    • The Deep
    • By The Deep 15th Apr 18, 7:08 PM
    • 9,209 Posts
    • 8,980 Thanks
    The Deep
    • #4
    • 15th Apr 18, 7:08 PM
    • #4
    • 15th Apr 18, 7:08 PM
    This is an entirely unregulated industry which is scamming the public with inflated claims for minor breaches of contracts for alleged parking offences, aided and abetted by a handful of low-rent solicitors.

    Parking Eye, CPM, Smart, and another 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 lose most of them, and have been reported to the regulatory authority by an M.P. for unprofessional conduct

    Hospital car parks and residential complex tickets have been especially mentioned.

    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 they will be out of business by Christmas.
    You never know how far you can go until you go too far.
    • rimbats
    • By rimbats 15th Apr 18, 9:21 PM
    • 5 Posts
    • 8 Thanks
    rimbats
    • #5
    • 15th Apr 18, 9:21 PM
    • #5
    • 15th Apr 18, 9:21 PM
    Thanks Castle I haven't seen that but I do have two letters from Paul King one of the made up characters so I shall definitely be quoting that case
    • KeithP
    • By KeithP 15th Apr 18, 9:51 PM
    • 7,261 Posts
    • 6,782 Thanks
    KeithP
    • #6
    • 15th Apr 18, 9:51 PM
    • #6
    • 15th Apr 18, 9:51 PM
    This thread will also interest you:

    .
    • Coupon-mad
    • By Coupon-mad 16th Apr 18, 1:30 AM
    • 57,564 Posts
    • 71,135 Thanks
    Coupon-mad
    • #7
    • 16th Apr 18, 1:30 AM
    • #7
    • 16th Apr 18, 1:30 AM
    Thanks Castle I haven't seen that but I do have two letters from Paul King one of the made up characters so I shall definitely be quoting that case
    Originally posted by rimbats
    Amazed this is proceeding this far; I expect MIL to fold without paying the hearing fee, if you filed a decent defence pointing out that they have no cause of action and obtained the data unlawfully.

    When this is over, claim £500 from the PPC who sold the data illegally.

    You have copied a DEFENCE but you are at Witness Statement stage! Don't muck this up. These are so easy to win, only one is known to have been lost that we know of (not on the forums, just one that we know someone managed to lose, must have been badly argued, we assume).

    Impossible to lose these, really, as long as they are well argued.

    You certainly DO NOT need any representation at a hearing, nor to contact anyone to 'help', so beware of that idea.

    What did your actual defence say? EXACTLY?

    And did the PPC get your keeper data from the DVLA and write to you first, or did you give THEM your name & address up front in an appeal to a windscreen PCN?
    Last edited by Coupon-mad; 16-04-2018 at 1:43 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.

    • rimbats
    • By rimbats 16th Apr 18, 5:45 PM
    • 5 Posts
    • 8 Thanks
    rimbats
    • #8
    • 16th Apr 18, 5:45 PM
    • #8
    • 16th Apr 18, 5:45 PM
    Amazed this is proceeding this far; I expect MIL to fold without paying the hearing fee, if you filed a decent defence pointing out that they have no cause of action and obtained the data unlawfully
    I know after the defense I sent (which is the one I posted in my first post) I was hoping they would've dropped it.

    I wrote to them to appeal the ticket all I admitted was that I was the keeper of the car and a resident of the car park the only information I gave was the details on the PCN. So I definitely will after the court I'm just trying to take it step by step.

    In regards to the witness statement am I to label reasons I'm disproving it and also all the court references I have in my defence do I need to use copies of them for evidence?
    • Redx
    • By Redx 16th Apr 18, 5:50 PM
    • 18,147 Posts
    • 22,954 Thanks
    Redx
    • #9
    • 16th Apr 18, 5:50 PM
    • #9
    • 16th Apr 18, 5:50 PM
    I wrote to them to appeal the ticket all I admitted was that I was the keeper of the car and a resident of the car park the only information I gave was the details on the PCN.
    Originally posted by rimbats
    WHO ?

    the THEM you appeal to would be the parking operator, the PPC

    you have not named the PPC involved, which was the only entitity you can appeal to

    MiL is a debt collector and so no appeal could be made

    MiL are issuing this court case , so you see them off and claim costs etc, then if the original PPC obtained DVLA details you take them to court for their KADOE breach (selling the DVLA data on)

    there are now 2 or 3 posts from april 2018 on parking pranksters website , so read them all
    Newbies !!
    Private Parking ticket? check the 2 sticky threads by coupon-mad and crabman in the Parking Tickets, Fines & Parking Board forum for the latest advice or maybe try pepipoo or C.A.G. or legal beagles forums if you need legal advice as well because this parking forum is not about debt collectors or legal matters per se
    • Coupon-mad
    • By Coupon-mad 17th Apr 18, 12:36 AM
    • 57,564 Posts
    • 71,135 Thanks
    Coupon-mad
    In regards to the witness statement am I to label reasons I'm disproving it and also all the court references I have in my defence do I need to use copies of them for evidence?
    Originally posted by rimbats
    Yes, case law, transcripts, and the Parking Prankster's Blog with the DVLA statement that blows the whole case to pieces:

    http://parking-prankster.blogspot.co.uk/2018/04/dvla-clarify-that-parking-companies.html

    As long as your data was supplied by the DVLA at the start, and was not supplied by you up front, by appealing against a windscreen ticket.

    If unsure, email the DVLA to ask if your data was given to the originating PPC (not MIL) around xx/xx (date) and while you are about it, ask for the official statements they sent to the BPA and the IPC last week and for a personal reply that confirms your data was obtained by the PPC from the DVLA and that it was NOT authorised to be sold or assigned.

    Then use the email as evidence with your WS. MIL will likely fold.

    Then you can use the same evidence to sue the PPC for £500 or so.
    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.

    • rimbats
    • By rimbats 22nd Apr 18, 10:39 PM
    • 5 Posts
    • 8 Thanks
    rimbats
    Apologies for my late reply I really appreciate the help.

    I appealed to the parking company (llawnroc parking) but only said I was the keeper, that I was a resident and the details I gave were those on the PCN.
    I have made a Witness Statement which I intend to send tomorrow if you could give me your criticism that would be greatly appreciated.

    1.I ****************!am the defendant in this case. I am unrepresented, with no experience of Court procedures. If I do not set out documents in the correct way, I trust the Court will excuse my inexperience.
    2.The facts in this statement come from my personal knowledge. Where they are not within my own knowledge they are true to the best of my information and belief.
    3. I am not liable to the Claimant for the sum claimed, or any amount at all and this is my witness statement in support of my Defence as already filed.
    4.I admit that I am indeed the registered keeper of the vehicle in question, however deny that I am the driver in question.
    5.The Claimant has provided no evidence of who was driving.
    6.The Claimant cannot !!!8220;presume!!!8221; that the Defendant and Registered Keeper was the driver at the time of the alleged contravention.
    7.Barrister and parking law expert Henry Greenslade was the 'Parking on Private Land Appeals' ("POPLA") Lead Adjudicator from 2012 - 2015. This is an independent appeals service offered by the British Parking Assosciation ("BPA"). Mr Greenslade's opinion in the POPLA Annual Report 2015 which confirms that there is no presumption in law that a keeper was the driver and that keepers do not have any legal obligation whatsoever, to name drivers to private parking companies. (Exhibit A).
    8.It is put forward to the court that the original letter received from the claimant (Exhibits B & C) do not contain any original signatures and in accordance with Civil Procedure Rules Part 22 and Practice Direction 22 (Exhibit D). It states on paragraph 3.4 !!!8216;Where a document is to be verified on behalf of a company or other corporation, subject to paragraph 3.7 below, the statement of truth must be signed by a person holding a senior position4!in the company or corporation. That person must state the office or position held.!!!8217; making these documents unreliable.
    9.In addition to this in a recent case of MIL Collections v George.!D8QZ60RM Truro 10/04/2018. DDJ Rutherford. After questioning from the Defendant the Claimant admitted the company often provide fictitious names or pseudonyms on documents used in evidence. He agreed Paul King, G Watson and Matt Murdoch, names which often appear on Mil litigation were all made up. As you can see from Exhibits B & C, Paul King appears on both.
    10.As in my Defence I argue that the Claimant has or has ever had any proprietary interest or ownership of the land and has no locus standi to bring the claim to court which the court found to be true in the case of ParkingEye Ltd. v Sharma, 3QT62646, Brentford CC,!23/10/2013 (Exhibit E).
    11.The car park itself is owned by the Ministry of Defence (MOD) with signs on the entrance stating this (Exhibit F) and have been informed that Llawnroc Parking have been contracted by the MOD to run the car park, of which the claimant is neither, day to day to deter non-residents from parking there. It is believed that the operator was not to offer a genuine contract to the residents but to deter non-residents as was found in the case of Civil Enforcement Ltd v McCafferty, 3YK50188, Luton CC, 21/02/2014 (Exhibit G)
    12.It is also put to the court that a fee of £100 is an unenforceable amount to charge a resident to park in a car park they are entitled to. In the case of ParkingEye v Beavis [2015] UKSC 67, 04/11/2015 (Exhibit H) it was found £85 was not a genuine pre-estimate of loss in as there was no direct loss to the parking management company.
    13.It is argued that the Claimant has obtained my personal information illegally as I never gave any of my personal information to the Parking Company (Llawnroc Parking). On the parking signs (Exhibit I) it states !!!8216;vehicle keeper details will be requested from the DVLA. A freedom of information request has established that parking companies cannot sell keeper data obtained from the DVLA to MIL Collections unless the DVLA has approved this.

    For parking companies to get keeper data from the DVLA, they sign a contract known as the KADOE contract (Exhibit J). This contract says what you can and cannot do with the keeper data. In particular, clause D5.1 of the KADOE contract prohibits the Customer from disclosing the information they have received from the DVLA to any other person except:-

    a) to a sub-contractor who acts as the Customer's data processor;
    b) to a sub- contractor who acts as the Customer's debt collector;
    c) with the prior written agreement of the DVLA.

    MIL Collections are clearly not acting as a sub-contractor, and therefore parking companies must have prior written agreement from the DVLA to sell KADOE data to MIL.!
    The Claimant is put to strict proof that they have a prior written agreement to be given my personal details from DVLA.
    14.The Court is invited to dismiss this claim as being without merit.
    15.I believe the facts stated in this witness statement to true to the best of my knowledge.!
    • twhitehousescat
    • By twhitehousescat 22nd Apr 18, 10:48 PM
    • 1,287 Posts
    • 1,742 Thanks
    twhitehousescat
    I would suggest you contact the DVLA and find out if llawnroc parking or a company employed by them asked for your info for the relivent day
    Time pretending I was asleep whilst under his desk , has given me insight to this sordid world
    • Coupon-mad
    • By Coupon-mad 22nd Apr 18, 11:05 PM
    • 57,564 Posts
    • 71,135 Thanks
    Coupon-mad
    10.As in my Defence I argue that the Claimant has no or has ever had any proprietary interest or ownership of the land and has no locus standi to bring the claim to court in their own name. MIL are not even a parking company and have no relationship with the landowner and no authority to sue drivers or registered keepers, and were incapable of making contracts on that site because the Claimant was not at the location in any respect. which the court found to be true in the case of ParkingEye Ltd. v Sharma, 3QT62646, Brentford CC,!23/10/2013 (Exhibit E).

    11.The car park itself is owned by the Ministry of Defence (MOD) with signs on the entrance stating this (Exhibit F) and have been informed that Llawnroc Parking have been contracted by the MOD to run the car park of which the claimant is neither day to day to deter non-residents from parking there. It is believed that the operator was not to offer a genuine contract to the residents but to deter non-residents, but in any case, this Claimant is not the parking operator and has no business in handling my data or pursuing me for an alleged contract that it was not a party to, regarding an event that this Claimant cannot evidence. The Claimant's claim is champertous, vexatious and wholly unreasonable.. as was found in the case of Civil Enforcement Ltd v McCafferty, 3YK50188, Luton CC, 21/02/2014 (Exhibit G)

    12.It is also put to the court that a fee of £100 is an unenforceable amount to charge a resident to park in a car park they are entitled to use, and have full authorisation under their lease agreement. In the case of ParkingEye v Beavis [2015] UKSC 67, 04/11/2015 (Exhibit H) it was found £85 was not a genuine pre-estimate of loss in as there was no direct loss to the parking management company.

    13.It is argued that the Claimant has obtained my personal information illegally as I never gave any of my personal information to the Parking Company (Llawnroc Parking). On the parking signs (Exhibit I) it states 'vehicle keeper details will be requested from the DVLA'. A freedom of information request has established that parking companies cannot sell keeper data obtained from the DVLA to MIL Collections unless the DVLA has approved this.
    Do not exhibit ParkingEye v Beavis.

    Also don't exhibit PE v Sharma or CEL v McCafferty which are not relevant.

    DO put in evidence the FOI answer from the DVLA (easy to Google) or even better, get a reply from the DVLA with a copy of their final decision about selling data to companies like MIL, which has never been allowed. You need to show the Judge your evidence that this claim involves data MIL were never allowed to access.

    You might want to find the other cases where people have shown a MIL WS already, to crib from. Search 'MIL bought some photographs' as your keywords and read cases like the MIL thread by Bambi82, who had extra points like this:

    At best, the alleged transaction described by MIL was an equitable assignment, not a legal assignment. Therefore the Claimant could not have issued a valid claim unless (the parking firm) was joined to it.
    I saw nothing in your WS about the assignment not being a true assignment.

    When this is over, sue Llawnroc for £500.

    Last edited by Coupon-mad; 22-04-2018 at 11:09 PM.
    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.

    • rimbats
    • By rimbats 26th Apr 18, 8:31 PM
    • 5 Posts
    • 8 Thanks
    rimbats
    Great news the day after I sent my witness statement Mil Collections sent a letter to discontinue the claim !!!55356;!!!57225;!!!55356;!!!57225;
    Thanks everyone for the help especially coupon-mad for taking the time to go through my witness statement.

    Just waiting for dvla to get back to me to see if I can fleece them for some money !!!55357;!!!56397;
    • Castle
    • By Castle 26th Apr 18, 8:36 PM
    • 1,715 Posts
    • 2,311 Thanks
    Castle
    Great news the day after I sent my witness statement Mil Collections sent a letter to discontinue the claim !!!55356;!!!57225;!!!55356;!!!57225;
    Thanks everyone for the help especially coupon-mad for taking the time to go through my witness statement.

    Just waiting for dvla to get back to me to see if I can fleece them for some money !!!55357;!!!56397;
    Originally posted by rimbats
    You can go after both the PPC, (Llawnroc), and MIL for breaches of the Data Protection Act and you have 6 years to do.
    • Coupon-mad
    • By Coupon-mad 27th Apr 18, 1:36 AM
    • 57,564 Posts
    • 71,135 Thanks
    Coupon-mad
    Hooray, now for stage 2 (revenge):

    When this is over, sue Llawnroc for £500.
    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.

Welcome to our new Forum!

Our aim is to save you money quickly and easily. We hope you like it!

Forum Team Contact us

Live Stats

166Posts Today

1,506Users online

Martin's Twitter
  • 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...

  • Follow Martin