Ok have tried my best to come up with something non-boilerplate that addresses the points on the Claim Form (as posted above)
Response to particulars of claim:
1.The Defendant is the Registered Keeper of the vehicle with registration mark #####.
2. The Defendant confirms that, to the best of their recollection, the vehicle entered and exited the car park on the date supplied.
3. Paragraph 3 is denied. The Defendant was not the driver of the vehicle at the material time and is under no legal obligation to identify the driver to a private entity.
4. The Defendant accepts being pursued as the keeper of the vehicle, but is not able to confirm whether or not the Notice to Keeper was supplied within the mandatory 14-day window that applies where no parking ticket was given on the vehicle, due to not being in possession of a record of when the NtK entered the postal system via independent evidence.
Response to claimant claims:
1. The Claimant is claiming a principal sum of £170.00, representing the initial £100 parking charge artificially inflated by £70.00 described as debt collection costs. PoFA Schedule 4, Paragraph 4(5) explicitly caps the maximum sum recoverable from a registered keeper at the amount specified in the original Notice to Keeper (typically £100). The addition of arbitrary "debt collection fees" or "damages" represents double recovery, violates the Civil Procedure Rules, and constitutes an abuse of the court process.
2. The Defendant notes the 8% interest rate given but has not been provided with a calculation to show how this has been used to reach the £181.68 amount given at the “amount claimed”.
3. The Defendant notes that costs and court fees have been added to the amount claimed.