Go with this.
Subject: Defective Warrant and Cease and Desist Notice under CPR Rule 6
Dear London Borough of Barnet,
I am writing to urgently address serious procedural deficiencies in the enforcement actions related to multiple Penalty Charge Notices (PCNs) issued for the alleged "no left turn" contravention from Tilling Road to Brentfield Gardens. I believe the Warrant of Control is defective, and procedural breaches render any ongoing enforcement invalid until these issues are resolved immediately.
Incorrect Address on the Warrant: Enforcement actions were directed to my previous address, despite my efforts to update my details and having a Royal Mail redirection in place. This breaches Regulation 8 of The Taking Control of Goods Regulations 2013, which requires enforcement notices to be sent to the "last known address". The failure to verify my address compromises the validity of the Warrant under CPR Rule 83.9.
Absence of Proper Notification: I received no correspondence at my new address. Under Schedule 12 of the Tribunals, Courts and Enforcement Act 2007 and Regulation 3 of The Civil Enforcement of Parking Contraventions (England) General Regulations 2007, notices must be sent to the registered keeper's current address. The lack of notice has obstructed my right to respond, further undermining the legitimacy of enforcement actions.
Repetitive Issuance of PCNs: Seven PCNs were issued for the same offence without prior warning or opportunity for rectification. This breaches the Statutory Guidance for Local Authorities on Civil Enforcement of Parking Contraventions, which advises authorities to inform motorists of recurring offences to avoid a punitive approach. Barnet Council's failure to do so is disproportionate and unfair.
In light of these serious procedural defects, I demand the immediate suspension of all enforcement actions related to these PCNs. I further request an urgent review of the Warrant to verify adherence to statutory regulations. Please provide written confirmation within 7 days outlining the steps Barnet Council will take to achieve full compliance. Additionally, I require a formal cease and desist notice from Barnet Council in writing by 14 November 2024, confirming the suspension of all enforcement actions until these procedural issues are fully resolved. If enforcement proceeds without resolving these statutory breaches, I will be left with no option but to commence formal legal action.
I trust you will treat this matter with the utmost urgency and respond promptly to avoid unnecessary escalation.
Yours sincerely,[Your Full Name]