Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: ticmick66 on November 01, 2024, 04:35:39 pm

Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on June 20, 2025, 11:27:26 am
I suspect that the claim has been discontinued or is about to be, as is standard with DCB Legal issued claims. The claimant was under the same deadline as you to submit their WS and they have not done so.

As predicted. Well done for persevering with our advice.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on June 20, 2025, 09:29:49 am
No problem, I have erased personal or identifiable bits of Info hopefully.

[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: DWMB2 on June 19, 2025, 11:20:41 pm
Could you please share a copy of the notice? It's good to have a record of their practice.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on June 19, 2025, 11:04:29 pm
Letter dropped through the letterbox today, the case has been withdrawn by UKPC, DCB letter informed me that court action was no longer being sought.

It was never just about the money they wanted, it was about the sheer brazen nature of the money grabbing process and nothing really to do with enforcement.

I can’t thank you enough for your patience and all of your help fighting this,

Very best regards.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on June 06, 2025, 12:00:09 pm
Send the Witness Statement I advised. Keep trying to call the court. I would suggest you try first thing in the morning, preferably around 8:30am.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on June 06, 2025, 09:14:42 am
Good morning, I have sent the form today as requested.

I haven't had any luck getting through to the Court, I was on hold for 35 minutes the other day before the call was dropped.

Shall I keep trying, or shall I just await the next letter with an update?

thank you as always.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on June 01, 2025, 11:28:12 am
I will do, thank you for your assistance.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on June 01, 2025, 02:28:20 am
I suspect that the claim has been discontinued or is about to be, as is standard with DCB Legal issued claims. The claimant was under the same deadline as you to submit their WS and they have not done so.

I would call the court on Monday and ask whether the claim has been discontinued and the hearing date vacated. They have until 4pm on 5th June to pay the trial fee or the case is automatically struck out.

If the claim has not been discontinued yet, I would advise you submit the following late WS to protect your position. ONLY submit this on 6th June. Do not submit it earlier. You must send it to the court by email as a PDF attachment to enquiries.northampton.countycourt@justice.gov.uk and you must also CC in info@dcblegal.co.uk and cc in yourself too. The subject line of the email must be marked “Urgent” and also include the claim number.

Quote
IN THE COUNTY COURT AT NORTHAMPTON
Claim No: [Claim Number]

BETWEEN:

UK Parking Control Ltd

Claimant

- and -

[Defendant's Full Name]


Defendant



WITNESS STATEMENT

1. I am the Defendant in this matter. I make this witness statement to preserve my position in advance of the hearing listed for 3rd July 2025. I understand that it is being filed outside the 22nd May 2025 deadline directed by the court, and I respectfully ask that the court admit it in the interests of justice under the overriding objective.

2. This witness statement is submitted as a formality, without prejudice to the court’s order that the claim be struck out if the Claimant failed to comply with directions by 5th June 2025. As of the date of this statement, I have not received any witness statement or evidence from the Claimant or their legal representatives.

3. The defence was filed and served in good time. It raised significant issues concerning the Claimant’s failure to comply with CPR 16.4, including the lack of clarity as to the basis of the claim and whether the Defendant is being pursued as the driver or the registered keeper.

4. The Claimant did not attach the contract it relies upon, nor the specific wording of any terms said to have been breached. No copy of the original Parking Charge Notice has been provided, nor any photographs, signage, or location details. The Particulars of Claim remain vague and fail to identify the alleged breach with the required precision.

5. I included a draft order with my defence, inviting the court to require the Claimant to produce further and better particulars so that I could properly understand and respond to the case. However, this was not actioned and the case was allocated to hearing without further clarification.

6. I have been unable to provide further documentary or substantive evidence in support of this witness statement due to the Claimant’s failure to comply with CPR 16.4 and to plead my case with sufficient clarity. As a result, I am placed at a disadvantage and remain unaware of the precise allegations or evidence relied upon.

7. The Claimant has made no attempt to set out how the amount claimed has been calculated, nor to identify the legal basis for any damages or additional charges. The claim simply refers to “registered users only” without explanation.

8. No evidence has been provided to demonstrate that I was the driver, nor that the Protection of Freedoms Act 2012 (PoFA) has been complied with in order to establish liability against myself as the registered keeper.

9. The Claimant’s conduct to date has been uncooperative and evasive. It has failed to comply with basic procedural obligations and, in my experience and understanding, DCB Legal frequently discontinues claims at the last moment when required to pay the trial fee.

10. I make this statement to protect my position in the event that the Claimant attempts to proceed, but if the claim has been struck out as ordered, then I rely on that strike-out and submit this statement for completeness only.

11. I reserve the right to submit a supplemental witness statement if the Claimant attempts to revive the claim or introduces evidence at a later stage.

Statement of truth

I believe that the facts stated in this Witness Statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed:


Date:
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on May 31, 2025, 11:12:19 pm
I must apologise in advance, I hadn’t contacted you before the 22nd to advise that I didn’t receive any paperwork from UKPC or their Legal representatives. Remiss of me I know, but redundancies at work have rather distracted me for the last month.
I am worried that I should have sent them some representations, or paperwork, have I messed up?
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on April 23, 2025, 12:26:14 pm
My apologies, it isn't my intention to be difficult, I am not familiar with any of these processes, this is as far removed as my daily work as can be, I did get confused before earlier om the claim with the email addresses, but that was a miscommunication of what I sent, on my part, I did follow the process correctly as advised in the end.

Your assistance is always appreciated.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on April 23, 2025, 12:11:33 pm
We need to see everything. you already have shown a propensity to not follow advice or provide clear answers to questions.

We need to see ALL of the order so that we can determine the various deadlines, which we now know are:

• Witness Statements (WS) to be submitted by 22nd May.
• Claimant to pay trial fee by 5th June
• Hearing date 3rd July.

Whilst UKPC/DCB Legal will not let this go to a hearing, there is slight problem because the court has ordered that the WS be submitted much earlier than the trial fee deadline. They will discontinue before that deadline but you will want to see if they send you a copy of their WS before 22nd May.

Remind us on 21st May if you have not received a copy of their WS by then. If you do receive one before then, she us immediately.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on April 23, 2025, 11:03:22 am
My apologies, so they sent the main letter (1st page I sent), then three sides of instructions, attached the final two below.

[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on April 23, 2025, 10:52:16 am
Is that it? What about the rest of the order?
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on April 23, 2025, 10:34:16 am
Nothing on the back of this letter, but there are two generic attached documents with details of the process, dates by which time the claimant needs to provide certain documents and payment, an offer of mediation, which we have already been through, with a hearing Date of July 2025.
I have attached one of the forms.

[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: DWMB2 on April 23, 2025, 09:49:23 am
All standard stuff - any more case-specific instructions on the reverse?
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on April 23, 2025, 09:48:09 am
Good morning, this arrived yesterday.

[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on March 26, 2025, 05:30:19 pm
OK, will do, thank you
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on March 26, 2025, 05:19:02 pm
All normal and expected. You will next receive  notice from your local court with an order advising you of a hearing date and some deadlines. When you receive that, show it to us, redacting only your personal data.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on March 26, 2025, 04:40:21 pm
Hello, I have received notice today that the case is being referred to my Local Court.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on March 05, 2025, 04:03:47 pm
Just goes to show you how the mediator is not legally trained and is a feckwit!

If it ever gets to court and you were unfortunate enough not to be successful defencing the claim, you still would never get a CCJ as long as it is paid in full within 30 days of judgment. This mediator is just perpetuating the ignorance of the vast majority of the general population that has no idea about how this system works.

You ae no w aging of this claim to be allocated to your local county court and you will be notified in due course.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on March 05, 2025, 02:47:31 pm
Good afternoon, I have just finished my mediation Phone call whereupon I said that my defence is detailed in the paperwork I had already sent, and was visible to the claimant, they said they will go back to the claimants solicitor and discuss, but to be advised that if it goes to Court and the case is found against me, I can receive a CCJ etc, but I have stuck to my principles thus far, and will see where it goes from here, thank you.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on February 03, 2025, 10:48:59 am
Appreciated, thank you
Title: Re: UKPC - Coventry - Private Car Park
Post by: DWMB2 on February 03, 2025, 10:44:52 am
b789's advice on mediation covers the main points, but from recent experiences people have shared on here, the one bit of advice I'd add is to not let yourself get pulled into a drawn out debate on your defence, or the merits of your case. Keep your answers brief - if you're asked about the basis of your defence, I'd just re-iterate that you have set out the basis of your defence in writing and the claimant is in possession of a copy of this - you stand by the points raised in the defence and accordingly, you're not prepared to offer anything by means of settlement.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on February 03, 2025, 10:34:11 am
Mediation Phone call appointment has now been booked, I will of course follow your advice previously given on this.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on January 28, 2025, 06:06:38 pm
OK. You have now submitted the DQ. Your MCOL history shows that they allegedly sent your DQ back in December. You should have received a copy of the claimants DQ with their response to the defence. You should have received, separate your own DQ. You are saying that you didn't receive it. You have received the genera sanctions order and complied with it.

You are back on track. Look out for your mediation phone call appointment. When you receive that and make the compulsory appointment, do not worry about it as it is not part of the judicial process and no judge or solicitors are involved. You simply offer £0 and it will be over in minutes.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on January 28, 2025, 05:20:14 pm
This was the confirmation that they had received the defence correctly on December 6th, and suggesting I needed to await the Claimants response.


Dear Sir/Madam,

Thank you for your email.

Please note that your defence has been filed.

The next step will be communicated to you as soon as the claimant replies.

Kind Regards
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on January 28, 2025, 05:16:13 pm
Hello, I can confirm after double checking, I sent the Defence to the correct address in November.

Todays Letter was for chasing the missing DQ which they say I should have sent to them by now, despite not receiving a request to send it, which I was awaiting based on your advice, I have now sent this to them, as you say, it gave me Seven days to send it.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on January 28, 2025, 04:55:58 pm
I seriously doubt that you sent the defence to claimresponses.cnbc@justice.org.uk otherwise you would have had a default CCJ by now. You must have sent the defence to the correct email address with "gov" not "org" in it otherwise you would never have received an N180DQ.

If you sent the DQ to the incorrect email address, even though it was provided to you correctly, they you appear to have a problem processing vital information that could seriously hurt you financially unless you pay more attention to detail.

The N18DQ was supposed to have been sent to dq.cnbc@justice.gov.uk.

If you are querying "something you received from the CNBC", then please just post a suitably redacted copy of it so that we can at least analyse it without having to chase you for the detail.

If it is a general sanctions order about not having received your copy of the N180DQ, I suspect it gives you a further 7 days or so to comply and submit the completed form. If so, then just resend a copy of the PDF form we suggested you send to the DQ email address to the correct email address!!!

Go back and re-read the post where you were advised how to download and complete your own N180DQ form and follow the instructions. You should already have a copy of the PDF file you sent to the wrong address. Just resend it to the correct email address, which is as follows for clarity and understanding:

dq.cnbc@justice.gov.uk
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on January 28, 2025, 03:07:00 pm
My apologies, the original Email i sent back in November 24 was the Defence, and yes, it was sent to justice.gov.uk I can confirm

They are saying that I have failed to return the DQ paperwork, I haven't had any email or physical Paperwork sent to me regards this as yet?

I have logged into the MCOL webpage, and I see the attached.


[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: DWMB2 on January 28, 2025, 02:31:18 pm
I have forwarded the previous email that I sent to claimresponses.cnbc@justice.gov.uk
Which previous email?

This was the most recent advice:
You will, in due course receive your own N180 DQ to complete. You can keep checking your MCOL history to see when yours has been sent.You can fill it all in, ready to send as a PDF attachment in a single email to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Don't send it until you see that yours has been send in your MCOL history or you receive the physical paper one.

to the New Email they supplied dq.cnbc@justice.org.uk
.gov.uk, surely?
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on January 28, 2025, 02:24:07 pm
Good afternoon, can I check something with you, I have had a letter from the CNBC today saying that I hadn't filed my Paperwork with them, I have forwarded the previous email that I sent to claimresponses.cnbc@justice.gov.uk, to the New Email they supplied dq.cnbc@justice.org.uk asking them to confirm, not sure if this is a standard reply, but a little worrying, I would hate to lose this case due to a mistake on my part.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on December 09, 2024, 04:33:11 pm
Will do, thank you as always for your swift response and assistance given.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on December 09, 2024, 04:04:14 pm
That is normal too. It is their copy of the N180 Directions Questionnaire (DQ). You can just file it. You will, in due course receive your own N180 DQ to complete. You can keep checking your MCOL history to see when yours has been sent.

However, you can preempt it by downloading your own from here: https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf

You can fill it all in, ready to send as a PDF attachment in a single email to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Don't send it until you see that yours has been send in your MCOL history or you receive the physical paper one.

Here are some answers to the most commonly asked questions about the DQ:

Quote
The name of the court is "Civil National Business Centre".
To be completed by "Your full name" and you are the "Defendant".
C1: "YES"
D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question."
F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service.gov.uk/search-option
F3: "1".
Sign the form by simply typing your full name for the signature.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on December 09, 2024, 03:27:08 pm
Amusingly, they seem to have included a form filled in by themselves (Directions Questionnaire), to be completed by/on behalf of UKPC?
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on December 09, 2024, 03:21:53 pm
As expected. There has been no actual "review". The only human involvement so far is someone pressing a button on the computer.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on December 09, 2024, 02:46:30 pm
Good afternoon, I have been awaiting the response from the PCN people to the defence you kindly provided, arrived today, please see letter below.



[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on November 04, 2024, 09:28:37 am
All done, thank you very much for your assistance.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on November 03, 2024, 04:33:37 pm
Quote
IN THE COUNTY COURT
Claim No: [Claim Number]

BETWEEN:

UK Parking Control Ltd

Claimant

- and -

[Defendant's Full Name]


Defendant



DEFENCE


1. The Defendant denies any liability for this claim.

2. There is a lack of precise detail in the Particulars of Claim (PoC) in respect of the factual and legal allegations made against the Defendant such that the PoC do not comply with CPR 16.4.

3. The Defendant is unable to plead properly to the PoC because:

(a) The contract referred to is not detailed or attached to the PoC in accordance with CPR PD 16(7.5);

(b) The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the contract (or contracts) which is/are relied on;

(c) The PoC do not set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts). Simply stating "Registered users only" is vague and inadequate;

(d) The PoC do not state with sufficient particularity exactly where the breach occurred, the exact time when the breach occurred and how long it is alleged that the vehicle was parked before the parking charge was allegedly incurred;

(e) The PoC do not state exactly how the claim for statutory interest is calculated;

(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;

(g) The PoC states that the Claimant is suing the defendant as the driver or the keeper. The claimant obviously knows whether the defendant is being sued as the driver or the keeper and should not be permitted to plead alternative causes of action.

4. The Defendant has attached to this defence a copy of an order made at another court which the allocating judge ought to make at this stage so that the Defendant can then know and understand the case which he/she/it faces and can then respond properly to the claim.

Statement of truth

I believe that the facts stated in this Defence are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed:


Date:

Draft Order for the defence (https://www.dropbox.com/scl/fi/o1xbmqxzmgn4dv9el96kd/Draft-Order.pdf?rlkey=td1ajprejse2mgq6z9x0fgahr&st=wqng5ecp&dl=0)

You only need to edit in the defence your name, the claim number and sign the defence by typing your full name for the signature and dating it. There is nothing to edit in the draft order.

When you have done that, you attach both files in PDF format to an email to claimresponses.cnbc@justice.gov.uk and CC in yourself. Make sure you include the claim number in the subject field of the email and in the body just put "Please find attached the defence and a draft order in the matter of UK Parking Control Ltd v [your full name] Claim No.: [claim number]"

After you have emailed it, you must get an auto-response from the CNBC.

Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on November 03, 2024, 04:11:43 pm
Attached, thank you

[attachment deleted by admin]
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on November 02, 2024, 12:16:29 pm
Please repost the claim form (suitably redacted this time) as we need to see the PoC in order to suggest the correct defence.
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on November 01, 2024, 05:44:25 pm
I have submitted the AOS on the MCOL Website.

thank you,

Mike
Title: Re: UKPC - Coventry - Private Car Park
Post by: ticmick66 on November 01, 2024, 05:27:51 pm
Thank you both, for the advice and catching my error.
Title: Re: UKPC - Coventry - Private Car Park
Post by: DWMB2 on November 01, 2024, 05:21:36 pm
I've removed that attachment as the MCOL password was showing.
Title: Re: UKPC - Coventry - Private Car Park
Post by: b789 on November 01, 2024, 05:08:32 pm
Easy one to get rid of. With an issue date of 30th October, you have until Monday 18th November to file your Acknowledgement of Service.

Follow the instructions in this PDF to submit the AoS:

https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0

There is nothing to be gained by delaying the AoS. Once the AoS has been submitted, you then have until 4pm on Monday 2nd December to file a defence.

Let us know when you've filed the AoS and we'll provide a defence and draft order you can send.
Title: UKPC - Coventry - Private Car Park
Post by: ticmick66 on November 01, 2024, 04:35:39 pm
Good afternoon all, I wonder if you can help with a question.

On the 7th of April 2024 I visited my Daughter at her Student Accommodation in Coventry, I was onsite for approximately 50 minutes, the parking is managed by UKPC. The local streets are Permit only parking, no Car Parks within a short walk, my Daughter was stressed because of the Course pressures and the need to complete dissertations, with her End exams looming ever closer.

Whilst I was inside the accommodation, a Private Car pulled up, photographed my Car, and then drove off, soon enough I got a letter through the door from UKPC.
I replied declining to Pay, explained why I was there and offered to pay a small fee for their admin costs.

I have had a variety of Debt collection companies contacting me, I have replied to most of them saying that I am dispute with UKPC, companies include:
ZZPS
GCTT
DCB

and finally today, an N1SDT Form from the CNBC with a claim for £262 which i feel needs to be taken a bit more seriously

Is this something I can fight, I am pretty stubborn when I think a company is being either unfair, or a complete rip-off as in the case of most PPC's.

Thank you in advance
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