You also need to put the following date in your diary and do not miss it... Wednesday 21st May. On that date you send the following to the same email address as the previous correspondence:
Dear Sirs,
Re:Letter of Claim dated 20 March 2025 – [Your Reference]
I refer to your Letter of Claim dated 20 March 2025 and to my earlier response dated 22nd April 2025 indicating that I was seeking debt advice. I now write further to request the following information...
I confirm that my address for service at this time is as follows, and I request that any outdated address be erased from your records to ensure compliance with data protection obligations:
[YOUR ADDRESS]
Please note that the alleged debt is disputed, and any court proceedings will be robustly defended.
I note that the sum claimed has been increased by an excessive and unjustifiable amount, which appears contrary to the principles established by the Government, who described such practices as “extorting money from motorists.” Please refrain from sending boilerplate responses or justifications regarding this issue.
In accordance with the Pre-Action Protocol for Debt Claims, I now request specific information and documentation in order to understand your client’s claim and to obtain further advice:
1. Does the additional £70 represent what you describe as a “Debt Recovery” fee? If so, is this figure net of or inclusive of VAT? If inclusive, I trust you will explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.
2. Regarding the principal sum of the alleged Parking Charge Notice (PCN): Is this being claimed as damages for breach of contract, or will it be pleaded as consideration for a purported parking contract?
3. Please provide a copy of the current, unredacted contract or chain of contracts between your client and the landowner that authorises your client to issue parking charges at the site and pursue them through litigation. If redacted, please ensure that the date, scope, and parties to the contract are visible.
4. Please provide all photographs relied upon, including time-stamped images of the vehicle and of the signage said to form the basis of the contract. Please also supply evidence of the ANPR system’s calibration and maintenance logs for the 30-day period surrounding the alleged contravention.
5. Please supply a site map or plan showing the location and layout of signage at the location on the material date, including evidence of visibility from the entry point and any alleged parking bay.
6. Please provide a copy of the original Notice to Keeper (NtK) and confirm whether your client intends to rely on the Protection of Freedoms Act 2012 to pursue the registered keeper.
7. Please confirm the date and lawful basis on which your client accessed my data from the DVLA and provide a copy of the DVLA request log relating to this vehicle.
8. Please supply a fully itemised breakdown of the amount claimed and identify the legal basis for each element of the claim (principal, interest, recovery fees, etc.).
9. Please clarify the cause of action relied upon: is this a claim in contract, breach of contract, or trespass? If contract is relied upon, please explain which terms are alleged to have been breached.
I would caution you against dismissing these questions with vague or boilerplate responses. For example, by claiming that PCNs are exempt from VAT while simultaneously inflating the debt recovery element, your client – with your assistance – appears to be evading VAT obligations owed to HMRC. Such conduct raises serious concerns regarding the legality and ethicality of these practices.
I strongly advise your client to cease and desist. Should this matter proceed to court, you can be assured that these issues will be brought to the court’s attention, alongside a robust defence and, if appropriate, a counterclaim for unreasonable conduct.
Yours faithfully,
[Your Name]
DO NOT send these email any earlier or later than the dates I have given you.