Why would you want to do the claimants job for them. If the Particulars of Claim (PoC) are insufficient for you to plead a proper defence then they are in breach of CPR 16.4.
Here is the suggested defence you should submit. You only need to edit your full name, the claim number and then to sign it by typing your full name for the signature and dating it. There is also a draft order that will be submitted with the defence and nothing needs editing in that. When done, both documents should be saved as PDF files and attached to an email which is sent to claimresponses.cnbc@justice.gov.uk and CC in yourself. Make sure that the claim number is in the email subject field and in the body of the email put "Please find attached the defence and draft order in the matter of Euro Car Parks Ltd v [your full name] Claim No.: [claim number]".
IN THE COUNTY COURT
Claim No: [Claim Number]
BETWEEN:
Euro Car Parks 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 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;
(d) The PoC do not state exactly how the claim for statutory interest is calculated;
(e) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;
(f) 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/gmpkg6f843yga1sw1iwdo/short-defence-order.docx?rlkey=ppd7dwlale9j25111548n2e1j&st=tmkjgu6v&dl=0)
Welcome.
cp8759 deals mostly with council/decriminalised PCNs, but the rest of us can help you.
the registered keeper was my partner [...] It is my name on the paperwork
This suggests that some correspondence was exchanged with ECP by someone at some point. That said, if you definitely were not the keeper of the vehicle, that makes the following statement in the particulars of claim even more ridiculous:
"In the alternative the defendant is pursued as the keeper pursuant to POFA 2012, Schedule 4"
Proof if ever it were needed that DCB Legal make absolutely no effort to check the details of the cases before wheeling out their standard wording.
You're correct that the next step is to acknowledge service. There is nothing to be gained by delaying the AoS. Follow the advice in this PDF on how to file the AoS:
https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0 (https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0)
When you have submitted the AoS, let us know.
A clear pattern has emerged with DCB Legal, especially with claims for single tickets, like this one, where as long as the case is defended, they eventually discontinue before the matter reaches a court hearing. For some background reading into this pattern, read the following: DCB LEGAL RECORD OF PRIVATE PARKING COURT CLAIM DISCONTINUATIONS (https://forums.moneysavingexpert.com/discussion/6377263/dcb-legal-record-of-private-parking-court-claim-discontinuations)