Trust me, no human was involved in generating that letter. It is a boilerplate that we see every day. It means nothing.
Having received your own N180 (make sure it is not simply a copy of the claimants N180), do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own here and fill it in on your computer. You sign it by simply typing your full name in the signature box.
https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
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.
When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
On what date did you complete the AoS? With a claim date of 21st November, you had until Tuesday 10th December to submit the AoS.
If the AoS was submitted within the deadline, you then have until 4pm on Tuesday 24th December to submit your Defence.
This is very easy to defend and I can tell you that it will never get to a hearing as they will discontinue before they have to pay the trial fee. It is a well known modus operandi of DCB Legal on behalf of their clients. They hope that you are low-hanging fruit on the gullible tree and will capitulate one litigation starts or else screw up the process and they will try and get a default CCJ.
Now that you are here, you will not be paying a penny to ECP.
Here's your defence. You only need to edit your name, the claim number and then sign it bye typing your full name for the signature and dating it. There is also a draft order to go with it and there is nothing to edit in that.
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=q2jva7s0&dl=0)
When done, save both as PDF files and attach them to an email addressed to claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim number must be in the email subject field and in the body of the email just 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]".
That's it for now.