For the mediation call, the only requirement is for you "attend" the call. It is not part of the judicial process and no judge is involved.
This is what I advise you to say when you receive the call from the mediator:
“Before I set out my position, please confirm from the claimant’s side:
• the full name of the person attending for them;
• their role/position at their legal representative’s firm; and
• whether they hold written authority to negotiate and settle today.
Please relay that back to me before we continue.”
After the mediator calls back...
If identified and authority confirmed:
“Thank you. I’m content to proceed on that basis. My settlement offer is £0, or I invite the claimant to discontinue with no order as to costs.”
If no/unclear authority:
“Please record that the claimant’s attendee has not confirmed settlement authority. My position remains that liability is denied and my offer is £0, subject to prompt approval by an authorised solicitor if they choose to discontinue.”
If the mediator probes your defence:
”In what capacity are you asking that question? Are you legally trained? If not, please refrain from offering opinions. I will be reporting any attempt to do so as inappropriate.”
All you need to know is the name and the position of the person acting for the claimant and report that back to us. It will be over within minutes. Complete waste of time otherwise.
Just wait for your own N180 DQ to arrive, or better still, check your MCOL history and as soon as it says your DQ has been sent, follow this advice:
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.
I seriously doubt that that response is from CUP. If you are going to tell us about anything, then please get the facts right and check exactly who sent you that response.
I am sure that it is from DCB Legal, not CUP. It is a boilerplate response to your request in response to their LoC. You can tell it is from the incompetents at DCB Legal because they always have the embarrassing grammatical error in their letter:
Had you of paid as per the Contract...
However, that response should have been given before they issued the claim. Not that it will alter the predicted outcome, but I suggest you send the following email to the SRA at report@sra.org.uk and CC yourself, so that this breach is on the recored:
Subject: DCB Legal Ltd – issuing proceedings before complying with the Pre-Action Protocol for Debt Claims
Dear Sirs,
I wish to report conduct by DCB Legal Ltd which, in my view, breaches the Pre-Action Protocol for Debt Claims (PAPDC) and falls below the standards required by the SRA Standards and Regulations.
Firm: DCB Legal Ltd
Your ref: [ABCDEFGHCUP]
Court: N1SDT claim issued 18/08/2025 (received 22/08/2025)
Chronology
• 15/07/2025 – DCB Legal served a Letter of Claim.
• ~05/08/2025 – I replied under the PAPDC asking for the key documents (NtK/PoFA basis, landowner authority, contemporaneous signage, and the precise terms relied upon), expressly saying I would give a substantive response within 30 days of receipt, as envisaged by PAPDC 5.1–5.2.
• 18/08/2025 – Without providing those documents, DCB Legal issued proceedings. Claim received 22/08/2025.
• 11/09/2025 – Only after issue did DCB Legal send a “response” enclosing documents.
Why this is a regulatory concern
The PAPDC requires creditors, on request, to provide documents and information so parties can understand each other’s position before proceedings (PAPDC 5.1–5.2), read with the Practice Direction – Pre-Action Conduct (PD-PAC) which emphasises early exchange of key documents and permits the court to impose sanctions for non-compliance (PD-PAC paras 6(a)–(c), 13–16). Issuing first and answering the protocol request afterwards frustrates those aims.
In my view this engages:
• SRA Principles 1, 2 and 5 (proper administration of justice; public trust and confidence; integrity).
Solicitors Regulation Authority
• SRA Code of Conduct for Solicitors: para 1.2 (not taking unfair advantage of others) and para 2.6 (do not waste the court’s time). Your “Conduct in disputes” guidance also expects solicitors to comply with pre-action obligations.
Solicitors Regulation Authority
Outcome sought
Please consider whether DCB Legal’s approach—issuing a claim before responding to a live PAPDC request—complies with the above standards. I ask that you review this matter and take any action you consider appropriate.
Evidence attached
DCB Legal Letter of Claim dated 15/07/2025.
My PAPDC response (~05/08/2025) requesting documents.
N1SDT Claim Form (issue 18/08/2025; received 22/08/2025).
DCB Legal’s post-issue response dated 11/09/2025 with enclosures.
Yours faithfully,
[Full name]
[Postal address]
[Email] [Telephone]
DCB Legal are an incompetent lot. Just reply to the LoC with the following to info@dcblegal.co.uk and CC yourself:
Dear Sirs,
Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of evidence your client places reliance upon and thus is in complete contravention of the Pre-Action Protocol for Debt Claims.
As a firm of supposed solicitors, one would expect you to be capable of crafting a letter that aligns with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and 6(c) of the Practice Direction. These provisions do not exist for decoration—they exist to facilitate informed discussion and proportionate resolution. You might wish to reacquaint yourselves with them.
The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols (Part 3), stipulate that prior to proceedings, parties should have exchanged sufficient information to understand each other’s position. Part 6 helpfully clarifies that this includes disclosure of key documents relevant to the issues in dispute.
Your template letter mentions a “contract”, yet fails to provide one. This would appear to undermine the only foundation upon which your client’s claim allegedly rests. It’s difficult to engage in meaningful pre-litigation dialogue when your side declines to furnish the very document it purports to enforce.
I confirm that, once I am in receipt of a Letter Before Claim that complies with the requirements of para 3.1 (a) of the Pre-Action Protocol, I shall then seek advice and submit a formal response within 30 days, as required by the Protocol. Thus, I require your client to comply with its obligations by sending me the following information/documents:
1. A copy of the original Notice to Keeper (NtK) that confirms any PoFA 2012 liability
2. A copy of the contract (or contracts) you allege exists between your client and the driver, in the form of an actual photograph of the sign you contend was at the location on the material date, not a generic stock image
3. The exact wording of the clause (or clauses) of the terms and conditions of the contract(s) which is (are) relied upon that you allege to have been breached
4. The written agreement between your client and the landowner, establishing authority to enforce
5. A breakdown of the charges claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” fee includes VAT
I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).
If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.
Until your client has complied with its obligations and provided this information, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.
Yours faithfully,
[Your name]