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 help@moorsidelegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
Subject: Claim number [xxxx] – your email dated [date]
Dear Sirs,
I acknowledge receipt of your email.
It is remarkable that Moorside Legal, having itself drafted and issued the Particulars of Claim, now seeks to suggest that the deficiencies identified in my Defence are mere “technicalities”. They are not. They are the direct result of your firm’s failure, as SRA‑regulated solicitors, to plead a coherent cause of action in compliance with CPR 16.4 and PD 16 at the point you chose to issue proceedings.
You were put on express notice in the Defence, with reference to the persuasive appeal decisions in Civil Enforcement Ltd v Chan and CPMS v Akande, that claims issued in materially similar form have been struck out for failure to comply with CPR 16.4. Instead of taking the proper procedural step of applying to amend and serve compliant particulars (and accepting the risks and consequences that flow from having issued a defective claim), you are attempting to “particularise” the claim by correspondence.
That is not how civil litigation works. A solicitor’s letter is not a statement of case. It is not verified by a statement of truth. It does not amend pleadings. It cannot cure defective Particulars of Claim, and it cannot retrospectively manufacture a properly pleaded cause of action after a Defence has exposed the inadequacy of the claim as issued.
Your suggestion that there is “no prejudice” because I “clearly understand the nature of the claim” is untenable. CPR 16.4(1)(a) requires the facts relied on to be pleaded, and CPR 16.4(1)(c) requires the remedy sought to be stated. I am entitled to know the case I have to meet from your client’s pleaded statement of case, not from informal narrative offered after the event. If your client wishes to pursue this claim properly, you must follow the rules: seek the Court’s permission where required, file and serve properly pleaded amended particulars, and accept any directions the Court considers appropriate. Any attempt to proceed while treating correspondence as a substitute for compliant pleadings will be opposed.
Your email also continues to advance “driver or keeper” liability in the alternative without pleading a coherent factual and legal basis for either route. That is precisely the type of vague, hedged pleading criticised in cases of this kind and it reinforces the point that this claim was issued without proper legal analysis.
For the avoidance of doubt, I will retain this correspondence. If your client persists with this claim to allocation and beyond, I will place this email before the Court as part of my evidence bundle to demonstrate that (1) your firm was on notice of the pleaded defects and the relevant persuasive authorities, and (2) your firm nonetheless attempted to bypass the CPR pleading requirements by seeking to retrofit a case via correspondence. I will invite the Court to consider whether such conduct is unreasonable and whether case management sanctions are appropriate.
Further, if the claim is discontinued at a late stage (including after allocation, after directions, or close to any final hearing), I will rely on the history of this matter, including this correspondence, when seeking my costs under CPR 27.14(2)(g) on the basis of unreasonable conduct.
Your settlement proposal is declined. I am content for this matter to be determined by the Court.
Email service: I will accept service of documents by email only if they are served as complete, legible PDF attachments. Please confirm you will serve documents in that manner. I also note your offer to accept service at litigationteam@moorsidelegal.co.uk in PDF format.
Nothing in this email is any admission as to the alleged event, the existence of any contract, the adequacy of signage, or liability as driver or keeper. All rights are reserved.
Yours faithfully,
[Name]
[Address]
[Email]
[Claim number]
1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and does not adequately disclose any comprehensible cause of action.
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(1)(a).
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 PD 16, para 7.3(1);
(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 adequately set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts)
(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 precisely how the sum claimed is calculated, including the basis for any statutory interest, damages, or other charges;
(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;
(g) The PoC do not provide clarity on whether the Defendant is sued as the driver or the keeper of the vehicle, as the claimant cannot plead alternative causes of action without specificity.
4. The Defendant submits that courts have previously struck out similar claims of their own initiative for failure to adequately comply with CPR 16.4(1)(a), particularly where the Particulars of Claim failed to specify the contractual terms relied upon or explain the alleged breach with sufficient clarity. The Defendant refers specifically to the persuasive appellate cases:
- Civil Enforcement Ltd v Chan (2023), Luton County Court, HHJ Murch, ref: E7GM9W44
- CPMS Ltd v Akande (2024), Manchester County Court, HHJ Evans, ref: K0DP5J30
In both cases, the claim was struck out due to materially similar failures to comply with CPR 16.4(1)(a).
5. The Defendant invites the Court to strike out this claim of its own initiative. The Defendant relies on the judicial reasoning set out in Chan and Akande, as well as other County Court cases involving identical failures to adequately comply with CPR 16.4. In those cases, the court further observed that, given the modest sum claimed, requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, the judge struck out the claim outright rather than permitting an amendment. The Defendant proposes that the following Order be made:
Draft Order:
Of the Court's own initiative and upon reading the particulars of claim and the defence.
AND the court being of the view that the particulars of claim do not comply with CPR 16.4(1)(a) because: (a) they do not set out the exact wording of the clause (or clauses) of the terms and conditions of the contract (or contracts) which is (or are) relied on; and (b) they do not adequately set out the reason (or reasons) why the claimant asserts that the defendant was in breach of contract.
AND the claimant could have complied with CPR 16.4(1)(a) had it served separate detailed particulars of claim, as it could have done pursuant to PD 7C, para 5.2, but chose not to do so.
AND upon the Court determining, having regard to the overriding objective (CPR 1.1), that it would be disproportionate to direct further pleadings or to allot any further share of the Court’s resources to this claim (for example by ordering further particulars of claim and a further defence, with consequent case management).
ORDER:
1. The claim is struck out.
2. Permission to either party to apply to set aside, vary or stay this order by application on notice, which must be filed at this Court not more than 7 days after service of this order, failing which no such application may be made.
Dear Sirs,
Re: Your response dated 18 August 2025 – Non-Compliance with Pre-Action Protocol
I refer to your email of 18 August 2025 and attachments, claiming a £170 balance on a Parking Charge Notice (PCN). Your reply remains deficient and in breach of the Civil Procedure Rules 1998, Part 3 Pre-Action Protocol for Debt Claims and the accompanying Practice Direction.
Despite your assertions, you have not provided:1. The original Notice to Keeper under the Protection of Freedoms Act 2012.
2. Photographic evidence of the actual signage displayed on the date in question, in situ.
3. The precise wording of the clause(s) within the Terms and Conditions you allege were breached.
4. The written contract between your client and the landowner, establishing enforcement authority.
5. A full breakdown of the £100 principal sum (clarifying whether sought as consideration or damages) and the £70 “recovery” fee, including VAT status and actual recovery costs.
These documents are mandatory under:- Pre-Action Protocol for Debt Claims, ¶3.1(a)–(d), 5.1–5.2
- Practice Direction, ¶6(a), 6(c)
Please provide the above documents within 7 days of this letter. Should you fail to do so, I will:- Apply for a stay of any proceedings under Practice Direction ¶15(b).
- Seek sanctions and an adverse costs order against your client and yourselves personally for non-compliance under Practice Direction ¶13, ¶16 and Protocol ¶7.2.
Once compliant disclosure is received, I will seek advice and deliver my substantive response within 30 days, as required. Until then, any attempt to issue proceedings will be premature and opposed on grounds of procedural unfairness, with immediate applications for case-management relief and costs.
Yours faithfully,
[Your Name]
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]
Come back when you receive a Letter of Claim (LoC). As advised, you can safely ignore Trace or any other debt recovery firm. We dob[t need to know about a powerless debt collector. All they can do is try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear. They certainly cannot give you a CCJ and here is why:
What CCJ? Do you have any understanding of how someone gets a CCJ? Nothing we advise on here will make anyone get a CCJ.QuoteA County Court Judgment (CCJ) does not just happen—it follows a clear legal process. If someone gets a Parking Charge Notice (PCN) from a private parking company, here's what happens step by step:1. Parking Charge Notice (PCN) Issued• The parking company sends a letter (Notice to Keeper) demanding money.
• This is not a fine—it’s an invoice for an alleged breach of contract.
2. Opportunity to Appeal• The recipient can appeal to the parking company.
•If rejected, they may be able to appeal to POPLA (if BPA member) or IAS (if IPC member).
• If an appeal is lost or ignored, the parking company demands payment.
3. Debt Collection Letters• The parking company might send scary letters or pass the case to a debt collector.
• Debt collectors have no power—they just send letters and can be ignored.
• No CCJ happens at this stage.
4. Letter Before Claim (LBC)• If ignored for long enough, the parking company (or their solicitor) sends a Letter Before Claim (LBC).
• This is a warning that they may start a court case.
• The recipient has 30 days to reply before a claim is filed.
• No CCJ happens at this stage.
5. County Court Claim Issued• If ignored or unpaid, the parking company may file a claim with the County Court.
• The court sends a Claim Form with details of the claim and how to respond.
• The recipient has 14 days to respond (or 28 days if they acknowledge it).
• No CCJ happens at this stage.
6. Court Process• If the recipient defends the claim, a judge decides if they owe money.
• If the recipient ignores the claim, the parking company wins by default.
• No CCJ happens yet unless the recipient loses and ignores the court.
7. Judgment & Payment• If the court rules that money is owed, the recipient has 30 days to pay in full.
• If they pay within 30 days, no CCJ goes on their credit file.
• If they don’t pay within 30 days, the CCJ stays on their credit file for 6 years.
Conclusion
CCJs do not appear out of thin air. They only happen if:• A parking company takes the case to court.
• The person loses or ignores the case.
• The person fails to pay within 30 days.
If you engage with the process (appeal, defend, or pay on time), no CCJ happens.
A County Court Judgment (CCJ) does not just happen—it follows a clear legal process. If someone gets a Parking Charge Notice (PCN) from a private parking company, here's what happens step by step:1. Parking Charge Notice (PCN) Issued• The parking company sends a letter (Notice to Keeper) demanding money.
• This is not a fine—it’s an invoice for an alleged breach of contract.
2. Opportunity to Appeal• The recipient can appeal to the parking company.
•If rejected, they may be able to appeal to POPLA (if BPA member) or IAS (if IPC member).
• If an appeal is lost or ignored, the parking company demands payment.
3. Debt Collection Letters• The parking company might send scary letters or pass the case to a debt collector.
• Debt collectors have no power—they just send letters and can be ignored.
• No CCJ happens at this stage.
4. Letter Before Claim (LBC)• If ignored for long enough, the parking company (or their solicitor) sends a Letter Before Claim (LBC).
• This is a warning that they may start a court case.
• The recipient has 30 days to reply before a claim is filed.
• No CCJ happens at this stage.
5. County Court Claim Issued• If ignored or unpaid, the parking company may file a claim with the County Court.
• The court sends a Claim Form with details of the claim and how to respond.
• The recipient has 14 days to respond (or 28 days if they acknowledge it).
• No CCJ happens at this stage.
6. Court Process• If the recipient defends the claim, a judge decides if they owe money.
• If the recipient ignores the claim, the parking company wins by default.
• No CCJ happens yet unless the recipient loses and ignores the court.
7. Judgment & Payment• If the court rules that money is owed, the recipient has 30 days to pay in full.
• If they pay within 30 days, no CCJ goes on their credit file.
• If they don’t pay within 30 days, the CCJ stays on their credit file for 6 years.
Conclusion
CCJs do not appear out of thin air. They only happen if:• A parking company takes the case to court.
• The person loses or ignores the case.
• The person fails to pay within 30 days.
If you engage with the process (appeal, defend, or pay on time), no CCJ happens.