Yes, you can log into their portal to view the "evidence" they say they have. It will need to be checked against what they were instructed to provide as part of the PAPDC.
If you can, download it all and host it on Google Drive, redacting only your personal information so we can see it. Make sure that you make the drive publicly visible.
Of course you don't pay it! Why on earth would you do that when any claim issued by the utter incompetents at Moorside Legal is easily defeated?
Respond to them by email with the following (and CC your sel:
Subject: Your Letter of Claim – PAPDC compliance and documents required
Dear Sirs,
Thank you for your email. I do not consent to using your portal; please correspond by email or post.
I note your Letter of Claim enclosed the Information Sheet, Reply Form and Financial Statement. However, the letter remains non-compliant in substance. It does not provide the information and documents necessary for informed engagement (PAPDC 3.1(a)–(d), 5.2), namely:
• The contractual basis alleged and the terms relied upon (clear images of the signage in force at the material time and a site plan showing locations/visibility).
• Evidence of the allegation, including contemporaneous images/observations and a stated period of parking (not merely a single timestamp).
• he Notice to Driver/Notice to Keeper relied upon, with dates and proof of posting; confirmation if you allege keeper liability under PoFA 2012 and, if so, the specific paragraphs relied upon; confirmation the location is relevant land.
• The landowner agreement/authority conferring standing to offer contracts and litigate in the operator’s name (unredacted as to authority and term).
• A full breakdown of the £170, identifying the principal sum and any add-ons with their legal basis and any interest calculation.
Your 7-day demand is inconsistent with the PAPDC. The earliest you could properly issue is 30 days after you provide the requested documents to me by email or post, and (if applicable) 30 days from receipt of my completed Reply Form, whichever is later. Uploading to a portal I have not agreed to use does not amount to provision. Please confirm you will not issue while the above documents are outstanding.
For the avoidance of doubt, I dispute the debt. Any attempt to recover an additional £70 is an impermissible double recovery. Trade association codes do not override statute or the small-claims costs regime; the add-on is not recoverable (see Excel Parking Services Ltd v Wilkinson (HHJ Jackson, 2020)).
Once you provide the documents listed, I will consider my position and return the Reply Form. If you issue proceedings without first complying with the PAPDC, I will seek a stay with directions and costs for unreasonable conduct under CPR 27.14(2)(g), relying on Webb Resolutions v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments v Park West Club (Part 20) [2003] EWHC 2872, and Charles Church Developments v Stent Foundations [2007] EWHC 855.
Please confirm that you will correspond by email or post and provide the above documents.
Yours faithfully,
[Keeper’s name]
[Postal address]
[Email]
Email the following to help@moorsidelegal.co.uk and CC yourself:
Dear Sirs,
Your so-called “Letter Before Claim” is a masterclass in procedural non-compliance. It reads less like a legal document and more like a payday loan advert—complete with “friendly team” and “flexible payment plans.” Charming, but irrelevant.
Let me be clear: this is not a compliant Letter Before Claim under the Pre-Action Protocol for Debt Claims. It fails to provide:
• The basis of the alleged claim (contract? tort? clairvoyance?)
• Any evidence whatsoever (no NtK, no signage, no landowner authority, no contract terms)
• A breakdown of the sum claimed (is the £170 damages, consideration, or just wishful thinking?)
• Copies of key documents relied upon
Your letter is devoid of substance, legal reasoning, and basic compliance. It does not enable informed dialogue, nor does it satisfy the requirements of paragraphs 3.1(a)–(d), 5.1, or 5.2 of the Protocol. It is procedurally defective and legally meaningless.
Should proceedings be issued on the back of this nonsense, 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.
Unless a compliant Letter Before Claim is issued, I will be referring this matter to the Solicitors Regulation Authority (SRA) under Rule 1.4 and Rule 2.1 of the SRA Code of Conduct for Firms, on the basis that your conduct:
• Misrepresents the legal status of the claim
• Fails to uphold proper standards of legal service
• Demonstrates a lack of integrity and competence in pre-action procedure
Should your client issue proceedings based on this defective LoC, I will present it to the court as evidence of unreasonable conduct and procedural non-compliance. I will seek:
• An immediate stay under paragraph 15(b) of the Practice Direction
• A costs order under CPR 27.14(2)(g) for unreasonable behaviour
• Sanctions under paragraphs 13 and 16 of the Practice Direction
If your client wishes to pursue this matter, I suggest they instruct solicitors capable of drafting a compliant Letter of Claim. Until then, I am under no obligation to respond further.
Yours faithfully,
[Your name]