Send the following by email to info@dcblegal.co.uk and CC yourself:
Subject: Claim [Court ref] — Request for copy N1 and confirmation of signatory’s authorisation
Dear Sirs,
I am the Defendant (litigant in person). Following notice of a CCJ in default, I received the Particulars of Claim from the Civil National Business Centre by email on [date], but I have never been provided with the N1 (claim form) for this matter.
Please provide, within 7 days:
1. A copy of the N1 claim form, including the statement of truth and signature block.
2. The name, role, and authorisation basis of the individual who signed/verified the N1 and/or Particulars of Claim, together with confirmation that they were authorised to conduct litigation for the purposes of the Legal Services Act 2007 at the time. If you say they were authorised, please identify the statutory/regulatory basis (e.g. practising certificate/authorisation number).
3. If the N1/PoC were signed by Ms Sarah Ensall, please confirm whether she is an authorised person with a right to conduct litigation. Conduct of litigation is a reserved legal activity under the LSA 2007. Recent binding High Court authority confirms that unauthorised individuals may not conduct litigation, even under supervision.
If you cannot provide satisfactory evidence that the claim was issued and verified by an authorised person, I will place this correspondence before the court at the set-aside hearing, invite the court to disallow any fixed costs included in the default judgment, and seek my own application costs. I also reserve the right to report this to the SRA as a potential breach of the LSA 2007 and the SRA Principles.
Please confirm receipt and provide the requested material within 7 days.
Without prejudice to my primary position, given that my N244 has already been filed and no fee has yet been requested by the CNBC, please confirm by return that you consent to the set-aside of the default judgment at your client’s cost and will (i) file/agree a consent order for the judgment to be set aside on the papers, (ii) ask the court to process the order without requiring my fee, or, if the court nevertheless requests payment, (iii) reimburse me in full immediately on proof of payment. Please also confirm that enforcement is stayed pending disposal of the set-aside.
If you decline to proceed by consent on the above basis, I will place this letter before the court on costs. Your refusal to agree a cheaper, quicker route will be relied on when I invite the court to make an adverse costs order.
Yours faithfully,
[Full name]
[Postal address]
[Email]
No. You need to be much more thorough and it needs to go directly to their DPO. So, address the following email to dpocontact@dcblegal.co.uk and you CC response@dcblegal.co.uk and also yourself:
Subject Access Request – [Your Name] – [Claim or reference number: Reference Number]
Dear Sir or Madam,
I am writing to you as the data subject under Article 15 of the UK General Data Protection Regulation and the Data Protection Act 2018.
Please supply the personal data you hold about me, which I am entitled to receive under data protection law. This includes, but is not limited to:
1. A full copy of all personal data you hold about me in any form (electronic, paper, or otherwise), including correspondence, notes, logs, call recordings, and internal communications.
2. Copies of all correspondence, notices, and letters you claim to have sent to me, including any Letter of Claim.
3. Metadata and/or system notes showing the date each such document was generated and issued.
4. Proof of posting for every item of correspondence sent to me, including the method of posting, date, and location. If you cannot provide proof of posting, please confirm this in writing.
5. Copies of all data you have received from third parties (such as the parking company or their agents) relating to me.
6. Records of any data sharing, including with the County Court Business Centre or the Claimant.
7. The source of my personal data, if not collected directly from me.
Please also confirm:
• The purposes for which you are processing my data.
• The categories of personal data concerned.
• The recipients or categories of recipient to whom my data has been or will be disclosed.
• The envisaged retention period for my personal data.[/indent@]
For the avoidance of doubt, I expressly rebut any presumption that a Letter of Claim was served on me. You are therefore put to strict proof that it was in fact posted. Proof of posting is required in order to rely on the presumption of delivery.
This request is made in full knowledge that you have already used my personal data to allegedly issue a Letter of Claim, commence proceedings via the Civil National Business Centre, and obtain a default judgment. Accordingly, there can be no reasonable requirement for you to seek further identification before responding.
Please treat this as a Subject Access Request. I require the information to be provided within one calendar month as required by law.
Yours faithfully,
[Your full name]
[Your address]
[Your reference/claim number]
For Q5, you should definitely request a hearing. Do not agree to it being decided on the papers. At a hearing, you’ll have the chance to explain directly to the judge what has happened. In many cases the claimant doesn’t bother to attend, so you may have the judge’s full attention without challenge.
Regarding evidence of postal problems, anything you can show is useful, even if it’s just a transcript of previous interactions about missing post. It helps to show a consistent pattern.
Remember that the presumption of delivery of both the Letter of Claim and the claim form can be rebutted. Under the Interpretation Act 1978, once you state you never received them, the burden shifts back. The claimant must then show proof of posting, and the court service centre (CNBC) must do the same for the claim form. Neither DCB Legal nor CNBC use recorded delivery, so they cannot rely on “proof of delivery” — they must be able to produce proof of posting.
Have you contacted the CNBC yet? You should ask them for a copy of the Particulars of Claim and the issue date of the claim. At the same time, tell them that you never received the claim form and that you are challenging the presumption of delivery. Make clear that you require proof of posting if they are to rely on it.
Use something like this for your WS:
In the County Court
Claim number: [Claim number]
Between ParkMaven Ltd (Claimant)
and
[Your full name] (Defendant)
Witness Statement (supporting N244 application)
1. I make this statement in support of my application to set aside the default judgment dated 20 August 2025.
2. I did not receive a Letter of Claim from the claimant’s solicitors prior to proceedings being issued, nor did I receive the claim form from the court. I only became aware of the matter when I received the default judgment. I acted promptly in making this application once I became aware of it.
3. I have experienced continuing issues with unreliable post at my address. I can provide evidence of missing or misdelivered items to demonstrate that postal service to my property has been erratic.
4. The presumption of delivery under the Interpretation Act 1978 is rebuttable. Having clearly stated that neither the Letter of Claim nor the claim form were received, the burden is on the claimant and the Civil National Business Centre to provide proof of posting if they seek to rely on that presumption. Neither uses recorded delivery, therefore they must be able to produce at least proof of posting.
5. I have contacted the Civil National Business Centre to obtain a copy of the Particulars of Claim and the issue date. I have also put them on notice that I challenge the presumption of delivery and require proof of posting.
6. A Subject Access Request was sent to the claimant’s solicitors on [insert date] requesting copies of the Letter of Claim and any proof of posting. They have 30 days to respond. At present I have no evidence that a Letter of Claim was ever served. I put the claimant to strict proof of service of both the Letter of Claim and the claim form.
Real Prospect of Defence
7. I also submit that I have a real prospect of successfully defending this claim should it proceed. I am a Blue Badge holder with protected characteristics under the Equality Act 2010. If the claimant issued a Parking Charge Notice against my vehicle without making reasonable adjustments for my disability, then the charge is unlawful and unenforceable.
8. I further believe the claimant’s signage and contractual terms will not withstand scrutiny. Based on my past experience with private parking operators, their notices often fail to comply with the Protection of Freedoms Act 2012, and the amount claimed is likely to include sums that constitute an abuse of process. These are all valid grounds of defence that I intend to raise in full once the Particulars of Claim are disclosed.
9. Accordingly, even if the court were to conclude that the claim form was served, there remains a good reason to set aside judgment under CPR 13.3, as I have a realistic and arguable defence and I acted promptly upon discovering the judgment.
Costs
10. I recognise that the service of the claim form is the responsibility of the Civil National Business Centre rather than the claimant. I therefore do not suggest that the claimant should be held responsible for any fault in that process.
11. However, I did not receive a Letter of Claim from the claimant’s solicitors before proceedings were issued. This is a requirement of the Pre-Action Protocol for Debt Claims. I have submitted a Subject Access Request to the claimant’s solicitors to obtain a copy of the Letter of Claim and proof of posting. Unless they can provide evidence that it was served, they will have failed to comply with the Protocol. In that case, I will ask the court to consider whether the £313 application fee should properly be borne by the claimant, as their failure to follow the required pre-action steps gave rise to unnecessary litigation.
12. In addition, if the claimant chooses to discontinue the claim following set aside, I reserve the right to seek recovery of my £313 under CPR 38.6 and CPR 27.14(2)(g). To discontinue after forcing me to incur the costs of this application would amount to unreasonable conduct.
Statement of Truth
I believe that the facts stated in this witness statement 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.
Use the following as your draft order:
Draft Order
Upon the application of the Defendant dated [insert date], and upon reading the evidence filed, it is ordered that:
1. The default judgment dated [insert date of judgment] be set aside pursuant to CPR 13.2 and/or CPR 13.3.
2. The Claim is reinstated.
3. The Claimant shall within 14 days of service of this order file and serve evidence of service of any Letter of Claim relied upon.
4. The Defendant shall file and serve a Defence within 14 days after the Claimant has complied with paragraph 3, or within 14 days of the court confirming that no such evidence is produced.
5. The Claimant shall pay the Defendant’s costs of this application, being the £313 court fee, unless the court is satisfied that the default judgment arose solely due to a failure of service by the court.
For Q3, you should write that you are asking the court to set aside the default judgment because you never received the claim form and therefore had no opportunity to defend. State that you are applying under CPR 13.2 and CPR 13.3. That wording covers both the mandatory set aside (if the court accepts the claim was never served) and the discretionary set aside (because you acted promptly and have a reasonable defence).
For Q4, you need to provide a short draft order showing what you want the judge to make. You do not need to overcomplicate this. Something like:
1. The default judgment dated [insert date] is set aside.
2. The defendant shall file and serve a defence within 14 days of the date of this order.
3. The claimant shall pay the defendant’s costs of this application.
Alongside the draft order you also need to attach your witness statement, which is your evidence. In that you explain that you never received the Letter of Claim or the claim form, that you only became aware of the case when you saw the default judgment dated 20 August, that you have had issues with unreliable post, and that you acted promptly once you found out. You can also explain that a Subject Access Request has been sent to the claimant’s solicitors asking for a copy of the Letter of Claim and proof of posting, and that you put them to strict proof of having properly served it. Make clear that even though you are waiting for their response, you are applying now to avoid any delay. You can also mention you hold a Blue Badge and therefore may have a valid defence under the Equality Act if the claim continues.
For Q9, you simply state that the application should be served on the claimant, which in practice will be via their legal representative DCB Legal. The court will take care of service, you do not need to serve it yourself.
In short:
Q3: Say you want the judgment set aside under CPR 13.2 and 13.3.
Q4: Provide the short draft order and attach your witness statement.
Q9: Write that the application should be served on the claimant through DCB Legal.
That covers the essentials the judge needs. Just show us what you have before you submit it so we can check it.