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.”
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.
Email back to info@dcblegal.co.uk and CC yourself with the following response:
Subject: Formal Complaint — Failure to Locate File / Unwarranted Rejection of Correspondence — Reference [Your reference]
Dear Litigation Team Leader,
This is a formal complaint.
On [date of first email] I provided the information your office requested (full name; first line address and postcode; DCB Legal reference number). Your subsequent automated reply claimed my message contained “offensive language” and was therefore not passed to the relevant team. That assertion is false.
Details:
• My original email sent on: [date/time]
• Information provided: Full name: [Your name]; Address/postcode: [first line/postcode]; DCB Legal reference number: [number]
• Automated response received on: [date/time] (copy attached/quoted below)
This automated rejection is unacceptable. I require the following:
1. Immediate confirmation that my supplied information has been located and associated with the correct file.
2. A clear explanation of what triggered the automated “offensive language” rejection, including the specific phrase or token flagged and the name of the filtering system (if any).
3. A copy of the correspondence log showing how my emails were processed and why they were blocked.
4. Confirmation that my case will not be prejudiced or delayed because of an erroneous automated screening.
If you cannot provide the above within 7 calendar days, I will escalate this matter to the Solicitors Regulation Authority and the Information Commissioner’s Office for review of professional conduct and records handling. I will also consider a formal complaint to your firm’s senior management and any other relevant regulatory body.
Please treat this as a formal complaint under your firm’s complaints procedure and acknowledge receipt within 48 hours.
Yours sincerely,
[Your full name]
[Postal address]
[Email address]
Use your current address for service (the one that is operative today) on the N180.
You have already filed a Notice of Change making the new address effective from 8 October 2025. Until that date, the “old” address remains the formal address for service. Putting a future-dated address on the N180 would conflict with your filed notice.
In your covering email/letter when filing your N180, add one line:
“Please note: my address for service changes on 8 October 2025 to [new address], as previously notified under CPR Part 6/PD 42.”
On another note, I see that Gladstones have signed their own N180 as a corporate entity and not a named individual. This must be objected to. The person who has completed their N180DQ is conducting litigation and must be a named individual who is authorised to do so. A paralegal or anyone else conducting litigation, even under the supervision of a solicitor is not authorised and is likely in breach of the Legal Services Act 2007, which is a criminal offence.
I advise you to email the following to the CNBC at dq.cnbc@justice.gov.uk and CC in Gladstones at enquiries@gladstonessolicitors.co.uk and yourself:
Subject: Claim [number] – [Claimant] v [Defendant] – Defendant’s N180 + Objection to Claimant’s N180
Please find attached: (1) Defendant’s N180 (signed) and (2) Objection to Claimant’s N180 (signed PDF).
Address for service: [current address]. Please note: my address for service changes on 8 October 2025 to [new address], as previously notified under CPR Part 6/PD 42.
Copied to the Claimant’s solicitors.
Attach the following as a pdf file together with your pdf copy of your completed N180DQ:
County Court Business Centre (CNBC)
Claim no.: [XXXXXXX]
Parties: [Claimant] v [Defendant]
OBJECTION TO CLAIMANT’S N180 DIRECTIONS QUESTIONNAIRE (DEFECTIVE SIGNATURE & AUTHORISATION)
I object to the Claimant’s purported filing of Form N180, which is “signed” only as “Gladstones Solicitors Ltd” with no identified individual signatory.
Signature defect (PD 5A)
Form N180 requires a valid signature by the party or an identified legal representative. Practice Direction 5A requires documents to be signed where indicated by the person responsible; where that person acts as a member/employee of a firm, the firm’s name may be added, but a firm name alone is not a signature. The absence of an identified individual undermines accountability and is procedurally defective.
Conduct of litigation (Legal Services Act 2007)
Signing and filing an N180 is a step in the “conduct of litigation” within s.12 and Schedule 2 paragraph 4 of the Legal Services Act 2007. Only the party, an authorised person, or an exempt person under Schedule 3 may carry out reserved legal activities.
Mazur authority
The High Court in Mazur & Anor v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB) (16 September 2025) confirmed that employees who are not themselves authorised (and not within a Schedule 3 exemption) cannot conduct litigation, even if supervised. The individual who signs must personally be authorised (or exempt).
Potential statutory non-compliance
If the person who completed/signed the N180 is not authorised or exempt, carrying on a reserved legal activity may contravene s.14 of the Legal Services Act 2007.
Directions sought
A) That the Claimant be directed within 7 days to re-file and serve a properly signed N180 which:
(i) identifies the individual signatory by name and status/position; and
(ii) confirms that the signatory is authorised (or states the relied-upon Schedule 3 exemption) to conduct litigation.
B) That until compliance, the current N180 be treated as defective and disregarded for case-management purposes, with any further sanction at the Court’s discretion in the event of non-compliance.
Service
These documents are served on the Claimant’s solicitors by copy of this email.
Signed: [Defendant’s full name]
[Date]
For your reference, here are therein things you need to know about completing your own N180DQ:
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.
Please show us a copy of the N180 DQ form. DO NOT redact the name or position of the person who has signed that DQ form.
This is very important as there is a very recent High Court appeal decision which is binding that can be used against them as the person who has signed that form is quite possibly not authorised to do so.
That letter is a standard boilerplate response. You are waiting for your own N180 Directions Questionnaire (DQ) to arrive. Just follow these instructions:
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.
Tell the court currently holding the file (CNBC/Money Claim Online before transfer; your local hearing centre after transfer).
Also Gladstones. Under CPR 6.7, once solicitors are instructed, service is on them.
Send a short written “Notice of Change of Address for Service” (you can use Form N434 or a simple letter with the same information). The rules require parties to maintain an address for service and to notify changes; a notice should be filed at court and served on every other party.
Include:
• Claim number and parties
• Your full name
• Old address for service
• New address for service
• Effective date (e.g., “effective 8 October 2025”)
• Optional: “I also consent to service by email at: [email]” (this helps you receive documents promptly; consent is needed for valid email service).
File and send by email to the court (if that court accepts it) or post; keep proof of posting.
As for the claimant, serve by post to their service address on the claim (and email a courtesy copy). If you want email-only service to count, ensure they have expressly agreed to accept service by email.
Do it now, stating the effective date of 08/10/2025. If the case later transfers to your local county court, re-send the same notice to that court so their file is up to date.
Updating your details on the MCOL user profile is helpful for contact, but the rules still require a filed and served notice of the new address for service.
You can use this as a letter or complete Form N434
Subject: Notice of Change of Address for Service
Court: [CNBC/Hearing Centre]
Claim no.: [XXXXXXX]
Parties: [Claimant] v [Defendant]
I, [full name], the Defendant, give notice under CPR Part 6 and PD 42 that my address for service has changed.
Old address for service: [full old address]
New address for service: [full new address]
Effective date: 8 October 2025
Please update the court record.
I also consent to service by email at: [email address].
Signed: [name]
Dated: [date]
Served on: the Claimant/Gladstones Solicitors at their address for service.
The PoC in any Gladstones issued claim never comply with CPR 16.4(1)(a) as they never include a concise statement of the facts on which the claimant relies. Think of CPR 16.4(1)(a) as the rule that says: if you sue someone, you must tell them, in short but clear terms, exactly what facts you rely on. Not conclusions, not labels, but the basic story: what contract, what term, what was done wrong, where and when, and how the sum is made up.
The PoC in a Gladstones issued claim don’t do that. Here’s why:
1. “Breach of parking terms” is just a conclusion. The PoC don’t say what the driver supposedly did: failed to pay, overstayed, left site, wrong bay, no permit, etc. Without the alleged act, there are no material facts to answer.
2. Contract cases must set out the contract relied upon. PD 16 paras 7.3–7.5 require the claimant to attach or set out the relevant terms if it’s written, or to state the terms if it’s oral or by conduct. The PoC don’t identify any contractual term or wording, so the defendant can’t see what term was allegedly broken.
3. The PoC don’t state who is being sued and on what basis: the driver, or the registered keeper under PoFA. If the keeper is pursued, the claimant should plead that PoFA Schedule 4 conditions are met. As drafted, the defendant cannot tell which case they have to meet.
4. Time and duration matter in parking claims. Saying only “23/07/2024” isn’t enough. There’s no start time, end time, or period of parking, so the defendant can’t check signage hours, machine logs, receipts, grace/consideration periods, or whether the vehicle was merely stopped briefly.
5. The place is vague. “Stack Shack” is a trading name, not a precise location or car park area. Many sites have multiple bays/zones with different signs. The PoC don’t say exactly where on the land the alleged breach occurred or what sign applied there.
6. The £60 “contractual costs” are just a label. The PoC don’t plead any contractual term that entitles that add-on, nor facts showing the defendant agreed to pay it. In contract, you must point to the term that creates liability for the extra sum.
7. Interest is not properly particularised. PD 16 para 4.2 says a claimant seeking s.69 interest should state the rate, the start date, the period to which it applies, the daily rate, and the amount claimed. The PoC give only a lump figure and 8% with no period or daily rate.
8. Standing is not pleaded. Private parking firms need authority from the landowner to contract and to sue. The PoC say nothing about the claimant’s authority, which is part of the factual basis of the claim.
9. The £50 “legal representative’s costs” are claimed but no basis is pleaded. On the small claims track, recoverable costs are tightly limited; if they say it’s part of the principal debt, they must plead the contractual basis. If they say it’s costs, they must accept the small-claims limits. As pled, it’s opaque.
Overall, the PoC read like “you broke some rule, pay £257.50” without telling the defendant what rule, how it was broken, or why the figures are due. CPR 16.4(1)(a) requires a concise statement of the facts relied on. These particulars give conclusions and totals, not facts, so the defendant cannot plead a proper response. That is why they breach CPR 16.4(1)(a).
MCOL limits do not excuse inadequate Particulars
MCOL’s character limit is real, but the rules provide a simple workaround. If the online box was too small, the claimant should have selected “particulars to follow” and then served full Particulars of Claim within 14 days of service of the claim form (CPR 7.4(1)(b); PD 7C paras 5.2 and 6.1). That route exists so claimants can comply with CPR 16.4(1)(a) and PD 16.
Full Particulars served separately should set out the contract relied on and the exact term said to be broken, who is sued and on what basis (driver or keeper under PoFA and how its conditions are met), the where/when/how long of the alleged parking event, and a clear breakdown of the sums claimed with the contractual or statutory basis for any add-ons and for interest (PD 16 paras 7.3–7.5; PD 16 para 4.2 on interest).
If MCOL still felt unsuitable, the claimant could have issued on paper using form N1. Nothing in the rules forced them to rely on an under-particularised MCOL narrative.
Prior letters, PCNs or emails are irrelevant to pleading compliance. The Particulars must stand on their own and enable a defendant, assumed to know nothing about the matter on receipt, to understand the case and plead a defence. The court cannot treat earlier correspondence as if it were part of the PoC.
In short, the claimant’s failure is one of choice, not constraint. The rules gave straightforward options to plead properly. MCOL is not an excuse.