You can check your MCOL history to see when your own N180 has been issued or just wait to receive it in the post. Having received your own N180 (make sure it is not simply a copy of the claimants N180) or been notified on MCOL that yours has been sent, do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own N180 DQ 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 [claimant to their legal representative]and CC in yourself. Make sure that the claim number is in the subject field of the email.
Perfect — they’ve basically sent you a payment demand plus a copy PCN and ignored almost everything you asked for. That’s classic PAP non-compliance. Reply once (firm, concise), then sit tight for either proper disclosure or a claim you can strike at.
Here’s the reply you can send back to Gladstones:
Subject: Your email of 17 November 2025 — Ref: [reference] — Bath Street Car Park, Ilkeston
Dear Sirs,
Thank you for your email. Your attachment is merely a copy PCN. It does not address the deficiencies I identified, nor does it comply with the Pre-Action Protocol for Debt Claims or PD-PAC 6(a) and 6(c). In particular, you have still failed to provide:
• Contemporaneous photographs of the entrance and on-site signage as displayed on the material date, with a site plan (locations/sizes/wording);
• Records showing when and how the historic “first hour free” was withdrawn and how motorists were notified at the point of entry;
• ANPR in/out logs and payment/machine logs for the visit;
• The landholder agreement in force (including authority to enforce and to litigate);
• An itemised legal basis for the sums claimed, including the £70 add-on.
Your 11 December deadline is rejected. The PAP affords 30 days to respond after service of a compliant Letter of Claim with key documents. You have not supplied those, so the PAP clock has not begun.
There are already live proceedings between the same parties for PCNs from the same site and contiguous period (June–Aug 2024): Claim No. [xxxx]. You are on notice that issuing a second claim will be opposed as an abuse per Henderson v Henderson; Johnson v Gore Wood; Aldi v WSP, and upon determination of the first action it will in any event be barred by cause of action estoppel/merger. Any such claim will attract an immediate CPR 3.4(2)(b) strike-out application and a CPR 27.14(2)(g) costs request (LiP rate £24/hour).
For the avoidance of doubt: the driver is already known to your client; PoFA is irrelevant. I do not consent to amendment or consolidation of the existing proceedings.
Please either (a) provide the above documents within 30 days so that meaningful Protocol engagement can occur, or (b) confirm that no separate proceedings will be issued.
Yours faithfully,
[Name]
[Address]
[Email]
Defendant in Claim No. [xxxx]
If they issue a claim anyway, you can move straight to a strike-out application (abuse/Henderson; or at least a stay pending the first claim) and ask for your application fee + LiP time at £24/hr.
Ah, OK, so it's an LoC, not a claim. I also not that it is a Notice to Hirer (NtH) not an NtK. Is it in your name as the Hirer?
When you received the NtH, did they include copies of a statement signed by or on behalf of the vehicle-hire firm to the effect that at the material time the vehicle was hired to a named person under a hire agreement, the Hire Agreement, a copy of a Statement of Liability signed by the hirer under that hire agreement and a copy of the original NtK sent to the Hire/Lease company?
You need to see the original NtK as the date it was issued also affects the relevant period for the issue of the NtH. Whilst that is important, there is enough evidence in their NtH to show that they can ONLY pursue the driver. They have absolutely no idea who that was unless you, the Hirer, blab it to them.
Never mind... I see you were in communication with Horizon about the PCNs and admitted liability by offering to pay for the "parking". I'm sorry, but that was a really silly move. Had the driver not been identified, there was no way they could pursue you as the Hirer. The driver is always liable and unless they conform to all the requirements of PoFA 2012, they cannot transfer liability from the driver to the Hirer.
It’s annoying, but it’s not game over. Admitting being the driver only knocks out the PoFA keeper/hirer route. You still have strong, driver-based defences that you can use once you see their WS and can then rebut the claim, if this is not first struck out for the CPR 16.4(1)(a) failures.
So, go ahead and submit the defence as advised and you can also respond to the second LoC with the following:
Subject: Response to your Letter of Claim — Ref: [reference number] — Bath Street Car Park, Ilkeston
Dear Sirs,
Your Letter of Claim contains insufficient detail and fails to provide the evidence your client relies upon. It does not comply with the Pre-Action Protocol for Debt Claims (paras 3.1(a)–(d), 5.1 and 5.2) and the Practice Direction – Pre-Action Conduct and Protocols (PD-PAC) paras 6(a) and 6(c).
There are already live proceedings between the same parties concerning PCNs from the same site and contiguous period (June–Aug 2024): Claim No. [xxxx]. Any separate claim now for another PCN from that same factual matrix would be an abuse (Henderson v Henderson; Johnson v Gore Wood; Aldi v WSP) and, upon determination of the first action, would be barred by cause of action estoppel (merger). I will apply under CPR 3.4(2)(b) to strike out any second claim and seek costs under CPR 27.14(2)(g) (LiP rate £24/hour). For the avoidance of doubt, I do not consent to any amendment of the existing claim or any attempt to “fold” this PCN into it.
To discharge my own Protocol duties, and so that informed discussion can occur, please provide within 30 days the key documents required by PD-PAC 6(a) and 6(c):
1. Copies of all notices relied upon for this PCN (NtD/NtK/NtH as applicable), all correspondence, and the evidence pack (ANPR images, timestamps, audit trail).
2. Contemporaneous photographs of the entrance and on-site signage as displayed on the material date (not library artwork), with a site plan showing sign locations, sizes and wording.
3. The precise contractual term(s) you allege were breached and the legal basis for each sum claimed (identify the principal as consideration or damages and the basis for any add-on).
4. The written landowner agreement in force at the material time, evidencing standing to enforce and to litigate and any variation introducing/withdrawing the historic “first hour free”.
5. Machine/payment logs for the material date and any records showing when and how the historic free first hour was withdrawn and publicised at the entry.
I will provide a full response within 30 days of receipt of a Protocol-compliant LoC and the above documents. Until then, meaningful engagement is not possible. If you issue regardless, I will seek immediate case management relief (including strike-out or a stay and disclosure) and costs.
I will not use any web portal. Correspond by post or email only.
Yours faithfully,
[Your name]
[Your address]
[Your email]
Defendant in Claim No. [xxxx]