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Private parking tickets / Re: Letter Before Claim Moorside Legal
« on: August 27, 2025, 11:44:42 am »
Hi @b789. Thanks for getting back to me.
I logged onto the portal and the link to view documents wasn't even working so I have tweaked your email slightly and sent the below.
Dear Sirs,
Thank you for your email. I do not consent to using your portal; please correspond by email or post.
The documentation you claim to have uploaded on to the portal is not showing and therefore I am unable to check you are now complying with the relevant legal obligations required.
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, particularly when the documents are not viewable and the reported link is not working.. 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,
Name, address and e mail
I logged onto the portal and the link to view documents wasn't even working so I have tweaked your email slightly and sent the below.
Dear Sirs,
Thank you for your email. I do not consent to using your portal; please correspond by email or post.
The documentation you claim to have uploaded on to the portal is not showing and therefore I am unable to check you are now complying with the relevant legal obligations required.
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, particularly when the documents are not viewable and the reported link is not working.. 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,
Name, address and e mail