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Private parking tickets / Re: NPM PCN – No e-Permit – Woodgrange Road E7 (13–15) – Notice to Keeper
« on: Today at 03:00:20 pm »
Thanks jfollows, that’s helpful.
I take the point about not copying wording from other cases without understanding whether it applies.
My aim is simply to respond properly to the Letter Before Claim by:
* denying the debt
* explaining the key reasons why the claim is disputed
* disputing the added £70
* asking only for documents/evidence I do not already have or that are central to the alleged contract
Would the following shorter response be more appropriate?
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Subject: Response to Letter Before Claim - PCN NPM207017
Dear Sirs,
Re: Letter Before Claim dated 2 June 2026
PCN: NPM207017
Client: National Parking Management Limited
Location: Woodgrange Road 13-15
I deny any debt to your client.
The claim is disputed. The vehicle was present on site for less than three minutes. I dispute that any contract was formed or breached during that time.
The signage at this location is disputed. In particular, I dispute that the signs made a clear contractual offer capable of acceptance, or that they explained how a driver could obtain an e-permit.
I also dispute the added £70. Please explain the legal basis on which this sum is claimed, whether it is said to be consideration, damages, debt recovery costs, or something else.
The following facts/parts of the claim are disputed:
1. That any contract was formed.
2. That any contractual term was breached.
3. That the signage was sufficiently clear and prominent.
4. That the driver was given a fair opportunity to read and accept any terms.
5. That the registered keeper is liable.
6. That the added £70 is recoverable.
Please provide the documents and evidence on which your client intends to rely, including:
1. Actual photographs of the signs in place on the material date.
2. A site plan showing the position of the signs.
3. The precise wording of the clause or clauses allegedly breached.
4. The written agreement between your client and the landowner showing authority to enforce and litigate at this location.
5. Your client’s basis for alleging keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.
6. Copies of any video evidence relied upon.
For the avoidance of doubt, I am seeking debt advice, but I deny the debt.
Please correspond by email or post.
Yours faithfully,
[Name]
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Is this now closer to what is needed for a Letter Before Claim response?
I take the point about not copying wording from other cases without understanding whether it applies.
My aim is simply to respond properly to the Letter Before Claim by:
* denying the debt
* explaining the key reasons why the claim is disputed
* disputing the added £70
* asking only for documents/evidence I do not already have or that are central to the alleged contract
Would the following shorter response be more appropriate?
---
Subject: Response to Letter Before Claim - PCN NPM207017
Dear Sirs,
Re: Letter Before Claim dated 2 June 2026
PCN: NPM207017
Client: National Parking Management Limited
Location: Woodgrange Road 13-15
I deny any debt to your client.
The claim is disputed. The vehicle was present on site for less than three minutes. I dispute that any contract was formed or breached during that time.
The signage at this location is disputed. In particular, I dispute that the signs made a clear contractual offer capable of acceptance, or that they explained how a driver could obtain an e-permit.
I also dispute the added £70. Please explain the legal basis on which this sum is claimed, whether it is said to be consideration, damages, debt recovery costs, or something else.
The following facts/parts of the claim are disputed:
1. That any contract was formed.
2. That any contractual term was breached.
3. That the signage was sufficiently clear and prominent.
4. That the driver was given a fair opportunity to read and accept any terms.
5. That the registered keeper is liable.
6. That the added £70 is recoverable.
Please provide the documents and evidence on which your client intends to rely, including:
1. Actual photographs of the signs in place on the material date.
2. A site plan showing the position of the signs.
3. The precise wording of the clause or clauses allegedly breached.
4. The written agreement between your client and the landowner showing authority to enforce and litigate at this location.
5. Your client’s basis for alleging keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.
6. Copies of any video evidence relied upon.
For the avoidance of doubt, I am seeking debt advice, but I deny the debt.
Please correspond by email or post.
Yours faithfully,
[Name]
---
Is this now closer to what is needed for a Letter Before Claim response?
Thanks for the help!