Moorside Legal Services
PO Box 82112
London
N17 1LG

[DATE]

Dear Sirs,

Your Ref: 10101246
Claimant: UKPS Ltd
Response to Letter of Claim dated 30 August 2026

I acknowledge receipt of your further Letter of Claim dated 30 August 2026.

The alleged debt remains disputed in full.

You previously issued a Letter of Claim concerning the same alleged parking charge in December 2024. I responded substantively on 23 December 2024, disputing the alleged debt and requesting specific information concerning the factual and legal basis of your client's claim.

I received no substantive response.

Paragraph 5.2 of the Pre-Action Protocol for Debt Claims provides that where a debtor requests a document or information, the creditor must provide it, or explain why it is unavailable, within 30 days of receipt of the request.

Your failure to respond to my requests of 23 December 2024 therefore remains unexplained. The issuing of a further Letter of Claim approximately 20 months later does not address those outstanding requests.

For the avoidance of doubt, the information previously requested remains outstanding. I continue to dispute the alleged debt and require the following information and documents in order properly to understand the basis of your client's proposed claim.

1. The alleged breach and contractual term relied upon

The notices issued by your client do not adequately identify the conduct said to have given rise to the parking charge, instead stating in substance that the vehicle was parked "in a manner whereby the driver became liable for a parking charge".

This issue was expressly raised in my correspondence of 23 December 2024, when I requested that you identify the specific contractual term(s) which the driver was alleged to have breached. You failed to answer that request.

Please now state clearly:

(a) precisely what the driver is alleged to have done or failed to do;

(b) the precise contractual term allegedly breached; and

(c) where and how that term was communicated to the driver.

Please also explain how your client contends that its notices satisfy the applicable requirements of Schedule 4 to the Protection of Freedoms Act 2012 in respect of the description of the circumstances in which the parking charge became payable.

2. The contractual signage

Please provide contemporaneous photographs of all signage relied upon by UKPS Ltd as forming the alleged contract at Eaton House Offices on 14 January 2023, including entrance signage and signage applicable to the location in which the vehicle was parked.

3. Evidence of the alleged contravention

Please provide copies of all photographs and other evidence upon which UKPS Ltd intends to rely in establishing that the identified contractual term was breached.

4. Authority

Please provide evidence of UKPS Ltd's authority from the relevant landowner to operate at the location, enter into parking contracts with motorists and pursue parking charges in its own name.

5. Quantum of the claim

Please provide a full explanation and calculation of the £160 now claimed.

The original Parking Charge Notice stated that the parking charge was £100. Your current Letter of Claim instead identifies £94 as "Parking Charge Notice(s)" and £66 as "Additional Charges".

Please explain:

(a) how the original £100 parking charge has become £94;

(b) precisely what the additional £66 represents;

(c) the contractual and/or legal basis upon which the additional £66 is claimed; and

(d) where in the alleged contract the driver agreed to become liable for that additional sum.

6. Previous correspondence

Please provide a copy of any substantive response which you contend was sent in response to my letter dated 23 December 2024.

If no response was sent, please confirm this and explain why the information requested was not provided within the period prescribed by paragraph 5.2 of the Pre-Action Protocol for Debt Claims.

Paragraph 5.1 of the Protocol provides that where any aspect of a debt is disputed, including the amount, charges or compliance with relevant statutes and regulations, the parties should exchange information and disclose documents sufficient to enable them to understand each other's position.

Paragraph 4.2 further provides that proceedings should not be commenced less than 30 days from receipt of a completed Reply Form or 30 days from the creditor providing documents requested by the debtor, whichever is later.

I therefore require a substantive response and the requested information and documents before proceedings are commenced.

Should your client nevertheless commence proceedings without properly addressing these requests, I reserve the right to draw this correspondence, my correspondence of 23 December 2024 and your client's subsequent failure to respond to the attention of the court when compliance with the Pre-Action Protocol is considered.

I invite your client to review this matter properly and discontinue its pursuit of this disputed charge.

Yours faithfully,

Peter Daly-Dickson

From: Emirul Husnee <EmirulH@dcblegal.co.uk>
Date: Thu, 20 Mar 2025 at 11:36
Subject: Our ref:


Dear

We act for the Claimant in the above matter. 
 
Our client has instructed us to discontinue Court proceedings and close our file. Therefore, please find enclosed the Claimant’s N279 Notice of Discontinuance for your records. 

The attached has also been filed with the Court.

We will now proceed to close our file accordingly.

Kind Regards,


Emirul Husnee
Case Manager
DCB Legal Ltd

Good afternoon,

Your email dated 7th March 2025 was referred to Deputy District Judge Aikman who has commented as follows:
 
‘Please inform the Defendant that she must comply with the directions order dated 24th February 2025 and that the hearing of the matter will proceed on 30th April 2025.’

I am the Defendant in this matter, and I write regarding the Order made on 21 February 2025 by DDJ Vickers, which lists the trial for 30 April 2025 and directs both parties to file and serve evidence by 24 March 2025.

Given that witness statements are required to be submitted by 24 March 2025, I respectfully request the Court to respond within seven days to allow sufficient time for procedural fairness to be restored.

Did you counter claim?

How long before the hearing date is the claimant ordered to pay the ring fee?