Free Traffic Legal Advice

It says at the bottom here "no later than 14 days before the hearing" https://ibb.co/23StLL6X

I'm wondering myself now...do they mean 14 days excluding the actual court day?  Should I send tomorrow maybe just to play it safe?

Ok thank you, so I should definitely send it on the 6th?

Thank you very much, I will do. Yep the hearing is on the 20th.

I’m sure you’ll be fine. You know all the points that you are contesting.

Did QDR give any indication whether they will attend the hearing?

One of your strongest points is that the original claim was never served within 4 months. Make sure you emphasise that at your hearing. There is no discretion on the court to allow an unserved claim to stands. I was very surprised when the set aside judge allowed it. I can’t remember if that was even brought up at the set aside.

On the day, arrive early enough to get through security and let the usher know you have arrived. Remember to ask for costs for unreasonable behaviour when you win. You can prepare a costs schedule for your time spent on this matter at the Litigant in person rate of £24/hour.

Time spent on research, preparing your set aside, defence, WS etc all count. Also, any travel expenses to and from the hearing are also allowed, such as transport, parking etc.

Just had this through from QDR, I have no idea what the purpose of it is or if I need to respond? This is a link to the three attachments, I've combined them: https://drive.google.com/file/d/1pQV4kWerPUDn5BQy2zFWCbBQV7qj3iF0/view?usp=sharing

Please help? 

We write in reference to the Hearing listed on 20 November 2025.
 
As per the Order dated, 3 July 2025, the parties are to agree a trial bundle and any relevant authorities bundle. Please find attached copies of the indexes for the relevant bundles, if you have any further documents you wish to be included in either version, please provide these by 13:00pm Wednesday 12 November 2025, so that we can ensure they are included within the bundles. For the avoidance of doubt, if we do not hear back from you, we will be filing and serving the Bundles with the Court to comply with the prescribed deadlines.
 
Please also find attached a copy of the proposed draft Case Summary for your approval, which is to be included within the bundle. Please also confirm if you propose any amendments.
 
We kindly await your confirmation and copies of any documents to be provided to be included within the bundle, ahead of next weeks hearing by no later than 13:00pm on Wednesday 12 November 2025

You reply to QDR as follows and CC yourself:

Subject: UKPC v [Defendant] – Claim No. [ ] – Objection to Late Bundle and Case Summary

Dear Sirs,

I acknowledge receipt of your email dated 11 November 2025 concerning the proposed trial bundle and Case Summary.

For the avoidance of doubt, paragraph 6 of the Court’s Order dated 3 July 2025 required each party to serve all documents intended to be relied upon no later than fourteen days before the hearing, namely by 6 November 2025. Your correspondence of 11 November 2025 is therefore out of time and non-compliant with that Order. No application for an extension of time or for relief from sanctions has been served. I do not consent to any retrospective variation or informal extension.

Your late approach appears to be an attempt to regularise procedural non-compliance after the fact. The Defendant will draw the Court’s attention to this and will invite the Court to disregard any material filed or served out of time unless permission is formally granted.

Without prejudice to that position, I do not agree with your proposed Case Summary, which contains several factual and procedural inaccuracies, including but not limited to:

– the claim was never properly served in accordance with CPR 7.5;
– the claimant has failed to comply with CPR 16.4; and
– the claimant has failed to comply with the Court’s specific directions concerning evidence and bundle preparation.

If, notwithstanding the above, the Court permits a late authorities bundle, please ensure inclusion of the following cases for completeness:

– Brennan v Premier Parking Solutions Ltd (Plymouth CC, HHJ Mitchell, 21 Aug 2023)
– Mazur v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB)
– Vinos v Marks & Spencer plc [2001] 3 All ER 784

Yours faithfully,

[Name]
Defendant

You also send the following to the court and you attach a copy of QDR's email and your response. CC QDR and yourself:

IN THE COUNTY COURT AT WATFORD
Claim No.: [Claim number]
Between:
UK Parking Control Ltd – Claimant
and
[Your full name] – Defendant

---

Date: [Insert today’s date]
To: The Court Manager
[Court’s email address]

Dear Sir or Madam,

Re: Late service of trial bundle and Case Summary – breach of paragraph 6 of order dated 3 July 2025

I write to place on record that the Claimant’s solicitors, QDR Solicitors Ltd, have served proposed bundle indexes and a draft Case Summary by email dated 11 November 2025.

Under paragraph 6 of the Court’s directions dated 3 July 2025, all documents to be relied upon at the hearing were required to be served and filed no later than fourteen days before the hearing — that is, by 6 November 2025. The claimant’s email of 11 November 2025 is therefore out of time and non-compliant.

No application for an extension of time or relief from sanctions has been served on me. I do not consent to any retrospective variation or informal extension of the timetable.

For the Court’s ease of reference, I attach:

• A copy of the claimant’s late email dated 11 November 2025; and
• A copy of my response letter to the claimant dated [insert date], setting out my objection.

I respectfully ask that this correspondence be placed on the case file for the trial judge’s attention.

Yours faithfully,

[Your full name]
Defendant

Here are links to the authorities for your bundle:

Brennan v PPS

Mazur v Charles Russell Speechlys LLP

Vinos v Marks & Spencer

You attach those authorities as PDF files to the email to QDR.

Thank you so much! All done.