Free Traffic Legal Advice

Have submitted my defence via email. I received the following automatically generated response:
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Thank you for emailing the Claim Responses Team in the Civil National Business Centre. Please expect a response to your enquiry in 10 days

When sending us documents please ensure you comply with the Practice Direction 5B
https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part05/pd_part05b

Documents not complying will not be accepted, in particular if it is over 10MB or 25 printed pages in size.
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What's next please?

Claim History
Your acknowledgment of service was submitted on 22/09/2024 at 14:36:50
Your acknowledgment of service was received on 23/09/2024 at 01:06:04
Your defence was received on 24/09/2024

MCOL has updated that they have received defence. Is there any timeline to receive DQ?

I received the following email from Gladstones Solicitors. They also attached their DQ to the email. MCOL site still shows that my defence has been received. I assume I wait for an update before sending in my DQ. Is that correct?

Also, I assume I dont do anything on their offer for mediation, correct?

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Dear XYZ


We act for the Claimant and have notified the Court of the Claimant’s intention to proceed with the Claim.

Please find enclosed a copy of the Claimant’s completed Directions Questionnaire, which has also been filed with the Court.

You will note the Claimant has elected to mediate in an attempt to settle this matter amicably, without the need for further Court intervention. Should you agree to mediation, please inform the Court who will contact both parties to arrange a mediation appointment.

Yours sincerely
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All as expected. Just a bit quicker than it has been recently. Looks like the CNBC are getting through the backlog.

You will note the Claimant has elected to mediate in an attempt to settle this matter amicably, without the need for further Court intervention. Should you agree to mediation, please inform the Court who will contact both parties to arrange a mediation appointment.

Hilarious. Mediation has been compulsory for any claim filed since 22nd May 2024. If they've "elected" to have mediation, then they are using an old version of the N180.

Mediation is only compulsory meaning that you must "attend" the phone call. It is not a trial and there is no judge or lawyers involved. It is some bod who has been on a mediation course. It is a complete waste of time in cases like this.

All you have to do is offer £0 and it will all be over in five minutes. It has absolutely no bearing on the claim itself and you will have complied because you"attended".

Don't send your DQ until your MCOL says that one has been sent to you. Just download one from:

https://assets.publishing.service.gov.uk/media/66a8b019ce1fd0da7b592f43/N180_0724.pdf

Fill it in and wait until you get notification that yours has been sent. When ready, send your completed N180 DQ as a PDF attachment in a single email addressed to dq.cnbc@justice.gov.uk and to the claimants solicitor and CC in yourself. Make sure that the email subject contains the claim number and in the body of the email just state that attached is the N180 DQ in the matter of [claimant name] v [your name] Claim number: [claim number].

Very high probability that it will get struck out for failure to comply with CPR 16.4(1)(a) and even if it wasn't, a very high probability that it would be successful at a hearing.

If I thought it had less than a 50% chance of being successful I would never advise continuing all the way to a hearing.

They allow 5 days for 'service' and then, I can't remember whether it's 14 or 28 days for it to be returned. The N180DQ is an administrative document and even if you fail to respond, you will usually receive a court order reminder.

As you've stated, simply download your own DQ, complete it, sign it by typing your full name for the signature and send it in a single email but addressed to both, dq.cnbc@justice.gov.uk AND enquiries@gladstonessolicitors.co.uk and also CC in yourself.

However, I see that for few other cases it has been advised to attached the following documents:

- Draft defence order
- PM v Akande transcript
- CEL v Chan transcript

Yes, attach the Draft Order and the transcripts with this as a covering letter to go with your DQ:

[Your Name]
[Your Address]
[Date]

The Court Manager
Civil National Business Centre
4th Floor, St Katharine’s House
21-27 St Katharine’s Street
Northampton
NN1 2LH

Claim Number: [Insert Claim Number]
Claimant: Private Parking Solutions (London) Ltd
Defendant: [Your Name]

Dear Sir/Madam,

Re: Request for Strike Out or Alternatively Compliance with Draft Order in Response to N180 Directions Questionnaire

I write concerning the above-referenced claim, for which I have received a Notice of Directions Questionnaire (N180). Due to the vague and deficient nature of the Particulars of Claim (PoC), I have been unable to plead a full defence. Therefore, I respectfully request that the court considers striking out the claim pursuant to CPR 3.4(2)(a) on the grounds that the PoC fail to comply with CPR 16.4(1)(a), as they do not disclose a cause of action or provide a concise statement of fact.

Alternatively, should the court decide not to strike out the claim, I request that the Claimant be ordered to comply with the attached draft order, which seeks further and better particulars of claim.

To support my application, I enclose transcripts of two persuasive appeal cases:

• Civil Enforcement Ltd v Chan (2023) [E7GM9W44]

• CPMS v Akande (2024) [K0DP5J30]

Both cases involved claims that were struck out due to similarly insufficient particulars.

I trust that the attached documents will assist the court in its assessment and in issuing appropriate case management directions.

Yours faithfully,

[Your Name]

Remember that a single email with the attached PDF files should be addressed to both dq.cnbc@justice.gov.uk and enquiries@gladstonessolicitors.co.uk and CC in yourself. Make sure the subject contains the claim number and in the body of the email refer to the case and just say see attached N180DQ, cover letter, draft order and two transcripts.

The claim status has been updated that I have filed my DQ.

A claim was issued against you on 11/09/2024
Your acknowledgment of service was submitted on 22/09/2024 at 14:36:50
Your acknowledgment of service was received on 23/09/2024 at 01:06:04
Your defence was received on 24/09/2024
DQ sent to you on 08/10/2024
DQ filed by claimant on 08/10/2024
You filed a DQ on 21/10/2024

I assume next I receive an arbitration letter? Do you know how long does it take normally?