Free Traffic Legal Advice

Criminal.. isn't it? However, stop fretting. You can safely ignore the debt collector letters. They are powerless to do anything except to try and make the low-hanging fruit on the gullible tree pay up out of ignorance and fear.

The debt collectors are not a party to the contract allegedly breached by the driver. Ignore them. Use their letters a kindling or to line the bottom of a litter tray. Never, ever, communicate with a useless, powerless debt collector.

You will now have to wait and see if/when they issue a Letter of Claim (LoC) which you should show us. They will in due course issue a claim which you must respond to and we will provide a suitable defence. These claims are easily defended and in 99% of cases, they discontinue. The very few that ever get was far as a hearing are either stuck out or won.

Come back if/when you receive an LoC.

Subject: UK-CPM v [Keeper] — Your Letter of Claim dated 28/08/2025 — PCN [reference]

Dear Sirs,

Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of evidence your client places reliance upon and thus is in complete contravention of the Pre-Action Protocol for Debt Claims.

As a firm of supposed solicitors, one would expect you to be capable of crafting a letter that aligns with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and 6(c) of the Practice Direction. These provisions do not exist for decoration—they exist to facilitate informed discussion and proportionate resolution. You might wish to reacquaint yourselves with them.

The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols (Part 3), stipulate that prior to proceedings, parties should have exchanged sufficient information to understand each other’s position. Part 6 helpfully clarifies that this includes disclosure of key documents relevant to the issues in dispute.

Your template letter mentions a “contract”, yet fails to provide one. This would appear to undermine the only foundation upon which your client’s claim allegedly rests. It’s difficult to engage in meaningful pre-litigation dialogue when your side declines to furnish the very document it purports to enforce.

I confirm that, once I am in receipt of a Letter Before Claim that complies with the requirements of para 3.1 (a) of the Pre-Action Protocol, I shall then seek advice and submit a formal response within 30 days, as required by the Protocol. Thus, I require your client to comply with its obligations by sending me the following information/documents:

1. A copy of the contract (or contracts) you allege exists between your client and the driver, in the form of an actual photograph of the sign you contend was at the location on the material date, not a generic stock image
2. The exact wording of the clause (or clauses) of the terms and conditions of the contract(s) which is (are) relied upon that you allege to have been breached
3. The written agreement between your client and the landowner, establishing authority to enforce
4. A breakdown of the charges claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” fee includes VAT

I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).

If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.

Until your client has complied with its obligations and provided this information, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.

Yours faithfully,

[Your name]

OP have you checked the entrance sign to that location? iirc it’s not even a CPM entrance sign at the time the PCN was issued. It’s an entrance sign from a complete different operator