Free Traffic Legal Advice

I am neither the driver nor the keeper of the vehicle.

I asked GXS

Does it matter that in the reply from GXS to my "appeal"

I intend to send a reply to GXS

OP, can we stop dancing around this pl.

If you are neither the driver nor keeper then you have no liability and you have no standing to make 'appeals'.

Whoever is liable must be kept in the loop because it's their neck on the block.

My understanding is that the OP is handling this on behalf of the keeper.  If so, as long as everything is done in the keepers name and it is the keeper who will be signing any statements of truth, there’s nothing wrong. Even if it ever got as fast as court hearing, as long as the defendant attends, the OP can represent them as a lay rep.

Moorside Legal
Jade Building
Albion Mills
Albion Road
Greengates
BD10 9TQ

By email to: help@moorsidelegal.co.uk

[Date]

Dear Sirs,

Re: Letter of Claim dated 29th January 2025

I refer to your Letter of Claim.

I confirm that my address for service at this time is as follows, and I request that any outdated address be erased from your records to ensure compliance with data protection obligations:

[YOUR ADDRESS]

Please note that the alleged debt is disputed, and any court proceedings will be robustly defended.

I note that the sum claimed has been increased by an excessive and unjustifiable amount, which appears contrary to the principles established by the Government, who described such practices as “extorting money from motorists.” Please refrain from sending boilerplate responses or justifications regarding this issue.

Under the Pre-Action Protocol for Debt Claims, I require specific answers to the following questions:

1. Does the additional £70 represent what you describe as a “Debt Recovery” fee? If so, is this figure net of or inclusive of VAT? If inclusive, I trust you will explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.

2. Regarding the principal sum of the alleged Parking Charge Notice (PCN): Is this being claimed as damages for breach of contract, or will it be pleaded as consideration for a purported parking contract?

I would caution you against simply dismissing these questions with vague or boilerplate responses, as I am fully aware of the implications. By claiming that PCNs are exempt from VAT while simultaneously inflating the debt recovery element, your client – with your assistance – appears to be evading VAT obligations due to HMRC. Such mendacious conduct raises serious questions about the legality and ethics of your practices.

I strongly advise your client to cease and desist. Should this matter proceed to court, you can be assured that these issues will be brought to the court’s attention, alongside a robust defence and potentially a counterclaim for unreasonable conduct.

Yours faithfully,


[YOUR NAME]