Good morning - I wonder if someone can tell me if this is a good response (AI generated):
Dear Sirs,
Re: Your Letter of Claim dated [DATE] PCN Reference: [PCN NUMBER] Vehicle Registration: [VRM]
I write in response to your Letter of Claim.
I deny any debt to your client and dispute the entirety of the claim.
At the time of the alleged contravention on 7 May 2025, the vehicle was parked in the underground car park of the residential development in which I am the leaseholder of Flat [NUMBER/ADDRESS], and to which I hold a valid parking entitlement under the terms of my lease. A valid parking permit was displayed on the dashboard of the vehicle. Due to hot weather conditions on the day in question, the permit (which is a sticker type) had curled and was placed on the dashboard with a pen to prevent movement. Photographic evidence provided by your client does in fact show the permit present within the vehicle, a matter which I raised in my original appeal to UK Car Park Management Ltd (CPM) on 15 May 2025.
Further, my lease grants parking rights and makes no mention of any requirement to display a permit or comply with any third-party parking enforcement scheme. The lease provides for a designated parking space, which has subsequently evolved into a general right to park within the underground car park, as confirmed in correspondence with the building management company.
Your client is put to strict proof that: 1. Any parking scheme has been lawfully introduced in accordance with the terms of the lease; 2. The leaseholder’s existing right to park has been validly varied or superseded; 3. Your client has the necessary authority from the landowner to override or interfere with leaseholder parking rights; 4. Clear and prominent signage created a contractual obligation capable of binding a leaseholder with pre-existing parking rights.
In the absence of any such variation to the lease, my primacy of contract takes precedence over any purported contractual terms imposed by signage.
In accordance with the Pre-Action Protocol for Debt Claims, please provide the following documents:
- A copy of the contract between your client and the landowner authorising enforcement at this location;
- Copies of all photographs relied upon;
- A copy of the signage terms and conditions in place on 7 May 2025;
- Evidence that the parking scheme has been introduced in accordance with the lease;
- A full breakdown of the sum claimed, including the legal basis for any additional costs added.
Until such time as this information is provided, I am unable to provide a more detailed response.
Accordingly, I require that this matter be placed on hold for not less than 30 days pursuant to paragraph 5.2 of the Pre-Action Protocol.
I also require you to treat this letter as a request for all personal data held by your client pursuant to Article 15 UK GDPR (Subject Access Request). This includes all photographs, notes, correspondence, and system data relating to myself and the above PCN. I look forward to your substantive response.
Yours faithfully,