Free Traffic Legal Advice

The reply #8 from b789 in the linked thread appears pertinent.

Update - Letter Before Claim received from Gladstones

I have now received a Letter Before Claim from Gladstones Solicitors, dated 2 June 2026.

Details:

PCN: NPM207017
Client: National Parking Management Ltd
Location: Woodgrange Road 13-15
Date of charge: 23/12/2025
Amount claimed: £170
Estimated total if proceedings are issued: £255

The letter gives 30 days to respond and refers to the Pre-Action Protocol for Debt Claims.

Redacted Letter Before Claim images:

Page 1:
Page 2:
Page 3:

I had previously seen this stage referred to on here as a “Letter of Claim”, but this letter is headed “Letter Before Claim”. I assume this is the same stage because it gives 30 days and refers to the PAPDC.

I searched the forum and found these similar threads where b789 recommended responding with a PAPDC/document request template:

https://www.ftla.uk/private-parking-tickets/letter-before-claim-recieved/
https://www.ftla.uk/private-parking-tickets/letter-before-claim-received-from-moorside-legal/

The Gladstones letter says I can respond via their website, which requires a login, or request a paper version of the Information Sheet and Reply Form. It does not appear to say I must use the portal. I would prefer not to use their web portal and to respond by email, CCing myself, or by post with proof of posting if email is not suitable.

This is what I am thinking of sending. I’d appreciate an expert view before I send it:

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Subject: Response to Letter Before Claim - Ref [Gladstones reference] / PCN NPM207017

Dear Sirs,

Re: Letter Before Claim dated 2 June 2026
Your reference: [Gladstones reference]
PCN: NPM207017
Client: National Parking Management Limited
Location: Woodgrange Road 13-15
Vehicle registration: [redacted]

I deny any debt to your client.

Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of the evidence your client places reliance upon, putting it in clear breach of the Pre-Action Protocol for Debt Claims.

As a supposed firm of solicitors, one would expect you to comply 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 exist to facilitate informed discussion and proportionate resolution.

Your template letter refers to a “contract” yet encloses none. That omission undermines the foundation upon which your client’s claim allegedly rests. It is not possible to engage in meaningful pre-litigation dialogue while you decline to furnish the very documents and evidence you purport to rely upon.

I confirm that, once I am in receipt of a Letter Before Claim that complies with the Pre-Action Protocol for Debt Claims, I shall seek advice and submit a formal response within 30 days, as required. Accordingly, please provide:

1. A copy of the original Notice to Keeper and any notice chain relied upon to assert keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.

2. Copies of all photographs and video evidence relied upon.

3. A copy of the contract you allege exists between your client and the driver, being actual photographs of the signs in place on the material date, not stock images, together with a site plan showing the sign locations.

4. The precise wording of the clause or clauses allegedly breached.

5. The written agreement between your client and the landowner evidencing standing and authority to enforce and to litigate at this location.

6. A breakdown of the sums claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” add-on includes VAT.

7. Your client’s full basis for alleging that the registered keeper is liable for the charge.

I am entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction, and I require it to meet my own obligation under paragraph 6(b).

If you fail to provide the above, I will treat that as non-compliance with the PAPDC and Pre-Action Conduct and reserve the right to place this correspondence before the Court and to seek appropriate sanctions and costs, including, where appropriate, a stay and/or other case management orders.

Until your client complies and provides the requested material, I am unable to respond properly to the alleged claim or to consider my position. It would be premature and a waste of costs and court time to issue proceedings. Should you do so, I will seek immediate case management relief and an order compelling provision of the above.

Please ensure that your and your client’s records have the correct address for service and erase any other addresses you may hold for the keeper. My current address for service is:

[full address]

Please note, I will not engage with any web portal. I will only respond by email or post.

Yours faithfully,

[my name]

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Am I on the right track with this wording and method of response? I’d really appreciate a view from one of the regulars, as I’ve drafted this as a layman browsing similar posts on this website.

Thanks jfollows, that’s helpful.

I take the point about not copying wording from other cases without understanding whether it applies.

My aim is simply to respond properly to the Letter Before Claim by:

* denying the debt
* explaining the key reasons why the claim is disputed
* disputing the added £70
* asking only for documents/evidence I do not already have or that are central to the alleged contract

Would the following shorter response be more appropriate?

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Subject: Response to Letter Before Claim - PCN NPM207017

Dear Sirs,

Re: Letter Before Claim dated 2 June 2026
PCN: NPM207017
Client: National Parking Management Limited
Location: Woodgrange Road 13-15

I deny any debt to your client.

The claim is disputed. The vehicle was present on site for less than three minutes. I dispute that any contract was formed or breached during that time.

The signage at this location is disputed. In particular, I dispute that the signs made a clear contractual offer capable of acceptance, or that they explained how a driver could obtain an e-permit.

I also dispute the added £70. Please explain the legal basis on which this sum is claimed, whether it is said to be consideration, damages, debt recovery costs, or something else.

The following facts/parts of the claim are disputed:

1. That any contract was formed.
2. That any contractual term was breached.
3. That the signage was sufficiently clear and prominent.
4. That the driver was given a fair opportunity to read and accept any terms.
5. That the registered keeper is liable.
6. That the added £70 is recoverable.

Please provide the documents and evidence on which your client intends to rely, including:

1. Actual photographs of the signs in place on the material date.
2. A site plan showing the position of the signs.
3. The precise wording of the clause or clauses allegedly breached.
4. The written agreement between your client and the landowner showing authority to enforce and litigate at this location.
5. Your client’s basis for alleging keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.
6. Copies of any video evidence relied upon.

For the avoidance of doubt, I am seeking debt advice, but I deny the debt.

Please correspond by email or post.

Yours faithfully,

[Name]

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Is this now closer to what is needed for a Letter Before Claim response?