Please can I have some feedback on my response below?
I'm trying my best, trawling through this site to gather info to form a response.
Anything feedback will be greatly appreciated.
Thank you
Dear Sirs,
Re: Letter of Claim dated 10 September 2026
Your Reference: [********************]
Your Client: Euro Car Parks Limited
PCN: *********************
I acknowledge receipt of your Letter of Claim dated 10 September 2026.
THE ALLEGED DEBT IS DISPUTED IN ITS ENTIRETY. NO ADMISSION OF LIABILITY IS MADE.
I am the registered keeper of the vehicle. Nothing contained in this correspondence is to be construed as identifying or admitting the identity of the driver.
Your Letter of Claim asserts, without adequate particularisation, that I am liable as the “Keeper or Driver”. Those are distinct potential bases of liability. Your client is required to identify the basis upon which it contends that I am personally liable, rather than leaving that fundamental issue ambiguous.
If your client contends that I am liable as the registered keeper, it must identify whether it relies upon Schedule 4 of the Protection of Freedoms Act 2012 (“POFA”) and demonstrate that the applicable statutory requirements were satisfied.
I no longer hold the original Parking Charge Notice/Notice to Keeper. Accordingly, your client’s assertion of keeper liability cannot presently be assessed.
Furthermore, your Letter of Claim demands £170, despite the underlying parking charge having been substantially lower. Your description of the additional sum merely as “debt recovery costs” is inadequate. The additional sum is expressly disputed, and your client is required to identify the contractual and legal basis upon which it contends that I am liable for it.
The underlying parking charge is also disputed.
A parking payment was made in connection with the parking event, although it subsequently transpired that payment had been made through the incorrect parking operator/payment system. This was raised during the appeal to Euro Car Parks.
The alleged event occurred at the Howard Centre Multi-Storey Car Park on a Sunday evening after the shopping mall had closed, in connection with use of the outdoor laundrette.
In rejecting the appeal, your client relied upon a photograph of signage situated near the entrance to the shopping mall. The adequacy, prominence and positioning of the contractual signage accessible to a motorist using the car park and outdoor laundrette at the material time are disputed.
FORMAL REQUEST FOR INFORMATION AND DOCUMENTS
In order that I may properly understand your client’s case and provide a fully informed response in accordance with the Pre-Action Protocol for Debt Claims, your client is required to provide the following:
1. A complete copy of the original Parking Charge Notice/Notice to Keeper, including the reverse and all accompanying pages, together with evidence of the date of issue and posting.
2. Confirmation of whether your client pursues me as the driver or the registered keeper.
3. If keeper liability is alleged, confirmation that your client relies upon Schedule 4 of the Protection of Freedoms Act 2012, identifying how and when each applicable statutory condition is said to have been satisfied.
4. Full particulars of the alleged breach, including the vehicle’s recorded entry and exit times and the alleged duration of parking.
5. Copies of all ANPR images and other photographic evidence upon which your client intends to rely.
6. Identification of the precise contractual term allegedly breached and a copy of the terms and conditions said to have formed the parking contract on 3 December 2025.
7. Contemporaneous photographs of all relevant signage actually displayed on 3 December 2025, showing its wording, location, height, font size, prominence and visibility.
8. A contemporaneous site plan showing the locations of all entrance signs, contractual signs, payment machines and other payment facilities.
9. Evidence showing what contractual/payment signage would actually have been encountered by a motorist entering the car park and accessing the outdoor laundrette after the shopping mall had closed.
10. Full details of the payment arrangements operating at the site on 3 December 2025, including whether payment could be made following exit and any period allowed for doing so.
11. Evidence of Euro Car Parks Limited’s authority from the relevant landowner to operate at the location, enter into parking contracts and pursue parking charges in its own name at the material date.
12. A complete itemised calculation of the £170 now demanded, identifying separately the original parking charge and every additional amount subsequently added.
13. If the additional £70 represents a debt recovery fee, identify the precise contractual term existing at the material time which your client alleges created a liability upon the driver and/or keeper to pay that sum, together with the legal basis upon which it is now recoverable from me.
14. Confirm whether the principal parking charge is alleged to constitute damages for breach of contract or consideration payable pursuant to a contractual term.
Your client has chosen to threaten litigation. It must therefore be prepared to properly particularise and evidence the case it proposes to bring.
Until the above information and documents have been supplied, the alleged debt remains disputed in full and your client’s case cannot be properly assessed.
Should your client commence proceedings without first providing the information reasonably requested above and complying substantively with its pre-action obligations, I reserve the right to place this correspondence before the Court when the issues of pre-action conduct, case management and costs are considered, and to seek any appropriate order, including a stay to permit proper compliance.
For the avoidance of doubt, I do not consent to the inference of driver identity from my status as registered keeper or from anything contained within this correspondence.
Please now provide the requested documents and information and confirm that proceedings will not be commenced while your client complies with its obligations under the Pre-Action Protocol for Debt Claims.
The alleged debt remains disputed in full.
Yours faithfully,
[*********************]
Registered Keeper