Free Traffic Legal Advice

Hello. 

We just received Letter of claim from Moorside Legal regarding UKPS.  This is from June 2022. 
We did request a SAR back in August 2022 due to UKPS sending. Details to my old address. 
Since then as registered owner  I have received numerous chaser letter and I have ignored them all and never responded. 

The PCN showes blurry photos, incorrect colour of my car and no details of any signs and was there for 15 minutes.  Now I’ve received letter of claim.

The location is a closed down pub attracting easy fines and has been in the media flooded with many complaints regarding the fines. X visited the pub which was closed with no payment options. The pub is 50 miles from our home and X was visiting family at the time.
 
Appreciate any advice and help.

https://imgur.com/a/GOaSUdu

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You do not fill in any of the forms they sent to you, especially the information sheet.

You email them back with the following and that is it:

Dear Sirs,

Your Ref. ############
Moorside Legal Ltd.
UKPS Ltd

I refer to your your letter of claim.

I confirm that my address for service for the time being - assuming you don't faff about and delay any claim - is as follows, and any older address must be erased from your records:

[MY ADDRESS]

The alleged debt is disputed and any court proceedings will be vigorously defended.

I note that the amount being claimed has increased by a hugely exaggerated amount which the Government called "extorting money from motorists". Don't send me your usual blather about that.

I have two questions, and under the PAP I am entitled to specific answers:

1. Am I to understand that the additional £70 represents what you lot dress up as a 'Debt Recovery' fee, and if so, is this nett or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?

2. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?

The message for your client is to cease and desist, and if they fail to understand, may I refer them - and you - to the reply given in the case of Arkell v Pressdram.

Yours faithfully,