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#Post#: 112052--------------------------------------------------
Re: Starbucks, Stansted - DB Legal
By: Claimagainst123 Date: March 4, 2026, 10:05 am
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Hi, I've logged onto MCOl. Haven't done much more but i'll log
on and then submit an AOS.
Do i need to contest the jurisdiction?
#Post#: 112053--------------------------------------------------
Re: Starbucks, Stansted - DB Legal
By: jfollows Date: March 4, 2026, 10:08 am
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No.
That’s for Scotland versus England & Wales, or you don’t live in
the UK at all.
#Post#: 112057--------------------------------------------------
Re: Starbucks, Stansted - DB Legal
By: Claimagainst123 Date: March 4, 2026, 10:22 am
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Thanks. AOS was submitted.
#Post#: 112058--------------------------------------------------
Re: Starbucks, Stansted - DB Legal
By: jfollows Date: March 4, 2026, 10:27 am
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You therefore have 5+14+14 days from the issue date (which you
obscured) on the N1SDT to submit a defence.
#Post#: 112146--------------------------------------------------
Re: Starbucks, Stansted - DB Legal
By: InterCity125 Date: March 5, 2026, 4:54 am
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These are the bulk of the defence points which should be
included.
As already advised, please read through some other threads which
deal with providing a defence submission.
Please ensure that you are vaguely familiar with the process
since it is not entirely complex and is designed for a litigant
in person rather than a legal professional.
Give it a few days for others to add further if needed - in my
opinion, this is a decent skeleton defence - more can be added
in the Witness Statement if needed.
I strongly suspect that the parking operator will NOT want to
provide the official plan since such a plan would destroy their
business at this location.
Southgate Park Defence Points
That the claim is denied in its entirety and that no debt is
owed.
It is acknowledged that I am the Registered Keeper of the
vehicle specifically mentioned in the Claim Form.
In the first instance, the vehicle driver is not known by the
claimant.
That this is a contract dispute and, as such, there is
absolutely no legal requirement for a Registered Keeper to
reveal driver details to an unregulated private parking
contractor.
As such, I will not be providing any driver details and no
presumption can be drawn from me simply exercising my legal
right.
That the land, mentioned by the Claimant, at Southgate Park,
Stansted is clearly inside the statutory boundary of the
Stansted Airport Area.
That all the land inside the Stansted Airport Area is
designated, by the Government, as being Land Under Statutory
Control and, as such, PoFA 2012 Schedule 4 cannot be used at
this particular location as this location is not 'relevant land'
as defined under PoFA 2012.
That a Statutory Instrument exists and is legally in place.
That this Statutory Instrument is known as 'The Stansted -
London Byelaws'.
That the Statutory Instrument sets out parking controls within
the Land Under Statutory Control.
That the 'Statutory Control' mentioned in the term 'Land Under
Statutory Control' is the Statutory Instrument and, as such, by
definition, the Statutory Instrument covers the entire area of
Land Under Statutory Control.
That while the land at Southgate Park is privately owned, it
remains within the official Airport Area and therefore remains
under the control of the Statutory Instrument.
The Claimant has stated (in previous communications) that the
land at Southgate Park is no longer within the designated area
under statutory control and that, consequently, PoFA 2012 can in
fact be used to establish Keeper Liability at the location.
That I therefore put the Claimant to STRICT PROOF to provide, to
the Court, a formal Airport Plan document provided by either the
LOCAL AUTHORITY or the GOVERNMENT which shows the claimed
revised airport area boundary which specifically excludes the
land at Southgate Park.
That the airport plan often used, by the claimant, in the
parking appeals process will not be accepted since that plan
specifically excludes land not owned by the airport operator -
meaning; that even if the land at Southgate Park was inside the
Airport Area it would never be shown on that particular plan.
That, as PoFA 2012 cannot be used at Southgate Park, the
Claimant is unable to move liability from the unknown driver
onto the Registered Keeper.
That, with both the driver unknown and, no keeper liability,
there is no legal route by which the Claimant can hold me
liable.
The Claim is therefore denied in its entirety.
Additional defence points which the Court should be made aware
of;
That the Claimant's issued Parking Charge Notices (PCNs) are in
clear breach of the parking operators Code of Practice since the
PCNs specifically mention PoFA Keeper Liability.
The operators Code of Practice EXPRESSLY PROHIBBITS operators
specifying keeper liability under PoFA 2012 when PoFA cannot
apply.
A breach of the Code of Practice is automatically a breach of
the operator's KADOE Agreement with the DVLA since that
agreement specifically requires that the operator agree to
follow the Code of Practice.
My details have therefore been obtained in breach of the KADOE
Agreement.
That this also constitutes a misuse of personal data.
#Post#: 112408--------------------------------------------------
Re: Starbucks, Stansted - DB Legal
By: Gooner063 Date: March 8, 2026, 5:30 am
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Intercity I somehow pressed dislike on your post, instead of
like, please dont hold that against me ;)
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