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       #Post#: 15035--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: H C Andersen
       Date: February 5, 2024, 3:38 am
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       Post the email or else transcribe the relevant part word for
       word regarding the latest date by which you must respond.
       At present we have you saying 'i have got 7 days from the date
       of this correspondence' and NP who, probably through experience,
       thinks this is '7 days beginning on the date'.
       As explained, these are not the same.
       #Post#: 15036--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: dk007
       Date: February 5, 2024, 4:06 am
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       Hi,  looks like today is the last day, this is what the email
       says:
       " you have seven days from the date of this correspondence to
       provide comments on the evidence uploaded by NCP limited-
       Gatwick Airport"
       And it is an 211 page pdf document with personal information at
       number of places, please advise how to hide the personal
       information in such a document and then to upload.
       #Post#: 15037--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: Nosy Parker
       Date: February 5, 2024, 4:14 am
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       I am sorry you sat on this for the entire 7 days before seeking
       advice.  Unfortunately, I have to go out to my day job now.
       Hopefully someone else will advise further.  All I can do is
       urge you to use the wording I've already provided.
       #Post#: 15040--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: DWMB2
       Date: February 5, 2024, 4:28 am
       ---------------------------------------------------------
       As a general rule, you should use the 'comments' stage, to point
       out any holes in the operator's evidence, anything within it
       that reinforces your case, and anything in it that weakens
       theirs. If you've made a point in your appeal that they have
       failed to address, point this out. If they have made a claim
       that is not backed up by their evidence pack, point this out,
       etc. etc.
       It would be useful to see the document but, like Nosy Parker, I
       also have a day job and will have little time to pour over such
       a large document in any great detail. We potentially don't need
       to see all 211 pages, but as we don't know what pages contain
       what, it's hard to advise on what would be useful to see.
       #Post#: 15044--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: H C Andersen
       Date: February 5, 2024, 4:45 am
       ---------------------------------------------------------
       7 days from is......7 days from! Ends on 6th.
       As regards 211 pages, look for anything which:
       1.Gives NCP the right to operate on the land - it's hard to
       believe that everyone is so mad that even large corporations
       don't know the status of their land. Look for anything which
       relates to bylaws applying.
       2. Explains the delay of 5 months between event and serving of
       NTK, surely there's something in the evidence to explain or
       which refers to this.
       In essence, your defence as registered keeper is that:
       In the event that a driver is liable to a landowner or their
       authorised agent for a charge or however else this might be
       described pursuant to a breach of contract, then the law allows
       the creditor to seek relief by holding the keeper liable in the
       driver's stead subject to 'all applicable conditions under this
       Schedule[Schedule 4 to PoFA]' being met by them.
       POPLA is not a judicial proceeding and therefore cannot require
       the appellant to take any particular action but may simply give
       their view as to whether in their opinion the creditor would be
       entitled to relief under Schedule 4 which relates solely to the
       right to hold the keeper liable.
       This must not be confused with the creditor's rights to pursue
       the driver which are legally distinct.
       Such relief is only available if all applicable conditions in
       the Schedule have been met by the creditor: no burden in this
       matter falls to the keeper.
       ..list the creditor's failings..which are objective.
       #Post#: 15047--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: Nosy Parker
       Date: February 5, 2024, 4:58 am
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       I agree it should be that way. But we are in the wacko world of
       POPLA. I don’t advise waiting till tomorrow to find out whether
       POPLA has come to its senses on this
       #Post#: 15048--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: H C Andersen
       Date: February 5, 2024, 5:25 am
       ---------------------------------------------------------
       But we do need the OP to give the 211 pages as good a review as
       they can.
       #Post#: 15056--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: b789
       Date: February 5, 2024, 6:16 am
       ---------------------------------------------------------
       OP, you say that you received the operators response “pack” by
       email. I’m assuming this is as a PDF attachment.
       If this is the case, you should duplicate the PDF file and then,
       using a PDF editor, redact any bits that we do not need to see
       such as your name, address, the VRN and the PCN number. You can
       then upload the redacted document to DropBox, making sure it is
       publicly accessible.
       You can set up a free DropBox account if you don’t already have
       one. Without doing all the legwork for you, there are probably
       other free hosting websites that let you publish PDF documents.
       Why have you left it so late to respond to this?
       #Post#: 15065--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: dk007
       Date: February 5, 2024, 7:47 am
       ---------------------------------------------------------
       Hi, I have tried to split the pdf, page 1 and page 3 are
       attached, page 2 has lots of personal information and just a
       context to page 3 which i am attaching so left page 2. then it
       has got all the pcn, appeals etc which is already here. Part 3
       is the one with all the images etc. I have removed many of the
       last pages as they had the same information as in the last page
       of part 3 pdf. it was increasing the size of the pdf to be very
       high and did not look relevant.
       I thought of raising it earlier but other things got me busy and
       got delayed.
       [attachment deleted by admin]
       #Post#: 15067--------------------------------------------------
       Re: PCN for Gatwick airport drop off zone
   DIR By: b789
       Date: February 5, 2024, 8:06 am
       ---------------------------------------------------------
       Unless there's anything else in the response pack that we
       haven't seen, so far, there is no rebuttal of the fact that you
       appealed as the keeper. Nowhere, in what you've shown us, is
       there a reference to why they are trying to hold you liable as
       the driver.
       The fact that the driver was at the location for 8-9 minutes
       matters not. They could be there for a day and still not be
       liable for the charge if they are not identified. Do they
       mention anywhere in any of the paperwork that they are
       "assuming" you must be the driver because you are also the
       keeper?
       As long as you have not identified as the driver, they cannot
       hold you liable as the keeper because this alleged contravention
       took place on land covered by bylaws. They have not responded or
       rebutted the fact that you are the keeper.
       You also have the fact that the signage is rubbish. Their photos
       of the signage prove that. Have they included any photos of the
       vehicle at the drop off zone?
       Subject to any other opinions, you only need to highlight the
       fact that they have not answered how they can hold you liable as
       the keeper. In your response, you should "lead" the assessor to
       the facts about their inability to hold you liable as the keeper
       and that no inference that you were the driver can be made.
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