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       #Post#: 123038--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: InterCity125
       Date: June 26, 2026, 5:17 am
       ---------------------------------------------------------
       You are now waiting for a Letter Before Claim which needs
       replying to.
       Ignore all other begging debt letters which will almost
       certainly arrive.
       Once the LBC arrives we can advise further.
       DCB Legal will almost certainly issue a County Court Claim but
       this is easy to defend - they work on the basis that the average
       person on the street doesn't know how the legal system works and
       cocks up at some stage.
       #Post#: 123613--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: TesterChavern
       Date: July 2, 2026, 11:45 am
       ---------------------------------------------------------
       Good afternoon,
       I have received the inevitable DCB Legal Letter of claim, please
       could you advise?
       We act for Euro Car Parks Limited and write in respect of an
       unpaid parking charge(s). This is a formal Letter of Claim in
       accordance with the Pre-Action Protocol for Debt Claims.
       Basis of Claim
       The vehicle with registration number XXXX XXX ("Vehicle") was
       parked on private land ("Land") managed by our Client. The signs
       displayed on the Land set out the Terms of parking (i.e. "the
       Contract"). The Vehicle was parked in breach of the Terms and as
       such the Contract was accepted and a Parking Charge(s) was
       issued. You are liable as the Keeper or Driver. The details of
       the Parking Charge(s) can be found in the schedule at the bottom
       of this letter. Payment was due within 28 days of the Parking
       Charge(s) being issued but remains outstanding.
       The amount of the debt is £170.00, which includes the Parking
       Charge(s) and debt recovery costs. If a claim is issued, further
       costs will be sought, together with accruing interest at 8%
       pursuant to s.69 of the County Courts Act.
       Next Steps
       Within 30 days of the date of this letter, you should either
       make payment using one of the methods detailed overleaf or
       complete the Reply Form and financial statement. Failure to do
       so is likely to result in a claim being issued without further
       notice. Please visit www.dcblegal.co.uk/response to complete and
       submit the reply form and financial statement. You will also
       find an additional information sheet summarising your rights and
       responsibilities under the Pre-Action Protocol for Debt Claims.
       Your attention is drawn to the Civil Procedure Rules 1998 and
       the Court's power to impose sanctions if you fail to pay or
       respond. Any such failure will be brought to the attention of
       the Court when considering costs. Any non-compliance with the
       Rules can increase liability for costs. The BPA Code of Practice
       requires us to make the customer (driver/keeper) aware of the
       implications of non-payment including, should the Court find
       against them, the risk to their credit rating.
       We suggest you deal with this as a matter of urgency to avoid a
       claim being issued. You may wish to seek independent legal
       advice from a Solicitor or other free money advice organisation.
       If you would like a 'dispute resolution call' with our team, or
       a paper copy of the information sheet, reply form or financial
       statement, please call our office on 0203 434 0427.
       #Post#: 123642--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: InterCity125
       Date: July 3, 2026, 1:38 am
       ---------------------------------------------------------
       Reply with the following;
       To whom it may concern,
       I write with reference with your Letter Before Claim which I
       received this morning - I have duly noted its contents.
       I am happy to make the following representation;
       It is acknowledged that I am the Registered Keeper of the
       vehicle in question.
       However, the driver is not known to your parking operator client
       and there is no legal requirement for me to provide such
       information and I will not be providing driver details under any
       circumstance because the law does not demand it.
       Furthermore, your client's PCN (Notice to Keeper) is not
       compliant with the requirements of PoFA Schedule 4 Paragraph
       9(2) and fails to convey all the conditions which the
       legislation clearly demands.
       Therefore, based on the above, there is no legal route by which
       I can be liable in this matter and I therefore deny that any
       monies are owed by myself to your client.
       I believe that this letter clearly sets out the correct legal
       position in this matter.
       I am sorry that I am unable to help you further.
       Best wishes,
       xxxxxxx xxxxxxxxx
       #Post#: 123951--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: TesterChavern
       Date: July 7, 2026, 5:00 am
       ---------------------------------------------------------
       Thanks,
       I sent that off, and got this email in return:
       We write in response to your correspondence received in our
       office.
       We now respond to the same as follows.
       Schedule 4 (4)(1) of the Protection of Freedoms Act 2012 (“the
       Act”) states “The creditor has the right to recover any unpaid
       parking charges from the keeper of the vehicle”. For the purpose
       of the Act; “keeper” means the person by whom the vehicle is
       kept at the time the vehicle was parked, which in the case of a
       registered vehicle is to be presumed, unless the contrary is
       proved, to be the registered keeper. The DVLA confirmed that you
       were the Registered Keeper at the time the parking charge was
       issued and as no transfer of liability has been received by our
       Client, they have the right to recover the parking charge from
       you as the Keeper of the vehicle.
       
       The Notice to Keeper was issued to you. A copy is attached. You
       were afforded the opportunity to; appeal the parking charge,
       transfer liability to the driver (if it was not you) or make
       payment. Neither a successful appeal, nor an adequate nomination
       were received, yet payment remains outstanding.
       
       The Final Notification Letter was issued to you. A copy is
       attached. This notice reiterated that payment was outstanding
       and confirmed that legal action may be taken, and additional
       costs incurred if the parking charge was not paid.
       
       Please note the timeframe in which to appeal the Parking Charge
       has expired. You were given the opportunity to lodge an appeal
       when the initial Notice was issued to you. Given that the case
       has been escalate to this firm for recovery action, the time to
       appeal has now elapsed and payment of the PC is now required.
       You now have 30 days from the date of this email to make payment
       of £170.00. Failure to make payment may result in a Claim being
       issued against you without any further reference.
       Payment can be made via bank transfer to our designated client
       account: -
       You must quote the correct case reference () when making
       payment. If you do not, we may be unable to correctly allocate
       the payment. If further action is taken by us as a result of an
       incorrect reference being quoted, you will be liable for any
       further fees or costs incurred.
       #Post#: 123953--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: jfollows
       Date: July 7, 2026, 5:14 am
       ---------------------------------------------------------
       They have no legal right to pursue the registered keeper if they
       did not comply with the requirements of PoFA 2012, which they’re
       happy to spout when it suits their narrative.
       You can ignore this, and wait for the N1SDT county court claim
       form. In the meantime, if you haven’t done so already, read up
       on what DCB Legal does with these by searching countless
       examples on the forum.
       As long as you stay on top of the process, it’s extremely likely
       that DCB Legal will discontinue before having to pay the court
       fee.
       You should think about and write your defence for the claim so
       that you’re not rushed into it in due course. Your defence
       should build on what you’ve already used by quoting the
       appropriate part of the legislation and why the PCN did not
       comply with this.
       #Post#: 123956--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: InterCity125
       Date: July 7, 2026, 5:33 am
       ---------------------------------------------------------
       What the legislation actually states is;
       the creditor will (if all the applicable conditions under this
       Schedule are met) have the right to recover from the keeper so
       much of that amount as remains unpaid
       Notice how they paraphrase the wording in order to remove that
       part which actually applies to the response made by you to their
       LBC?
       #Post#: 123957--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: TesterChavern
       Date: July 7, 2026, 5:44 am
       ---------------------------------------------------------
       Thanks, this is really helpful and matches what I’ve been
       reading on here. I hadn’t fully clocked the DCB Legal
       discontinuance pattern until mentioned above, good to know what
       to expect l
       I won’t respond to the LBC beyond what I’ve already sent, and
       I’ll sit tight for the N1/PCOL claim form rather than chasing
       them. In the meantime I’ll get my Defence properly drafted
       rather than leaving it to the last few days - I’ll build on the
       POFA point and reference the specific paragraph of Schedule 4
       that the NTK failed to comply with, rather than just asserting
       non-compliance generally.
       Will keep this thread updated as it progresses in case it helps
       anyone else facing DCB Legal on the same pattern.
       Again, big thanks for all your help
       #Post#: 127723--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: TesterChavern
       Date: August 13, 2026, 8:30 am
       ---------------------------------------------------------
       Hi all,
       I've received the claim form today, Issue date 10 August 2026,
       via the Civil National Business Centre. Particulars of Claim
       plead it two ways:
       "3. The Defendant is pursued as the driver of the vehicle for
       breach of the terms on the signs... 4. In the alternative the
       Defendant is pursued as the keeper pursuant to POFA 2012,
       Schedule 4."
       So they've now expressly alleged I was the driver, as well as
       the keeper argument in the alternative. I've never said I was
       the driver anywhere in correspondence and don't intend to start
       now.
       Claim is for £170, described in the Letter of Claim as "PC +
       debt recovery costs" but in the Particulars as "PC + damages,"
       which seems like an inconsistency worth flagging.
       ---------------------------------------------------------
       I'm Filing AOS now (defend in full, no admissions beyond
       registered keeper status). I've outlined my draft defence below,
       I'm grateful for eyes on the wording before I file:
       -
       Admit registered keeper only. Deny the rest. Deny entering into
       any contract with the Claimant. Driver never identified.
       As to driver allegation - not admitted, Claimant put to strict
       proof, no presumption keeper = driver.
       As to PoFA/keeper allegation - deny Claimant can rely on
       Schedule 4. NTK fails 9(2)(b) (no express statement charges
       unpaid) and 9(2)(e) (no "creditor doesn't know driver"
       statement, no pay-or-identify invitation).
       No valid liability route established either way.
       £170 figure disputed given the PC/damages inconsistency between
       LBC and Particulars - Claimant to prove basis for anything
       beyond the bare charge.
       Interest/costs denied accordingly.
       Invite Court to dismiss.
       -
       ---------------------------------------------------------
       Does the 9(2)(b)/9(2)(e) analysis above hold up, or am I missing
       something in the wording?
       Anything you'd add/cut from the draft defence given they've now
       explicitly pleaded driver AND keeper in the alternative?
       Any known pattern for whether DCB Legal tend to discontinue once
       a defence citing 9(2)(e) specifically is filed, or does it
       usually run further?
       Is the PC/damages wording discrepancy worth a line in the
       defence or is it a distraction from the main argument?
       #Post#: 127731--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: InterCity125
       Date: August 13, 2026, 11:10 am
       ---------------------------------------------------------
       We can come up with a short & sharp defence which covers the
       salient points.
       Can we assume that the claim is from the clueless DCB Legal?
       Assuming that it is, then it is important to note that they will
       not (99%) go through with a formal Court hearing.
       This process is simply a case of you knocking the ball back over
       the net each time you need to.
       As the hearing gets near they will bottle out and discontinue -
       they are hoping that in the meantime they can apply enough
       pressure to make you cave in.
       #Post#: 127732--------------------------------------------------
       Re: ECP / DCBL - No Valid Payment - Weavers Wharf Kidderminster
       - No LBC yet
   DIR By: TesterChavern
       Date: August 13, 2026, 11:14 am
       ---------------------------------------------------------
       Hello, yes it is from DCB Legal, I’m hoping the same thing and
       feel strong with the defence points.
       As always, appreciate your help on this one.
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