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       #Post#: 124285--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: jfollows
       Date: July 10, 2026, 8:21 am
       ---------------------------------------------------------
       You can obtain the original PCN with a Subject Access Request to
       CEL. It may be important to help you construct your defence.
       However it is unlikely you will receive this original PCN in
       time for you to construct your defence.
       #Post#: 124288--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: sace321
       Date: July 10, 2026, 8:28 am
       ---------------------------------------------------------
       do i have to send the subject access request by email or does it
       have to be by post?
       #Post#: 124290--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: sace321
       Date: July 10, 2026, 8:38 am
       ---------------------------------------------------------
       okay i have sent an email to CEL with the subject access
       request. Will update when i get a response
       #Post#: 124296--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: InterCity125
       Date: July 10, 2026, 9:28 am
       ---------------------------------------------------------
       You could submit this skeleton defence just so you appear to be
       jumping through the hoops.
       Nothing to worry about at this stage - the chances of you having
       to pay anything is minimal.
       Obviously you need to put in the correct reg number.
       CEL Defence
       1. I am defendant named on the Claim Form and I completely deny
       the allegation that any money is owed by myself to the Claimant.
       2. The Claimant's Particulars of Claim (POC) are extremely vague
       which makes responding in the correct manner difficult given
       that the alleged debt stems from an alleged contract breach
       which they claim occurred some years ago.
       3. The Claimant's POC fail to state the nature of the contract
       breach on which their claim is based.
       4. Not withstanding the above, I will press on and offer a
       'skeleton defence' - I request that the Court note the vague
       nature of the claim since I may need to add additional points at
       a later point in time.
       5. It is acknowledged that I was the Registered Keeper of
       vehicle AB12 CDE at the material time.
       6. The vehicle driver is not known to the Claimant and the
       Claimant has offered no evidence of the drivers identity.
       7. That there is no legal requirement for a vehicle keeper to
       provide driver details to an unregulated parking operator and
       therefore I will not be providing such driver details under any
       circumstance since the law simply does not demand it.
       8. That no inference can be drawn from my refusal to provide
       such driver details as I am simply exercising my right to say
       nothing.
       9. That the Claimant is not pleading any further keeper
       liability (on my part) under Protection of Freedoms Act 2012
       (POFA) and I therefore ask the Court to note this fact in case
       they attempt to breach protocol and add such an additional plea
       at a further point in time.
       10. That with the driver unknown and no plea under POFA, the
       Claimant has absolutely no legal route by which they can hold me
       liable for the alleged debt.
       11. The debt is therefore denied in its entirety.
       #Post#: 124298--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: DWMB2
       Date: July 10, 2026, 9:35 am
       ---------------------------------------------------------
       Worth noting that this is even more vague than many we see, in
       that they don't state at all in what capacity they are seeking
       to recover from the OP.
       One could assume they're seeking to do so as the driver, but
       only insofar as that would be the default party to any contract
       and they don't make any claims to the contrary in their PoC.
       #Post#: 124302--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: sace321
       Date: July 10, 2026, 10:03 am
       ---------------------------------------------------------
       thank you all for the responses. I will wait a till Monday to
       see if i get a reply from the subject access request to see if i
       can get some more information about the original PCN. if i
       haven't gotten an reply by then i will send the skeleton
       defense. I've been doing a bit of research and it seems CEL have
       a notoriously bad reputation with adding fake charges on PCNs.
       ill send an update when i hear anything back.
       #Post#: 124312--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: InterCity125
       Date: July 10, 2026, 11:31 am
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > Worth noting that this is even more vague than many we see, in
       that they don't state at all in what capacity they are seeking
       to recover from the OP.
       >
       > One could assume they're seeking to do so as the driver, but
       only insofar as that would be the default party to any contract
       and they don't make any claims to the contrary in their PoC.
       >
       --- End Quote ---
       I agree 100% and hopefully a decent Judge will pick up on that
       immediately especially if he or she is familiar with such
       private parking issues.
       The POC does specifically mention the word "Drivers" in their
       preamble so we can use that under the guise of reasonable
       assumption when trying to interpret the vague particulars.
       I think there's enough in the vague POC to be able to use that
       against them if the matter progresses.
       #Post#: 125950--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: sace321
       Date: July 27, 2026, 5:30 pm
       ---------------------------------------------------------
       here an update. i sent a response denying the claim on the MCOL
       website and got a letter in the post saying we are waiting for a
       response from the claimant. Earlier this week i got another
       letter from civil enforcement with a copy of the " directions
       questionaire" and also confirming they have sent another copy to
       the court. The questionaire has a box checked that says they
       agree that the small claims track is appropriate for this case
       and also checking the box that says they agree that the claim is
       suitable for determination without a hearing. apart from that
       they requested the gearing be conducted remotely. All other
       boxes are checked no. Is there anything else i need to do at
       this point?
       #Post#: 125971--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: jfollows
       Date: July 28, 2026, 1:18 am
       ---------------------------------------------------------
       No, but search the forum for "N180" which will result in your
       finding advice on completion of your Directions Questionnaire,
       which you need to do when the court sends you the paperwork or
       when your MCOL account shows that it's been sent to you.
       Your form will say that you request a hearing in person at a
       court local to you and your wishes will override those of the
       claimant.
       #Post#: 126130--------------------------------------------------
       Re: recieved a claim form for a parking ticket from parking
       outside a pub in 2023
   DIR By: sace321
       Date: July 28, 2026, 8:17 pm
       ---------------------------------------------------------
       will do thanks
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