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       #Post#: 125114--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: DottieRottie
       Date: July 19, 2026, 2:58 pm
       ---------------------------------------------------------
       Thanks Tincombe for your reply. In answer to your reply:
       The photos provided are for the entry and exit of the whole site
       apart from staff parking and A & E. Everybody that parks at the
       hospital will pass these cameras. I have no idea why they state
       the driver was parked in the drop off zone, they turned left
       into the main car park before what I assume is the drop off
       zone. The cameras are not in the drop off zone.
       My mother’s appointment was at 2.15pm, the driver arrived at
       1.30pm allowing time to find a parking space which they did
       immediately. Why would the driver park in a drop off zone for a
       pre booked appointment for what could potentially be all
       afternoon? The ophthalmology clinic saw my mother at 14.05pm as
       she was early and she was finished by 14.25pm approx. It was an
       8-10 minute walk from the payment machine in the main entrance
       back to the car. Had the driver been parked in the drop off
       zone, which I assume to be the red zone outside the main
       entrance, it would have been a 2 minute slow walk, absolute
       maximum. The driver has the ticket that confirms payment, time
       of payment and the camera shows time of exit.
       The rejection of appeal email from Group Nexus stated:
       Clear signs at the entrance of this site and throughout inform
       drivers that the drop-off car parking space has a 15-minute time
       limit, and payment is not permitted. Your representations are
       not considered a mitigating circumstance for appeal.
       In light of this, on this occasion, your representations have
       been carefully considered and rejected.
       There are payment facilities obviously but I think they are
       saying the car was parked in the drop off zone and a normal
       parking payment is not allowed as there is a 15 minute walk time
       limit. It did not register with the driver the location of drop
       off zone on their original parking invoice, they were so
       perplexed as to why a notice had been received as no offence had
       been committed.
       I am not paying the charge which would be the easy and hassle
       free way out but I am so angry that a parking company can make
       an incorrect assumption with no proof and expect a person to
       just pay up. If I were in the wrong I would accept the charge
       but this is just not right.
       I have emailed PALs and will await their response.
       If no joy, I will really need help with putting together an
       appeal for POPLA. I appreciate all the help and advice I’ve
       received so far.
       #Post#: 125117--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: tincombe
       Date: July 19, 2026, 3:32 pm
       ---------------------------------------------------------
       IMO, you've got the essence of any submission to POPLA.
       I know you know the minutiae, but this isn't necessary at POPLA
       and, please don't take this wrongly, IMO serves only to confuse
       because it doesn't address the key issues:
       What is the PPC's evidence;
       Does it withstand scrutiny and meet the required legal standard
       of proof?
       #Post#: 125118--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: DottieRottie
       Date: July 19, 2026, 4:15 pm
       ---------------------------------------------------------
       I understand what you’re saying which is why I will ask for/
       need help with any POPLA appeal if PALS can’t assist. You guys
       clearly have vast experience in these matters.
       The PPC (private parking company?) have no evidence of the
       vehicle being parked in the drop off zone because there isn’t
       any as it wasn’t.
       #Post#: 125119--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: tincombe
       Date: July 19, 2026, 5:23 pm
       ---------------------------------------------------------
       'It wasn't' cannot be proved by you. Whether you were is NOT the
       issue.
       As I suggested:
       Substantially, it would appear that the photos do not prove that
       you were parked in the Drop-Off zone unless these are from
       cameras which cover ONLY the drop off zone and there is no other
       exit from that zone.
       It is THEIR evidence which you attack with facts.
       #Post#: 125976--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: DottieRottie
       Date: July 28, 2026, 2:02 am
       ---------------------------------------------------------
       Good morning
       I’m sorry but  I need your further help please.
       I sent an urgent email to PALS 8 days ago as suggested and I
       have received neither a reply nor an acknowledgement from them.
       I have yesterday received a reminder from Group Nexus, please
       see attached.
       The time limit for submitting an appeal to POPLA is 28 days from
       6th July 2026 this being the date of  the email from Group Nexus
       rejecting my appeal with them.
       Please could you help me construct an appeal to POPLA as I do
       not want to get it wrong . GN have stated they may appoint a
       debt recovery company if I don’t pay the full Ł80 within 14
       days. How long does it take for POPLA to reply? I really don’t
       want a debt recovery company chasing me for a charge I don’t owe
       and for a charge that is ever increasing.
       Thanking you in anticipation.
  HTML https://ibb.co/VYgPLhJ9
       #Post#: 125977--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: InterCity125
       Date: July 28, 2026, 2:44 am
       ---------------------------------------------------------
       I can jot something down.
       Give me 48 hours.
       #Post#: 125993--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: DottieRottie
       Date: July 28, 2026, 5:10 am
       ---------------------------------------------------------
       Thank you so much, it really is appreciated!
       #Post#: 126003--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: DottieRottie
       Date: July 28, 2026, 6:44 am
       ---------------------------------------------------------
       Email form PALS received at 11.42 today.
       Mitie is who I emailed requesting footage of me being parked in
       the drop off zone and also where I was actually parked. No
       response from them, I wonder why ………………
       “Thank you for your email to the Patient Advice and Liaison
       Service (PALS) at The Dudley Group NHS Foundation Trust (DGFT)
       regarding the car parking fine received at Russells Hall
       Hospital. I am sorry to note the circumstances of what happened.
       As a Private Finance Initiative (PFI) hospital, the Facilities
       Management of the site, including the car parking management, is
       run by Mitie who utilise a company named GroupNexus to manage
       the car parks. If you require further information/assistance,
       please email Mitie directly to anpr.rhh@mitie.com be assured
       that a member of the Mitie ANPR team will contact you.
       Regarding your appeal that has been rejected:   As you are not
       happy with the response from GroupNexus, we recommend contacting
       the Parking on Private Land Appeals (POPLA) on 03301 596 126.
       Yours sincerely,”
       #Post#: 126336--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: DottieRottie
       Date: July 30, 2026, 3:25 pm
       ---------------------------------------------------------
       @Intercity 125
       I’m sorry to chase but just aware of time limit to appeal to
       POPLA is fast approaching.
       Did you manage to put something together? Should I rely on the
       fact they have no proof I was parked in the drop off zone?
       Thanks in anticipation.
       #Post#: 126365--------------------------------------------------
       Re: Russell’s Hall Hospital, Dudley
   DIR By: InterCity125
       Date: July 31, 2026, 1:45 am
       ---------------------------------------------------------
       POPLA Appeal.
       I make this appeal as the Registered Keeper - the driver is not
       known to the parking operator.
       Appeal Point One - The operator's NtK does not demonstrate that
       any contravention occurred.
       The operator claims that the vehicle was parked in the 'drop off
       zone' at the hospital. I can confirm that my vehicle was never
       parked in that location and was in fact parked in the correct
       car park for longer stays and that this stay was correctly paid
       for. The operator accepts that payment was made.
       The operator's NtK appears to be reliant on ANPR images which
       monitor the entry and exit of vehicles to the WHOLE hospital
       site.
       However, the ANPR images shown cannot differentiate between
       vehicles using the different car parks or the drop off zones -
       meaning; the ANPR system cannot be used as evidence of parking
       in the drop off zone because the driver could well have parked
       (correctly) in a different car park.
       In this instance I understand that the vehicle was parked
       correctly and that payment was made.
       Appeal Point Two - No keeper liability. The Notice to Keeper
       does not comply with PoFA Schedule 4 paragraph 9(2)(e).
       Paragraph 9(2)(e) requires the Notice to Keeper to state that
       the creditor does not know both the name of the driver and a
       current address for service for the driver and to invite the
       keeper either to pay the unpaid parking charge or, if the keeper
       was not the driver, to notify the creditor of the name of the
       driver and a current address for service for the driver and to
       pass the notice to the driver.
       This Notice to Keeper does not properly give that statutory
       invitation to the keeper. Instead, it refers to the driver being
       liable and seeks the driver’s details, but it does not properly
       invite the keeper to pay the unpaid parking charge in the form
       required by PoFA. Keeper liability is purely statutory. If the
       operator wishes to rely upon it, it must comply strictly with
       the statute. It has not done so.
       This is not a trivial or academic point. In a recent Court case,
       ParkingEye Ltd v Ghansah, claim number M4FC56Q6, dated 29
       December 2025, in which the court expressly dismissed the claim
       because the claimant pursued the defendant as keeper, not
       driver, and the claimant’s notice to keeper “does not include
       the invitation to pay required by POFA paragraph 9(2)(e)”. That
       is not cited as binding authority, but as a clear example of a
       court recognising that this exact defect is fatal where keeper
       liability is being asserted. POPLA is not being asked to treat
       that order as precedent, but it is invited to recognise the
       obvious point it illustrates: paragraph 9(2)(e) is a mandatory
       statutory condition, not an optional form of words.
       The operator’s rejection letter makes its position plain. It
       states that the charge was issued under Schedule 4 of PoFA and
       that, because no driver details were provided, the registered
       keeper is being held liable. That is an express reliance on
       PoFA. It therefore remains for the operator to demonstrate full
       compliance with paragraph 9(2)(e). It cannot do so.
       As the Notice to Keeper does not comply with paragraph 9(2)(e),
       the operator has failed to establish any right to recover the
       charge from the keeper.
       Appeal Point Three - No keeper liability. The Notice to Keeper
       does not comply with PoFA Schedule 4 paragraph 9(2)(h).
       Paragraph 9(2)(h) requires the Notice to Keeper to identify the
       creditor. That means the legal person said to be entitled to
       recover the parking charge.
       This Notice to Keeper does not clearly identify the creditor. It
       uses GroupNexus branding, refers in the footer to CP Plus
       Limited (company number 02595379) t/a GroupNexus, and elsewhere
       refers to “our Client’s property”. That wording is not clear
       identification of the creditor. It leaves the recipient to infer
       the alleged creditor’s identity rather than stating it
       expressly.
       That defect is particularly serious here because GroupNexus is
       no longer merely a trading name used by CP Plus Limited.
       GroupNexus Limited (company number 15560549) is now itself a
       separate incorporated legal entity. That is the crucial point.
       Historically, an operator might have argued that “GroupNexus”
       was simply branding for CP Plus Limited and nothing more. That
       is no longer safely arguable once GroupNexus Limited exists as a
       distinct company in its own right.
       Accordingly, when this Notice to Keeper uses “GroupNexus”
       branding, refers in the footer to CP Plus Limited (company
       number 02595379) t/a GroupNexus, and also refers to “our
       Client’s property”, the recipient is left uncertain as to which
       legal person is allegedly the creditor. Is it said to be CP Plus
       Limited? Is it said to be GroupNexus Limited (company number
       15560549)? Or is it some unnamed client or principal? The Notice
       does not say.
       That is not a trivial technicality. The whole purpose of
       paragraph 9(2)(h) is to ensure that the recipient knows the
       identity of the creditor. PoFA requires the creditor to be
       identified clearly within the Notice to Keeper itself. It is not
       enough for the recipient to be left to guess from branding,
       trading styles or vague references to a client.
       POPLA is therefore invited to understand the precise implication
       here: once GroupNexus Limited exists as a separate legal entity,
       the old casual use of “GroupNexus” as if it were merely a
       harmless trading label is no longer sufficient for PoFA
       purposes. The Notice must make clear which legal person is the
       creditor. This Notice fails to do so. Paragraph 9(2)(h) has
       therefore not been complied with.
       The operator may not cure that defect later by assertion in its
       rejection letter. The statutory notice itself must comply.
       The operator has not shown that the appellant is the driver.
       I am the registered keeper. I am appealing only as keeper. The
       driver has not been identified.
       There is no lawful presumption that the keeper was the driver
       and I am under no obligation to name the driver. If the operator
       cannot rely on PoFA, it cannot recover the parking charge from
       the keeper merely because the keeper has not named the driver.
       The operator’s own rejection confirms that it is not alleging
       that it knows who the driver was. Instead, it seeks to rely on
       Schedule 4. Once that reliance fails, the appeal must succeed.
       In a recent POPLA case (ET6121/001), POPLA Assessor Paul E
       Walker found that the same operator's pro forma NtK did not meet
       the requirements of POFA as the NtK did not clearly identify the
       creditor - in this instance, the operator, whoever they may be,
       are relying on an absolutely identical NtK to the one assessed
       by Paul E Walker and therefore the same outcome must prevail.
       Best wishes,
       xxxxx xxxxxxx
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