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       #Post#: 125916--------------------------------------------------
       Re: HELP! Money claim from UK Parking Control LTD
   DIR By: dfwtolhr
       Date: July 27, 2026, 11:40 am
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       The Defendant is the Hirer/Lessee of the vehicle xxx. The
       Defendant denies that the Claimant is entitled to the relief
       claimed, or any relief at all.
       The Claimant’s particulars of claim state that a parking charge
       was incurred by the driver of the vehicle on xxx. The Defendant
       was not the driver of the vehicle at the material time and is
       under no legal obligation to identify the driver to a private
       parking operator.
       The Claimant has brought these proceedings against the Defendant
       under the assumption that the Hirer must be held liable for the
       actions of the driver. In English Law, there is no presumption
       that the hirer or keeper of a vehicle was the driver on any
       given occasion (Combined Parking Solutions v Ms X).
       To transfer liability for a parking charge from the driver to a
       Hirer, the Claimant must strictly comply with the mandatory
       statutory requirements set out in Paragraph 13 and Paragraph 14
       of Schedule 4 of the Protection of Freedoms Act (PoFA) 2012.
       The Claimant failed to comply with PoFA 2012 Schedule 4.
       Specifically, the Claimant failed to provide the mandatory
       documentation required under Paragraph 14(2)(a), which dictates
       that the Notice to Hirer must be accompanied by a copy of the
       hire agreement and a copy of the signed statement of liability.
       The Claimant failed to provide these documents, rendering the
       Notice to Hirer defective and invalid.
       Due to the Claimant’s strict failure to adhere to the rigid
       statutory requirements of PoFA 2012 Schedule 4 regarding hired
       vehicles, the Claimant has forfeited the right to claim hirer
       liability.
       Consequently, the Claimant has no lawful cause of action against
       the Defendant. The Defendant cannot be held liable for a
       contract to which they were not a party.
       The Court is respectfully invited to strike out this claim as
       having no reasonable prospect of success.
       #Post#: 126017--------------------------------------------------
       Re: HELP! Money claim from UK Parking Control LTD
   DIR By: dfwtolhr
       Date: July 28, 2026, 7:38 am
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       Is the defence above ok?
       #Post#: 126020--------------------------------------------------
       Re: HELP! Money claim from UK Parking Control LTD
   DIR By: jfollows
       Date: July 28, 2026, 7:45 am
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       --- Quote from: dfwtolhr link ---
       >
       > Is the defence above ok?
       >
       --- End Quote ---
       PoFA also requires the notice to keeper to be sent along with
       the notice to hirer. Even if you happened to have it anyway.
       Otherwise your defence is sound, and remember that DCB Legal
       will almost certainly discontinue eventually, before having to
       pay the court fee, but in the meantime you will need to complete
       a N180 Directions Questionnaire when DCB Legal sends you theirs
       and the court tells you, you will need to attend a meaningless
       mandatory mediation session, and you will eventually get the
       case allocated to your local court with a deadline for DCB Legal
       to pay the court fee.
       Search the forum for "N180" and mediation to know more, and
       please post the letter of allocation when you eventually receive
       it. We don't need to see DCB Legal's DQ because they are all the
       same and your preferences override theirs anyway.
       #Post#: 126878--------------------------------------------------
       Re: HELP! Money claim from UK Parking Control LTD
   DIR By: dfwtolhr
       Date: August 5, 2026, 4:23 am
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       Received response from the DPO of UKPC:
       Please can you confirm your identity as per the following for
       verification purposes (if you are the keeper of the vehicle, if
       you are not, we would need the information of the keeper of the
       vehicle as well as confirmation that you are authorised to
       receive the subject access request documents):
       i)            your proof of address
       ii)           your photo identification
       Am I ok to send the above?
       As for the keeper (leasing company) info and authorisation would
       I need to send the transfer of liability letter?
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