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       #Post#: 129468--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: Tarli
       Date: September 3, 2026, 7:00 am
       ---------------------------------------------------------
       Hi, thanks for your response. I have attached all evidence here
       so please review and let me know your thoughts -
  HTML https://drive.google.com/drive/folders/19NMnhEl4zjCuGdHaXZ3FCap6-aIDzfVZ?usp=sharing
       An interesting point I came across when collecting evidence that
       I've not previously thought about but might be very important,
       is that I don't think I've ever had a physical letter from
       Parking Eye delivered to me. My vehicle was a company car so the
       NTK came through the lease company Novuna via email, it's in the
       evidence attached dated 14-03-22, and then I have the letter
       sent from Novuna to PE dated 22-03-22 providing my details and
       giving authorisation to communicate with me. So to answer your
       question, since the initial NTK which was received from my lease
       company, I've not received any follow up correspondence from PE,
       hence why I am challenging it.
       To address your other points,
       I have attached the WhatsApp response from the Swim company
       owner, and a letter he provided from me confirming my use of the
       hotel facilities. This letter was provided following me
       receiving the DCBL notice as I didn't need it for the original
       appeal that was done through the Swim company.
       To expand on that point and my initial appeal, yes it was done
       through the Swim company directly to the Holiday Inn, the
       landowner and not to PE, as this was the guidance we had from
       the swim company. PE has only been introduced to the hotel
       carpark in Oct 2021 and we were advised there was a 6mths period
       we could challenge any fines, this was verbal from the swim
       company. Hence why when the notice came through I challenged
       through them and not PE directly. The swim company spoke with
       the Holiday Inn directly and I was advised it was cancelled.
       This happened to a number of the parents attending lessons.
       The last contact I had with the swim company was them providing
       the letter confirming I was using the hotel facilities. Another
       detail for this that I touch on previously but not in detail, is
       that the hotel closed to the public in 2023 and now houses
       refugees, so both myself and the swim company have been unable
       to contact them or attend the premises to follow this up or get
       any further information on what action was previously taken.
       #Post#: 129471--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: tincombe
       Date: September 3, 2026, 7:12 am
       ---------------------------------------------------------
       Stop drafting, you're wasting time and effort.
       My vehicle was a company car so the NTK came through the lease
       company Novuna via email,
       My goodness! A completely different light on the whole issue.
       One step at a time:
       To whom is the NTK you posted dated 14 March 2022 addressed?
       #Post#: 129472--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: Tarli
       Date: September 3, 2026, 7:26 am
       ---------------------------------------------------------
       Sorry...
       Its addressed to the lease company.
       I've been racking my brain trying to remember if I received a
       letter or not but genuinely can't remember. I'm normally pretty
       good at keep them for evidence, I have all other letters so
       makes me think I didn't.
       I know I definitely didn't receive any follow up stating the
       fine was still outstanding or due to progress to debt collection
       or I would've followed it up.
       #Post#: 129477--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: tincombe
       Date: September 3, 2026, 8:05 am
       ---------------------------------------------------------
       Back to square 1.
       You are on completely the wrong tack as regards any claim
       against the keeper.
       But you have to acknowledge service, so at least engage with
       this procedure.
       Your defence:
       You were not the driver;
       You were the hirer but cannot be considered to be the 'keeper'
       under Protection of Freedoms Act 2012 Sch.
       #Post#: 129484--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: Tarli
       Date: September 3, 2026, 8:31 am
       ---------------------------------------------------------
       Thanks for your advice, really helpful.
       Would there be any repercussions for my partner who was the
       driver?
       How is this for a defence -
       Alternative Draft Defence – Driver/Keeper Liability Only
       1. Defence
       1.
       relief claimed, or any relief at all.
       2.
       material date.
       3.
       was not sent directly to the Defendant, but to the lease
       company.
       4.
       ParkingEye. The Defendant was therefore identified, at most, as
       the hirer/user of the vehicle.
       5.
       purposes of Schedule 4 of the Protection of Freedoms Act 2012.
       6.
       pursue the Defendant if it has fully complied with the statutory
       requirements required to transfer liability from the driver to a
       keeper or hirer.
       7.
       Schedule 4 of the Protection of Freedoms Act 2012, including the
       requirements applicable to hire vehicles.
       8.
       notices and documents required by Schedule 4 were served
       correctly on the Defendant within the relevant statutory
       timescales.
       9.
       Hirer/Keeper and any subsequent correspondence relied upon were
       properly served on the Defendant after the lease company
       provided the Defendant’s details.
       10.
       correspondence from ParkingEye confirming that the charge
       remained outstanding, that any cancellation had not been
       actioned, that the amount had increased, or that the matter
       would be escalated.
       11.
       Protection of Freedoms Act 2012, the Defendant cannot be held
       liable as keeper or hirer.
       12.
       requests that the claim be dismissed.
       TIA
       #Post#: 129494--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: InterCity125
       Date: September 3, 2026, 9:07 am
       ---------------------------------------------------------
       4 - should only reference 'hirer of the vehicle' - remove the
       word 'user'.
       9 - should only reference a NtH - remove the NtK bit as a
       parking operator can only issue a NtH once the lease company
       have supplied the hirers details - there is no facility under
       POFA to issue a second NtK in the hirer's name.
       6 - ditto above.
       Also, introduce a line space between each defence points -
       Judge's do like a wall of words - keep them happy with spacing!
       #Post#: 129526--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: Tarli
       Date: September 3, 2026, 1:42 pm
       ---------------------------------------------------------
       Thanks so much, I've made the relevant changes.
       To play devils advocate, what happens if PE did issue me the
       correct letter? Like I've said I don't recall receiving it but I
       assume they will need to provide evidence also, so if the
       correct letter is provided by them how would that affect my
       defence? Is it worth including anything relating to my original
       defence around the supposed cancellation? Or is it a stronger
       case to stick with this route?
       Any advice on the next steps would be great too please, re: the
       Acknowledging of service and entering my defence for review? Can
       someone explain what will happen please as I'm unsure of the
       process and next steps, what it actually entails?
       TIA
       #Post#: 129531--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: tincombe
       Date: September 3, 2026, 4:09 pm
       ---------------------------------------------------------
       That's not a defence IMO.
       Your defence is as I posted.
       You were not the driver;
       You were not the keeper.
       The rest goes into your witness statement IMO.
       Do not take weight of evidence literally and try and make the
       judge's life easy.
       #Post#: 129533--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: Tarli
       Date: September 3, 2026, 4:43 pm
       ---------------------------------------------------------
       Ok thanks.
       So I now acknowledge the service and literally just add those 2
       points to my defence?
       What is the process then if you don’t mind me asking, do I wait
       to see if the decision is to get it dismissed? And if not it
       would proceed to mitigation and that’s when I provide a witness
       statement?
       If you could shed some light on the process that would be great
       please.
       TIA
       #Post#: 129568--------------------------------------------------
       Re: Parking Eye / DCB Legal Court Claim – Charge Was Supposedly
       Cancelled
   DIR By: tincombe
       Date: September 4, 2026, 6:29 am
       ---------------------------------------------------------
       just add those 2 points to my defence?
       IMO, they are your defence, or at least the main part!
       Let's be clear: their claim is against you (read the Claim Form)
       as either:
       Driver, or
       Keeper.
       You are NEITHER. That's it, they have fallen at the first
       hurdle.
       You were not the driver. They have no evidence that you were,
       but if pressed on the matter you could state truthfully that the
       vehicle was driven by your wife, but I wouldn't volunteer this.
       You were not the keeper either. The keeper is a legal concept
       and is presumed to be the registered keeper. They have no
       evidence that you were the keeper, because you weren't, you were
       the hirer under a lease agreement. The ONLY way in which they
       could hold you liable as hirer* is if ss13 and 14 of Sch 4 to
       PoFA have been complied with:
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4
       They haven't.
       You have never been served with a Notice to Hirer and you have
       not been provided with the mandatory documents which would
       enable you to examine the creditor's claim.
       IMO, everything else is secondary.
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