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       #Post#: 14303--------------------------------------------------
       Received two PCNs from April 2023 with legal and court fees on
       top but this is the first time I am hearing about this
   DIR By: bz.08
       Date: January 25, 2024, 5:54 am
       ---------------------------------------------------------
       So earlier this week I received a letter from the Civil National
       Business Centre County Court regarding two unpaid PCNs dating
       back to April 2023. The letter gives me the option to either
       admit the amount claimed against me, to prepare my
       defence/contest the court's jurisdiction or to dispute the whole
       claim/make a counter claim. The letter also threatens me with
       the potential of further legal costs and interest accruing if I
       do not pay in the next few days. I believe the original PCNs
       were issued by a private company (according to the court letter,
       the claimaint is Hounslow Enforcement Ltd) and the alleged
       contraventions were in West London.
       The problem is that this is LITERALLY the first time I am
       hearing about these alleged contraventions. I have not received
       any prior communication on this - neither in the form of tickets
       on my windshield (I guess these are ANPR tickets) on the days of
       the alleged contraventions nor in the form of follow up letters
       to my address. Based on the dates and locations detailed, it is
       possible that the driver incurred these PCNs but I have not seen
       any definitive proof (e.g. pictures of my car at said location)
       so far.
       I have not moved address in the last 10 years and I have never
       had an issue like this before. I have received other PCNs
       through the post in the past and always paid promptly to avoid
       escalations. I would never just willingly risk bailiffs/CCJs by
       just ignoring PCNs.
       I presume that the reason for this sudden revelation is that the
       initial PCNs and subsequent escalations were either not sent to
       me at all (IT error?) or somehow sent to the wrong address. The
       total amount requested is around £450 of which £350 is the total
       for the PCNs and the rest are legal fees. The actual PCN total
       would have been around £150 if I had paid within 28 days of
       issuance.
       I read online that if I somehow prove I did not receive follow
       up communication then I can get them to revert to the original
       charge but how on earth is it possible to prove this (especially
       when I have not moved house)? If proven (again I have not seen
       evidence of my car breaching the rules), I am ready to pay the
       original PCN charges but I do not think it's fair at all to pay
       all the extra costs given that I have been completely ignorant
       to this situation.
       What is the best thing to do in this case?
       #Post#: 14306--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: Nosy Parker
       Date: January 25, 2024, 8:39 am
       ---------------------------------------------------------
       The best thing is to fight and win (ie pay nothing) as you could
       have done with all other private PCNs that you might have paid
       in the past.
       To start with upload a copy of the front page of the claim form
       (it’s not a “letter”) on an external hosting site like
       www.imgur.com and post the link here. Make sure to redact your
       name, address, vehicle number, all references and the MCOL
       password but leave all dates showing.
       In the meantime it’s not a bad thing that you have no idea what
       this is all about as it will form an important part of the
       defence.
       The most important thing is not to lose by default so even
       before you post the claim form, tell us the issue date of the
       claim
       #Post#: 14315--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: b789
       Date: January 25, 2024, 1:16 pm
       ---------------------------------------------------------
       As stated above, you need to show us a copy of the claim,
       especially the particulars of the claim (PoC). Whilst you know
       who the claimant is, who does the claim form say to send any
       correspondence to? Is it the same as the clamant or are they
       using one of a few dedicated roboclaim solicitors? For example,
       DCB Legal, Gladstones, BW Legal, Elms or A N Other?
       Contesting this at a hearing, even if you were to lose, you
       would end up paying less than the original claim. These scammers
       invariably include costs/damages that are not allowed in a small
       claim. Unfortunately, most victims who get to this stage often
       capitulate because of irrational fears over their lack of
       knowledge of the legal system and pay up the inflated demands.
       More often than not, a robustly defended claim will be
       discontinued when the roboclaim solicitors realise that they are
       not dealing with low hanging fruit on the gullible tree. It's
       just a pity that more victims of these scammers don't know or
       understand this.
       You have already revealed this when you stated in your opening
       post:
       --- Quote ---
       > I would never just willingly risk bailiffs/CCJs by just
       ignoring PCNs.
       --- End Quote ---
       There is no way you can get a CCJ or have a bailiff knock at
       your door without going through a very thorough process. Despite
       the wording used in communications with these scammers, you
       would need to have a hearing in front of a judge, lose the claim
       and then ignore paying it within 30 days to actually get a CCJ
       on your record. Any CCJ paid within 30 days of judgment is
       automatically expunged from your record. The same gos for
       bailiffs. A CCJ for less than £600, unpaid for over 30 days will
       not qualify for a bailiff.
       You are the victim of a speculative invoice from an unregulated
       private parking company (ex-clampers) for an alleged breach of
       contract. This is not a criminal matter. It is a civil matter.
       It's not Rumpole of the Bailey and horsehair wigs and flowing
       black gowns. Fight it.
       First, show us the Claim form, suitable redacted of claim
       number, your name and address, your VRM. PCN number and your
       MCOL password. Everything else should be visible.
       #Post#: 14318--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: Nosy Parker
       Date: January 25, 2024, 2:01 pm
       ---------------------------------------------------------
       Echoing b789's sound advice, you don't come close to getting
       bailiffs or a CCJ if you fight a private parking ticket the
       right way.
       #Post#: 14353--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: bz.08
       Date: January 26, 2024, 7:00 am
       ---------------------------------------------------------
       --- Quote from: Nosy Parker link ---
       >
       > The best thing is to fight and win (ie pay nothing) as you
       could have done with all other private PCNs that you might have
       paid in the past.
       >
       > To start with upload a copy of the front page of the claim
       form (it’s not a “letter”) on an external hosting site like
       www.imgur.com and post the link here. Make sure to redact your
       name, address, vehicle number, all references and the MCOL
       password but leave all dates showing.
       >
       > In the meantime it’s not a bad thing that you have no idea
       what this is all about as it will form an important part of the
       defence.
       >
       > The most important thing is not to lose by default so even
       before you post the claim form, tell us the issue date of the
       claim
       >
       --- End Quote ---
       Please see the below link:
  HTML https://imgur.com/a/TDnLUir
       The issue date is 19 January 2024 but I did not get this through
       the post until earlier this week.
       #Post#: 14356--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: b789
       Date: January 26, 2024, 8:19 am
       ---------------------------------------------------------
       You have until Wednesday 7th February to acknowledge the claim.
       Do this on the MCOL website. There is no advantage to delaying
       it. You then have until 4pm on Wednesday 21st February to file
       your defence which is sent as a PDF attachment to an email to
       ccbcaq@justice.gov. You must make sure you receive an automatic
       acknowledgement email which should be almost immediately after
       you send it. That is your proof of of having sent it. Your MCOL
       will eventually update with confirmation but it can take a while
       for that to show.
       The Particulars of Claim fail to comply with Civil Procedure
       Rule 16.4(1)(e) and Practice Direction Part 16.7.5. This must be
       highlighted in the defence and it should be thrown out at
       allocation stage. Use this defence:
       ---------------------------------------------------------
       All you need to do is add your own, very brief, reason why you
       were at the location.
       ---------------------------------------------------------
       IN THE COUNTY COURT
       [right]Claim No.:  xxxxxx[/right]
       Between
       [center]Full name of parking firm Ltd. (not the solicitor!)
       (Claimant)
       - and -
       Defendant’s name from N1 claim (can’t be changed to driver
       now)


       (Defendant)
       _______________________________
       DEFENCE[/center]
       1. The Defendant denies that the Claimant is entitled to relief
       in the sum claimed, or at all.  It is denied that any conduct by
       the driver was in breach of any term.  Further, it is denied
       that this Claimant (understood to have a bare licence as agents)
       has standing to sue or form contracts in their own name.
       Liability is denied, whether or not the Claimant is claiming
       'keeper liability', which is unclear from the boilerplate text
       in the Particulars of Claim ('the PoC').
       Preliminary matter
       2. The Defendant draws to the attention of the allocating Judge
       that there is now a persuasive Appeal judgment to support
       striking out the claim (in these exact circumstances of
       typically poorly pleaded private parking claims, and the extant
       PoC seen here are far worse than the one seen on Appeal).  The
       Defendant believes that dismissing this meritless claim is the
       correct course, with the Overriding Objective in mind.  Bulk
       litigators (legal firms) should know better than to make little
       or no attempt to comply with the Practice Direction.  By
       continuing to plead cases with generic auto-fill unspecific
       wording, private parking firms should not be surprised when
       courts strike out their claims based in the following persuasive
       authority.
       A recent persuasive appeal judgment in Civil Enforcement Limited
       v Chan (Ref. E7GM9W44) would indicate the PoC fails to comply
       with Civil Procedure Rule 16.4 and Practice Direction Part 16.
       On the 15th August 2023, in the cited case, HHJ Murch held that
       'the particulars of the claim as filed and served did not set
       out the conduct which amounted to the breach in reliance upon
       which the claimant would be able to bring a claim for breach of
       contract'. The same is true in this case and in view of the CEL
       v Chan judgment, the Court should strike out the claim, using
       its powers pursuant to CPR 3.4
       CEL v Chan transcript jpg’s inserted here
  HTML https://i.imgur.com/vyAUGtj.jpeg
  HTML https://i.imgur.com/BM9BC98.jpeg
  HTML https://i.imgur.com/RlrBhLe.jpeg
  HTML https://i.imgur.com/Ca8NseV.jpeg
       The facts as known to the Defendant:
       3. The facts in this defence come from the Defendant's own
       knowledge and honest belief.  Conversely, the Claimant sets out
       a cut-and-paste incoherent and sparse statement of case.  The
       PoC is devoid of any detail and even lacks specific breach
       allegation(s), making it very difficult to respond. However, it
       is admitted that the Defendant was the registered keeper of the
       vehicle.
       ^EDIT THIS PARAGRAPH RE WHO WAS DRIVING^.
       If you were driving, add 'and driver' after the word 'keeper'.
       OR if the Defendant doesn't know who was driving, say that.
       OR deny being the driver if you weren't: ONLY IF TRUE!
       [color=black]4. [EXPLAIN IN YOUR OWN WORDS...NB: defences are
       written in the THIRD person as 'the Defendant', not 'I did this'
       nor 'my/me'].
       Explain briefly what business the driver had there & what went
       wrong?  If you don't know, didn't get any letters or it was
       years ago & you cannot recall, say that instead.  Signs unlit in
       darkness?  Did a permit slip off the dash? a VRM keying error?
       If the PCN was issued at a residential site where the driver
       lives or was a permitted visitor, state those parking rights.
       It is recommended you continue with this (yes, all of
       it)[/color]
       5. The Claimant will concede that no financial loss has arisen
       and that in order to impose an inflated parking charge, as well
       as proving a term was breached, there must be:
       (i) a strong 'legitimate interest' extending beyond mere
       compensation for loss, and
       (ii) 'adequate notice' of the 'penalty clause' charge which, in
       the case of a car park, requires prominent signs and lines.
       6. The Defendant denies (i) or (ii) have been met. The charge
       imposed, in all the circumstances is a penalty, not saved by
       ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case'), which
       is fully distinguished.

Exaggerated Claim and
       'market failure' currently being addressed by UK Government
       7. The alleged 'core debt' from any parking charge cannot exceed
       £100 (the industry cap).  It is denied that any 'Debt Fees' or
       damages were actually paid or incurred by this Claimant, who is
       put to strict proof of:
       (i) the alleged breach, which is not pleaded in the PoC and
       requires further and better particulars, and
       (ii) a breakdown of how they arrived at the enhanced sum in the
       POC, including how interest was calculated, which looks to be
       improperly applied on the entire inflated sum, as if that was
       all overdue on the day of the alleged event.
       8. The Defendant avers that this claim is unfair and inflated
       and it is denied that any sum is due, whether in debt or
       damages. This Claimant routinely pursues an unconscionable fixed
       sum added per PCN, despite knowing that the will of Parliament
       is to ban it.
       9. This case is a classic example where adding exaggerated fees
       funds the 'numbers game' of bulk litigation of weak and/or
       archive parking cases.  MoJ statistics of bulk litigators reveal
       that there are several hundred thousand parking claims per
       annum, with some 90% causing default CCJs totalling hundreds of
       millions of pounds.  No checks and balances are likely to have
       been made to ensure facts, merit or a proper cause of action
       (given away by the woefully inadequate PoC).
       10. The Department for Levelling Up, Housing and Communities
       ('the DLUHC') first published a statutory Parking Code of
       Practice in February 2022, here:
  HTML https://www.gov.uk/government/publications/private-parking-code-of-practice&#8232;&#8232;<br
       />The Ministerial Foreword is damning: "Private firms issue
       roughly 22,000 parking tickets every day, often adopting a
       labyrinthine system of misleading and confusing signage, opaque
       appeals services, aggressive debt collection and unreasonable
       fees designed to extort money from motorists."
       11. Despite legal challenges delaying the Code's implementation
       (marking it as temporarily 'withdrawn') a draft Impact
       Assessment (IA) to finalise it was published on 30th July 2023.
       The Government's analysis has exposed what they state are
       industry-gleaned facts about supposed 'Debt Fees'. The analysis
       is found here:
  HTML https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1171438/Draft_IA_-_Private_Parking_Code_of_Practice_.pdf
       12. Paragraphs 4.31 and 5.19 suggest that the parking industry
       has informed the DLUHC that the true minor cost of what the
       parking industry calls debt recovery or 'enforcement' ( =
       pre-action) stage totals a mere £8.42 per recovery case (not per
       PCN).
       13. With that in mind, it is clear that the extant claim has
       been enhanced by an extreme sum, believed to be routinely
       retained by the litigating legal team, not the Claimant.  In
       this Claim it is additional to the intended 'legal
       representatives fees' cap set within small claims track rules.
       This conduct has been examined and found - including in a
       detailed judgment by Her Honour Judge Jackson, now a specialist
       Civil High Court Judge on the Leeds/Bradford circuit - to
       constitute 'double recovery'. The Defendant takes that position.
       14. The draft IA shows that the intimidating letter-chains
       actually cost 'eight times less' than the seemingly
       'price-fixed' +£70 per PCN. This causes consumer harm in the
       form of almost half a million wrongly-enhanced CCJs each year,
       that District Judges are powerless to prevent.  This false fee
       was enabled by the self-serving Codes of Practice of the rival
       parking Trade Bodies who suddenly aligned in 2021 re allowing
       +£70, each led by a Board of the very parking operators and debt
       firms who stood to gain from it. &#8232;
       15. It is denied that the purported damages or Debt Fee sought
       was incurred or is recoverable. Attention is drawn to paras 98,
       100, 193, 198 of ParkingEye Ltd v Beavis [2015] UKSC67 ('the
       Beavis case').  Also ParkingEye Ltd v Somerfield Stores Ltd ChD
       [2011] EWHC 4023(QB) where the parking charge was £75,
       discounted to £37.50 for prompt payment.  Whilst £75 was
       reasonable, HHJ Hegarty (decision later ratified by the CoA)
       held in paras 419-428 that unspecified 'admin costs' inflating a
       parking charge to £135 was not a true reflection of the cost of
       a template letter and 'would appear to be penal'.&#8232;
       16. This Claimant has not incurred costs. A parking charge model
       already includes what the Supreme Court called an 'automated
       letter-chain' and it is a model that generates a healthy profit.
       In Beavis, there were 4 pre-action letters/reminders and the £85
       'PCN' was held to more than cover the minor costs of the
       operation.  The DLUHC's IA confirms that the parking charge more
       than covers the minor costs of the letters (NB: the debt
       collectors do not charge anything in failed collection cases).
       17. Whilst the new Code is not retrospective, all non-monetary
       clauses went unchallenged by the parking industry. The 2022
       DLUHC Code will replace the self-serving BPA & IPC Codes, which
       are not regulation and carry limited weight.  In a clear steer
       for the Courts and for the avoidance of doubt: the DLUHC say
       they are addressing 'market failure'.
       18. In addition, pursuant to Schedule 4 paragraph 4(5) of the
       Protection of Freedoms Act 2012 ('the POFA') the sum claimed
       exceeds the maximum potentially recoverable from a registered
       keeper.  Further, the Claimant is put to strict proof of POFA
       compliance.
       19. The Defendant avers that the DLUHC's analysis now overrides
       plainly wrong assumptions made by Circuit Judges steered by
       Counsel in astonishingly weak appeal cases that the parking
       industry engineered their way: Britannia v Semark-Jullien, One
       Parking Solution v Wilshaw, Vehicle Control Services v Ward and
       Vehicle Control Services v Percy. Far from being persuasive,
       regrettably these one-sided appeals cherry-picked
       litigant-in-person consumers without the wherewithal to appeal.
       Incorrect presumptions were made in every case; and there were
       major evidence discrepancies (e.g. in Wilshaw, where the Judge
       was also oblivious to the DVLA KADOE requirement for landowner
       authority). One Judge inexplicably sought out for himself and
       quoted from the wrong Code of Practice (Percy). In Ward, a few
       seconds' emergency stop out of the control of the driver was
       wrongly aligned with the agreed contract in Beavis.
       20. The Defendant avers that there was no agreement to pay a
       parking charge or added 'damages' which were not even incurred,
       let alone quantified in bold, prominent text. This Claimant
       failed to erect well-placed, large and readable signs on a par
       with the yellow & black warnings seen in Beavis, and unlike the
       signage requirements set out in the DLUHC Code which reflects
       the already statutory requirement for 'prominence' (Consumer
       Rights Act 2015 - the 'CRA').
       &#8232;&#8232;CRA Breaches
       21. Section 71 CRA creates a statutory duty upon Courts to
       consider the test of fairness whether a party raises it or not.
       Claiming costs on an indemnity basis is unfair, per the Unfair
       Contract Terms Guidance (CMA37, para
       5.14.3):&#8232;&#8232;
  HTML https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/450440/Unfair_Terms_Main_Guidance.pdf
       22. The CRA introduced new requirements for 'prominence' of both
       terms and 'consumer notices'.  In a parking context, this
       includes a test of fairness and clarity of 'signs & lines' and
       all communications intended to be read by consumers. Signage
       must be prominent (lit in hours of darkness/dusk) and all terms
       must be unambiguous and contractual obligations clear.
       23. The Defendant avers that the CRA has been breached due to
       unfair/unclear terms and notices, pursuant to s62 and paying
       regard to examples 6, 10, 14 & 18 of Schedule 2 and the duties
       of fair/open dealing and good faith (NB: this does not
       necessarily mean there has to be a finding of bad faith).
       &#8232;&#8232;Parking Eye v Beavis is distinguished
       24. Unlike in Beavis, the penalty rule remains engaged in this
       claim due to the unconscionable added 'Fee'.  The CRA covers
       disproportionate sums, which are not exempt from being assessed
       for fairness because a late-added Fee is not the core parking
       price term and neither was it prominently proclaimed on the
       signs.
       25. The Supreme Court held that deterrence is likely to be penal
       if there is a lack of a 'legitimate interest' in performance
       extending beyond the prospect of compensation flowing directly
       from the alleged breach.  The intention cannot be to punish a
       driver, nor to present them with hidden terms,
       unexpected/cumbersome obligations nor 'concealed pitfalls or
       traps'.  In the present case, the Claimant has fallen foul of
       those tests. Their small signs have vague/hidden terms and
       minuscule text, incapable of binding a driver.  Court of Appeal
       authorities about a lack of ‘adequate notice’ of a parking
       charge include:
       (i) Spurling v Bradshaw [1956] 1 WLR 461 (Lord Denning's ‘red
       hand rule’) and
       (ii) Thornton v Shoe Lane Parking Ltd [1970] EWCA
       Civ2,&#8232;&#8232;both leading authorities that a clause cannot
       be incorporated after a contract has been concluded; and
       (iii) Vine v London Borough of Waltham Forest: CA 5 Apr 2000,
       where Ms Vine won because it was held that she had not seen the
       terms by which she would later be bound, due to "the absence of
       any notice on the wall opposite the parking space".
       26. Fairness and clarity of terms and notices are paramount in
       the DLUHC Code and these clauses stand unchallenged and are
       supported by the BPA & IPC.  In November 2020's Parking Review,
       solicitor Will Hurley, CEO of the IPC, observed: "Any regulation
       or instruction either has clarity or it doesn’t. If it’s clear
       to one person but not another, there is no clarity. The same is
       true for fairness. Something that is fair, by definition, has to
       be all-inclusive of all parties involved – it’s either fair or
       it isn’t. The introduction of a new ‘Code of Practice for
       Parking’ provides a wonderful opportunity to provide clarity and
       fairness for motorists and landowners alike."
       Lack of standing or landowner authority, and lack of ADR
       27. DVLA data is only supplied to pursue parking charges if
       there is an agreement flowing from the landholder (ref: KADOE
       rules).  It is not accepted that this Claimant (an agent of a
       principal) has authority to form contracts at this site in their
       name.  The Claimant is put to strict proof of their standing to
       litigate in their own name.
       28. The Claimant failed to offer a genuinely independent
       Alternative Dispute Resolution (ADR). The Appeals Annex in the
       DLUHC Code shows that genuine disputes such as this should see
       PCNs cancelled, had a fair ADR existed.  The rival Trade Bodies'
       time-limited and opaque 'appeals' services fail to properly
       consider facts or rules of law and reject most disputes: e.g.
       the IAS upheld appeals in a woeful 4% of decided cases (2020
       Annual Report).  The Claimant's consumer blame culture and
       reliance upon their own 'appeals service' (described by MPs as a
       kangaroo court and about to be replaced by the DLUHC, who have
       in the IA criticised the lack of transparency or independence)
       should lead Judges to realise that a truly fair appeal was never
       on offer.&#8232;&#8232;
       Conclusion
       29. There is now evidence to support the view - long held by
       many District Judges - that these are knowingly exaggerated
       claims that are causing consumer harm.  The July 2023 DLUHC IA
       analysis shows that the usual letter-chain costs eight times
       less than the sum claimed for it.  The claim is entirely without
       merit and the POC embarrassing.  The Defendant believes that it
       is in the public interest that claims like this should be struck
       out.
       30. In the matter of costs, the Defendant seeks:
       (a) standard witness costs for attendance at Court, pursuant to
       CPR 27.14, and
       (b) a finding of unreasonable conduct by this Claimant, and
       further costs pursuant to CPR 46.5.
       31. Attention is drawn specifically to the (often-seen) distinct
       possibility of an unreasonably late Notice of Discontinuance.
       Whilst CPR r.38.6 states that the Claimant is liable for the
       Defendant's costs after discontinuance (r.38.6(1)) this does not
       normally apply to claims allocated to the small claims track
       (r.38.6(3)). However, the White Book states (annotation 38.6.1):
       "Note that the normal rule as to costs does not apply if a
       claimant in a case allocated to the small claims track serves a
       notice of discontinuance although it might be contended that
       costs should be awarded if a party has behaved unreasonably
       (r.27.14(2)(dg))."
       &#8232;
       Statement of Truth
       I believe that the facts stated in this defence are true.  I
       understand that proceedings for contempt of court may be brought
       against anyone who makes, or causes to be made, a false
       statement in a document verified by a statement of truth without
       an honest belief in its truth.
       Defendant’s signature:
       Date:
       #Post#: 14357--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I 
   DIR By: b789
       Date: January 26, 2024, 8:22 am
       ---------------------------------------------------------
       When you have edited the defence to your own circumstances, just
       show us paragraphs 3 & 4 that you have changed for review.
       Your defence should include all the paragraphs shown. If you do
       add more to your paragraph 4, make sure that all subsequent
       paragraphs are renumbered sequentially. All you need are basic
       facts such as the reason you were at the location, eg. "I was a
       patron of the business/restaurant etc." or "I have no
       recollection of the reasons I would have been at the location
       and this claim is the first communication I have ever received
       on this matter".
       Do not try and create "War & Peace". You are responding to
       deficient PoC. If it should ever get as far as a hearing, you
       will expand on your defence in your Witness Statement.
       #Post#: 14739--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I 
   DIR By: bz.08
       Date: February 1, 2024, 5:36 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > When you have edited the defence to your own circumstances,
       just show us paragraphs 3 & 4 that you have changed for review.
       >
       > Your defence should include all the paragraphs shown. If you
       do add more to your paragraph 4, make sure that all subsequent
       paragraphs are renumbered sequentially. All you need are basic
       facts such as the reason you were at the location, eg. "I was a
       patron of the business/restaurant etc." or "I have no
       recollection of the reasons I would have been at the location
       and this claim is the first communication I have ever received
       on this matter".
       >
       > Do not try and create "War & Peace". You are responding to
       deficient PoC. If it should ever get as far as a hearing, you
       will expand on your defence in your Witness Statement.
       >
       --- End Quote ---
       Thanks for the detailed response. I am unable to get into the
       MCOL website as I have lost my Government Gateway details -
       however, I have been informed by the County Court Business
       Center that I can respond via email too. They have given me one
       of response three options as outlined in the image:
  HTML https://imgur.com/a/udciPzz
       I assume the "Acknowledgment of service" is the one I should
       fill out and return? I am just confirming because in the image
       they say you should only fill this form out if:
       If you need 28 days (rather than 14) from the date of service to
       prepare your defence, or
       wish to contest the court’s jurisdiction
       #Post#: 14756--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: b789
       Date: February 1, 2024, 8:07 am
       ---------------------------------------------------------
       You need the 4th item... acknowledgement of service (AoS). That
       must be received by the CNBC no later than 7th February. That
       will then give you until 4pm on Wednesday 21st February to get
       the defence submitted.
       All you are doing at this stage is the AoS. Do not use the
       defence form.
       As they mentioned to you, you can submit the AoS form as a pdf
       attachment by email to ccbcaq@justice.gov. I would advise CC'ing
       yourself as that gives you an added bit of proof you sent it
       should someone claim you didn't send it. However, if it has been
       received by the CNBC, you should get an immediate
       auto-acknowledgement email back from them. If you don't, keep
       trying and if necessary, try again using a different email
       agent.
       #Post#: 15074--------------------------------------------------
       Re: Received two PCNs from April 2023 with legal and court fees
       on top but this is the first time I am hearing about thi
   DIR By: bz.08
       Date: February 5, 2024, 9:46 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > You need the 4th item... acknowledgement of service (AoS).
       That must be received by the CNBC no later than 7th February.
       That will then give you until 4pm on Wednesday 21st February to
       get the defence submitted.
       >
       > All you are doing at this stage is the AoS. Do not use the
       defence form.
       >
       > As they mentioned to you, you can submit the AoS form as a pdf
       attachment by email to ccbcaq@justice.gov. I would advise CC'ing
       yourself as that gives you an added bit of proof you sent it
       should someone claim you didn't send it. However, if it has been
       received by the CNBC, you should get an immediate
       auto-acknowledgement email back from them. If you don't, keep
       trying and if necessary, try again using a different email
       agent.
       >
       --- End Quote ---
       Thank you. Sorry one last question: I am just on the AoS form
       (as the deadline is by tomorrow) and it asks me to choose one of
       the following:
       --- Quote ---
       > 1) I Intend to defend all of this claim
       > 2) I Intend to defend part of this claim
       > 3) I intend to contest jurisdiction
       --- End Quote ---
       I am not sure which of these I am supposed to tick?
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