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       #Post#: 59903--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: _wooky_
       Date: February 27, 2025, 12:34 pm
       ---------------------------------------------------------
       --- Quote ---
       > How long before the hearing date is the claimant ordered to
       pay the ring fee?
       --- End Quote ---
       The trial date is 30 April 2025.
       Claimant has to pay the hearing fee by 2 April 2025.
       Witness statement has to be in by 4pm on 24 March 2025.
       #Post#: 59904--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: February 27, 2025, 12:35 pm
       ---------------------------------------------------------
       Please show us the order then.
       #Post#: 59937--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: _wooky_
       Date: February 28, 2025, 2:54 am
       ---------------------------------------------------------
       I've not included pages that have standard text.
       Notice of Allocation
  HTML https://imgur.com/DKgY7Iv
       Notice of Trial Date
  HTML https://imgur.com/AyaenvT
       #Post#: 59939--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: February 28, 2025, 3:32 am
       ---------------------------------------------------------
       Good job you showed it. The DDJ has erred in their order because
       they’ve ordered the claimant to submit further evidence (PoC in
       effect) but not ordered you to submit an amended defence.
       I will get back to you on how to deal with this irregularity.
       Did you counter claim?
       #Post#: 59950--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: _wooky_
       Date: February 28, 2025, 5:05 am
       ---------------------------------------------------------
       --- Quote ---
       > Did you counter claim?
       --- End Quote ---
       No. I've only been following instructions here and I don't
       recall that being mentioned.
       Perhaps I missed it 😬
       #Post#: 59955--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: February 28, 2025, 5:17 am
       ---------------------------------------------------------
       No, it's not a problem. It's just a bit unusual that the judge
       would order the claimant to send evidence that was not included
       in the PoC and not give the defendant an opportunity to amend
       their defence because of this new evidence that should have been
       in the PoC in the first place.
       I doubt that the claimant will provide the required evidence
       because they are going to discontinue anyway. I'm just checking
       with the courts to see how this irregularity should be best
       handled.
       #Post#: 59977--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: February 28, 2025, 8:31 am
       ---------------------------------------------------------
       Send the following in an email to the court at
       civilenquiries.coventry.countycourt@justice.gov.uk and CC in
       info@dcblegal.co.uk and yourself. This is urgent so mark the
       subject as "URGENT: Procedural Unfairness – Claim No.: [claim
       number]".
       --- Quote ---
       > [Your Name]
       > [Your Address]
       > [Your Email]
       > [Your Phone Number]
       >
       > [Date]
       >
       > The Court Manager
       > Coventry Combined Court Centre
       > 140 Much Park Street
       > Coventry
       > CV1 2SN
       >
       > By email to:
       civilenquiries.coventry.countycourt@justice.gov.uk
       > CC: info@dcblegal.co.uk
       >
       > Claim Number: [Claim Number]
       > Claimant: UK Parking Control Ltd
       > Defendant: [Defendant’s Name]
       >
       > URGENT: Procedural Unfairness – Request for Reconsideration of
       the Order Dated 21 February 2025
       >
       > Dear Sirs,
       >
       > I am the Defendant in this matter, and I write regarding the
       Order made on 21 February 2025 by DDJ Vickers, which lists the
       trial for 24 March 2025 and directs both parties to file and
       serve evidence by the same deadline.
       >
       > I respectfully submit that this Order is procedurally unfair,
       wrong and prejudicial to my ability to defend myself at trial.
       If the situation remains unchanged, I will be severely
       disadvantaged and unable to defend myself despite having filed a
       proper Defence.
       >
       > 1. Why the Order is wrong and Procedurally Unfair
       >
       > In my Defence, I clearly stated that I was unable to respond
       properly to the Claimant’s claim for no fewer than eight
       separate reasons, due to deficiencies in the Particulars of
       Claim (PoC). To rectify this, I attached to my Defence a draft
       order requesting the Court to require the Claimant to file
       properly particularised PoC, after which I would be permitted to
       file an amended Defence in response.
       >
       > However, instead of granting this order, the Court’s Order of
       21 February 2025 has directed the Claimant to introduce these
       missing details for the first time within its witness statement.
       This is procedurally irregular because:
       >
       > [indent]• I am not given an opportunity to amend my Defence
       once the missing details are provided.
       >
       > • I am required to file my witness evidence at the same time
       as the Claimant, meaning I have no opportunity to respond to
       their new evidence.
       >
       > • As things stand, I will be denied a fair trial because I
       have not been able to properly defend myself due to the
       Claimant’s failure to plead its case in compliance with CPR
       16.4.[/indent]
       >
       > This is not only unfair but contrary to the Overriding
       Objective (CPR 1.1), which requires cases to be dealt with
       fairly, justly, and with both parties on an equal footing.
       >
       > 2. What I Request the Court to Do
       >
       > I respectfully request the Court to set aside the Order of 21
       February 2025 in its entirety, as it is procedurally unjust.
       >
       > I further request the Court to instead make the order I
       originally attached to my Defence, which would require the
       Claimant to:
       >
       > [indent]1. File and serve properly particularised PoC that
       comply with CPR 16.4.
       >
       > 2. Permit me, as the Defendant, to file and serve an amended
       Defence in response to the properly pleaded claim.
       > This ensures that I have a fair opportunity to defend myself
       properly and on equal footing with the Claimant.[/indent]
       >
       > 3. Why I Am Not Filing a Formal Application
       >
       > Under normal circumstances, I would make a formal application
       using Form N244. However, this would require a £303 application
       fee, which is disproportionate and unfair in a Small Claims
       Track case, where costs are generally unrecoverable.
       >
       > As the claim is for a sum far lower than £303, requiring me to
       pay this fee would be wholly unreasonable and contrary to the
       Overriding Objective (CPR 1.1). The Court is empowered to vary
       its own order under CPR 3.3(1) and should consider doing so in
       the interests of justice, without requiring an unnecessary
       application fee.
       >
       > 4. Urgency of the Matter
       >
       > Given that the hearing is listed for 24 March 2025, I
       respectfully request the Court to respond within seven days to
       allow sufficient time for procedural fairness to be restored.
       >
       > In accordance with CPR 39.8, I have copied this letter to the
       Claimant’s solicitors.
       >
       > I appreciate the Court’s consideration of this urgent matter
       and look forward to your response.
       >
       > Yours faithfully,
       >
       > [Your Name]
       > Defendant (Litigant in Person)
       --- End Quote ---
       #Post#: 60071--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: _wooky_
       Date: March 1, 2025, 2:26 am
       ---------------------------------------------------------
       Amazing. Thank you b789 🙏💚
       Only note is that the hearing is listed for 30 April. The WS and
       evidence has to be in by 24 March.
       The Notice of Allocation says, "The parties must send copies of
       their witness statements and documents to the Court AND EACH
       OTHER no later than 4pm on 24 March 2025." (emphasis mine)
       Does this mean we have enough time to respond, given the fact
       they have to pay the £27 court trial fee by 2 April and I assume
       that's the point by which they bail out?
       #Post#: 60092--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: b789
       Date: March 1, 2025, 8:32 am
       ---------------------------------------------------------
       This DDJ has basically caused problems because it is not usually
       the case that witness statements have to be submitted so far in
       advance of the hearing. Normally, they are expected to be sent
       no later than 14 days before the hearing date, which means that
       the hearing fee is due at least a fortnight before the
       statements. As they normally discontinue just before the hearing
       fee is due, there is no need to waste time on a WS.
       Hopefully the letter will get the order set aside and a new
       order will be issued. However, even if nothing else happens, you
       have over three weeks to submit a WS. Plenty of time to prepare.
       #Post#: 60462--------------------------------------------------
       Re: UKPC PCN - No Payment - Lower Precinct Shopping Centre,
       Coventry
   DIR By: _wooky_
       Date: March 4, 2025, 2:12 am
       ---------------------------------------------------------
       I've slightly amended (underlined below) your excellent email
       b789, in light of the precise dates...
       --- Quote ---
       > I am the Defendant in this matter, and I write regarding the
       Order made on 21 February 2025 by DDJ Vickers, which lists the
       trial for 30 April 2025 and directs both parties to file and
       serve evidence by 24 March 2025.
       --- End Quote ---
       
       and
       --- Quote ---
       >
       > Given that witness statements are required to be submitted by
       24 March 2025, I respectfully request the Court to respond
       within seven days to allow sufficient time for procedural
       fairness to be restored.
       --- End Quote ---
       That ok?
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