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       #Post#: 26928--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: RhysGrif
       Date: June 20, 2024, 4:33 pm
       ---------------------------------------------------------
       --- Quote from: NighSoul link ---
       >
       > You may revise the wording of the communication to ensure it
       can be used as evidence if the council does not cooperate and
       you need to present this letter to the Ombudsman or make a claim
       for a breach.
       >
       >
       >
       >
       > Dear Parking Services
       >
       > I refer to the above matter and the applicable PCN enforcement
       timetable you recently provided. I emphasise that this is your
       evidence.
       >
       > My frustration at being pursued for a penalty is now
       compounded by my annoyance at the council's blatantly unlawful
       demand, which should have been evident with proper oversight.
       Your timeline is attached, from which I have concluded the
       following:
       >
       > An entry indicates that a Notice to Owner (NTO) was dated and
       posted on 25 Oct.
       > Another entry shows a second NTO was produced, dated, and
       posted on 26 Oct.
       > An entry states a Charge Certificate (CC) was produced, dated,
       and posted on 27 Nov.
       > An entry shows payment of £70 received on 27 Nov.
       > An entry shows a CC posted on 27 Nov., citing and relying upon
       the NTO issued on 26 Oct., which, based on the council's
       evidence, was an unlawful notice.
       > A copy of the NTO dated 26 Oct. is provided in the council's
       evidence.
       > A copy of a receipt issued by the Council for payment of £70
       dated 26 November 2023.
       >
       > The following points are evident from the above:
       >
       > a. The unlawful act of issuing a second NTO on 26 Oct.
       > b. Even if the CC was legitimate, the council's legal right to
       demand the surcharge penalty arose only on 29 Nov. when the CC
       (posted on 27 Nov.) was served.
       > c. The council acted unlawfully by refusing payment of the
       extant, unsurcharged penalty on 27 Nov.
       > d and pursuing the owner based on an unlawful NTO and CC.
       >
       > The Enforcement Agent has taken an unlawful money transfer of
       £514 under the pain of removing my car. I will now file an Out
       of Time application to the Traffic Enforcement Centre.
       >
       > Given the council's actions to date, I expect a successful
       outcome and anticipate that the council will not object to my
       application. However, considering the above, it would be in the
       authority's best interest to cancel the Charge Certificate and
       Order for Recovery now rather than referring the matter to the
       adjudicator.
       >
       > In this context, having been made aware of your actions,
       should the council object to my submission and it be refused, I
       will refer this matter to your Complaints Procedure and, if
       necessary, the Ombudsman. Such action could only be seen as a
       failure to discharge the council's public duty to act fairly and
       reasonably.
       > My bank details for the return of the money are as follows
       [provide bank details here]. Once the money is returned, I will
       consider the matter solved.
       >
       > I have copied your enforcement agent for their information.
       >
       --- End Quote ---
       Hello,
       Am I sending an email to Swansea Council & sending the ‘OOT’ &
       ‘Witness Statement’ to the TEC
       #Post#: 26942--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: H C Andersen
       Date: June 21, 2024, 3:04 am
       ---------------------------------------------------------
       OP, it's not really 'either' 'or'
       You have paid the debt and this closes procedural matters unless
       you re-open them by submitting an OOT. There is no set time for
       this.
       So, you could write to the authority and give them, say, 7 days
       in which to confirm that the sums paid to the enforcement agents
       will be refunded in full failing which you would submit an OOT.
       TEC's normal practice is to accept an OOT unless the authority
       object.
       I see 3 scenarios:
       1. They realise their error and refund the debt.
       2. They continue to act as if they were judges in their own
       cause and do not comply and object to your OOT, which would
       probably be refused;
       3. They do nothing.
       1. They save themselves embarrassment which would arise with an
       adjudication hearing.
       2. You receive their objection and raise the matter through the
       council's complaints procedure. IMO, an objection in light of
       the irrefutable facts puts them in the realm of failure to
       comply with their public law duty to act fairly and has nothing
       to do with enforcement of road traffic contraventions.
       3. TEC approve your OOT at which point the authority must refer
       the matter to the adjudicator and any hearing would IMO carpet
       them for abusing their power.
       My draft would need amending depending on which route you choose
       to take, I leave this to you.
       #Post#: 26949--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: Enceladus
       Date: June 21, 2024, 5:45 am
       ---------------------------------------------------------
       I'd pursue both routes. The longer the delay with submitting the
       OOT, as that is the procedure the law provides for the
       circumstances, the more chance there is that the Council will
       claim that the PCN has been closed by the OP.
       It's always best with Councils and PCNs to follow the defined
       procedures.
       It's true that the Council might well oppose your OOT. However
       the processing of your OOT at the TEC is liable to take at least
       two and as much as eight weeks. Sending the complaint to the
       Council should be processed faster than that.
       The wording on the OOT application needs to be optimised.
       Assuming the OOT is granted then the Order for Recovery would be
       revoked and the Charge Cert cancelled. Since the PCN itself has
       been paid the matter should be closed. I'm not sure that the
       case would be referred to the Adjudicator. Only perhaps if the
       Council continue to claim that payment was late.
       #Post#: 27257--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: ivanleo
       Date: June 23, 2024, 9:11 am
       ---------------------------------------------------------
       --- Quote from: RhysGrif link ---
       >
       > However, slightest possibility there is a street 10 mins away
       from my address which ends in ‘Street’ and my address ends in
       ‘Road’. Both address have same name and same 4 starting post
       codes ‘**11’
       >
       > My house has received postage from similar street name before
       so it’s not an impossible scenario.
       >
       --- End Quote ---
       Have you got any evidence of this, such as misdelivered letters
       for the other address? Have you ever made a complaint to Royal
       Mail about this?
       I'm Neil's colleague who was meant to look at this a few
       evenings ago, unfortunately I've only just got to this. What
       strikes me here is that the key reason why the various statutory
       notices have gone missing has not been established, and the all
       the documents were posted to the same exact address as given on
       the V5C, then an OOT is more likely than not to be rejected. You
       can of course hope that the council simply doesn't object, but
       if they do then you'd be in a spot of bother as you'd have to
       risk more money to request a review by a district judge.
       TLDR: The fact that the council is very, very wrong does not
       mean they won't successfully object to the OOT.
       #Post#: 27513--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: RhysGrif
       Date: June 25, 2024, 3:48 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > OP, it's not really 'either' 'or'
       >
       > You have paid the debt and this closes procedural matters
       unless you re-open them by submitting an OOT. There is no set
       time for this.
       >
       > So, you could write to the authority and give them, say, 7
       days in which to confirm that the sums paid to the enforcement
       agents will be refunded in full failing which you would submit
       an OOT. TEC's normal practice is to accept an OOT unless the
       authority object.
       >
       > I see 3 scenarios:
       >
       > 1. They realise their error and refund the debt.
       > 2. They continue to act as if they were judges in their own
       cause and do not comply and object to your OOT, which would
       probably be refused;
       > 3. They do nothing.
       >
       > 1. They save themselves embarrassment which would arise with
       an adjudication hearing.
       > 2. You receive their objection and raise the matter through
       the council's complaints procedure. IMO, an objection in light
       of the irrefutable facts puts them in the realm of failure to
       comply with their public law duty to act fairly and has nothing
       to do with enforcement of road traffic contraventions.
       > 3. TEC approve your OOT at which point the authority must
       refer the matter to the adjudicator and any hearing would IMO
       carpet them for abusing their power.
       >
       > My draft would need amending depending on which route you
       choose to take, I leave this to you.
       >
       --- End Quote ---
       Hello,
       I have contact swansea council for an email address for their
       parking services depart as I can't find one online. I will
       contact them and then if that fails fill out an OOT
       #Post#: 27561--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: RhysGrif
       Date: June 26, 2024, 8:53 am
       ---------------------------------------------------------
       Hello,
       Swansea council have sent me the following:
       ‘Good afternoon
       
       Thank you for your email.
       
       We have reviewed your case and can confirm the following:
       
       A Notice to Owner was sent for printing and posting on
       25/10/2023 however, due to an internal issue it appears that the
       documentation failed to print. For this reason, the Notice to
       Owner was requeued and subsequently printed and posted on
       26/10/2023 to the address provided to us by the DVLA as being
       that of the registered keeper, which was still within the legal
       timescales to serve a Notice to Owner.
       
       The Notice to Owner documentation advised that a payment of
       £70.00 was outstanding to be paid within 28 days of the date the
       Notice was deemed served, which in this case was no later than
       25/11/2023. The Notice also advised that failure to make payment
       before the end of the 28 days period would result in the penalty
       increasing by 50% taking the total to £105.00.
       
       Due to a payment of £70.00 not being received until 26/11/2024
       which was after the 28 day period, the case progressed as an
       underpayment and we issued a Charge Certificate requesting the
       outstanding balance of £35.00 (£105.00 minus £70.00 received).
       
       As no further payment or correspondence was received in response
       to the Charge Certificate, the case continued to progress and we
       issued an Order for Recovery (TE3 TE9) on 20/12/2023 which
       incurred further charges.
       
       Due to no payment or completion of the TE3 and TE9 being made
       within the statutory timescales the case was registered for a
       warrant of control and was subsequently passed to Andrew James
       Enforcement on 09/02/2024 to recover the outstanding debt plus
       Enforcement Fees.
       
       Having reviewed your case in full Swansea Council are satisfied
       that no procedural impropriety has occurred and that the case
       has progressed correctly. For this reason, we regret that we
       will be unable to cancel the Charge Certificate and Order for
       Recovery or recall the case from the Enforcement Agent and issue
       any refunds of payments made.
       
       Your only options at this late stage are to either, lodge an Out
       Of Time Witness Statement with the Traffic Enforcement Centre
       (TEC) for your case to be reviewed by a Court Officer if one of
       the four options on the witness statement apply to your case or
       your case will remain closed as full payment has now been
       received by the Agent.
       
       Here are the four options you could choose from:
       
       *  I did not receive the Notice to Owner / Penalty Charge Notice
       *  I appealed against the Local Authority’s decision to reject
       my representation, within 28 days of service of the rejection
       notice, but have had no response.
       *  I made representations about the penalty charge to the
       enforcing authority concerned within 28 days of the service of
       the Notice to Owner, but did not receive a rejection notice.
       *  The Penalty Charge Notice was paid in full.
       
       To request the relevant documentation to lodge an Out of Time
       Witness Statement you would be required to contact TEC on 0300
       123 1059 (select option 6) or download the relevant forms (TE7 &
       TE9) online at www.gov.uk (see direct links below)
       
  HTML https://www.gov.uk/government/publications/form-te9-witness-statement-unpaid-penalty-charge-parking
       
  HTML https://www.gov.uk/government/publications/form-te7-application-to-file-a-statement-out-of-time-extension-of-time-parking
       
       The completed forms must be returned to the Traffic Enforcement
       Centre at the address they provide or via email to
       tec@justice.gov.uk .
       
       Where possible we would request that you please provide
       supporting documentary evidence with your statement.
       
       Once we are in receipt of notification from TEC that an Out Of
       Time Witness Statement has been lodged on this case, we will
       place the case on hold until a decision has been made regarding
       this matter.
       
       Please be advised, should no action be taken, the case will
       remain active with the Enforcement Agent and further charges may
       be incurred.
       
       Cofion/Regards’
       #Post#: 27565--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: fraser.mitchell
       Date: June 26, 2024, 9:21 am
       ---------------------------------------------------------
       So the key point is what did their system ask for when you made
       payment ? Their not printing the NtO on their first attempt
       hints at system problems.
       #Post#: 27566--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: H C Andersen
       Date: June 26, 2024, 9:31 am
       ---------------------------------------------------------
       Great news.
       Write back.
       Thank them for replying so quickly and clarifying that a NTO was
       posted on THURSDAY 26 October 2023. However, you can see that
       the error made by the authority in 2023 has been repeated in
       their last reply with their inability to calculate 28-day
       periods as follows:
       Date of posting: Thursday 26 Oct.
       Date deemed served: Monday 30th October.
       Latest date of the 28-day period beginning on date of service:
       Sun. 26th Nov. and not 25 Nov. as stated by the council.
       You would ask that the authority consider their position in this
       matter and accept that payment of £70 (which the council
       acknowledge was made on 26 Nov.) discharges the owner's legal
       obligation in this matter.
       #Post#: 27583--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: RhysGrif
       Date: June 26, 2024, 12:21 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Great news.
       >
       > Write back.
       >
       > Thank them for replying so quickly and clarifying that a NTO
       was posted on THURSDAY 26 October 2023. However, you can see
       that the error made by the authority in 2023 has been repeated
       in their last reply with their inability to calculate 28-day
       periods as follows:
       >
       > Date of posting: Thursday 26 Oct.
       > Date deemed served: Monday 30th October.
       > Latest date of the 28-day period beginning on date of service:
       Sun. 26th Nov. and not 25 Nov. as stated by the council.
       >
       > You would ask that the authority consider their position in
       this matter and accept that payment of £70 (which the council
       acknowledge was made on 26 Nov.) discharges the owner's legal
       obligation in this matter.
       >
       --- End Quote ---
       Hello,
       So I would I be correct in saying that they have confirmed that
       the document was posted on 26th and not 25th therefore giving me
       a 28 day period of 27th November due to the working day falling
       on the Monday.
       #Post#: 27641--------------------------------------------------
       Re: Bailiffs Swansea Council - 02 - Page Street
   DIR By: ivanleo
       Date: June 26, 2024, 5:31 pm
       ---------------------------------------------------------
       I would suggest you want to start drafting your OOT application.
       If you can get this accepted and the matter is referred to the
       tribunal, I have little doubt you can get the £70 refunded.
       Depending on how much of a fuss the council makes, you might
       even get a costs order.
       *****************************************************
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