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       #Post#: 32454--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: August 6, 2024, 11:07 am
       ---------------------------------------------------------
       [quote author=b789 link=topic=2323.msg32448#msg32448
       date=1722958103]
       [quote author=Keeper link=topic=2323.msg32443#msg32443
       date=1722955839]
       It's just a comment box - can't upload or attach anything so
       mentioning is the best I can do...
       [/quote]
       I meant did you highlight the doctored photos in your original
       appeal? If you didn't, you must try and describe what is
       obviously an alteration of the evidential photo which is in
       breach of the CoP.
       It may need painting out to the local priest that the landowner
       is jointly and severally liable for the actions of their agents.
       Maybe there's a religious metaphor that can be used.  :o
       [/quote]
       Yes I did highlight the doctored photos:
       [quote]Evidence Tampering by the operator
       The operator has submitted as supposed evidence a photograph of
       the sign that is alleged to have formed the contract. The BPA
       CoP specifically Staes at 21.5a as follows:
       Use of photographic evidence: Photographic evidence must not be
       used by you as the basis for issuing a parking charge unless: b)
       the images bear an accurate time and date stamp applied at the
       point the picture was taken;
       It is obvious from the photograph above, provided by the
       operator, that it has been tampered with and altered. There are
       two different timestamps, one of which has, without a doubt,
       been added after the point the picture was taken. Additionally,
       in section 21.5a it states:
       Alteration of photographic evidence: You must not digitally or
       by other means alter images used as photographic evidence other
       than: e) to blur faces or the VRMs of other vehicles in the
       image in accordance with your GDPR obligations; or f) to enhance
       the image of the VRM for clarity, but not to alter the letters
       and numbers displayed.
       It is obvious that this breach of the BPA CoP must invalidate
       the PCN as it has been issued incorrectly.[/quote]
       [quote author=DWMB2 link=topic=2323.msg32451#msg32451
       date=1722959592]
       [quote author=b789 link=topic=2323.msg32448#msg32448
       date=1722958103]
       Maybe there's a religious metaphor that can be used.  :o
       [/quote]
       "He who is without sin can cast the first Parking Charge Notice"
       [/quote]
       Something about flocks and who thou leaves in charge of thy
       sacred land... I don't think the argument that CEL are agents of
       the Lord will fly though!
       #Post#: 39916--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: October 9, 2024, 3:20 am
       ---------------------------------------------------------
       POPLA Appeal has come back - unsuccessful (explanation below for
       those interested) - what should be my next steps?
       Many thanks!
       [quote]Assessor summary of operator case
       The operator has issued the PCN because the vehicle was parked
       on the site and failed to obtain a permit during the notified
       period.
       Assessor summary of your case
       The appellant has raised the following grounds of appeal: • The
       signage on the site does not comply with Section 19.3 and 19.4
       of the British Parking Association (BPA) Code of Practice. • The
       evidence provided by the operator has been tampered with. • The
       operator has not provided adequate evidence of their authority
       to issue parking charges at this location. In the comments the
       appellant has advised the following: • The confirmation of
       appointment is not a contract. • The images provided by the
       operator show different timestamps which indicates potential
       tampering. • The signage does not comply with Section 19.4 of
       the BPA Code of Practice. The appellant has provided a document
       detailing their appeal.
       Assessor supporting rational for decision
       When assessing an appeal POPLA considers if the operator has
       issued the parking charge notice correctly and if the driver has
       complied with the terms and conditions for the use of the car
       park. The operator has provided evidence of the vehicle parked
       on the site for one hour and 11 minutes on the day in question.
       The data from the permit system shows that the vehicle had not
       been registered for a permit on the day of the incident. In this
       case, it is not clear who the driver of the appellant’s vehicle
       is, so I must consider the Protection of Freedoms Act (PoFA)
       2012, as the operator issued the Parking Charge Notice (PCN) to
       the keeper of the vehicle. The operator has provided me with a
       copy of the notice to keeper sent to the appellant. I have
       reviewed the notice to keeper against the relevant sections of
       PoFA 2012 and I am satisfied that it is compliant. I will
       therefore be assessing keeper liability. The appellant has
       advised that the signage on the site is not compliant. The
       British Parking Association (BPA) has a Code of Practice which
       set the standards its parking operators need to comply with.
       Section 19.3 of the code states that signs must be placed
       throughout the car park so that drivers have the chance to
       review the terms and conditions. The code confirms that these
       signs must be conspicuous and legible and written in
       intelligible language so that they are easy to see read and
       understand. The operator has provided multiple images of the
       signs within the car park and after reviewing these, I am
       satisfied that there are plenty of signs located within the car
       park and that these signs meet the requirements of section 19.3
       of the Code of Practice.The signage clearly advises that a
       permit is required to park and failing to obtain one is a breach
       of the terms. Further to the appellant’s statement that the
       operator’s evidence has been tampered with I am satisfied that
       the evidence the operator has provided is correct and has not
       been tampered with. The fact that there are different timestamps
       on some of the images does not invalidate the PCN in any way.
       Section 19.4 of the Code of Practice states that if parking
       operators intend to use the keeper liability provisions in
       Schedule 4 of the Protection of Freedoms Act (PoFA) 2012, the
       signs must give adequate notice of the charge. I have reviewed
       the signs and I am satisfied that the charge amount is clear as
       it has been highlighted to draw motorist’s attention to the
       amount. The appellant has questioned landowner authority .I note
       the appellant’s comments and I refer to Section 7 of the British
       Parking Association(BPA) Code of Practice which states in 7 .1
       “If you do not own the land on which you are carrying out
       parking management, you must have the written authorisation of
       the landowner (or their appointed agent). The written
       confirmation must be given before you can start operating on the
       land in question and give you the authority to carry out all the
       aspects of car park management for the site that you are
       responsible for. In particular, it must say that the landowner
       (or their appointed agent) requires you to keep to the Code of
       Practice and that you have the authority to pursue outstanding
       parking charges. 7.2 If the operator wishes to take legal action
       on any outstanding parking charges, they must ensure that they
       have the written authority of the landowner (or their appointed
       agent) prior to legal action being taken. 7.3 The written
       authorisation must also set out: a the definition of the land on
       which you may operate, so that the boundaries of the land can be
       clearly defined b any conditions or restrictions on parking
       control and enforcement operations, including any restrictions
       on hours of operation c any conditions or restrictions on the
       types of vehicles that may, or may not, be subject to parking
       control and enforcement d who has the responsibility for putting
       up and maintaining signs e the definition of the services
       provided by each party to the agreement”. The operator has
       provided a confirmation of appointment document and I am
       satisfied that the operator has the authority to issue PCN’s on
       this site. The operator does not need to provide a full copy of
       the full contract as it may contain commercially sensitive
       information. The evidence provided in relation to this appeal
       meets the criteria POPLA requires, and therefore I am satisfied
       that the operator has sufficient authority at the site on the
       date of the parking event. After considering the evidence from
       both parties the vehicle was parked on the site and failed to
       obtain a permit during the notified period and therefore did not
       comply with the terms and conditions of the site. Based on the
       evidence provided, I am satisfied the parking charge has been
       issued correctly therefore, I must refuse the appeal.[/quote]
       #Post#: 39944--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: b789 Date: October 9, 2024, 5:12 am
       ---------------------------------------------------------
       Fairly typical and fails to fully address the points raised in
       your POPLA submission. POPLA have to justify their paymasters
       and do so by obfuscation in their responses, as you can see.
       Nothing to worry about. This has no bearing on anything going
       forward and you are not bound by the POPLA decision. Don't pay
       CEL.
       For the time being, you now have to ignore all the debt
       collector letters they are going to send you. Whilst these may
       appear to be scary, they are in fact powerless to do anything
       and are simply employed on a no-win, no-fee basis by the
       operator and use words such as "bailiff" and "CCJ" to try and
       scare low-hanging fruit on the gullible tree into pooping their
       pants and paying up. Never, ever engage with a debt collector.
       You can safely ignore them. You should use their letters to line
       the bottom of a cat litter tray.
       What you are waiting for is to see if when they send a Letter of
       Claim (LoC). They hope that the initiation of litigation will be
       another step in scaring the gullible into paying up. Of course,
       you are not gullible as you are here receiving well worn advice
       on how to deal with these scams.
       Even if the do escalate to a claim, that is a good thing as the
       county court is the ultimate dispute resolution service. Not
       that most claims ever reach a hearing when we deal with them.
       The majority of (over 99%) them end up being discontinued once
       they realise that you intend to go all the way and they know
       they are in fact on shaky ground and so go off in search of
       lower-hanging fruit to go pick on. Most of the few other claims
       that aren't discontinued are struck out due to procedural
       deficiencies in the actual claim.
       In the remote, worst case scenario, should you be on of the less
       than one percenters who actually make it to a hearing and are
       unsuccessful, there is no danger of a CCJ.
       So, are you aggrieved enough to want to fight them on this?
       #Post#: 40034--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: October 9, 2024, 2:28 pm
       ---------------------------------------------------------
       Absolutely.
       I have had a similar experience with a different operator,
       guided expertly by those on this forum and they pulled out at
       the last minute.
       Quite ready to receive (and ignore) debt collection letters.
       So for now, wait till the actual letter of claim - got it!
       Many thanks as always
       #Post#: 40038--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: DWMB2 Date: October 9, 2024, 2:46 pm
       ---------------------------------------------------------
       As I noted on a previous thread, if you move house before the
       matter is resolved, make sure you tell CEL your new address for
       service.
       #Post#: 91175--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: September 23, 2025, 1:43 pm
       ---------------------------------------------------------
       Hello! Hope all are doing well!
       Well here we are, nearly a year since the last update and after
       ignoring several debt collection service letters, I'm now the
       lucky recipient of a Letter before action from CE.
       Letter attached (note that it's dated 04 September but received
       just a few days ago, probably around the 18th.
       They've also included Annex 1 from here
  HTML https://www.justice.gov.uk/documents/debt-pap.pdf
       and a Press
       Summary of two cases: Cavendish Square Holding v Talal El
       Makdessi and ParkingEye ltd v Beavis as well as some paperwork
       to fill in if one is unable to pay.
  HTML https://www.justice.gov.uk/documents/debt-pap.pdf
       Letter: (not sure how to get it to embed?)
  HTML https://imgur.com/a/qC1ILkW
       #Post#: 91246--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: b789 Date: September 24, 2025, 6:13 am
       ---------------------------------------------------------
       You do not use any of the forms that demand. Simply respond with
       the following in an email and CC yourself:
       [quote]Subject: Response to your Letter of Claim Ref: [reference
       number]
       Re: PCN at Sacred Heart Wimbledon, Edge Hill – VRM [reg] – LBC
       dated 04/09/2025
       Dear Sirs,
       1) Protocol non-compliance
       Your Letter Before Claim contains insufficient detail and omits
       the key documents required to enable informed engagement. It
       fails to comply with the Pre-Action Protocol for Debt Claims
       (paras 3.1(a)–(d), 5.1–5.2) and the Practice Direction –
       Pre-Action Conduct and Protocols (PD-PAC), including the duty to
       exchange key documents before proceedings.
       2) Documents required
       Pursuant to PAPDC 5.1–5.2 and PD-PAC 6, provide in a single
       paginated PDF bundle:
       [indent](1) The original NtK (both sides) and all subsequent
       notices.
       (2) The precise legal basis relied on (keeper liability under
       PoFA 2012 or driver liability) and strict proof of PoFA
       compliance, including the statutory warning and an identified
       period of parking.
       (3) All photographs/ANPR images and full VRM [reg] in/out logs
       covering at least one hour either side of the material times,
       plus any manual checks.
       (4) Contemporaneous photographs of the actual signs in situ on
       the material date, the full terms in readable close-ups, and a
       site plan showing location/number of signs and the entrance
       signage.
       (5) An unredacted landowner contract/chain of authority showing
       your standing to offer contracts, issue PCNs and litigate in
       your own name at this site on the material date.
       (6) Machine/payment records and audit logs for the relevant
       period (or confirmation none existed).
       (7) A full breakdown of the sum claimed and the legal basis for
       any sums over the core PCN, identifying whether the principal is
       alleged consideration or damages and whether the £70 “debt
       recovery” add-on attracts VAT (and if so, on what basis).
       (8) The name, role and regulatory status of the person with
       conduct of this matter.[/indent]
       3) Timing and hold
       Given the late receipt of your LBC, confirm that the 30-day
       period runs from service of a compliant, document-supported LBC.
       In accordance with PAPDC 5.2, place the matter on hold for a
       minimum of 30 days after you have supplied the above.
       4) Next steps
       Upon receipt of a compliant Letter Before Claim and the
       requested documents I will seek advice and provide a substantive
       response within 30 days. If you issue proceedings prematurely, I
       will apply for a stay and appropriate sanctions for
       non-compliance, relying on Webb Resolutions v Waller Needham &
       Green [2012] EWHC 3529 (Ch), Daejan Investments v Park West Club
       (Part 20) Buxton Associates [2003] EWHC 2872, and Charles Church
       Developments v Stent Foundations & Peter Dann [2007] EWHC 855,
       together with PD-PAC paras 13, 15(b)–(c) and 16 and PAPDC 7.2.
       5) Address for service & data accuracy
       Record the address after my signature as my address for service.
       If you hold any other address, rectify your records and confirm
       erasure of incorrect data.
       Yours faithfully,
       [Your name]
       [Address for service][/quote]
       #Post#: 91318--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: September 24, 2025, 10:46 am
       ---------------------------------------------------------
       Brilliant, thanks! I got half way through point 2 and started
       chuckling.
       Do you think they will back down, or send me everything
       requested?
       I have used the following email addresses for CE
       office@ce-service.co.uk
       Legal3@ce-service.co.uk
       I've also seen that the email has been opened (possibly
       automatically) 1 minute after sending
       #Post#: 112159--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: March 5, 2026, 8:26 am
       ---------------------------------------------------------
       Update on this one! Received this letter by post
       [img width=180
       height=165]
  HTML https://i.postimg.cc/Yvmd4QPd/Letterfrom-CE.png[/img]
  HTML https://postimg.cc/Yvmd4QPd
       I feel they've not responded adequately to my previous
       correspondence, so I assume the next step is to respond
       basically pointing out their non-compliance with the PD-PAC.
       Anything else at this stage?
       OR, no response at all?
       THANKS for the continued advice
       #Post#: 112164--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: DWMB2 Date: March 5, 2026, 8:51 am
       ---------------------------------------------------------
       Is this the first response you've received? If so, yes I would
       do as you suggest, but also make clear that it has taken them 5
       months to issue a 3 paragraph response that neither properly
       engages with the issues you raised nor complies with the PAPDC.
       You don't want to end up in an endless letter ping-pong, but if
       you can create a clear paper trail that evidences their shoddy
       conduct this is advantageous.
       As ever feel free to show us a draft.
       *****************************************************
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