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       #Post#: 112402--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: March 7, 2026, 11:07 pm
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > 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.
       >
       --- End Quote ---
       Yes this was the first response!
       Planning to respond with the below, although I realised there is
       no return address and I'm overseas so may just try sending via
       email again, cc'ing myself.
       _____________________
       Dear Sirs,
       I acknowledge receipt of your letter dated 26 February 2026.
       Your response does not properly engage with the matters raised
       in my previous correspondence and fails to provide the documents
       specifically requested pursuant to the Pre-Action Protocol for
       Debt Claims (PAPDC) and the Practice Direction - Pre-Action
       Conduct and Protocols (PD-PAC).
       1. Continuing Protocol Non-Compliance
       In my previous correspondence I requested disclosure of key
       documents required under PAPDC paragraphs 5.1-5.2 and PD-PAC
       paragraph 6, in order to enable the parties to properly
       understand the issues in dispute and to comply with the
       objectives of the pre-action process.
       Your response contains none of the requested material and
       instead consists of a brief assertion that the Parking Charge
       Notice was correctly issued. Such a response falls materially
       short of the obligations imposed upon a creditor under the
       Protocol.
       For the avoidance of doubt, the requested documents remain
       outstanding.
       2. Failure to Meaningfully Engage
       It is notable that your organisation has taken approximately
       five months to produce a response comprising only a few
       paragraphs which neither addresses the substantive issues raised
       nor provides the documentation required to allow meaningful
       engagement with the alleged claim.
       This conduct does not comply with either the letter or the
       spirit of the Pre-Action Protocol for Debt Claims or the
       Practice Direction on Pre-Action Conduct, both of which require
       parties to exchange sufficient information and documentation to
       properly narrow or resolve disputes prior to litigation. Your
       letter dated 26 February 2026 also fails to provide any address
       for correspondence. This omission further undermines compliance
       with the Pre-Action Protocol, which requires parties to provide
       sufficient information to enable meaningful engagement and
       response prior to the commencement of proceedings.
       3. Requested Documentation
       The documents previously requested remain outstanding, including
       but not limited to:
       the original Notice to Keeper and all subsequent notices;
       strict proof of the legal basis of liability, including
       compliance with Schedule 4 of the Protection of Freedoms Act
       2012 if keeper liability is alleged;
       all ANPR images, photographs and VRM logs relating to the
       alleged incident;
       contemporaneous evidence of signage in situ on the material date
       together with a site plan showing sign locations and entrance
       signage;
       the unredacted landowner contract or chain of authority
       establishing your standing to offer parking contracts and pursue
       litigation at the site;
       any payment machine records or audit logs relevant to the
       alleged period; and
       a full breakdown of the sum claimed, including the legal basis
       for any amount above the core parking charge.
       Until these documents are provided, it is not possible to
       properly assess the basis of your claim or provide a substantive
       response.
       4. Reservation of Rights
       We reserve the right to bring to the court’s attention, in any
       proceedings you may commence, your apparent failure to disclose
       information that is plainly central to your claim. We will
       further contend that your unreasonable withholding of such
       material amounts to a deliberate obstruction of the pre-action
       protocol. In those circumstances, we will seek appropriate costs
       sanctions against you.
       Further, I expressly reserve the right to rely upon your
       continued non-compliance with the Pre-Action Protocol when
       addressing case management directions and any costs issues that
       may arise should proceedings be issued.
       5. Protocol Timing
       As previously stated, the 30-day response period under the PAPDC
       cannot properly commence until a compliant Letter Before Claim
       supported by the requested documentation has been provided.
       Should proceedings be issued without compliance with the
       Protocol, I will invite the court to consider a stay of
       proceedings to allow proper compliance, together with any
       appropriate directions and sanctions.
       6. Availability
       Please note that I will be overseas until mid-April 2026. During
       this period I will be able to respond only to email
       correspondence. Any further communication should therefore be
       sent electronically.
       If you intend to pursue this matter, please provide the
       requested documentation in a single paginated electronic bundle
       so that the issues may be properly considered.
       Yours faithfully,
       Keeper
       #Post#: 116708--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: April 22, 2026, 10:31 am
       ---------------------------------------------------------
       Have now received a response by email:
       --- Quote ---
       > Dear Sir/Madam,
       >
       >
       > We write further to your recent correspondence regarding the
       above Parking Charge Notice (PCN).
       > We confirm that your initial appeal was rejected on 27 June
       2024. Your subsequent appeal to POPLA was also rejected on 9
       October 2024. The decision confirmed that the signage at the
       site was adequate, that we had the necessary landowner authority
       to operate and issue the PCN, and that the charge was issued
       correctly based on the evidence provided.
       > We can confirm that the PCN is compliant with the Protection
       of Freedoms Act 2012 (PoFA) and that we have the appropriate
       landowner authority. However, as noted in POPLA’s response, we
       are not required to provide a copy of the landowner contract, as
       it is commercially sensitive.
       > For your reference, we have attached images of the signage in
       place at the time of the contravention, ANPR images of the
       vehicle, and copies of all correspondence previously sent to
       you.
       > We have now provided all information that we are legally
       required to disclose at this stage. Any further documentation
       will be submitted in advance of a hearing, should proceedings be
       issued.
       > Please note that all appeal avenues have now been exhausted,
       and we are unable to consider any further representations. The
       outstanding balance is £170.00. If full payment is not received
       within 14 days, we will proceed with legal action without
       further notice.
       > Please use the link below to make payment.
       >
  HTML https://payments.ce-service.co.uk/
       >
       >
       > Kind regards,
       >
       >
       >
       > Legal Team
       >
       >
       > Email: legal@ce-service.co.uk
       > Tel: 01614 515151
       --- End Quote ---
       What next?
       #Post#: 116713--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: DWMB2
       Date: April 22, 2026, 10:54 am
       ---------------------------------------------------------
       I'd not bother with any further letters - wait for them to issue
       proceedings.
       #Post#: 124440--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: July 12, 2026, 11:56 am
       ---------------------------------------------------------
       So I've just received another full Letter before action pack
       from CE with the reply forms and everything.
       It seems like they're getting things mixed up. Respond or leave
       it?
       #Post#: 124467--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: InterCity125
       Date: July 13, 2026, 2:51 am
       ---------------------------------------------------------
       --- Quote from: Keeper link ---
       >
       > So I've just received another full Letter before action pack
       from CE with the reply forms and everything.
       >
       > It seems like they're getting things mixed up. Respond or
       leave it?
       >
       --- End Quote ---
       We're seeing this more often now - repeat LBCs.
       Ignore it but file it just in case you ever have to proved their
       bungling incompetence.
       #Post#: 124583--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: July 14, 2026, 4:23 am
       ---------------------------------------------------------
       Thanks will do this. It's really dragging on now, wish they'd
       just take me to court or Eff off!
       #Post#: 129197--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: August 30, 2026, 9:36 am
       ---------------------------------------------------------
       Prayers have been answered! Finally got a Claim Form from them
       on 26th August. Particulars of claim are:
       Claim for money relating to a Parking Charge
       (PC) for breach of contract terms (TC) agreed
       upon entry/parking in private car park (CP)
       managed by Claimant. PC issued for breach of
       the following TC:
       Parked in breach of the terms notified on the
       signage at the car park
       .
       .
       .
       PC: RefXXXXXXXXXXXXXXXX
       Violation date:04/06/2024 Pay due:03/07/2024
       Time in: 20:08 Time out: 21:19
       Vehicle reg mark: XXXXXXXXXX CP site:-
       Sacred Heart Wimbledon
       Total amount due- £170.00
       Pay: www.ce-service.co.uk or call 01614515151
       The Claimant claims the sum of £200.26
       for the unpaid parking charge inc £30.26
       interest under S.69 of the CCA 1984
       Rate: 8.00% pa from due date to 25/08/26
       Same rate to Judgment or sooner payment
       at daily rate of- £0.04
       Total debt and interest due- £200.26
       At this stage what should I do? Just file the AOS, stating I
       intend to fully defend the claim?
       #Post#: 129208--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: InterCity125
       Date: August 31, 2026, 1:35 am
       ---------------------------------------------------------
       Please post up the claim form redacting only personal info and
       password.
       #Post#: 129227--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: August 31, 2026, 9:26 am
       ---------------------------------------------------------
       Thanks, here you go
  HTML https://i.postimg.cc/DSv1ZhmX/Claim.jpg
  HTML https://postimg.cc/DSv1ZhmX
       #Post#: 129516--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church
       Wimbledon
   DIR By: Keeper
       Date: September 3, 2026, 12:48 pm
       ---------------------------------------------------------
       Bumping this to the top - if someone can recommend next course
       of action, would be great!
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