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       #Post#: 28182--------------------------------------------------
       Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: daisy
       Date: July 1, 2024, 10:14 am
       ---------------------------------------------------------
       Hello,
       My husband received this PCN a week ago. My husband believes
       that he is not at fault. We have tried to find someone to help
       us with the challenge. Since we could not find anyone, we are
       turning to you.
  HTML https://i.imgur.com/CcB04ZI.jpeg
       I hope I have added the video as well:
  HTML https://youtu.be/4Z_aQIU6Uxc
       This is the street view link:
  HTML https://maps.app.goo.gl/cy4sfpxHWAci6csj6
       Thanks.
       #Post#: 28198--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: MrChips
       Date: July 1, 2024, 12:46 pm
       ---------------------------------------------------------
       Thanks for posting all the information.
       I can't see any problems with the PCN letter, nor anything in
       the video which might help with a challenge. The van enters the
       box and then gets stuck behind the stationary bus.
       For what reason does your husband think he is not at fault?
       #Post#: 28199--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: fraser.mitchell
       Date: July 1, 2024, 12:54 pm
       ---------------------------------------------------------
       --- Quote ---
       > My husband believes that he is not at fault.
       --- End Quote ---
       Why does your husband believe he is not at fault, because,
       (sorry to have to say it), the video seems to show a clear
       contravention ?
       That's not to say there is no appeal argument, but we need to
       hear from your husband concerning the circumstances at the time.
       The camera is mounted high up so doesn't show the situation from
       a driver point-of-view It is always best to submit
       representations rather than cough-up straightaway. but there
       does need to be a reasonable argument, however skeletal.
       #Post#: 28207--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: daisy
       Date: July 1, 2024, 2:03 pm
       ---------------------------------------------------------
       He thinks he is not at fault because the traffic is moving fine
       when entering the yellow box. Suddenly, the van in front of the
       bus pulls to the side causing traffic. As a result of that, my
       husband gets stuck on the yellow box. How could he predict that
       the van in front of the bus would choose to pull over?
       I hope I have explained it right.
       #Post#: 28224--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: fraser.mitchell
       Date: July 1, 2024, 4:13 pm
       ---------------------------------------------------------
       --- Quote from: daisy link ---
       >
       > He thinks he is not at fault because the traffic is moving
       fine when entering the yellow box. Suddenly, the van in front of
       the bus pulls to the side causing traffic. As a result of that,
       my husband gets stuck on the yellow box. How could he predict
       that the van in front of the bus would choose to pull over?
       > I hope I have explained it right.
       >
       --- End Quote ---
       I see what you mean, and he has my sympathy ! As you say, all
       was moving well when he entered the box, and that is a key
       event, because the van stopping out-of-course could not be
       foreseen. So wait a bit to see what others say, although don't
       miss any deadline dates on the PCN. Don't just cough-up as we
       always recommend submitting some representations before deciding
       whether to pay or go to LT.
       #Post#: 28227--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: MrChips
       Date: July 1, 2024, 4:32 pm
       ---------------------------------------------------------
       It is tough on your husband and such circumstances would catch
       very many out.
       Unfortunately, the nature of box junctions is that drivers
       aren't meant to go inside unless they have a vacant exit already
       available. As such they enter at their own risk that traffic
       ahead will come to a halt, even unexpectedly.
       If it was a valid defence to say 'I didn't expect the traffic to
       stop' then box junctions would effectively be unenforceable so,
       personally, I don't think that will help. Let's see if anyone
       can come up with something more concrete.
       #Post#: 28254--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: ivanleo
       Date: July 1, 2024, 6:37 pm
       ---------------------------------------------------------
       I don't see any unforeseeable event in the video, the van might
       in front of the bus might be pulling over or taking a left turn,
       it hardly matters.
       The arguments I can see are:
       1) De-minimis, the van behind the bus only stops for 5 / 6
       seconds, but this is really the upper-limit for a de-minimis
       defence and won't be accepted by most adjudicators
       2) Paperwork errors. The PCN makes a reference to the date of
       service right next to the payment periods, which is arguably
       ambiguous and confusing.
       3) The website argument explained in the cases at rows 587 to
       603 here
  HTML https://docs.google.com/spreadsheets/d/1pVrE76_RYY6bNmEpYGbsZkxtpfIeud_BT3SKfg7TzQM/edit?gid=642784037#gid=642784037&range=A587.
  HTML https://i.imgur.com/jszTAYE.png
       The third point should only be raised at the tribunal stage, but
       given its success rate it's definitely worth running given
       Brent's website doesn't list any statutory grounds of appeal at
       all.
       As a starting point please post all the remaining pages of the
       PCN so that we can check for further issues.
       #Post#: 28357--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: daisy
       Date: July 2, 2024, 1:16 pm
       ---------------------------------------------------------
  HTML https://i.imgur.com/2DbBc3N.jpeg
  HTML https://i.imgur.com/s2uRWEg.jpeg
       Thank you!
       #Post#: 28488--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: ivanleo
       Date: July 3, 2024, 11:53 am
       ---------------------------------------------------------
       Draft reps:
       [indent]
       Dear London Borough of Brent,
       In the first instance I contend the PCN should be cancelled
       because any contravention can be properly described as
       de-minimis, the stopping time being around 5 seconds or so.
       Furthermore I dispute the validity of the PCN because the
       payment deadlines are ambiguous and unclear. The PCN asserts
       that I have 28 days from the date of the notice to make payment,
       but this is follow by text indicating that the date of service
       is considered to be 2 working days from the date of the notice.
       If the payment period is 28 days from the date of the notice
       then the date of service would be irrelevant, so is appears that
       the PCN should assert the payment period is 28 days from the
       date of service of the notice. On the other hand if the payment
       period is 28 days from the date of the notice, then it would
       make no sense to indicate how the date of service is to be
       calculated, as the date of service would be irrelevant. The same
       ambiguity and uncertainty applies to the 14 day discount period.
       In the circumstances the PCN is ambiguous and confusing as to
       what the payment period is, so the PCN should be cancelled.
       Yours faithfully,
       [/indent]
       Send this online via
  HTML https://brent.tarantoportal.com/
       and keep a
       screenshot of the confirmation page.
       #Post#: 28501--------------------------------------------------
       Re: Brent, Code:31, Entering and stopping in a box junction when
       prohibited, yellow box,Acton Lane/Mordaunt Road
   DIR By: daisy
       Date: July 3, 2024, 12:19 pm
       ---------------------------------------------------------
       I have followed your advice and have submitted the
       representation, with a screenshot of the confirmation.
       I will keep you posted.
       Thanks a million!
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