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       #Post#: 29171--------------------------------------------------
       Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: Parkingchase
       Date: July 8, 2024, 4:38 pm
       ---------------------------------------------------------
       Hi FTLA,
       The driver, an NHS staff member, attended a training at the
       hospital for a short stay.
       When they arrived in the carpark (they found a space, they also
       check and found that the parking machine did not dispense
       tickets that could be displayed inside the car as it is a
       paperless system.)
       The process as indicated on instructional signage was to enter
       your numberplate as you leave the facility which will then
       display the amount that needs to be paid.
       
       The driver arrived at the hospital at 10:48 once parked the
       driver checked the ticketing machine which confirmed they needed
       to enter their details when leaving.
       They attended their training which lasted approximately 2 ½
       hours, when they return to their car they followed the
       instructions on the machine to pay for parking.
       
       Once they entered their numberplate they had expected to be
       prompted to pay the amount in line with the 3 hour parking
       charge, however the machine required £10 to be paid (the maximum
       charge for a 24h period).
       In addition, the machine would not allow payment by card
       ‘out of order’ and stated It would take cash payment
       only.
       There was no option to amend the amount or dispute the charge
       and once paid no receipt was dispensed or option to request
       confirmation of payment again as the machine only accepted cash.
       
       On 02/04/2024 they received via post, a parking fine from
       Parkingeye LTD. a discounted £60 fine charging them £100 if not
       paid ‘early’.
       Their claim is that the driver parked and left without paying at
       the carpark on the day of their training (21.04.24).
       The driver does not dispute parking between the stated hours,
       they do however dispute both having parked without paying the
       appropriate parking amount and remaining in the carpark longer
       than permitted.
       
       In addition to the above they were unable to dispute the charge
       with Parkingeye LTD. As their appeals process on the parking eye
       website was unusable due to an ongoing website error which block
       the submission of appeals on their portal.
       The driver attempted to contact the Royal free trust parking
       team close to the date of receiving the PCN but received no
       response for several months and this remained quite after
       following up in the last weeks.
       The driver unfortunately did not contact POPLA as they waited
       for a reply from the NHS royal free trust parking team.
       Now a county court letter arrived from parking eye. The details
       of which will be attached below.
       Time is unfortunately very limited and the driver intends to
       defend themselves as they paid firstly more than what should
       have been owed and now are being pursued for £210. However lack
       of a receipt is a key issue challenge.
       Any advice would be very much appreciated. Thank you.
       #Post#: 29178--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: Parkingchase
       Date: July 8, 2024, 5:06 pm
       ---------------------------------------------------------
       Timeline
       Parking - 21/03/2024
       PCN Received - 02/04/2024 [Image 1]
       Parking Eye Website Appeal Attempt - 15/04/2024 [Image 2]
       Email Sent to PARKINGRFL (The hospital parking management) -
       15/04/2024
       Note: In this email a screenshot of parking eye website
       complaint failure and almost identical description of the
       situation as above took place.
       County Court Letter arrived - 28/04/2024 [Image 3]
       Follow up emails to PARKINGRFL - 30/06/2024, 02/07/2024,
       05/07/2024
       Note: The follow up emails ask for them to get in
       touch.[attachmini=1]
       #Post#: 29201--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: b789
       Date: July 8, 2024, 8:29 pm
       ---------------------------------------------------------
       We can’t see any images so it is difficult to advise. Have you
       followed the instructions in this thread:
       READ THIS FIRST - Private Parking Charges Forum guide
  HTML https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
       There is already a thread on an almost identical situation at
       the location already running. However, in that case the driver
       has a receipt.
       The date the PCN was “received” is irrelevant. The date it was
       “issued” is what counts if the keeper is trying to figure out
       whether they can be liable under PoFA.
       You say you’ve received a “county court letter”. Do you mean an
       N1SDT claim form from the CNBC? If so, did you receive a Letter
       of Claim (LoC) before the claim was issued?
       What is the date of “issue” of the claim form? Has it been
       issued by PE directly or are they using a solicitor, usually DCB
       Legal? The box under the claimants name and address tells you
       who any correspondence should be addressed to.
       Ideally, please show us the claim form redacting only your
       personal details, the VRM, the claim number and the MCOL
       password. Everything else should remain.
       #Post#: 29219--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: Parkingchase
       Date: July 9, 2024, 4:30 am
       ---------------------------------------------------------
       Thanks for your reply b789.
       Attachments now uploaded via imgur. Yesterday this was not
       possible as the server was apparently full and advised to
       contact administrators, see image.
       It's a N1SDT claim form.
       Need to check with the driver that no other letters were
       received.
       Issue date of PCN 27/03/2024
       Issue date of the N1SDT 24/06/2024
       [img]
  HTML https://imgur.com/a/In4bO6z[/img]
  HTML https://imgur.com/a/In4bO6z
  HTML https://imgur.com/a/In4bO6z[img]https://imgur.com/3lMzjCQ[/img][img]https://imgur.com/3lMzjCQ[/img]
       [img]
  HTML https://imgur.com/3lMzjCQ[/img]
       #Post#: 29236--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: b789
       Date: July 9, 2024, 7:27 am
       ---------------------------------------------------------
       With a claim issue date of 24th June, you need to acknowledge
       service (AoS) of the claim by 13th July. Here is a guide on how
       to do that:
  HTML https://www.dropbox.com/scl/fi/gp4lan4cb225p7ajkoy6z/money-claim-online-How-to-Acknowledge.pdf?rlkey=pu8zhuiaxbva4cjdmge72nh4r&e=1&dl=0
       There is no advantage to delaying AoS but by filing it in a
       timely manner, you then have until 4pm on Monday 29th July to
       file your defence. That's almost three weeks away.
       Do not use MCOL to file the defence. Your defence will be filed
       as a PDF attachment by email to the CNBC. Do not use the MCOL
       website to file your defence.
       Here is a link to the template for the defence. You only need to
       state whether you were the keeper, driver, both or neither and
       then add a single paragraph outlining your response to the
       allegation in the PoC.
       There are a couple of additional paragraphs which I will give
       you to put in to the defence as preliminary matters once you've
       shown us the paragraph that is your defence. The rest of the
       template cover everything and must be used.
       Do not write War & Peace. You are answering the woefully
       inadequate PoC. You will expand on everything at a later date
       when it is time for your Witness Statement.
  HTML https://www.dropbox.com/scl/fi/2hnjkuljjr54pvs7m2pte/Updated-defence-Aug2023-4.rtf?rlkey=yzw080l0rw6l41dzv4m0867va&st=ohe4hf1m&dl=0
       We could do with seeing the back of the NtK as PE have failed to
       show what the added £25 in the claim is for. The are in breach
       of PoFA 4(5) in that they are not allowed to claim for more than
       the amount that was on the NtK, which was £100.
       The burden of proof lies with PE to show that the driver didn't
       pay. You say that the driver did. How do you think you can
       evidence that a parent was made? Would their payment machine
       keep a log of all payments made?
       #Post#: 29296--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: Parkingchase
       Date: July 9, 2024, 3:50 pm
       ---------------------------------------------------------
       Thanks.
       Sorry what is NtK and PoC short for?
       So I have checked with the driver and they did indeed receive
       another letter I have attached that one it is also where PE
       claim £25 where added for debt collection.
       Page 1
  HTML https://imgur.com/sGWKmRs
       Page 2 (backside)
  HTML https://imgur.com/HcHXwd8
       Important Note: The driver was not aware of the second letter as
       they were very ill in hospital for an extended period and had
       just been released 2 days prior and were still recovering from
       home when that letter arrived. This could easily be proven as
       they were also off work (rare for the driver) and it will be on
       their patient file somewhere.
       Image of the backside of the PCN (I assume the NtK)
  HTML https://imgur.com/q35e9G8
       Payment was just made with the loose change the driver managed
       to find as they were not expecting to pay the full day fee as it
       was supposed to be the <3hrs.
       Therefore the only evidence would indeed be if the PE machine
       logs payments on a daily basis or weekly basis.
       Would the driver be able to argue that the end of day accounting
       would not have added up correctly on that day when compared with
       the tariffs and timestamps of all the cars on the lot.
       As they definitely inserted more money than PE's system would
       have logged parking time on the ANPR.
       
       (So unless someone else paid too little for their parked time
       the total accounting on that day would have to be around £7
       higher than the total parked time.)
       #Post#: 29298--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: DWMB2
       Date: July 9, 2024, 3:56 pm
       ---------------------------------------------------------
       NtK = Notice to Keeper (the original parking charge notice
       received through the post)
       PoC = Particulars of Claim (bottom left corner of the county
       court claim form)
       You keep referring to the driver, and what he can/cannot argue,
       but the Claim Form suggests that ParkingEye are not suing the
       driver, but instead the Registered Keeper - if that's the case,
       it is the keeper who will be off to court. Has the identity of
       the driver been revealed to ParkingEye at any point in the
       process?
       #Post#: 29299--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: Parkingchase
       Date: July 9, 2024, 4:04 pm
       ---------------------------------------------------------
       Driver has not been identified to PE.
       What happens in these two scenarios Driver = Keeper?
       Driver is not the keeper?
       (Asked both questions to avoid publicly putting information out
       there)
       In addition I reached out to POPLA to confirm there is nothing
       they can do at this point.
       They confirmed they can only become involved if an appeal has
       been reject (issues a 10 digit code).
       As PE website for appeals was not working at the time there was
       no way to obtain a 10 digit code.
       Therefore no POPLA appeal could have been made at the time.
       Would this be a valid argument? Or would the driver/keeper be
       expected to revisit the website frequently until it works again
       to appeal?
       #Post#: 29312--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: b789
       Date: July 9, 2024, 7:43 pm
       ---------------------------------------------------------
       The driver and the keeper are two separate legal entities. A
       person can be either, both or neither. The driver is always the
       person that is liable for the alleged debt. PE have no idea who
       the driver is. If they issue the PCN (an NtK in this case) and
       fully comply with the requirements of PoFA, and the keeper
       doesn’t identify the driver to them, they can transfer the
       liability from the unknown driver to the known keeper.
       As the keeper has not identified the driver, PE are pursuing the
       known keeper… you.
       As the keeper did not appeal the PCN, there was no rejection. A
       POPLA code is only provided with the appeal rejection. A POPLA
       code lasts for 33 days. You cannot appeal to POPLA without a
       code.
       Was any communication initiated with PE about the failure of
       their appeals web portal? Does the NtK mention any other way to
       submit an appeal?
       You could go through the BPA Code of Practice (CoP) as there is
       a clause regarding circumstances when they should re-initiate
       the appeals process. It is also expanded on in the new joint CoP
       with the IPC. There is a link to the new joint CoP on the
       private parking forum home page and there is a link to the BPA
       CoP in [member=103]DWMB2[/member]’s signature.
       #Post#: 29561--------------------------------------------------
       Re: Parking Eye Chase Farm (Carpark: Patient and Visitor 3)
   DIR By: Parkingchase
       Date: July 11, 2024, 5:45 pm
       ---------------------------------------------------------
       Thanks b789.
       Unfortunately the backside of the NtK does state appeals can
       also be made via postal mail.
       The site failure + screenshot was not sent to PE online it is
       near impossible except for a narrow set of predefined topics to
       contact them.
       Further developments:
       - A reply after escalating was finally received from the
       hospitals parking team.
       Will share more details when solid developments come through.
       For now we will assume that everything proceeds as normal with
       the court process as this is already underway.
       Q's after reading the BPA CoP:
       Q1)  23.3 Photographic evidence. Can one try to ask PE for
       photographic evidence of the driver paying? As they would have
       to provide it due to the CoP. As we know the ticket on the day
       was paid this would help clarify (not conclusively of course)
       that PE have no evidence at all that the driver didn't pay.
       Q2) Thinking of defence...there are two signs
  HTML https://imgur.com/B1nbdkQ
       and
  HTML https://imgur.com/gek3EsZ.
       Step 6
       says a receipt is automatically issued. This did not happen.
       On that sign the only contact details are for the telephone
       number which is used to pay fines, you cannot wait and get
       through to someone it ends the call. Could this be part of an
       argument that PE is not reachable in the case of a failure at
       their fully automated carpark. Forcing a driver to leave the
       site without a receipt in case of a malfunction making them
       susceptible to situations such as this one before writing to the
       PO Box. It makes it impossible for them to report failures in
       automation at the scene, which immediately results in a PCN
       being issued.
       Q3) CoP 23.13.a.b) Given the occurrence of a similar case I'm
       sure I saw on another website but that disappeared at the same
       carpark and the other one (where the person has a receipt) on
       this site it would not be surprising if there are far more. Can
       BPA be asked to try and access this information?
       Q4) Finally does anyone know in CoP 7.2 if PE have to ask the
       owners of the private land (I believe the hospital, but would
       need to check that) every single time they want to pursue a
       legal case or just once with a general outline?
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