DIR Return Create A Forum - Home
---------------------------------------------------------
FreeTrafficLegalAdvice
HTML https://ftla.createaforum.com
---------------------------------------------------------
*****************************************************
DIR Return to: Private parking tickets
*****************************************************
#Post#: 63256--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: March 19, 2025, 10:55 am
---------------------------------------------------------
There is a few more pages. Do you want them too?
[attachment deleted by admin]
#Post#: 63257--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: March 19, 2025, 11:00 am
---------------------------------------------------------
HTML https://imgur.com/a/UsF5KnS
All photos are here.
#Post#: 63258--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: b789
Date: March 19, 2025, 11:00 am
---------------------------------------------------------
With an issue date of 11th March, you have until 4pm on Monday
31st March to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Monday 14th April to submit your defence.
If you want to submit an AoS then follow the instructions in
this linked PDF:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Here is the defence and link to the draft order that goes with
it. You only need to edit your name and the claim number. You
sign the defence by typing your full name for the signature and
date it. There is nothing to edit in the draft order.
When you're ready you combine both documents as a single PDF
attachment and send as an attachment in an email to
claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim
number must be in the email subject field and in the body of the
email just put: "Please find attached the defence and draft
order in the matter of National Parking Control Group Ltd v
[your full name] Claim no.: [claim number]."
--- Quote ---
>
> [center]IN THE COUNTY COURT[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> National Parking Control Group Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> DEFENCE[/center]
>
> 1. The Defendant denies the claim in its entirety. The
Defendant asserts that there is no liability to the Claimant and
that no debt is owed. The claim is without merit and does not
adequately disclose any comprehensible cause of action.
>
> 2. There is a lack of precise detail in the Particulars of
Claim (PoC) in respect of the factual and legal allegations made
against the Defendant such that the PoC do not comply with CPR
16.4.
>
> 3. The Defendant is unable to plead properly to the PoC
because:
>
> [indent](a) The contract referred to is not detailed or
attached to the PoC in accordance with CPR PD 16(7.5);
>
> (b) The PoC do not state the exact wording of the clause (or
clauses) of the terms and conditions of the contract (or
contracts) which is/are relied on;
>
> (c) The PoC do not adequately set out the reason (or reasons)
why the claimant asserts the defendant has breached the contract
(or contracts)
>
> (d) The PoC do not state with sufficient particularity
exactly where the breach occurred, the exact time when the
breach occurred and how long it is alleged that the vehicle was
parked before the parking charge was allegedly incurred;
>
> (e) The PoC do not state precisely how the sum claimed is
calculated, including the basis for any statutory interest,
damages, or other charges;
>
> (f) The PoC do not state what proportion of the claim is the
parking charge and what proportion is damages;
>
> (g) The PoC do not provide clarity on whether the Defendant is
sued as the driver or the keeper of the vehicle, as the claimant
cannot plead alternative causes of action without
specificity.[/indent]
>
> 4. The Defendant attaches to this defence a copy of a draft
order approved by a district judge at another court. The court
struck out the claim of its own initiative after determining
that the Particulars of Claim failed to comply with CPR 16.4.
The judge noted that the claimant had failed to:
>
> [indent](i) Set out the exact wording of the clause (or
clauses) of the terms and conditions relied upon;
>
> (ii) Adequately explain the reasons why the defendant was
allegedly in breach of contract;
>
> (iii) Provide separate, detailed Particulars of Claim as
permitted under CPR PD 7C.5.2(2).
>
> (iv) The court further observed that, given the modest sum
claimed, requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, the judge struck out the claim outright rather
> than permitting an amendment.[/indent]
>
> 5. The Defendant submits that the same reasoning applies in
this case and invites the court to adopt a similar approach by
striking out the claim for the Claimant’s failure to comply with
CPR 16.4.
>
> Statement of truth
>
> I believe that the facts stated in this Defence are true. I
understand that proceedings for contempt of court may be brought
against anyone who makes, or causes to be made, a false
statement in a document verified by a statement of truth without
an honest belief in its truth.
>
> Signed:
>
>
> Date:
--- End Quote ---
Draft Order for the defence
HTML https://www.dropbox.com/scl/fi/tcewefk7daozuje25chkl/Strikeout-order-v2.pdf?rlkey=wxnymo8mwcma2jj8xihjm7pdx&st=nbtf0cn6&dl=0
#Post#: 63261--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: March 19, 2025, 11:14 am
---------------------------------------------------------
I don't have the knowledge to represent myself in the court, and
it's quite stressful procedure for me since English is not my
first language. I don't want my words to be taken wrongfully.
That's the first thing I've received after the rejection. I
haven't received anything else.
#Post#: 63264--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: b789
Date: March 19, 2025, 11:19 am
---------------------------------------------------------
As I mentioned, the odds of this actually making it all the way
to a hearing where you'd have to speak in court is less than 1%.
For now, just follow the advice I have given you above.
#Post#: 64975--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: March 31, 2025, 8:51 am
---------------------------------------------------------
I've done everything you've advised me. What is next now?
#Post#: 64986--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: b789
Date: March 31, 2025, 9:32 am
---------------------------------------------------------
You are now waiting for an acknowledgement from the CNBC that
you defence was received and a copy was sent to the claimant.
You will also probably receive a letter from the claimant
stating that they have received a copy of your defence and that
their client intends to proceed. All part of the process.
Next you will receive (possibly with the claimants confirmation
that they intend to proceed) a copy of their N180 Directions
Questionnaire.
Please check your MCOL history shows that your defence was
received.
When you receive the claimants N180, follow these instructions:
--- Quote ---
> Having received your own N180 (make sure it is not simply a
copy of the claimants N180), do not use the paper form. Ignore
all the other forms that came with it. you can discard those.
Download your own here and fill it in on your computer. You sign
it by simply typing your full name in the signature box.
>
>
HTML https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
>
> Here are the answers to some of the less obvious questions:
>
> [indent]• The name of the court is "Civil National Business
Centre".
>
> • To be completed by "Your full name" and you are the
"Defendant".
>
> • C1: "YES"
>
> • D1: "NO". Reason: "I wish to question the Claimant about
their evidence at a hearing in person and to expose omissions
and any misleading or incorrect evidence or assertions.
> Given the Claimant is a firm who complete cut & paste parking
case paperwork for a living, having this case heard solely on
papers would appear to put the Claimant at an unfair advantage,
especially as they would no doubt prefer the Defendant not to
have the opportunity to expose the issues in the Claimants
template submissions or speak as the only true witness to events
in question.."
>
> • F1: Whichever is your nearest county court. Use this to find
it:
HTML https://www.find-court-tribunal.service.gov.uk/search-option
>
> • F3: "1".
>
> • Sign the form by simply typing your full name for the
signature.[/indent]
>
> When you have completed the form, attach it to a single email
addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk
and CC in yourself. Make sure that the claim number is in the
subject field of the email.
--- End Quote ---
#Post#: 70208--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: May 6, 2025, 6:54 am
---------------------------------------------------------
Thank you for your response. I've just received email from the
person who represents the claimant. They attached their N180.
Here is the screenshot of the email and part of their N180.
[attachment deleted by admin]
#Post#: 70411--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: May 7, 2025, 9:17 am
---------------------------------------------------------
Thank you for your response. I've just received email from the
person who represents the claimant. They attached their N180.
Here is the screenshot of the email and part of their N180.
[attachment deleted by admin]
#Post#: 72487--------------------------------------------------
Re: NPC Parking Charge Notice- No NPC e-permit, Greenwich
Millennium Village, SE100X
DIR By: Velina
Date: May 21, 2025, 1:50 am
---------------------------------------------------------
Good morning,
I've just received this letter. I've already filled up N180 form
online when I received email from NPC and send it on the email
that you advise me in the previous comments.
Should I do something else or I should ignore it?
[attachment deleted by admin]
*****************************************************
Page 2 of 4
DIR Previous Page
DIR Next Page