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#Post#: 67209--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: April 15, 2025, 7:50 am
---------------------------------------------------------
Many thanks once again, I will respond to them today.
#Post#: 74525--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: June 3, 2025, 6:24 am
---------------------------------------------------------
Good afternoon,
Further to your previous advice, I have now received a letter
from HM Courts & Tribunals Service, advising that a money claim
has been made against me and that the claimant could request a
CCJ if I do not respond.
I have added the documents to a Google Drive, I would be most
appreciative of your advice please.
HTML https://drive.google.com/file/d/1CqWlezOhd7zUoWDJJSfkLUkUwhfslHpw/view?usp=drive_link
Many thanks.
#Post#: 74544--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: June 3, 2025, 9:17 am
---------------------------------------------------------
Why have you redacted the issue date?Leave ALL dates
visible!!!!!!!!
#Post#: 74554--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: June 3, 2025, 9:44 am
---------------------------------------------------------
Whilst you have redacted the issue date and so I cannot advise
you on deadlines, you should follow the information in this link
to submit the Acknowledgement of Service (AoS) which will extend
your deadline to submit a defence to 33 days plus any weekend or
bank holidays if day 33 is one of those:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Also, here is the defence you need to submit. I will discuss
other aspects of this later. For now 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 Vehicle Control Services Ltd v [your full
name] Claim no.: [claim number]."
--- Quote ---
> [center]IN THE COUNTY COURT[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> Vehicle Control Services 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#: 74558--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: June 3, 2025, 10:07 am
---------------------------------------------------------
DCB Legal were explicitly warned in oyur response to their
Letter of Claim that if they issued a claim based on PoFA
liability at Bristol Airport, and continued to pursue a keeper
with no evidence of driver identity, a formal complaint would be
submitted to the Solicitors Regulation Authority (SRA).
They have now issued a claim regardless, without engaging with
the legal arguments raised, and without providing a valid basis
for doing so. This confirms that their behaviour was not a
mistake or oversight, but a deliberate decision to press ahead
with a claim they know to be legally defective.
You should therefore prepare a formal SRA complaint setting out:
[indent]• That PoFA does not apply at Bristol Airport
(non-relevant land).
• That the Defendant has never been identified as the driver.
• hat DCB Legal have relied on a misstatement of the law in
claiming the keeper is liable based on “the balance of
probabilities”.
• That the particulars of claim are vague and fail to comply
with CPR 16.4 and PD16.
• That the claim includes inflated and unrecoverable “damages”
in breach of established case law (e.g. Britannia v
Semark-Jullien).
• That this conduct breaches multiple SRA Principles,
particularly those relating to integrity, honesty, and upholding
the rule of law.[/indent]
The complaint will include a copy of your original Letter of
Claim response to show that DCB Legal were put on notice and
chose to proceed regardless.
This is now necessary both to protect the Defendant and to
discourage similar conduct by DCB Legal in other cases.
To report DCB Legal Ltd to the Solicitors Regulation Authority
(SRA) for potential breaches of professional conduct, you can
use the SRA's official report form. This form allows you to
detail your concerns and provide any supporting evidence.
Visit the SRA's "Reporting a solicitor or firm to us" page:
HTML https://www.sra.org.uk/consumers/problems/report-solicitor/
Download the report form and submit the completed form by email
to report@sra.org.uk and CC in yourself.
Information to Include:
[indent]• The name and address of the solicitor or firm you're
reporting (DCB Legal Ltd).
• A clear description of your concerns, including dates and
details of the alleged misconduct.
• Copies of any relevant documents, such as correspondence or
court papers.
• Your contact details for any follow-up.[/indent]
After receiving your complaint, the SRA will assess the
information provided and determine whether to initiate an
investigation. They may contact you for further details during
this process.
Here is the substance of your complaint:
--- Quote ---
> I am submitting this complaint about DCB Legal Ltd for serious
breaches of the SRA Principles in the way they have conducted
litigation against me.
>
> DCB Legal issued a court claim despite having received a
detailed response to their Letter of Claim, which clearly raised
multiple legal objections and evidential challenges. They did
not respond to or engage with any of the issues raised. They
simply proceeded to issue a claim without explanation.
>
> This is a direct breach of the Pre-Action Protocol for Debt
Claims, which requires parties — especially professional
representatives — to engage meaningfully and proportionately
with pre-action correspondence. The PAPDC specifically requires
a full and considered reply to any substantive issues raised.
DCB Legal ignored that entirely.
>
> Their failure to respond was not an oversight. They were
explicitly warned that if they issued a claim without addressing
the points raised, the matter would be referred to the SRA. They
ignored that warning too.
>
> Their conduct shows disregard for their obligations under the
SRA Principles, including:
>
> [indent]• Principle 1: Upholding the rule of law and proper
administration of justice
> • Principle 4: Acting with honesty
> • Principle 5: Acting with integrity
> • Principle 7: Acting in the best interests of their client
and not misusing the court process[/indent]
>
> This is not simply a civil dispute. It is a regulatory issue
about the professional conduct of a firm that routinely issues
claims without properly assessing the legal basis or responding
to pre-action challenges. I ask that the SRA investigate whether
this is part of a wider pattern and whether DCB Legal are
complying with their professional duties.
--- End Quote ---
#Post#: 74560--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: June 3, 2025, 10:11 am
---------------------------------------------------------
Thank you, the date of issue was 30th May 2025.
Thank you for all of the advice, which I shall now follow.
#Post#: 74578--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: June 3, 2025, 11:50 am
---------------------------------------------------------
With an issue date of 30th May, you have until 4pm on Wednesday
18th June to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Wednesday 2nd July to submit your defence.
#Post#: 74605--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: June 3, 2025, 12:59 pm
---------------------------------------------------------
Thank you, much appreciated.
#Post#: 82299--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: July 23, 2025, 6:18 am
---------------------------------------------------------
Good afternoon,
I have today received the email below from DCB Legal, informing
me that their client intends to proceed with the claim and
encouraging me to settle, together with a copy of their
Directions questionnaire, a copy of which I can post here if
required. The DQ only contains their details and none of mine,
other than the claim number. I presume next steps is to wait to
hear further from them, since I have no intention of settling
with them. Any advice greatly received, as always, many thanks.
------------------------------------------------
Good morning
Having reviewed the content of your defence, we write to inform
you that our client intends to proceed with the claim.
In due course, the Court will direct both parties to each file a
directions questionnaire. In preparation for that, please find
attached a copy of the Claimant's, which we confirm has been
filed with the Court.
Without Prejudice to the above, in order to assist the Court in
achieving its overriding objective, our client may be prepared
to settle this case - in the event you wish to discuss
settlement, please call us on 0203 434 0433 within 7 days and
make immediate reference to this correspondence.
If you have provided an email address within your Defence, we
intend to use it for service of documents (usually in PDF
format) hereon in pursuant to PD 6A (4.1)(2)(c). Please advise
whether there are any limitations to this (for example, the
format in which documents are to be sent and the maximum size of
attachments that may be received). Unless you advise otherwise,
we will assume not.
Kind Regards,
xxx
Collections Associate
DCB Legal Ltd
#Post#: 82301--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: July 23, 2025, 6:22 am
---------------------------------------------------------
It's all standard boilerplate stuff. Just follow the
instructions below for filing your own N180 DQ.
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.
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