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       #Post#: 35566--------------------------------------------------
       New court claim issued - 28th Aug
   DIR By: cm790
       Date: September 4, 2024, 2:43 am
       ---------------------------------------------------------
       Good morning everyone, long time Pepipoo user and I had a long
       thread running on there about my PCN. I've been advised to join
       this forum so thank you in advance, I appreciate your support
       and time to read this.
       I've had a long running PCN which I've ignored since the
       original appeal. However, I've now had a court claim through the
       post, dated 28th Aug.
       Back in 2020 I complained to POPLA and the assessor upheld the
       complaint.
       I complained to POPLA's complaints team about the assessor on
       this basis:
       --- Quote ---
       > This appeal must be allowed because the operator Euro Car
       Parks failed to deliver a notice to hirer that was fully
       compliant with the requirements of paragraph 14 of Schedule 4 of
       the Protection of Freedoms Act (PoFA) 2012, which is relevant to
       the hirer and operator. The assessor appears to be mistakenly
       using POFA 13 for the operator/hirer relationship. The operator
       has not shown that the individual it is pursuing is the driver
       of the vehicle and potentially liable for the charge. I have
       referred to the right to not name the name and keeper liability.
       A notice to hirer was sent to the appellant on 11/06/2020, this
       was after a PCN was issued to the hire company on 27/05/2020.
       The operator has failed to provide evidence which shows that the
       appellant had signed a statement of liability when he hired the
       vehicle and that this was sent along with the PCN. The assessor
       has completely ignored the requirement to supply the hire
       agreement and notice to keeper with the notice to hirer.
       >
       > The assessor has used the phrase “registered hirer” in their
       response, I would ask what meaning does this have in the context
       of this case as it is not clear as to what he means. The
       registered hirer could not possibly be the registered keeper as
       this role is taken by the hire company, more clarity is needed
       by the assessor and I would hasten to say more training. I feel
       that the lead assessor in this matter has erred in the
       interpretation of law, it must be reviewed and the decision
       amended to one of an upholding of the appeal.
       --- End Quote ---
       I then received this response from the complaint's team:
       --- Quote ---
       > I note within your grounds of appeal you stated:
       >
       > “1) The Operator failed to deliver a Notice to Hirer that was
       fully compliant with the requirements of Schedule 4 of the
       Protection of Freedoms Act 2012 (“POFA”).”
       >
       > You raised concerns about hirer liability. As you have not
       identified as the driver, the operator can only seek to hold you
       responsible for the PCN under hirer liability.
       >
       > Having reviewed the operator’s evidence, I can see that the
       operator is holding you responsible for the PCN. In its evidence
       it states that you identified as the driver, then you declined
       to identify the driver, so it is holding you responsible as
       hirer. I also note that you did not identify as the driver.
       >
       > As such the assessor was required to review the relevant
       sections of PoFA2012 that applied.
       >
       > Schedule 4 Paragraph 14 of PoFA 2012 states:
       >
       > “(2) The conditions are that—
       >
       > (a)the creditor has within the relevant period given the hirer
       a notice in accordance with sub-paragraph (5) (a “notice to
       hirer”), together with a copy of the documents mentioned in
       paragraph 13(2) and the notice to keeper;”
       >
       > Paragraph 13 (2) OF PoFA 2012 states:
       >
       > “The creditor may not exercise the right under paragraph 4 to
       recover from the keeper any unpaid parking charges specified in
       the notice to keeper if, within the period of 28 days beginning
       with the day after that on which that notice was given, the
       creditor is given—
       >
       > (a)a statement signed by or on behalf of the vehicle-hire firm
       to the effect that at the material time the vehicle was hired to
       a named person under a hire agreement;
       >
       > (b)a copy of the hire agreement; and
       >
       > (c)a copy of a statement of liability signed by the hirer
       under that hire agreement.”
       >
       > Having viewed the operator’s evidence I can see that the
       operator has not provided any documents.
       >
       > The assessor within their grounds of appeal was satisfied that
       hirer liability was met when assessing this appeal. Whilst this
       is not the decision I would have made personally; the assessor
       has considered all evidence and ultimately made an incorrect
       judgement call. The assessor has not made a procedural error and
       as such the case would not need reassessing.
       >
       > I have taken your feedback on board and forwarded this to the
       assessor’s team leader for coaching purposes and have upheld
       this complaint.
       --- End Quote ---
       I ignored the letters I received subsequently and as much as I
       have fought up until this point, I'd be really grateful for a
       little guidance on the next steps based on the information above
       please.
       Happy to provide any redacted docs necessary.
       Thanks :)
       #Post#: 35570--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: b789
       Date: September 4, 2024, 3:42 am
       ---------------------------------------------------------
       POPLA are slightly better now at interpreting POPLA. However, as
       you have seen, they will never reverse a decision once made,
       irrespective of whether they erred.
       Never mind. The ultimate dispute resolution service is the small
       claims track in the county court. You appear to be at this
       stage.
       Have you received an N1SDT claim form from the CNBC? If so, what
       is the “issue date” on it. Also, who is the Claimant and, if
       they’re using one, the solicitor?
       Please show us the Particulars of Claim (PoC).
       As I’m not familiar with this case from Pepipoo, I don’t need
       any more details at this point as I would like to see the PoC
       for CPR 16.4 failures of compliance and whether it is even
       possible to understand what happened and the basis of thei
       claim.
       #Post#: 35573--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: cm790
       Date: September 4, 2024, 3:55 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > POPLA are slightly better now at interpreting POPLA. However,
       as you have seen, they will never reverse a decision once made,
       irrespective of whether they erred.
       >
       > Never mind. The ultimate dispute resolution service is the
       small claims track in the county court. You appear to be at this
       stage.
       >
       > Have you received an N1SDT claim form from the CNBC? If so,
       what is the “issue date” on it. Also, who is the Claimant and,
       if they’re using one, the solicitor?
       >
       > Please show us the Particulars of Claim (PoC).
       >
       > As I’m not familiar with this case from Pepipoo, I don’t need
       any more details at this point as I would like to see the PoC
       for CPR 16.4 failures of compliance and whether it is even
       possible to understand what happened and the basis of thei
       claim.
       >
       --- End Quote ---
       --- Quote from: b789 link ---
       >
       > POPLA are slightly better now at interpreting POPLA. However,
       as you have seen, they will never reverse a decision once made,
       irrespective of whether they erred.
       >
       > Never mind. The ultimate dispute resolution service is the
       small claims track in the county court. You appear to be at this
       stage.
       >
       > Have you received an N1SDT claim form from the CNBC? If so,
       what is the “issue date” on it. Also, who is the Claimant and,
       if they’re using one, the solicitor?
       >
       > Please show us the Particulars of Claim (PoC).
       >
       > As I’m not familiar with this case from Pepipoo, I don’t need
       any more details at this point as I would like to see the PoC
       for CPR 16.4 failures of compliance and whether it is even
       possible to understand what happened and the basis of thei
       claim.
       >
       --- End Quote ---
       Thanks for the prompt response.
       Here is the claim form. The issue date is 28th Aug, I've been
       away and just returned last night to the letter.
  HTML https://emergencyservicechallenge.co.uk/wp-content/uploads/2024/09/Claim-form-front-page.png
       #Post#: 35581--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: b789
       Date: September 4, 2024, 4:25 am
       ---------------------------------------------------------
       With an issue date of 28th August, you have until Monday 16th
       September to file your Acknowledgement of Service (AoS). To file
       your AoS, follow the advice in this document:
  HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
       There is no advantage in delaying the AoS and once filed, you
       then have until 4pm on Monday 30th September to file your
       defence. Do not file your defence using the MCOL website. It
       will be filed as a PDF attachment to an email to
       claimresponses.cnbc@justice.gov.uk and CC in yourself.
       Please show us exactly the location of the car park as shown 9n
       the claim form in the Particulars of Claim (PoC).
       We will get back to you with some suggestions for your defence
       once you can confirm that you have completed the AoS.
       #Post#: 35819--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: cm790
       Date: September 5, 2024, 1:17 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > With an issue date of 28th August, you have until Monday 16th
       September to file your Acknowledgement of Service (AoS). To file
       your AoS, follow the advice in this document:
       >
       >
  HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
       >
       > There is no advantage in delaying the AoS and once filed, you
       then have until 4pm on Monday 30th September to file your
       defence. Do not file your defence using the MCOL website. It
       will be filed as a PDF attachment to an email to
       claimresponses.cnbc@justice.gov.uk and CC in yourself.
       >
       > Please show us exactly the location of the car park as shown
       9n the claim form in the Particulars of Claim (PoC).
       >
       > We will get back to you with some suggestions for your defence
       once you can confirm that you have completed the AoS.
       >
       --- End Quote ---
       Sorry, I've looked over this form and I don't see a 9N.
       I just have:
       N1SDT
       N9SDT
       N9A
       N9B
       In my pack.
       #Post#: 35820--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: DWMB2
       Date: September 5, 2024, 1:18 pm
       ---------------------------------------------------------
       It should say "as shown in the claim form".
       #Post#: 35821--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: cm790
       Date: September 5, 2024, 1:33 pm
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > It should say "as shown in the claim form".
       >
       --- End Quote ---
       The location is The Meadows Retail Park Chelmsford.
       I just read my appeal back, and it was very thorough at the
       time. I've started building my defence document from this
       template.
       --- Quote ---
       > IN THE COUNTY COURT
       >
       > Claim No.:  xxxxxx
       >
       > Between
       >
       > Full name of parking firm Ltd, not the solicitor!
       >
       > (Claimant)
       >
       > - and -
       >
       > Defendant named on claim (can’t be changed to driver now)
       >
       > (Defendant)
       >
       > _________________
       >
       > DEFENCE
       >
       >
       >
       > 1.  The Defendant denies that the Claimant is entitled to
       relief in the sum claimed, or at all.  It is denied that any
       conduct by the driver was in breach of any term.  Further, it is
       denied that this Claimant (understood to have a bare licence as
       agents) has standing to sue or form contracts in their own name.
       Liability is denied, whether or not the Claimant is claiming
       'keeper liability', which is unclear from the boilerplate text
       in the Particulars of Claim ('the POC').
       >
       >
       >
       > The facts known to the Defendant:
       >
       > 2. The facts in this defence come from the Defendant's own
       knowledge and honest belief.  Conversely, the Claimant sets out
       a cut-and-paste incoherent and sparse statement of case. The POC
       appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to
       "state all facts necessary for the purpose of formulating a
       complete cause of action". The Defendant is unable, on the basis
       of the POC, to understand with certainty what case,
       allegation(s) and what heads of cost are being pursued, making
       it difficult to respond. However, the vehicle is recognised and
       it is admitted that the Defendant was the registered keeper.
       >
       > ^EDIT THIS PARAGRAPH If you weredriving, add 'and driver'
       after the word 'keeper'.
       >
       > OR if the Defendant doesn't know who was driving, say that.
       >
       > OR deny being the driver if you weren't: ONLY IF TRUE!
       >
       >
       >
       > 3. [EXPLAIN IN YOUR OWN WORDS...NB: defences are written in
       the THIRD person as 'the Defendant', not 'I did this' nor
       'my/me'].
       >
       > Say why the car was there - if you know - but don't answer to
       details that are not stated in the PARTICULARS OF CLAIM. If you
       didn't get any letters or it was years ago & you can't recall if
       you were driving, say that.  ONLY IF TRUE.
       >
       > Most claims do not even state the alleged breach. If yours
       doesn't state what the breach was, add the paragraphs and
       judgments seen in the defence by @hharry100  here:
       >
       >
  HTML https://forums.moneysavingexpert.com/discussion/comment/80343627/#Comment_80343627
       >
       > and change the paragraph numbering.
       >
       > If this was a residential site where the driver lives/was a
       permitted visitor, statethose parking rights.
       >
       > Older residential defence examples are in the NEWBIES thread.
       CRIB SOME PARAGRAPHS BUT USE THIS TEMPLATE AS YOUR BASE.
       >
       > We recommend you continue with this wording  (yes, all of it.
       Paragraphs suitably re-numbered to allow for the above).
       >
       >
       >
       > 4. The Claimant will concede that no financial loss has arisen
       and that in order to impose an inflated parking charge, as well
       as proving a term was breached, there must be:
       >
       > (i). a strong 'legitimate interest' extending beyond mere
       compensation for loss, and
       >
       > (Ii). 'adequate notice' of the 'penalty clause' charge which,
       in the case of a car park, requires prominent signs and lines.
       >
       > 5. The Defendant denies (i) or (ii) have been met. The charge
       imposed, in all the circumstances is a penalty, not saved by
       ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case'), which
       is fully distinguished.
       >
       >
       > Exaggerated Claim and 'market failure' currently being
       addressed by UK Government
       > 6. The alleged 'core debt' from any parking charge cannot
       exceed £100 (the industry cap).  It is denied that any 'Debt
       Fees' or damages were actually paid or incurred.
       >
       > 7. This claim is unfair and inflated and it is denied that any
       sum is due in debt or damages. This Claimant routinely pursues
       an unconscionable fixed sum added per PCN, despite knowing that
       the will of Parliament is to ban it.
       >
       > 8. This is a classic example where adding exaggerated fees
       funds bulk litigation of weak and/or archive parking cases. No
       checks and balances are likely to have been made to ensure
       facts, merit or a cause of action (given away by the woefully
       inadequate POC).
       >
       > 9. The Department for Levelling Up, Housing and Communities
       ('the DLUHC') published a statutory Parking Code of Practice in
       February 2022:
  HTML https://www.gov.uk/government/publications/private-parking-code-of-practice.
       >
       > The Ministerial Foreword is damning: "Private firms issue
       roughly 22,000 parking tickets every day, often adopting a
       labyrinthine system of misleading and confusing signage, opaque
       appeals services, aggressive debt collection and unreasonable
       fees designed to extort money from motorists."
       >
       > 10. Despite legal challenges delaying the Code (temporarily
       withdrawn) it is now 'live' after a draft Impact Assessment (IA)
       was published on 30th July 2023. The Government's analysis is
       found here:
  HTML https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1171438/Draft_IA_-_Private_Parking_Code_of_Practice_.pdf
       >
       > 11. Paragraphs 4.31 and 5.19 state that the parking industry
       has shown the DLUHC that the true minor cost of pre-action stage
       totals a mere £8.42 per case (not per PCN).
       >
       > 12. This claim has been enhanced by a disproportionate sum,
       believed to enrich the litigating legal team. It appears to be
       double recovery, duplicating the intended 'legal fees' cap set
       by small claims track rules.
       >
       > 13. The draft IA shows that the intimidating letter-chains
       endured by Defendants cost 'eight times less' than the  fixed
       +£70 per PCN. This causes immense consumer harm in the form of
       some half a million wrongly-enhanced CCJs each year, that Judges
       are powerless to prevent.  MoJ statistics reveal several hundred
       thousand parking claims per annum, with c90% causing default
       CCJs totalling hundreds of millions of pounds. The false fee was
       enabled by the self-serving Codes of Practice of the rival
       parking Trade Bodies who aligned in 2021 to allow +£70, each led
       by a Board comprising the parking and debt firms who stood to
       gain from it.
       >
       > 14. It is denied that the added damages/fee sought was
       incurred or is recoverable. Attention is drawn to paras 98, 100,
       193, 198 of Beavis.  Also ParkingEye Ltd v Somerfield Stores Ltd
       ChD [2011] EWHC 4023(QB) where the parking charge was £75,
       discounted to £37.50 for prompt payment.  Whilst £75 was
       reasonable, HHJ Hegarty (decision ratified by the CoA) held in
       paras 419-428 that 'admin costs' inflating a PCN to £135
       exaggerated the cost of template letters and 'would appear to be
       penal'.
       >
       > 15. This Claimant has not incurred costs. A PCN model already
       includes what the Supreme Court called an 'automated
       letter-chain' and it generates a healthy profit. In Beavis,
       there were 4 pre-action letters/reminders and £85 was held to
       more than cover the minor costs of the operation (NB: debt
       collectors charge nothing in failed collection cases).
       >
       > 16. Whilst the new Code is not retrospective, all non-monetary
       clauses went unchallenged. It will replace the self-serving BPA
       & IPC Codes, which are not regulation and carry limited weight.
       It is surely a clear steer for the Courts that the DLUHC said in
       2023 that it is addressing 'market failure'.
       >
       > 17. At last, the DLUHC's analysis overrides plainly wrong
       findings by Circuit Judges steered by Counsel in weak appeal
       cases that the parking industry steamrollered through. In
       Vehicle Control Services v Percy, HHJ Saffman took a
       diametrically opposed position to that taken by DJ Hickinbottom,
       DJ Jackson (as Her Honour Judge Jackson then was), and other
       District Judges on the North Eastern Circuit, including DJ
       Skalskyj-Reynolds and DJ Wright (Skipton) all of whom have
       consistently dismissed extortionate added 'fees/damages'.
       District Judges deal with private parking claims on a daily
       basis, whereas cases of this nature come before Circuit Judges
       infrequently. The Judgments of HHJ Parkes in Britannia v
       Semark-Jullien, and HHJ Simpkiss in One Parking Solution v
       Wilshaw were flawed. These supposedly persuasive judgments
       included a universal failure to consider the court's duty under
       s71 of the CRA 2015 and factual errors. In Wilshaw: a badly
       outdated reliance on 'ticket cases' which allowed poor signage
       to escape fair scrutiny and a wrong presumption that landowner
       authority 'is not required' (DVLA rules make it mandatory). In
       Percy, HHJ Saffman made an incorrect assumption about pre-action
       costs and even sought out the wrong Code of Practice of his own
       volition after the hearing, and used it to inform his judgment.
       >
       > 18. In addition, pursuant to Schedule 4 paragraph 4(5) of the
       Protection of Freedoms Act 2012 ('the POFA') the sum claimed
       exceeds the maximum potentially recoverable from a registered
       keeper. The Claimant is put to strict proof of POFA compliance
       if seeking 'keeper liability'.
       >
       > 19. The Defendant avers that there was no agreement to pay a
       parking charge or added 'damages' which were not even incurred,
       let alone quantified in bold, prominent text. This Claimant's
       lack of large, readable signs are nothing like the yellow &
       black warnings seen in Beavis, nor do they meet the signage
       requirements in the DLUHC Code which reflects the already
       statutory requirement for 'prominence' (Consumer Rights Act 2015
       - the 'CRA').
       >
       > CRA breaches
       >
       > 20. Section 71 CRA creates a statutory duty upon Courts to
       consider the test of fairness whether a party raises it or not.
       Further, claiming costs on an indemnity basis is unfair, per the
       Unfair Contract Terms Guidance (CMA37, para 5.14.3):
       >
       >
  HTML https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/450440/Unfair_Terms_Main_Guidance.pdf
       >
       > 21. The CRA introduced new requirements for 'prominence' of
       both terms and 'consumer notices'.  In a parking context, this
       includes a test of fairness and clarity of 'signs & lines' and
       all communications (written or otherwise). Signs must be
       prominent (lit in hours of darkness/dusk) and all terms must be
       unambiguous and contractual obligations clear.
       >
       > 22.  The Defendant avers that the CRA has been breached due to
       unfair/unclear terms and notices, pursuant to s62 and paying
       regard to examples 6, 10, 14 & 18 of Schedule 2 and the duties
       of fair/open dealing and good faith (NB: this does not
       necessarily mean there has to be a finding of bad faith).
       >
       > ParkingEye v Beavis is distinguished
       >
       > 23.  Unlike in Beavis, the penalty rule remains engaged. The
       CRA covers disproportionate sums, which are not exempt from
       being assessed for fairness because a 'fee' is not the core
       price term and neither was it prominently proclaimed on the
       signs.
       >
       > 24. The Supreme Court held that deterrence is likely to be
       penal if there is a lack of a 'legitimate interest' in
       performance extending beyond the prospect of compensation
       flowing directly from alleged breach.  The intention cannot be
       to punish a driver, nor to present them with hidden terms or
       cumbersome obligations ('concealed pitfalls or traps').  This
       Claimant has failed those tests, with small signs, hidden terms
       and minuscule small print that is incapable of binding a driver.
       Court of Appeal authorities about a lack of ‘adequate notice’ of
       a parking charge include:
       >
       > (i) Spurling v Bradshaw [1956] 1 WLR 461 (Lord Denning's ‘red
       hand rule’) and
       >
       > (ii) Thornton v Shoe Lane Parking Ltd [1970] EWCA Civ2,
       >
       > both leading authorities that a clause cannot be incorporated
       after a contract has been concluded; and
       >
       > (iii) Vine v London Borough of Waltham Forest: CA 5 Apr 2000,
       where Ms Vine won because it was held that she had not seen the
       terms by which she would later be bound, due to "the absence of
       any notice on the wall opposite the parking space''.
       >
       > 25.  Fairness and clarity of terms and notices are paramount
       in the DLUHC Code and these clauses are supported by the BPA &
       IPC. In the official publication 'Parking Review' the IPC's CEO
       observed: "Any regulation or instruction either has clarity or
       it doesn’t. If it’s clear to one person but not another, there
       is no clarity. The same is true for fairness. Something that is
       fair, by definition, has to be all-inclusive of all parties
       involved – it’s either fair or it isn’t."
       >
       > Lack of standing or landowner authority, and lack of ADR
       >
       > 26. DVLA data is only supplied if there is an agreement
       flowing from the landholder (ref: KADOE rules). It is not
       accepted that this Claimant (an agent of a principal) has
       authority to form contracts at this site in their name. The
       Claimant is put to strict proof of their standing to litigate.
       >
       > 27. The Claimant failed to offer a genuinely independent
       Alternative Dispute Resolution (ADR). The DLUHC Code shows that
       genuine disputes such as this should see PCNs cancelled, had a
       fair ADR existed. The rival Trade Bodies' time-limited and
       opaque 'appeals' services fail to properly consider facts or
       rules of law and reject most disputes: e.g. the IAS upheld
       appeals in a woeful 4% of decided cases (ref: Annual Report).
       This consumer blame culture and reliance upon their own 'appeals
       service' (described by MPs as a kangaroo court and about to be
       replaced by the Government) should satisfy Judges that a fair
       appeal was never on offer.
       >
       > Conclusion
       >
       > 28. There is now evidence to support the view - long held by
       many District Judges - that these are knowingly exaggerated
       claims that are causing consumer harm.  The July 2023 DLUHC IA
       analysis shows that the usual letter-chain costs eight times
       less than the sum claimed for it.  The claim is entirely without
       merit and the POC embarrassing.  The Defendant believes that it
       is in the public interest that poorly pleaded claims like this
       should be struck out.
       >
       > 29. In the matter of costs, the Defendant seeks:
       >
       > (a) standard witness costs for attendance at Court, pursuant
       to CPR 27.14, and
       >
       > (b) a finding of unreasonable conduct by this Claimant, and
       further costs pursuant to CPR 46.5.
       >
       > 30.  Attention is drawn to the (often-seen) distinct
       possibility of an unreasonably late Notice of Discontinuance.
       Whilst CPR r.38.6 states that the Claimant is liable for the
       Defendant's costs after discontinuance (r.38.6(1)) this does not
       'normally' apply to claims allocated to the small claims track
       (r.38.6(3)). However, the White Book states (annotation 38.6.1):
       "Note that the normal rule as to costs does not apply if a
       claimant in a case allocated to the small claims track serves a
       notice of discontinuance although it might be contended that
       costs should be awarded if a party has behaved unreasonably
       (r.27.14(2)(dg))."
       >
       >
       >
       > 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.
       >
       > Signature:
       >
       > Date:
       --- End Quote ---
       #Post#: 35824--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: cm790
       Date: September 5, 2024, 2:02 pm
       ---------------------------------------------------------
       These were my reasons on my appeal to POPLA.
       1) The Operator failed to deliver a Notice to Hirer that was
       fully compliant with the
       requirements of Schedule 4 of the Protection of Freedoms Act
       2012 (“POFA”).
       2) The signs in this car park are not prominent, clear or
       legible from all parking space and
       there is insufficient notice of the sum of the parking
       charge itself. The car park has a
       sign that is completely missing which I evidence with a
       photograph.
       3) There is no evidence to show that the ANPR is reliable.
       4) The operator has not shown that the individual who it is
       pursuing is in fact the driver
       who was liable for the charge.
       5) No evidence of Landowner Authority - the operator is put to
       strict proof of full
       compliance with the BPA Code of Practice.
       6) Vehicle Images contained in PCN: BPA Code of Practice -
       non-compliance.
       7) The Signs Fail to Transparently Warn Drivers of what the ANPR
       Data will be used for.
       Re point number 2, the side that the vehicle was parked on, the
       sign had completely fallen off of on to the floor.
       #Post#: 35840--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: H C Andersen
       Date: September 5, 2024, 4:27 pm
       ---------------------------------------------------------
       It's verbiage, waffle. Lacks any coherence and what's more
       you've no understanding of the matters.
       Why you want to cast doubt on who was driving by giving such
       apparent eye-witness views with such clarity regarding signs
       I've no idea.
       The LAW.
       If the claimant wants to hold the hirer liable in lieu of the
       keeper then the keeper and claimant must comply with PoFA.
       As regards the keeper:
       To challenge their liability by providing the prescribed docs in
       s13.
       As regards the claimant:
       To issue an in-time notice to the hirer which includes mandatory
       info and is accompanied by the specified docs which ARE NOT just
       those in s13 but include the original PCN.
       Have both parties complied?
       This is not about codes of practice but the law. Keep it short
       and to the point IMO.
       Plus, IMO you could ask for the court to strike out the claim by
       virtue of not being brought in a timely manner.
       6 years is not a target, it's the ultimate limit. The claimant
       in this case was fully aware of all relevant info after POPLA's
       decision was served in 2020, 4 years ago. The only apparent
       purpose in delaying pursuing their claim would seem to be to
       hope that the defendant had moved or forgotten matters or died
       or whatever such that they might obtain a default judgment.
       Luckily for you, you were still at the same address and received
       their claim, otherwise you could have found yourself subject to
       a default judgment.
       #Post#: 35844--------------------------------------------------
       Re: New court claim issued - 28th Aug
   DIR By: cm790
       Date: September 5, 2024, 4:54 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > It's verbiage, waffle. Lacks any coherence and what's more
       you've no understanding of the matters.
       >
       > Why you want to cast doubt on who was driving by giving such
       apparent eye-witness views with such clarity regarding signs
       I've no idea.
       >
       > The LAW.
       >
       > If the claimant wants to hold the hirer liable in lieu of the
       keeper then the keeper and claimant must comply with PoFA.
       >
       > As regards the keeper:
       > To challenge their liability by providing the prescribed docs
       in s13.
       >
       > As regards the claimant:
       > To issue an in-time notice to the hirer which includes
       mandatory info and is accompanied by the specified docs which
       ARE NOT just those in s13 but include the original PCN.
       >
       > Have both parties complied?
       >
       > This is not about codes of practice but the law. Keep it short
       and to the point IMO.
       >
       > Plus, IMO you could ask for the court to strike out the claim
       by virtue of not being brought in a timely manner.
       >
       > 6 years is not a target, it's the ultimate limit. The claimant
       in this case was fully aware of all relevant info after POPLA's
       decision was served in 2020, 4 years ago. The only apparent
       purpose in delaying pursuing their claim would seem to be to
       hope that the defendant had moved or forgotten matters or died
       or whatever such that they might obtain a default judgment.
       Luckily for you, you were still at the same address and received
       their claim, otherwise you could have found yourself subject to
       a default judgment.
       >
       --- End Quote ---
       With respect, like most people in my position, we rely on the
       good nature of people like yourselves for advice. I'm grateful,
       but I'm also not an expert. I try my best to tell these
       companies to stick it, just like the rest.
       This was my explanation of point 1) The Operator failed to
       deliver a Notice to Hirer that was fully compliant with the
       requirements of Schedule 4 of the Protection of Freedoms Act
       2012 (POFA).
       --- Quote ---
       > In order to rely upon POFA to claim unpaid parking charges
       from a vehicle’s hirer, an operator
       > must deliver a Notice to Hirer in full compliance with POFA’s
       strict requirements. In this instance,
       > the Operator’s Notice to Hirer did not comply.
       > The relevant provisions concerning hire vehicles are set out
       in Paragraphs 13 and 14 of
       > Schedule 4 of POFA with the conditions that the Creditor must
       meet in order to be able to hold
       > the hirer liable for the charge being set out in Paragraph 14.
       > Paragraph 14(2) (a) specifies that in addition to delivering a
       Notice to Hirer within the relevant
       > period, the Creditor must also provide the Hirer with a copy
       of the documents mentioned in
       > Paragraph 13(2) (i.e. (a) a statement signed by or on behalf
       of the vehicle-hire firm to the effect
       > that at the material time the vehicle was hired to a named
       person under a hire agreement; (b) a
       > copy of the hire agreement; and (c) a copy of a statement of
       liability signed by the hirer under
       > that hire agreement), together with a copy of the Notice to
       Keeper (i.e. the notice that had
       > originally been sent to the lease company (as Registered
       Keeper)). The Operator did not
       > provide me with copies of any of these documents.
       > Should the Operator try to suggest that there is any other
       method whereby a vehicle’s keeper
       > (or hirer) can be held liable for a charge where a driver is
       not identified, I draw POPLA’s
       > attention to the guidance given to operators in POPLA's 2015
       Annual Report by Henry
       > Greenslade, Chief Adjudicator in which he reminded them of a
       keeper's (or hirer's) right not to
       > name the driver whilst still not being held liable for an
       unpaid parking charge under Schedule 4
       > of POFA. Although I trust that POPLA's assessors are already
       very familiar with the contents of
       > this report, for ease of reference I set out a link as
       follows:
       >
  HTML https://assets.ctfassets.net/jsycjdw1p8kq/1BbHkInc8M97VAxJjjasLe/
       > b6ac462cf8916a04597fa65628a53726/popla_annualreport_2015.pdf
       > I draw POPLA’s particular attention to the section entitled
       “Keeper Liability” in which Mr.
       > Greenslade explains that:
       > “There appears to be continuing misunderstanding about
       Schedule 4. Provided certain
       > conditions are strictly complied with, it provides for
       recovery of unpaid parking charges from
       > the keeper of the vehicle.......
       > .......... However keeper information is obtained, there is no
       ‘reasonable presumption’ in law
       > that the registered keeper of a vehicle is the driver.
       Operators should never suggest anything
       > of the sort. Further, a failure by the recipient of a notice
       issued under Schedule 4 to name the
       > driver does not of itself mean that the recipient has accepted
       that they were the driver at the
       > material time. Unlike, for example, a Notice of Intended
       Prosecution where details of the driver
       > of a vehicle must be supplied when requested by the police,
       pursuant to Section 172 of the
       > Road Traffic Act 1988, a keeper sent a Schedule 4 notice
       has no legal obligation to name the
       > driver”.
       > Through its failure to deliver a compliant Notice to Hirer,
       the Operator has forfeited its right to
       > claim unpaid parking charges from the vehicle’s hirer. For
       this reason alone, POPLA may
       > determine that the Operator’s claim against me is invalid.
       --- End Quote ---
       This was in my appeal email to the POPLA complaint's team (prior
       to them sending me the email in my first post):
       --- Quote ---
       > I recently appealed a PCN that I received from Euro Car Parks
       and the appeal was unsuccessful. The assessor name for my case
       was xx and I believe he has made a procedural error by not
       acknowledging my appeal point of there being no hirer liability.
       >
       > This appeal must be allowed because the operator Euro Car
       Parks failed to deliver a notice to hirer that was fully
       compliant with the requirements of paragraph 14 of Schedule 4 of
       the Protection of Freedoms Act (PoFA) 2012, which is relevant to
       the hirer and operator. The assessor appears to be mistakenly
       using POFA 13 for the operator/hirer relationship. The operator
       has not shown that the individual it is pursuing is the driver
       of the vehicle and potentially liable for the charge. I have
       referred to the right to not name the name and keeper liability.
       A notice to hirer was sent to the appellant on xx/xx/2020, this
       was after a PCN was issued to the hire company on xx/xx/2020.
       The operator has failed to provide evidence which shows that the
       appellant had signed a statement of liability when he hired the
       vehicle and that this was sent along with the PCN. The assessor
       has completely ignored the requirement to supply the hire
       agreement and notice to keeper with the notice to hirer.
       >
       > The assessor has used the phrase “registered hirer” in their
       response, I would ask what meaning does this have in the context
       of this case as it is not clear as to what he means. The
       registered hirer could not possibly be the registered keeper as
       this role is taken by the hire company, more clarity is needed
       by the assessor and I would hasten to say more training. I feel
       that the lead assessor in this matter has erred in the
       interpretation of law, it must be reviewed and the decision
       amended to one of an upholding of the appeal.
       --- End Quote ---
       Does the above answer both questions that you have asked me?
       Is there case law which supports the claim being struck off due
       to the time that has passed?
       *****************************************************
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