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       #Post#: 99625--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: Eryobotrya
       Date: November 24, 2025, 1:05 pm
       ---------------------------------------------------------
       OK, thx.
       Again, can it go out from my email account but with her typed
       name as the signature?
       or ...
       Should I prepare the correspondence for her to send from her
       email a/c?
       If only I could claim for your and my time too  :-\
       #Post#: 99669--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: b789
       Date: November 25, 2025, 3:30 am
       ---------------------------------------------------------
       It matters not one iota from whose account the email is sent.
       That is the same as asking whether I should post something from
       my local post office or a different one.
       If you're worried about something, you can just use like "Hide
       my email" if you're an Apple user. Just make sure you use an
       email address that will be checked regularly.
       #Post#: 100233--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: Eryobotrya
       Date: November 28, 2025, 10:43 am
       ---------------------------------------------------------
       No, not worried about anything as such. Just thought it might
       look a bit odd if the signatory was different from the e-mail
       a/c name.
       OK, thx for all the advice. About to file the complaint & claim
       now - at last. I'll assume you want me to report back on any
       progress/response from the court as I get it, unless you tell me
       otherwise.
       Thx again for guiding me thru this. Really appreciated.
       #Post#: 100507--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: Eryobotrya
       Date: December 1, 2025, 7:40 am
       ---------------------------------------------------------
       Sorry, back again.
       OK, so I tried to amalgamate your draft letters to the court
       posted at #141 and 144 into a single letter, and it's fairly
       clear to me from those drafts that the only costs I can claim
       appear to relate exclusively to post-discontinuance time spent.
       But as already advised, that was all my time - not the
       defendant's - which you have told me cannot be claimed.
       The defendant spent approx. 4-5hrs of her time on this claim,
       but that was all pre-discontinuance. If she cannot claim
       pre-discontinuance time, doesn't that remove the raison d'etre
       for the letter to the court? The complaint to the SRA is looking
       like the only valid option available to us in this case - unless
       you can explicitly confirm that pre-discontinuance costs can be
       claimed.
       I'm not sure how DCB Legal can be held liable for those costs,
       and I don't want to submit a fraudulent claim just to make a
       point about their non-compliance and ignorance of process.
       #Post#: 100553--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: b789
       Date: December 1, 2025, 11:15 am
       ---------------------------------------------------------
       Once a claim has been allocated to the small claims track,
       discontinuance does not automatically entitle the defendant to
       all of their “pre-discontinuance” costs.
       The normal rule in CPR 38.6 is that when a claimant discontinues
       they must pay the defendant’s costs up to the date of
       discontinuance. However, CPR 38.6(3) switches that rule off for
       any case that is proceeding on the small claims track. Once
       allocated, you are back in the small-claims costs regime, which
       is CPR 27.14.
       That does not mean you can only claim post-discontinuance costs.
       It means that any costs you claim, whether incurred before or
       after discontinuance, have to fit within what CPR 27.14 allows.
       There are two routes.
       First, the “ordinary” small claims costs: fixed issue fee, any
       hearing fee, and certain limited disbursements such as
       reasonable travel expenses and witness expenses. Those can
       include things incurred before discontinuance, but they are a
       narrow category.
       Second, CPR 27.14(2)(g). The court can depart from the no-costs
       rule and award “such further costs as it may assess on the small
       claims track” where a party has behaved unreasonably. Under this
       route you can ask the court to award your reasonable time as a
       litigant in person at £24 per hour, plus any additional
       disbursements, to the extent that work was caused by the
       claimant’s unreasonable behaviour. That can cover work done
       before discontinuance (for example, dealing with incoherent or
       non-compliant particulars of claim, having to put them to proof
       on points they ought never to have pursued, or work forced on
       you by abusive pre-trial conduct) and work after discontinuance
       (for example, having to chase them about an N279 signed by
       someone whose authority they refuse to clarify).
       So the short, honest answer is:
       You cannot claim your full pre-discontinuance costs “as of
       right” in the way a fast-track defendant could rely on CPR 38.6.
       But you can still seek recovery of pre-discontinuance time and
       expenses if you present them either as ordinary small-claims
       costs (where they fit that box) or as costs flowing from
       unreasonable behaviour under CPR 27.14(2)(g). The key is to tie
       each chunk of time and spend to specific examples of
       unreasonable conduct and then invite the court, in its
       discretion, to award those sums.
       In this case, a late discontinuance very close to a hearing (or
       after you have incurred substantial work) can support an
       application for unreasonable behaviour costs under CPR
       27.14(2)(g), especially where, as in this case, the claim was
       obviously weak or defective from early on (e.g. hopeless PoC,
       clear PoFA failure, no standing, duplicate claims) and the
       claimant pressed on, ignored clear rebuttals, then pulled out
       only at the last minute.
       #Post#: 100748--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: Eryobotrya
       Date: December 2, 2025, 12:30 pm
       ---------------------------------------------------------
       OK, got it. Thx.
       And phew! Good to know all that hard work (ie, yours) hasn't
       gone to waste.
       #Post#: 101034--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: Eryobotrya
       Date: December 4, 2025, 12:48 pm
       ---------------------------------------------------------
       What is:
       --- Quote ---
       > (b) Liberty to apply.
       --- End Quote ---
       ?
       #Post#: 101072--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: b789
       Date: December 5, 2025, 3:43 am
       ---------------------------------------------------------
       “Liberty to apply” is a standard civil-procedure clause that
       gives either party permission to return to the court only for
       issues about the implementation of the order, not to reopen the
       substance of the case.
       It does not allow the losing party to re-argue anything decided.
       It simply preserves the court’s ability to deal with practical
       or consequential points that might arise after the order is
       made.
       #Post#: 101196--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: Eryobotrya
       Date: December 5, 2025, 12:20 pm
       ---------------------------------------------------------
       OK, thx.
       All done bar the sending. Before I send the letter to the court,
       do I cc DCB Legal?
       #Post#: 101198--------------------------------------------------
       Re: Civil Enforcement Ltd - N1SDT Claim form recieved for PCN
       isssued for Swanley Park parking in New Barn Rd
   DIR By: b789
       Date: December 5, 2025, 12:24 pm
       ---------------------------------------------------------
       Yes. Anything you send to he court must be Ccd to DCB Legal.
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