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#Post#: 41564--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: H C Andersen
Date: October 20, 2024, 10:15 am
---------------------------------------------------------
How can you appeal, nobody is pursuing you for money!
Sorry, but the note left on your windscreen is not a Notice to
Driver, it bears no resemblance, doesn't contain any of the
statutory info, doesn't state what's owing OR to whom, how to
pay, how to appeal etc. etc. And as the Act ONLY refers to the
contents of a NTD and not the colour, shape, material, writing
on or whatever of the envelope or packaging then to pin one's
hopes on 'it must be a NTD because this is what the packaging
said' would be foolish IMO, particularly as the Act does NOT
refer to Parking Charge Notice, let alone define it.
There's a logical and IMO legal distinction to be made between a
NTD, some of whose info is missing or incorrect, and therefore
not compliant, and a note written on hospital notepaper which
doesn't contain any of the statutory info.
It is not a NTD IMO.
So OP, as you don't have a Notice to Keeper your* actions are
premature IMO.
*- are you the registered keeper and are your DVLA details
current?
#Post#: 41565--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: DWMB2
Date: October 20, 2024, 10:50 am
---------------------------------------------------------
HC Andersen, please try to ensure you read threads more
carefully before commenting.
The OP has received a Notice to Keeper, they provided a copy in
their opening post.
#Post#: 41569--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: H C Andersen
Date: October 20, 2024, 11:25 am
---------------------------------------------------------
Point taken, I can now see page 1 of a Notice to Keeper.
Which begs the question: why the focus on a non-existent NTD as
being the basis of an appeal? Sorry, but surely this is simply a
view and not something the OP should take away as being the law:
UKPC’s issuance of the Notice to Keeper (NtK) has failed to
comply with the Protection of Freedoms Act (PoFA). The notice
left on my windscreen, regardless of whether it was classed as a
proper Notice to Driver (NtD), is effectively an NtD under
PoFA...
Also, how come the date of 20 Oct. has been given as the last
day of the appeals period, surely if posted on Fri. 20 Sept.
then it's given on Tues. 24th, the 28-day period beginning on
25th would therefore end on 22 Oct. or is my maths out?
6)A notice sent by post is to be presumed, unless the contrary
is proved, to have been delivered (and so “given” for the
purposes of sub-paragraph (4)) on the second working day after
the day on which it is posted; and for this purpose “working
day” means any day other than a Saturday, Sunday or a public
holiday in England and Wales.
#Post#: 41612--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: b789
Date: October 20, 2024, 6:30 pm
---------------------------------------------------------
The NtD was left on the windscreen: The notice placed on the
vehicle constitutes a Notice to Driver (NtD) for the purposes of
PoFA. Even if it does not fully comply with all the requirements
set out in paragraph 7 (for example, if it does not contain all
the necessary information), it still triggers the rules
governing the subsequent issuance of an NtK. The mere fact that
a physical notice was placed on the vehicle is sufficient to be
considered an NtD under PoFA.
Thankfully, if it ever got that far, at least a real judge would
be able to decide. (This will never get that far)
Besides telling us that it isn’t a real NTD, which has been
explained above, how do you propose dealing with the NtK which
attempts to be issued under PoFA section 9? Your view that the
PCN attached to the vehicle was not an NtD, is, thankfully, just
your view.
--- Quote from: b789 link ---
>
> You had until Tuesday 22nd October to submit an appeal. That's
three days away.
>
--- End Quote ---
So what’s the gripe about? Who mentioned 20th as the last day?
#Post#: 41982--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: nothavingthis
Date: October 23, 2024, 6:30 am
---------------------------------------------------------
--- Quote from: b789 link ---
>
> You had until Tuesday 22nd October to submit an appeal. That's
three days away.
>
--- End Quote ---
Hi again,
As expected the NHS Trust CEO Martin Hodgson has not replied
yet, so i am glad i had submitted the appeal in time. (I used
what was suggested below by userB789) I have however heard back
from UKPC as pasted below (correspondence sent to me via email
today):
Thank you for your recent communication concerning parking
charge reference [REDACTED].
We have carefully considered your appeal based on the
information provided and the evidence supporting the parking
charge. In this instance having completed our assessment, we
consider the parking charge to have been correctly issued, as
the vehicle was parked on site without displaying a valid pay
and display ticket.
Our appeals process is now concluded, you may now choose one of
the following options:
1) Pay the parking charge detailed above at the reduced rate of
£35.00 to UK Parking Control Ltd. PLEASE REFER OVERLEAF FOR
PAYMENT OPTIONS
AND ADDRESS DETAILS.
2) Make an appeal to the independent adjudicator POPLA (Parking
on Private Land Appeals) using the verification code provided
above. Please note that if you wish to appeal to POPLA, you will
lose the right to pay the discounted rate of £35.00, and should
POPLA reject your appeal you will be required to pay the full
amount of £65.00. If you opt to pay the parking charge you will
be unable to appeal with POPLA. Appeals to POPLA must be made
within twenty-eight days from the date of this letter. To appeal
with POPLA, please visit www.popla.co.uk. If you are unable to
access the internet, you may
appeal by post – this must be done using a POPLA postal form
which may be obtained by contacting POPLA by phone (0330 159
6126) or post (PO Box1270, Warrington, WA4 9RL).
By law we are also required to inform you that Ombudsman
Services (www.ombudsman-services.org/) provides an alternative
dispute resolution service that would be competent to deal with
your appeal. However, we have not chosen to participate in their
alternative dispute resolution service. As such should you wish
to appeal then you must do so to POPLA, as explained above.
3) If you choose to do nothing the parking charge will
automatically increase after thirty-five days from the date of
this letter to £65.00 and the matter will be passed to our debt
recovery agent, at which point you will be liable to pay an
additional charge of £70, in accordance with the terms and
conditions of parking, and further charges will be claimed if
court action is taken against you. Any unpaid court judgement
may adversely affect your credit rating.
Yours sincerely,
Appeals Department
UK Parking Control Limited
I guess off to POPLA we go ;)
------------------------------------------------------------------------------
--- Quote from: b789 link ---
>
> So, in this case, the initial appeal to UKPC, assuming PALS
doesn't get the PCN cancelled is an easy one to defeat... as
long as the unknown drivers identity is not revealed. There is
no legal obligation on the known keeper (the recipient of the
Notice to Keeper (NtK)) to reveal the identity of the unknown
driver and no inference or assumptions can be made.
>
> The NtK is not compliant with all the requirements of PoFA
which means that if the unknown driver is not identified, they
cannot transfer liability for the charge from the unknown driver
to the known keeper.
>
> Use the following as your appeal. No need to embellish or
remove anything from it:
>
> [quote]I am the keeper of the vehicle and I dispute your
'parking charge'. I deny any liability or contractual agreement
and I will be making a complaint about your predatory conduct to
your client landowner.
>
> As your Notice to Keeper (NtK) does not fully comply with ALL
the requirements of PoFA 2012, you are unable to hold the keeper
of the vehicle liable for the charge. Partial or even
substantial compliance is not sufficient. There will be no
admission as to who was driving and no inference or assumptions
can be drawn. UKPC has relied on contract law allegations of
breach against the driver only.
>
> The registered keeper cannot be presumed or inferred to have
been the driver, nor pursued under some twisted interpretation
of the law of agency. Your NtK can only hold the driver liable.
UKPC have no hope at POPLA, so you are urged to save us both a
complete waste of time and cancel the PCN.
--- End Quote ---
[/quote]
#Post#: 41988--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: b789
Date: October 23, 2024, 6:43 am
---------------------------------------------------------
As expected. UKPC will always reject an appeal. There's no money
it for them if they don't.
So, you now have a POPLA code and you need to prepare an appeal
to them based on the points I have already given you earlier.
You have 33 days from the date of the appeal rejection to submit
the POPLA appeal so, no rush.
Show us what you think is suitable for the POPLA appeal and we
will provide corrections and suggestions to make sure it is
suitable for submission.
No one pays UKPC PCNs if they are getting advice here. Even if
it went all the way to a court claim, it would eventually be
discontinued.
#Post#: 43223--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: nothavingthis
Date: October 30, 2024, 5:32 pm
---------------------------------------------------------
--- Quote from: b789 link ---
>
> A fob off. Escalate your complaint to the NHS Trust CEO. Get
back in touch with PALS and remind whichever moron sent you that
response that there has been no "PENALTY" Charge Notice issued
because an unregulated private parking company of ex-clamper
thugs is not and could never be an "authority" that could issue
a "penalty" of any kind. Also remind them that no "offence" has
been committed. A "PARKING" Charge Notice is simply a
speculative invoice form an alleged breach of contract by the
driver of the vehicle and their use of the word "penalty" in
their correspondence shows a level of ignorance that is
embarrassing and will be reported.
>
> Also point them to the Department of Health and Social Care
guidance: NHS car parking guidance 2022 for NHS trusts and NHS
foundation trusts
HTML https://www.gov.uk/government/publications/nhs-patient-visitor-and-staff-car-parking-principles/nhs-patient-visitor-and-staff-car-parking-principles#:~:text=Parking%20will%20be%20provided%20free,a%20period%20of%2030%20days.,<br
/>specifically the bit about "Contracted out parking".
>
> Tell them that you are escalating this to the East Lancashire
Hospital Trusts CEO, Martin Hodgson.
>
> You need to immediately send a complaint to the CEO at
martin.hodgson@elht.nhs.uk
>
> [quote]Subject: Urgent Complaint Regarding Unjust Parking
Charge Notice and PALS Response at Burnley Hospital
>
> Dear Mr. Hodgson,
>
> I am writing to formally complain about the handling of my
issue by the PALS department and the unfair Parking Charge
Notice (PCN) issued by UK Parking Control (UKPC), which operates
on behalf of Burnley General Hospital.
>
> During a recent emergency visit to the maternity suite, while
my wife was heavily pregnant, I parked quickly to get her the
urgent care she needed. Upon returning to my vehicle, I found an
irregular notice left on the windscreen, stating that a PCN
would be sent to the registered keeper by post. That PCN has now
been received, but I must highlight a serious issue.
>
> UKPC’s issuance of the Notice to Keeper (NtK) has failed to
comply with the Protection of Freedoms Act (PoFA). The notice
left on my windscreen, regardless of whether it was classed as a
proper Notice to Driver (NtD), is effectively an NtD under PoFA.
As such, UKPC should not have requested the keeper’s details
from the DVLA until 28 days after the issue of the NtD. By
requesting these details prematurely, UKPC has breached both the
British Parking Association (BPA) Code of Practice and PoFA.
>
> This is a serious violation, and it demonstrates that UKPC is
operating outside the requirements of its own Code of Practice,
effectively making them a "rogue contractor" on your hospital’s
premises.
>
> I would also like to draw your attention to the NHS Car
Parking Guidance 2022, which makes it clear that:
>
> [indent]• "NHS organisations are responsible for the actions
of private contractors who run car parks on their behalf."
>
> • "NHS organisations should act against rogue contractors in
line with the relevant codes of practice."
>
> • "Contracts should not be let on any basis that incentivises
additional charges, for example, ‘income from parking charge
notices only’."[/indent]
>
> UKPC’s conduct in this case is unacceptable and in clear
violation of both PoFA and the BPA Code of Practice. It is your
responsibility, as the Trust, to hold them accountable and
ensure that your contractors are operating within the law.
>
> I demand that this PCN be cancelled immediately, and that
UKPC’s practices on your hospital grounds be reviewed to ensure
compliance with both the law and NHS guidelines. I also expect a
formal response regarding how you will address the breaches I
have outlined. Furthermore, the PALS department should be better
equipped to provide real support rather than simply redirecting
patients to appeal directly with rogue contractors like UKPC.
>
> I look forward to your prompt response.
>
> Yours sincerely,
>
> [Your Full Name]
> [Your Contact Information]
--- End Quote ---
[/quote]
I have heard back from when i sent the above email today, it
said:
Good morning
Please see response below from the Head of Estates to the issues
you raised regarding the Parking Charge Notice, following
further investigation on your behalf.
With kind regards,
Jacqui
Dear [xxxxxxxxxx],
Thank you for your recent correspondence with me in which you
raised your concerns.
I asked for a full investigation into each of the issues you
raised so that I could provide a response that would address
each issue comprehensively.
You were not happy with how your complaint was handled by the
PALS (Patient Advice and Liaison Service) department.
The PALS Team as part of what they do will coordinate responses
for patients. In some cases, such as yours, they will contact
the relevant department to investigate the concern and ensure
the correct advice is given. Since your complaint was regarding
a Parking Charge Notice, the PALS Team contacted the Estates and
Facilities (Car Parking) service for advice. The advice the PALS
Team offered you was advice they received from the Estates and
Facilities (Car Parking Team). This advice to follow the appeal
process with UKPC and if you were not happy with their response
to contact the Trust again, was reasonable advice. The current
Trust Car Parking Policy 2023, page 9, paragraph 15 is detailed
below;
15. PARKING CHARGE NOTICES
15.1 If a Parking Charge Notice (PCN) is issued, it is the
responsibility of the recipient of the PCN to follow the
procedure stated on the ticket. It should be noted, not
following the procedure may result in increased parking charges
being imposed. In the event of an appeal against the PCN, the
first level of appeal is with the Car Park Operator as stated.
Hence, I can’t see how the PALs Team could have handled your PCN
complaint to them any differently. For these reasons, I find it
difficult to uphold this part of your complaint.
If the company issuing the PCN has not followed the Trust Car
Parking policy or breached any code of practice, then the Trust
will challenge them, directly which is the second part of your
complaint detailed below.
You believed that an unfair Parking Charge Notice (PCN) was
issued by UK Parking Control (UKPC), and that they were in
serious violation and operating outside the requirements of its
own Code of Practice,
These were serious allegations, hence I had to request a full
response from UK PC.
The response below was received on Friday 25th October 2024 and
I have reviewed this.
Good afternoon.
Following your email yesterday regarding the complaint from the
motorist, I have consulted with our legal department. Please see
the below they have prepared in response to the motorist’s
claims:
UKPC sets out the following response to the complainant’s
allegations that UKPC has failed to comply with (and is in
breach of) the Protection of Freedom Act 2012 (POFA) and the
British Parking Association Code of Practice (the Code) as:
1. The vehicle was issued a Notice to Driver (NtD)
2. UKPC did not wait 28 days after the NtD before issuing a
Notice to Keeper (NtK)
It appears that the complainant has misunderstood both the
provisions of POFA and the Code.
No NtD was issued to the vehicle. Section 4 Paragraph 7(2) of
POFA is clear that a NtD must have a number of things,
including:
1.Specify the vehicle details, land details and period of
parking to which the PCN relates
2.Provide details such as the time and date the PCN was issued
3.Inform the driver of the reasons why the PCN arose and the
requirement of the PCN
4. Inform the driver of the PCN value, any discounts and period
for payment
5. Inform the driver of UKPC’s details and how to raise a
dispute or complaint
The document which the Trust have requested is placed on
vehicles that will receive a PCN do not contain all of the
required elements listed above which would make it an NtD under
POFA. Therefore, it is disputed that any NtD was issued to the
complainant; and the complainant’s assertion that any document
left on the vehicle, even if it is not classed as a proper NtD
under POFA is still effectively a NtD under POFA is incorrect.
UKPC has complied with the requirements of Section 4 of POFA to
send a valid NtK to the complainant.
Further, the Code provides that to be an effective NtD the
document left with the vehicle must meet the requirements of
Section 4 of POFA, in particular Paragraph 7(2). If no effective
NtD has been given, the Code requires that UKPC complies with
the requirements of Section 4 of POFA to send out a NtK.
As stated above, UKPC has complied with the requirements of
Section 4 of POFA to send a valid NtK to the complainant and as
such was in compliance with the Code.
Sincerely
Dean Ckark
UKPC.
Having read the UK PC response above, it does address your issue
with the irregular notice left on the windscreen. It is correct
that the Trust requested the parking officers’ issue this as a
way of notifying drivers that they will be receive a PCN and
also to deter other drivers from parking without displaying a
valid pay and display ticket.
I understand why you feel UK PC are in breach of regulations,
and having checked the Protection of Freedoms Act 2012, schedule
4, paragraph 7 (2), I can agree that this document above (Figure
1) does not fit the description of a Notice to Driver (NtD).
Consequently, I find it difficult to see where the law has been
broken and to uphold your complaint that UKPC ‘is operating
outside the requirements of its own Code of Practice,
effectively making them a "rogue contractor" on your hospital’s
premises’.
I believe my response so far has covered two distinct points you
have raised, so I will now move on to address the final point
3. Your statement ‘I demand that the PCN be cancelled
immediately’
You have explained the events that led to you not displaying the
pay and display ticket on 18 September. I understand the
stressful conditions you described while trying to ensure your
wife received the care she needed.
However, I must also re-instate that the first level of appeal
for a PCN is with the Car Park Operator and this process is
detailed on the PCN document. Following this, an appeal with the
reasons and evidence can be escalated to the Trust.
At this point, I find it hard to justify an instruction to UKPC
to cancel your PCN on the grounds that UK PC have issued you
with a PCN unfairly or operated outside code of practice.
I would be more comfortable to ask for such a cancellation with
the evidence of your mitigations around how the urgent care of
your wife on 18th September led to your car being parked without
the pay and display ticket.
After considering my response if you remain dissatisfied and
wish to discuss the matter further or require further
information regarding the next stage of complaints resolution,
please do not hesitate to contact Customer Relations, Tel 01254
733700, as the Trust is committed to resolving complaints
locally.
Yours sincerely
Kind regards,
Andrew Appiah MSc(Eng) ICIOB
Head of Estates & Facilities (Interim)
#Post#: 43996--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: nothavingthis
Date: November 4, 2024, 4:22 pm
---------------------------------------------------------
[member=26]b789[/member] do you have any comments on what they
have sent me and the validity of it? Thanks
#Post#: 44023--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: b789
Date: November 5, 2024, 3:15 am
---------------------------------------------------------
I suggest you respond to Mr Appiah at the Trust with the
following:
--- Quote ---
> Subject: Formal Response to PCN Complaint – Joint and Several
Liability for UKPC’s Actions
>
> Dear Mr. Appiah,
>
> I am writing in response to your letter dated [insert date],
regarding my complaint about the Parking Charge Notice (PCN)
issued by UK Parking Control (UKPC) at Burnley General Hospital.
I appreciate the time taken to review my concerns, but I must
address several key points where I believe your response has
overlooked both legal and procedural obligations under the
Protection of Freedoms Act (PoFA) 2012 and the British Parking
Association (BPA) Code of Practice. I also hold East Lancashire
Hospitals NHS Trust jointly and severally liable for any future
legal action that may arise should UKPC pursue this matter
further.
>
> 1. Misclassification of the "Parking Charge Notice" as Not an
NtD
>
> While the notice left on my vehicle does not meet all the
specific requirements under Schedule 4, PoFA 2012 for an
official Notice to Driver (NtD) – lacking details such as
vehicle information, location, and time of issue – it is
explicitly labelled a "Parking Charge Notice" (PCN). This
classification and the use of such terminology imply an
enforceable charge under PoFA, thereby reasonably inducing me to
regard it as an NtD.
>
> The labelling of this notice as a PCN aligns with the function
and purpose of an NtD as intended by PoFA: to inform the driver
of an alleged breach and the imposition of a charge.
Consequently, the notice should be considered an NtD in
substance, if not in full form, thus requiring UKPC to observe
the 28-day delay before accessing registered keeper details.
>
> 2. Substance Over Form – Legal Doctrine and Reasonable
Interpretation
>
> In legal interpretation, courts frequently apply the doctrine
of “substance over form”, which prioritises the intent and
practical effect of a document over its technical format. By
labelling this document as a “Parking Charge Notice”, UKPC
created the reasonable impression that it serves as a formal
notice initiating the enforcement process, effectively
functioning as an NtD.
>
> The lack of certain minor details does not negate its role as
an NtD, and I would expect the Trust, in holding UKPC
accountable to PoFA and BPA Code of Practice, to consider this
document in substance as an NtD. Failure to do so could allow
UKPC to bypass statutory protections through technical evasions,
which is neither in line with PoFA’s intent nor with fair
consumer practice.
>
> 3. Expectation of the Reasonable Person and Transparency
>
> The notice’s prominent labelling as a “Parking Charge Notice”
would lead any reasonable person to interpret it as a formal
notice of a charge in line with PoFA procedures. UKPC’s denial
that this is an NtD contradicts the reasonable expectation
created by their choice of language. By failing to treat this
notice as an NtD and by accessing my details prematurely, UKPC
has violated both PoFA and BPA Code of Practice guidelines,
which your Trust is obligated to enforce through your contract
with them.
>
> 4. NHS Trust Liability – Obligations Under NHS Car Parking
Guidance 2022
>
> The NHS Car Parking Guidance 2022 clearly states that NHS
organisations are responsible for the actions of contractors
managing parking on their behalf. It further emphasises that
contracts with parking operators should be managed to prevent
rogue practices and to ensure compliance with relevant codes of
practice.
>
> UKPC’s actions in this instance are not only non-compliant
with PoFA and the BPA Code of Practice but could also be viewed
as contrary to NHS guidance, particularly in failing to respect
the rights of vehicle keepers. East Lancashire Hospitals NHS
Trust has an obligation to ensure that UKPC adheres to both
legal requirements and ethical standards, particularly when
dealing with vulnerable patients attending medical facilities.
>
> 5. Joint and Several Liability for Future Legal Action
>
> In light of the above points, I hold East Lancashire Hospitals
NHS Trust jointly and severally liable for any future legal
action that may arise should UKPC pursue this PCN. The Trust’s
contractual relationship with UKPC places it in a position of
accountability, particularly where contractors are found to be
operating outside of legal guidelines and established codes of
practice.
>
> Should UKPC pursue further action, I will not hesitate to
include the Trust as a co-defendant, based on its duty of care
to enforce compliance with PoFA and the BPA Code. By allowing
UKPC to operate in such a manner, the Trust is effectively
endorsing practices that could result in unfair legal claims
against innocent motorists, which is entirely unacceptable for
an organisation committed to patient welfare.
>
> Conclusion
>
> In conclusion, I expect East Lancashire Hospitals NHS Trust to
hold UKPC accountable for adhering to all statutory
requirements, including PoFA’s 28-day delay requirement
following a Notice to Driver. I further expect that this PCN
will be cancelled immediately, given the numerous procedural
errors outlined above, and that steps will be taken to ensure
UKPC’s compliance with PoFA and NHS guidelines on your premises.
>
> Please confirm in writing within 14 days how the Trust intends
to address these issues and whether UKPC will be instructed to
cancel this PCN. Should the Trust choose not to act on this
matter, I will take appropriate steps to protect my legal
rights, including holding the Trust accountable as a joint party
in any further action.
>
> Yours sincerely,
>
> [Your Full Name]
> [Your Address]
> [Contact Information]
--- End Quote ---
#Post#: 44905--------------------------------------------------
Re: UKPC PARKING CHARGE - BURNLEY BIRTH CENTRE BURNLEY HOSPITAL
DIR By: nothavingthis
Date: November 10, 2024, 10:15 am
---------------------------------------------------------
Hi, is the 33 days to appeal to POPLA correct or is it 28 days
as stated in the rejection letter.
Thanks
--- Quote from: b789 link ---
>
> As expected. UKPC will always reject an appeal. There's no
money it for them if they don't.
>
> So, you now have a POPLA code and you need to prepare an
appeal to them based on the points I have already given you
earlier. You have 33 days from the date of the appeal rejection
to submit the POPLA appeal so, no rush.
>
> Show us what you think is suitable for the POPLA appeal and we
will provide corrections and suggestions to make sure it is
suitable for submission.
>
> No one pays UKPC PCNs if they are getting advice here. Even if
it went all the way to a court claim, it would eventually be
discontinued.
>
--- End Quote ---
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