URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Private parking tickets
       *****************************************************
       #Post#: 53406--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: b789
       Date: January 14, 2025, 10:28 pm
       ---------------------------------------------------------
       I’m not sure if I already stayed earlier on, you can safely
       ignore all debt collector letters. We really don’t need to know
       about them and you should not be concerned.
       The debt collector is not a party to the contract allegedly
       breached by the driver. They are powerless to do anything except
       to try and scare the low-hanging fruit on the gullible tree into
       paying out of ignorance and fear.
       Coke back if you receive a Letter of Claim or an actual N1SDT
       Claim Form from the CNBC.
       #Post#: 53538--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: boxer29
       Date: January 15, 2025, 4:22 pm
       ---------------------------------------------------------
       Thanks for your reply.
       Will ignore such letters from debt recovery as advised.
       Thanks once again
       #Post#: 81731--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: boxer29
       Date: July 19, 2025, 4:23 pm
       ---------------------------------------------------------
       --- Quote from: jfollows link ---
       >
       > Debt recovery company = ignore and file or use as cat litter.
       > They are simply on commission for any money they can extract
       from you. They use scary words to intimidate you into paying.
       > Don’t fall for it.
       > Only reply to a formal letter from UKCPS themselves, such as a
       Letter before Claim. UKCPS probably know you’re a lost cause, so
       they have sent the bully boys in to hope that you’ll pay up. If
       they pay TRACE 10% they still get £90 or more from you.
       >
       --- End Quote ---
       --- Quote from: b789 link ---
       >
       > I’m not sure if I already stayed earlier on, you can safely
       ignore all debt collector letters. We really don’t need to know
       about them and you should not be concerned.
       >
       > The debt collector is not a party to the contract allegedly
       breached by the driver. They are powerless to do anything except
       to try and scare the low-hanging fruit on the gullible tree into
       paying out of ignorance and fear.
       >
       > Coke back if you receive a Letter of Claim or an actual N1SDT
       Claim Form from the CNBC.
       >
       --- End Quote ---
       Hello,
       Today in post I have receive claim form N1SDT dated 17 July 2025
       from Civil National Business Centre to pay
       amount claimed = 170
       court fee      = 35
       legal rep fee  =50
       Total amount   = 255
       you have a limited time in which to reply to this claim form.
       you can respond to this claim online log on to
       www.moneyclaim.gov.uk     you will need the claim number
       M1MP6F3K  and the following password xxxxxxx
       There is also a STATEMENT OF TRUTH , RESPONSE PACK ADMISSION (
       specified amount)..
       Can some one please recommend to me what is the next step which
       your expert can advice..
       Thanks for your support.
       #Post#: 81735--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: jfollows
       Date: July 20, 2025, 2:26 am
       ---------------------------------------------------------
       Post the front page of the N1SDT you received here, we need to
       see the words used. Obscure the password, of course, but not
       dates.
       Did you not get a Letter of Claim prior to this?
       #Post#: 81815--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: boxer29
       Date: July 20, 2025, 3:36 pm
       ---------------------------------------------------------
       I dont remember to have received a letter or claim.
       posting first page of N1SDT
  HTML https://i.imgur.com/UR75O28.jpeg
       #Post#: 81821--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: H C Andersen
       Date: July 20, 2025, 4:02 pm
       ---------------------------------------------------------
       From your first post:
       Received a letter addressed to me in post dated 03.10.2024,
       which I opened today,[23 Oct].
       I asked why the delay but you didn't respond.
       You've also posted that on or around 14 Jan. you have 'received'
       a letter from TRACE dated 31 Dec.
       Now we have that on 19th July you have received a claim form
       dated 17 July.
       But mysteriously you did not previously receive a Letter of
       Claim.
       OP, so that I can sleep well tonight pl confirm:
       Are you the registered keeper of the vehicle;
       Are your DVLA details the same now as on the day of the alleged
       breach;
       Do you actually reside at the registered RK address?
       Are the addresses on the Notice to Keeper, TRACE letter and
       claim form the same and those registered with DVLA on the
       relevant date?
       #Post#: 81824--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: boxer29
       Date: July 20, 2025, 4:42 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > From your first post:
       >
       > Received a letter addressed to me in post dated 03.10.2024,
       which I opened today,[23 Oct].
       >
       > I asked why the delay but you didn't respond.
       >
       > You've also posted that on or around 14 Jan. you have
       'received' a letter from TRACE dated 31 Dec.
       >
       > Now we have that on 19th July you have received a claim form
       dated 17 July.
       >
       > But mysteriously you did not previously receive a Letter of
       Claim.
       >
       > OP, so that I can sleep well tonight pl confirm:
       > Are you the registered keeper of the vehicle;
       > Are your DVLA details the same now as on the day of the
       alleged breach;
       > Do you actually reside at the registered RK address?
       > Are the addresses on the Notice to Keeper, TRACE letter and
       claim form the same and those registered with DVLA on the
       relevant date?
       >
       --- End Quote ---
       yes these all are correct
       #Post#: 81908--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: b789
       Date: July 21, 2025, 6:57 am
       ---------------------------------------------------------
       With an issue date of 17th July, you have until 4pm on Tuesday
       5th August to submit your defence. If you submit an
       Acknowledgement of Service (AoS) before then, you would then
       have until 4pm on Tuesday 19th August to submit your defence.
       If you want to submit an AoS then follow the instructions in
       this linked PDF:
  HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
       Normally, we would advise not to use the MCOL to submit a
       defence due to some limitations with character count and
       formatting. However, due to recent systemic failures within the
       CNBC with defences submitted by email, we are changing tactics.
       I will know later tomorrow and certainly by Wednesday on the
       format and wording to use to submit your defence using the MCOL.
       Please do not put anything in the defence box until I get back
       to you by Wednesday. Please remind me if I haven't responded
       with the defence which will need to be copied and pasted into
       the MCOL defence text box.
       #Post#: 81979--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: boxer29
       Date: July 21, 2025, 12:26 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > With an issue date of 17th July, you have until 4pm on Tuesday
       5th August to submit your defence. If you submit an
       Acknowledgement of Service (AoS) before then, you would then
       have until 4pm on Tuesday 19th August to submit your defence.
       >
       > If you want to submit an AoS then follow the instructions in
       this linked PDF:
       >
       >
  HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
       >
       > Normally, we would advise not to use the MCOL to submit a
       defence due to some limitations with character count and
       formatting. However, due to recent systemic failures within the
       CNBC with defences submitted by email, we are changing tactics.
       I will know later tomorrow and certainly by Wednesday on the
       format and wording to use to submit your defence using the MCOL.
       >
       > Please do not put anything in the defence box until I get back
       to you by Wednesday. Please remind me if I haven't responded
       with the defence which will need to be copied and pasted into
       the MCOL defence text box.
       >
       --- End Quote ---
       Thanks b789 for your help and support.
       Will wait for your reply.
       #Post#: 82179--------------------------------------------------
       Re: UKCPS Parking NTK (  Postal -PoFA) issued on private land
       Mak Court WF13 4AF
   DIR By: b789
       Date: July 22, 2025, 12:58 pm
       ---------------------------------------------------------
       OK, here is the defence that you should copy and paste, as is,
       into the defence text box on MCOL:
       --- Quote ---
       > 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 adequately
       comply
       > with CPR 16.4.
       >
       > 3. The Defendant is unable to plead properly to the PoC
       because:
       >
       > (a) The contract referred to is not detailed or attached to
       the
       > PoC in accordance with CPR PD 16.7.3(1);
       >
       > (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.
       >
       > 4. The Defendant submits that courts have previously struck
       out
       > similar claims of their own initiative for failure to
       adequately
       > comply with CPR 16.4, particularly where the Particulars of
       > Claim failed to specify the contractual terms relied upon or
       > explain the alleged breach with sufficient clarity.
       > In comparable cases involving modest sums, judges have found
       > that requiring further case management steps would be
       > disproportionate and contrary to the overriding objective.
       > Accordingly, strike-out was deemed appropriate. 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
       > due to the Claimant’s failure to adequately comply with
       > CPR 16.4, rather than permitting an amendment. The Defendant
       > proposes that the following Order be made:
       >
       > Draft Order:
       >
       > Of the Court's own initiative and upon reading the particulars
       > of claim and the defence.
       >
       > AND the court being of the view that the particulars of claim
       > do not adequately comply with CPR 16.4(1)(a) because:
       > (a) they do not set out the exact wording of the clause
       > (or clauses) of the terms and conditions of the contract which
       > is (or are) relied on; and
       > (b) they do not adequately set out the reason (or reasons) why
       > the claimant asserts that the defendant was in breach of
       > contract.
       >
       > AND the claimant could have complied with CPR 16.4(1)(a) had
       it
       > served separate detailed particulars of claim, as it could
       have
       > done pursuant to CPR PD 7C.5.2(2), but chose not to do so.
       >
       > AND upon the claim being for a very modest sum such that the
       > court considers it disproportionate and not in accordance with
       > the overriding objective to allot to this case any further
       share
       > of the court's resources by ordering further particulars of
       > claim and a further defence, each followed by further
       referrals
       > to the judge for case management.
       >
       > ORDER:
       > 1. The claim is struck out.
       > 2. Permission to either party to apply to set aside, vary or
       > stay this order by application on notice, which must be filed
       at
       > this Court not more than 5 days after service of this order,
       > failing which no such application may be made.
       --- End Quote ---
       The formatting should remain, more or less, as you see it as it
       is limited to a max of 65 characters per line and is less than
       122 lines.
       If you can, and it would assist us greatly, take some screen
       shots of the defence as it appears on your screen just before
       and after you submit it.
       *****************************************************
       Page 3 of 8
   DIR Previous Page
   DIR Next Page