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#Post#: 63884--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: concoj
Date: March 23, 2025, 4:46 pm
---------------------------------------------------------
I received an email:
attached screenshots.
--- Quote ---
> Dear
> By email only:
> Re: CLAIM NO:
> WITHOUT PREJUDICE SAVE AS TO COSTS
> We refer to your application to set aside judgment which has
been forwarded to us by Croydon County Court.
> It is our position that your application to set aside judgment
will be refused. Even if the application is granted, we will
proceed with the claim against you.
> However, bearing in mind this process can take time and will
incur unnecessary costs for both parties, we will consent to
setting aside the judgment (to remove it from your record) and
to discontinue the claim against you if you agree to pay the
original £100.00 parking charge plus the administration costs
and fees we have incurred in trying to recover payment of the
PCN, limited to £35.00, making a total of £135.00. Each party
will bear its own costs of this application. We would have made
a similar offer to you had you contacted us prior to lodging
your application with the Court.
> Please confirm in writing by 04104/2025 that you agree to
accept this offer. If the offer is not accepted, we reserve the
right to show this letter to the judge on the issue of who
should pay the costs of your application.
> You can make the payment of £135 on www.ce-service.co.uk.
> Yours faithfully,
> Legal Team
> For and on behalf of
> Civil Enforcement Limited
--- End Quote ---
--------------------------------------------
[attachment deleted by admin]
#Post#: 63932--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: b789
Date: March 24, 2025, 7:21 am
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Nothing to worry about. Typical of a claimant that is now
panicking and realises they have nowhere to run.
Your case is very strong.Their letter is marked "Without
Prejudice Save as to Costs". This protects the contents from
being shown to the judge when determining liability, unless and
until the court is considering the question of costs after the
outcome has been decided.
Therefore, the letter cannot lawfully be used to influence the
judge's decision on whether to set aside judgment or strike out
the claim.
They can try to show it at the end, only if the judge reaches a
point of deciding who should bear costs — but this cuts both
ways. You can point to your earlier offer and their refusal to
engage before the application was filed, which makes their
conduct worse.
A draft consent order is not binding unless both parties sign it
and it is approved by the court. If they try to submit the draft
order alone, implying agreement when you haven’t consented, that
would be misleading the court — potentially amounting to abuse
of process or even professional misconduct if done deliberately.
CEL’s claim in their “without prejudice save as to costs” letter
— that they “would have made a similar offer had you contacted
us prior to lodging your application” — is plainly false. You
not only contacted them in advance, but you also provided
detailed legal reasoning, gave them a clear and fair deadline,
offered a cooperative solution (joint application) and deferred
unilateral action to allow them time to respond.
This amounts to a reasonable and constructive pre-action offer
in line with both CPR 1.1 (overriding objective) and CPR 44.2
(costs discretion).
I suggest you send a Supplemental Witness Statement (SWS)ogether
with two additional exhibits, your original letter to CEL
offering an uncontested set aside and their electronic receipt
of that letter having been sent. Additionally, you can send CEL
an SAR requiring them to provide copies of every piece of data
that they hold on you. It will be interesting to see if they
include anything that references that electronic receipt.
You should send the SWS
--- Quote ---
>
> [center]IN THE COUNTY COURT AT CROYDON[/center]
> [right]Claim No: H3GM808Q[/right]
>
> [center]BETWEEN:
>
> Civil Enforcement Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> SUPPLEMENTAL WITNESS STATEMENT[/center]
>
> I, [Defendant’s Full Name], of [full address], make this
supplemental statement in support of my application to set aside
the default judgment entered on 15th June 2021 and to strike out
the claim.
>
> I make this statement in response to recent correspondence
received from the Claimant, and to clarify the position
regarding my efforts to resolve this matter prior to issuing my
application.
>
> Clarification Regarding Pre-Application Conduct
>
> 1. I have received a letter from the Claimant marked “Without
Prejudice Save as to Costs”. I do not intend to rely upon the
contents of that letter at this stage and understand that such
correspondence is inadmissible until and unless the Court
considers the issue of costs. However, I consider it necessary
to clarify the factual record regarding my own pre-application
conduct.
>
> 2. On 2nd November 2024, I submitted a detailed and reasoned
letter to the Claimant via their online contact portal. In that
letter, I proposed a joint application to set aside the default
judgment and dismiss the claim, suggesting that the Claimant
bear the application fee and that there be no order as to costs.
A copy of that letter is attached as Exhibit XX-09.
>
> 3. I invited a response by 4 pm on 13th November 2024 and
stated clearly that I would defer submitting a unilateral
application until that deadline had passed. Despite this, the
Claimant did not reply or acknowledge my proposal. I therefore
proceeded to issue the application unilaterally, at my own
expense.
>
> 4. I also attach as Exhibit XX-10 a copy of the automated
receipt generated by the Claimant’s system confirming receipt of
my correspondence on 2nd November 2024, under reference
CELC_20241102_MB_933. The receipt stated that I would receive an
acknowledgement and a substantive response within 28 days. I did
not receive either.
>
> 5. I provide this information solely to assist the Court in
understanding the full background to the application and to
demonstrate that I took all reasonable steps to resolve the
matter cooperatively prior to engaging the Court. I reserve the
right to refer to any further correspondence if and when the
Court considers the issue of costs.
>
> Relevance to Application
>
> 6. The Claimant’s failure to respond to my open and
constructive approach resulted in unnecessary proceedings and
expense. This is particularly significant given that I made
clear the procedural errors in the Claimant’s service of the
claim and the prejudice I had suffered as a result.
>
> 7. I respectfully submit that my conduct was entirely
reasonable and consistent with the overriding objective. The
Claimant’s failure to engage with my open offer and their
subsequent conduct support the view that their behaviour has
been unreasonable.
>
> Statement of truth
>
> I believe that the facts stated in this Supplemental Witness
Statement are true. I understand that proceedings for contempt
of court may be brought against anyone who makes, or causes to
be made, a false statement in a document verified by a statement
of truth without an honest belief in its truth.
>
> Signed:
>
>
> Date:
--- End Quote ---
--- Quote ---
>
> [center]IN THE COUNTY COURT AT CROYDON[/center]
> [right]Claim No: H3GM808Q[/right]
>
> [center]BETWEEN:
>
> Civil Enforcement Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> INDEX OF DOCUMENTS[/center]
>
> 1. Supplemental Witness Statement of [Your Full Name]
>
> 2. List of Additional Exhibits:
>
> [indent]Exhibit XX-09: Letter from Defendant to Claimant dated
2nd November 2024
> [indent][Insert your full letter beginning “URGENT – Dear
Sirs...”][/indent]
>
> Exhibit XX-10: Submission Receipt
> [indent][Insert the screenshot receipt or the wording from it
here: “Thank you for contacting us. Your reference number is
CELC_20241102_MB_933 for all correspondence. Please note we will
respond to your complaint within 28 days. You will also receive
an email acknowledgement with this reference on. If you do not
receive one shortly, please check your email junk folder and/or
ensure you supplied the correct email address.”
> — Civil Enforcement Ltd online contact form, 2nd November
2024][/indent][/indent]
--- End Quote ---
Each exhibit should have its own header as per all these pages
and the title "Exhibit XX-NN". For example:
--- Quote ---
>
> [center]IN THE COUNTY COURT AT CROYDON[/center]
> [right]Claim No: H3GM808Q[/right]
>
> [center]BETWEEN:
>
> Civil Enforcement Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> EXHIBIT XX-09
>
> Letter from Defendant to Claimant (2nd November 2024)[/center]
>
> This letter was submitted as a PDF attachment on the Claimants
website:
HTML https://www.ce-service.co.uk/submit-a-complaint/
>
>
---------------------------------------------------------
>
> [center]URGENT[/center]
>
> Dear Sirs,
>
> CIVIL ENFORCEMENT LIMITED (THE ‘CLAIMANT’) V [your full name]
CLAIM REFERENCE H3GM80Q8
>
> On 24th October 2024, I received the attached letter dated
13th October 2024 from yourselves. This came as a tremendous
shock as it is the first and only communication I have received
from your company or any organisation representing you in
relation to this claim.
>
> I made immediate enquiries of the CNBC from which I was able
to establish that:
>
> [indent]1. the claim relates to an alleged parking event in
March 2019;
> 2. the claim form was sent to an old address at which I no
longer reside; and
> 3. if I had been given the opportunity to do so, I would have
successfully defended the claim.[/indent]
>
> I did not receive any pre-claim correspondence, not even a
letter of claim as required by the PAP. Nor did I receive the
claim form or any particulars of claim and was thus deprived of
the ability to defend the claim. Your company is well aware that
people move home from time to time. You also know that I did not
respond to any communications sent to me at my old address.
>
> This situation is explicitly dealt with in the Civil Procedure
Rules which provide at CPR 6.9(3):
>
> [indent](3) Where a claimant has reason to believe that the
address of the defendant ... is an address at which the
defendant no longer resides or carries on business, the claimant
must take reasonable steps to ascertain the address of the
defendant’s current residence or place of business (‘current
address’).[/indent]
>
> As your company is a member of the British Parking Association
(the ‘BPA’) and is bound by the BPA’s Code of Practice which
gives voice to CPR 6.9(3) in the following terms:
>
> [indent]24.1c Before serving a Letter Before Claim and prior
to the issue of proceedings, Operators must, if no responses
have been received to the NtD/NtK/reminder letters, take
reasonable endeavours to ensure that the contact details for the
person you are writing to are correct.[/indent]
>
> If your company had taken the actions required by the Civil
Procedure Rules and the Code of Practice, my current address
would have been found easily, which is obviously what you did
before sending your letter dated 13th October 2024. If those
actions had been performed at the correct time rather than after
judgment, I would not have been deprived of the ability to
defend the claim.
>
> By reason of Civil Enforcement's breach of the Civil Procedure
Rules, which amounts to an abuse of the process of the Court,
the claim form was never properly served and the judgment must
be set aside at your expense and the claim dismissed because it
is now too late for the particulars of claim to be re-served.
>
> In view of the foregoing, I invite Civil Enforcement Ltd to
join with me in an application to set aside the judgment and
dismiss the claim, with Civil Enforcement Ltd paying the court
fee and no order as to costs.
>
> Please respond to the above offer as soon as possible so that,
if the offer is acceptable to you, we can work together to right
the wrong that Civil Enforcement has done to me.
>
> To give you a reasonable time to take instructions and for us
to agree a suite of documents for the Court, I am willing to
defer making a unilateral application to set aside the judgment
until 4 pm on Wednesday 13th November 2024. If a joint
application has not been made by that time, I intend to instruct
a solicitor to apply to the Court unilaterally for an order
setting the judgment aside, striking out the particulars of
claim, dismissing the claim and awarding costs against Civil
Enforcement Ltd on a full indemnity basis.
>
> Pease respond by immediate return.
>
> Yours faithfully,
--- End Quote ---
And also the receipt:
--- Quote ---
>
> [center]IN THE COUNTY COURT AT CROYDON[/center]
> [right]Claim No: H3GM808Q[/right]
>
> [center]BETWEEN:
>
> Civil Enforcement Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> EXHIBIT XX-10
>
> Submission Receipt from Civil Enforcement Ltd[/center]
>
>
HTML https://i.imgur.com/BTrHHbB.jpeg
>
--- End Quote ---
You send the SWS and extra exhibits as a PDF attachment in a
single email addressed to:
enquiries.croydon.countycourt@justice.gov.uk and
legal@ce-service.co.uk and you also CC in yourself.
Make sure the email subject contains the clam number and in the
body write something along these lines:
--- Quote ---
> “Please find enclosed the Defendant’s Supplemental Witness
Statement dated [insert date], filed in support of the set-aside
application. This statement addresses new developments and
provides additional evidence relating to the Claimant’s conduct
and the Defendant’s pre-application correspondence.”
--- End Quote ---
You should combine all the pages into a single PDF with each
page numbered. When this goes to the hearing, you should prepare
a single PDF document with the WS, exhibits, draft order for the
set aside, SWS and additional exhibits, each page numbered. Take
two hard copies of each with you. I tis not unusual for the
claimants rep to feign that they haven't received all the
paperwork. You can impress the judge by having available extra
copies for both the court and the claimant.
#Post#: 63933--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: b789
Date: March 24, 2025, 7:30 am
---------------------------------------------------------
Send a Subject Access Request (SAR) to Civil Enforcement. Send
it in an email to: dataprotectionofficer@ce-service.co.uk and CC
in yourself
--- Quote ---
> [DATE of submission]
>
> Dear Sir/Madam,
>
> RE: SUBJECT ACCESS REQUEST
>
> I write to make a formal Subject Access Request in respect of
my personal information. I am entitled to make this request
under data protection laws. The request is made in accordance
with section 45 of the Data Protection Act 2018 and Article 15
of the retained EU General Data Protection Regulation 2016/679
(UK GDPR). You can identify my records using the information
which is listed below.
>
> Requester (data subject) information
>
> (a). Full name:
> (b). Address:
> (c). Email address:
> (d). Telephone number:
> (e). PCN number:
> (f). VRM:
>
> Requested information
>
> In accordance with my right of access under data protection
law, I request the following:
>
> (a) Copies of my personal data
>
> I request that I am provided with full copies of all personal
data relating to me which is held by CIVIL ENFORCEMENT LTD.
>
> I would prefer to receive an electronic copy of the requested
information.
>
> (b) Purpose of the processing
>
> Please confirm within your response the purpose (or purposes)
for which my personal data was collected by [Operator name] in
the first instance and the purpose (or purposes) for which is
has been used by CIVIL ENFORCEMENT LTD to date.
>
> (c) Categories of the data
>
> Please confirm within your response which categories of my
personal data have been collected by CIVIL ENFORCEMENT LTD.
>
> (d) Sharing of the data
>
> Please confirm within your response which recipients my
personal data has or will be disclosed to. Please also confirm
whether my data will be shared outside of the United Kingdom and
if so, what safeguards are in place in relation to this.
>
> (e) Storage of the data
>
> Please confirm within your response the retention periods for
the storage of my personal data. If you are unable to confirm a
specific retention period, please confirm what criteria will be
used to determine this.
>
> (f) Source of the data
>
> Please confirm within your response which sources my personal
data is collected from.
>
> (g) Details about automated decision-making
>
> Please confirm within your response whether any automated
decision-making which uses my personal data is taking place or
will take place. If this is the case, I ask that you please
provide me with information about the logic involved in any such
process and the relevant consequences the decision-making will
have upon me.
>
> (h). Existence of my rights
>
> Please acknowledge and confirm within your response my right
to request the rectification or erasure of my personal data and
the right to object to or request a restriction the processing
which is taking place.
>
> Responding to my request
>
> The above contains all necessary information in order for you
to process my request and any delay by yourselves will not
absolve you from providing me with the information within one
calendar month of the date above as this is being sent to you as
an attachment by email.
>
> I believe that the information which has been requested should
be readily available to you.
>
> This request should not therefore fall within the legal
definition of an excessive or manifestly unfounded request and
should not attract any processing fee.
>
> I would be grateful for your assistance in processing my
request within the required one month period of your receipt.
>
> Yours faithfully,
>
> [your full name]
--- End Quote ---
#Post#: 70085--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: concoj
Date: May 5, 2025, 2:49 pm
---------------------------------------------------------
New hearing date
[attachment deleted by admin]
#Post#: 70147--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: b789
Date: May 6, 2025, 4:06 am
---------------------------------------------------------
Have you not had a response to your SAR? They were bound to
provide the information no later than 30 days after you sent it.
When you sent the SAR, presumably by email to their DPO, did you
also CC yourself? If so, you should have a copy of the email you
sent in your in box which is evidence that the email was sent as
it will also show the DPO email address.
#Post#: 72685--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: concoj
Date: May 22, 2025, 1:01 am
---------------------------------------------------------
Nope. unfortunately I haven’t got a response to the SAR. Yes I
sent CC to myself as you advised. I have check all the emails
and nothing. I sent it on the 1/4/25
#Post#: 72691--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: DWMB2
Date: May 22, 2025, 2:36 am
---------------------------------------------------------
Chase them
#Post#: 72801--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: concoj
Date: May 22, 2025, 11:14 am
---------------------------------------------------------
thanks, i chase them...
Dear Sir/Madam,
I am writing to follow up on the Subject Access Request (SAR) I
submitted to you on 1st April 2025, under Article 15 of the UK
GDPR and section 45 of the Data Protection Act 2018.
Under data protection law, you are required to respond to SARs
without undue delay and, in any case, within one calendar month
of receipt. As of today, over 50 days have passed, and I have
not received a response or any indication of an extension being
applied under Article 12(3) of the UK GDPR.
I therefore formally request that you respond immediately, as
your organisation is now in clear breach of its legal
obligations under UK data protection law.
If I do not receive a full and adequate response within 7 days,
I will have no choice but to escalate this matter to the
Information Commissioner’s Office (ICO) for further
investigation.
Please treat this matter with urgency and ensure that my rights
under data protection law are respected.
Yours faithfully
[ full name]
#Post#: 74297--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: concoj
Date: June 2, 2025, 7:05 am
---------------------------------------------------------
Tomorrow is the hearing and I don't know what to do or say
Please HELP
#Post#: 74366--------------------------------------------------
Re: Civil Enfocement letter Aka: ce-sevice.co.uk
DIR By: concoj
Date: June 2, 2025, 12:48 pm
---------------------------------------------------------
Got an email this afternoon including a 55 pages pdf
[attachment deleted by admin]
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