URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Private parking tickets
       *****************************************************
       #Post#: 48954--------------------------------------------------
       Re: Gemini Parking Solutions - Gunnersbury Park
   DIR By: shadowliner
       Date: December 9, 2024, 3:32 am
       ---------------------------------------------------------
       As expected...
       I will post my thoughts later, bit busy this morning!
       --- Quote ---
       > Dear Mr XXXX,
       > Re: Parking Charge Notice Number XXXX (Vehicle: XXXX)
       >
       > Site: Gunnersbury Park
       > Contravention date: 18/10/2024
       > You recently contacted us to appeal the Parking Charge Notice
       (PCN) XXXX that was issued to the above vehicle
       > registration on 18/10/2024 at Gunnersbury Park, London, W54NH.
       This PCN was issued because the vehicle broke the
       > following parking regulation: Failure to Pay for Duration of
       Stay.
       >
       > Our letter dated the 19/11/24 requested you to supply
       information regarding the driver from the date in question and
       advised
       > that proof was to be supplied within 14 days To date you have
       failed to provide sufficient evidence showing this therefore we
       > will continue to pursue this Charge.
       >
       > Having considered all grounds for the appeal you will
       understand that sadly we are unable to accept your appeal.
       >
       > You have now reached the end of our internal appeals procedure
       and therefore you now have two options: You can pay the
       > total amount due or you can appeal to an Independent Appeals
       Service within 21 days. Should you wish to make a second
       > appeal, this can be done through IAS – the independent appeals
       service – at www.theias.org/appeal.
       >
       > 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 further appeal then you must do so to the IAS, as
       > outlined here.
       >
       > Please note that if you wish to appeal to the IAS, you will
       regrettably no longer be able to pay the charge at the
       discounted rate of £60.00. Should the IAS's decision not go in
       your favour, you will then be required to pay the full amount of
       £100.00. When
       > parking on private land, the motorist agrees to abide by any
       clearly displayed conditions of parking in return for permission
       to
       > park. This location is private property and is managed by
       Gemini Parking Solutions London Ltd on behalf of the land owner.
       >
       > Gemini Parking Solutions fully complies with the guidelines
       set by the International Parking Community. Please note that
       > photographic evidence is taken with every PCN that is issued.
       >
       > Payment at the discounted rate £60.00 can be made within 14
       days from the date of this letter. Regrettably payments made
       > after this period will be for the full amount of £100.00.
       Failure to pay the amount may result in further costs being
       incurred and
       > may also result in Gemini Parking Solutions Ltd, reluctantly
       instructing a Debt Collection agency to collect any sum due.
       > Please make Cheques / Postal Orders payable to: Gemini Parking
       Solutions London Ltd Send Cheques / Postal Orders to:
       > Payments Department, PO Box 815, Wigan, WN1 9WX. Please write
       your Name, Address and Parking Charge Notice Number
       > (PCN) on the rear of all cheques and postal orders. When
       making payment by post we recommend using the Royal Mail’s
       > ‘Recorded – Signed For’ or ‘Special Delivery’ services. Cash
       should not be sent through the post.
       > Yours sincerely,
       > Appeals Department
       > Gemini Parking Solutions London Ltd.
       --- End Quote ---
       #Post#: 48996--------------------------------------------------
       Re: Gemini Parking Solutions - Gunnersbury Park
   DIR By: b789
       Date: December 9, 2024, 6:52 am
       ---------------------------------------------------------
       Here is a suitable IAS appeal you could use. Some would suggest
       a more serious approach. However, I have zero respect for the
       IAS or anyone who purports to be an adjudicator for them. Unlike
       POPLA, they operate anonymously and their rate of upholding
       appeals is under 4% which is derisory when compared to POPLA
       which is around 45%.
       --- Quote ---
       > Appeal Against Parking Charge Notice [Reference Number]
       >
       > Dear Sirs,
       >
       > This appeal exists solely to expose the procedural
       incompetence of Gemini Parking Solutions and the flawed nature
       of this entire process. I am the registered keeper of the
       vehicle, and I was not the driver on the date of the alleged
       contravention. There is no legal obligation for me to identify
       the driver, and neither Gemini nor the IAS can assume or infer
       otherwise.
       >
       > 1. Non-Compliance with PoFA
       >
       > Gemini’s Notice to Keeper (NtK) is not compliant with Schedule
       4 of the Protection of Freedoms Act 2012 (PoFA), and they
       therefore have no legal right to transfer liability to me as the
       keeper.
       >
       > Failure to issue the NtK within the relevant period:
       >
       > [indent]The alleged contravention occurred on 18/10/2024. The
       NtK was issued on 30/10/2024. Even under the most generous
       interpretation of deemed service, this is beyond the 14-day
       "relevant period" set out in Paragraph 9(4)(b) of PoFA.[/indent]
       >
       > Failure to include mandatory information:
       >
       > [indent]The NtK lacks the full details required under
       Paragraph 9(2) of PoFA, rendering it legally
       insufficient.[/indent]
       >
       > Gemini Parking Solutions’ blatant disregard for statutory
       requirements is their problem, not mine.
       >
       > 2. I Am Not the Driver
       >
       > For the avoidance of doubt, I was not the driver on the date
       of the alleged contravention. However, I decline to identify the
       driver to an unregulated private parking company. There is no
       legal obligation for me to do so, and there is persuasive
       appeals case law supports this position.
       >
       > Any assumption or inference by Gemini or the IAS that I, as
       the keeper, must also be the driver is both legally unfounded
       and embarrasingly desperate.
       >
       > 3. Gemini’s Lack of Evidence
       >
       > Gemini has failed to provide credible evidence:
       >
       > [indent]• Of the alleged contravention.
       > • That their signage at the site meets the requirements of the
       IPC Code of Practice.
       > • Of a contractual agreement between the driver and Gemini
       Parking Solutions.
       > • That they hold a valid contract flowing from the landowner
       to issue PCNs in their own name.[/indent]
       >
       > This entire case rests on speculative invoicing, not legal
       merit.
       >
       > 4. The IAS’s Role
       >
       > I have no illusions about the IAS process. It is well known
       that the IAS appeals process is designed to protect IPC members
       at the expense of fairness and legality. The anonymity of the
       adjudicator and the IAS’s abysmally low success rate for
       appellants suggest this appeal will likely be rejected,
       regardless of the facts.
       >
       > However, I am submitting this appeal as a matter of principle,
       fully confident that a real court—presided over by a qualified
       judge—will promptly dismiss Gemini’s baseless claim.
       >
       > 5. Conclusion
       >
       > 1. Gemini Parking Solutions has failed to comply with PoFA,
       and liability cannot be transferred to me as the keeper.
       >
       > 2. I was not the driver, and I am under no obligation to name
       the driver.
       >
       > 3. The PCN is legally unenforceable and must be cancelled.
       >
       > Should this appeal be rejected, it will serve only to further
       highlight the IAS’s lack of independence and Gemini’s predatory
       practices. I look forward to addressing this matter in court,
       where proper legal standards apply.
       --- End Quote ---
       #Post#: 52247--------------------------------------------------
       Re: Gemini Parking Solutions - Gunnersbury Park
   DIR By: shadowliner
       Date: January 7, 2025, 6:22 am
       ---------------------------------------------------------
       Happy to update with the following;
       Thank you for your appeal. Due to further information Gemini
       Parking Solutions London LTD has confirmed they will no longer
       be pursuing the matter and the parking charge has been
       cancelled.
       Thanks to [member=26]b789[/member], I did use your template but
       I have to admit I was a bit nervous of sending as is, so I did
       tone it back a bit!
       #Post#: 52274--------------------------------------------------
       Re: Gemini Parking Solutions - Gunnersbury Park
   DIR By: b789
       Date: January 7, 2025, 9:26 am
       ---------------------------------------------------------
       They don't like it up 'em Pike! Of course they withdrew. They
       don't have a chance if this were ever to go to court. The IAS
       probably advised them as such.
       A win is a win. Well done.
       *****************************************************
       Page 2 of 2
   DIR Previous Page