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#Post#: 69326--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: DWMB2
Date: April 30, 2025, 3:37 am
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Show us what you have received.
You should have received at least a Letter of Claim before this.
#Post#: 69339--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: b789
Date: April 30, 2025, 4:57 am
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As above... when did you receive the LoC? Why did you not keep
us updated? What is the issue date of the claim?
You DO NOT complete any of the forms you have received!!!!!
The first thing you do is answer the question about the LoC and
then you SHOW us the N1SDT part of the Claim Form. WE do not
need to see anything else that came with the letter from HMCTS!
You only redact your personal data, the claim number and the
MCOL password. You leave EVERYTHING else visible, especially all
dates and times.
#Post#: 69457--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: m_odwong@hotmail.com
Date: April 30, 2025, 4:14 pm
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I found the initial LOC, hadn't read it carefully , thought it
was just another debt collector letter. The LOC is dated: 21
March 2025.
I don't see any mention of N1SDT though. I may have discarded it
if it were sent in a different letter, but I doubt it.
I've linked the claim form from HMCTS and the initial LOC (front
and back).
HTML https://i.imgur.com/bhDIlwB.jpeg
HTML https://i.imgur.com/AD7Wd9w.jpeg
HTML https://i.imgur.com/7I9ZINU.jpeg
#Post#: 69488--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: b789
Date: May 1, 2025, 2:52 am
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With an issue date of 25th April, you have until 4pm on
Wednesday 3rd 14th May to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Wednesday 28th May 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
Otherwise, here is the defence and link to the draft order that
goes with it. You only need to edit your name and the claim
number. You sign the defence by typing your full name for the
signature and date it. There is nothing to edit in the draft
order.
When you're ready you combine both documents as a single PDF
attachment and send as an attachment in an email to
claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim
number must be in the email subject field and in the body of the
email just put: "Please find attached the defence and draft
order in the matter of Vehicle Control Services Ltd v [your full
name] Claim no.: [claim number]."
--- Quote ---
> [center]IN THE COUNTY COURT[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> Vehicle Control Services Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> DEFENCE[/center]
>
> 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 comply with CPR
16.4.
>
> 3. The Defendant is unable to plead properly to the PoC
because:
>
> [indent](a) The contract referred to is not detailed or
attached to the PoC in accordance with CPR PD 16(7.5);
>
> (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.[/indent]
>
> 4. The Defendant attaches to this defence a copy of a draft
order approved by a district judge at another court. The court
struck out the claim of its own initiative after determining
that the Particulars of Claim failed to comply with CPR 16.4.
The judge noted that the claimant had failed to:
>
> [indent](i) Set out the exact wording of the clause (or
clauses) of the terms and conditions relied upon;
>
> (ii) Adequately explain the reasons why the defendant was
allegedly in breach of contract;
>
> (iii) Provide separate, detailed Particulars of Claim as
permitted under CPR PD 7C.5.2(2).
>
> (iv) The court further observed that, given the modest sum
claimed, requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, the judge struck out the claim outright rather than
permitting an amendment.[/indent]
>
> 5. 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 for the Claimant’s failure to comply with
CPR 16.4.
>
> Statement of truth
>
> I believe that the facts stated in this Defence 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 ---
Draft Order for the defence
HTML https://www.dropbox.com/scl/fi/tcewefk7daozuje25chkl/Strikeout-order-v2.pdf?rlkey=wxnymo8mwcma2jj8xihjm7pdx&st=nbtf0cn6&dl=0
#Post#: 70053--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: m_odwong@hotmail.com
Date: May 5, 2025, 7:52 am
---------------------------------------------------------
Many thanks for the defence and draft order links! I've
submitted the defence and will keep you all updated on progress.
Out of interest, why are the forms supplied by HMCTS not the
right ones to submit in this instance, and/or not use the online
service to respond to the claim (moneyclaim.gov.uk)?
Thanks all for the help so far, much appreciated!
#Post#: 70058--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: b789
Date: May 5, 2025, 8:47 am
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The forms that accompany the claim are not necessary. Why would
you want to provide detailed personal information that is not
necessary for the conduct of the claim?
You don't use the MCOL to submit your defence because it is
severely limited in the number of characters you can enter and
it is not only not formatted, but it simply puts the defence as
a single wall of unreadable text.
#Post#: 80150--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: m_odwong@hotmail.com
Date: July 8, 2025, 2:14 pm
---------------------------------------------------------
Hey all,
I've received an email now from the solicitors stating that the
client wishes to proceed with the claim, that the N180 has been
filed with the court, but also that their client may be willing
to settle the case.
Should I just ignore this correspondence, and wait for the court
to issue the N180?
Thanks
#Post#: 80162--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: b789
Date: July 8, 2025, 2:51 pm
---------------------------------------------------------
Yes. Here is the advice for your won N180 DQ:
Having received your own N180 (make sure it is not simply a copy
of the claimants N180), do not use the paper form. Ignore all
the other forms that came with it. you can discard those.
Download your own here and fill it in on your computer. You sign
it by simply typing your full name in the signature box.
HTML https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
[indent]• The name of the court is "Civil National Business
Centre".
• To be completed by "Your full name" and you are the
"Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their
evidence at a hearing in person and to expose omissions and any
misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking
case paperwork for a living, having this case heard solely on
papers would appear to put the Claimant at an unfair advantage,
especially as they would no doubt prefer the Defendant not to
have the opportunity to expose the issues in the Claimants
template submissions or speak as the only true witness to events
in question.."
• F1: Whichever is your nearest county court. Use this to find
it:
HTML https://www.find-court-tribunal.service.gov.uk/search-option
• F3: "1".
• Sign the form by simply typing your full name for the
signature.[/indent]
When you have completed the form, attach it to a single email
addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk
and CC in yourself. Make sure that the claim number is in the
subject field of the email.
#Post#: 80176--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: filippi9
Date: July 8, 2025, 4:02 pm
---------------------------------------------------------
Great, will do. Many thanks for the quick response!
#Post#: 80177--------------------------------------------------
Re: VCS - Parked after expiry time - Powis Car Park, Woolwich
DIR By: DWMB2
Date: July 8, 2025, 4:05 pm
---------------------------------------------------------
--- Quote from: filippi9 link ---
>
> Great, will do. Many thanks for the quick response!
>
--- End Quote ---
You are not the OP...?
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