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       #Post#: 47267--------------------------------------------------
       Claim Form from Euro Car Parks– parked longer than max period al
       lowed – Goldstone Retail Park, Hove
       By: bhabob Date: November 27, 2024, 8:16 am
       ---------------------------------------------------------
       Hi all,
       On the 10/05/2022, the driver parked in Goldstone Retail Park,
       Hove just before 1:00 PM  (12:55:33 as per PCN)
  HTML https://maps.app.goo.gl/72xzFCR6Am4rKakh8
  HTML https://maps.app.goo.gl/72xzFCR6Am4rKakh8
       They browsed in TK MAXX, and then entered another of the stores
       on the site, DFS, primarily to talk about potential furniture
       purchases as there were Ukrainian refugees staying with the
       family. They were interested in furnishing a one bedroom flat in
       the town. This may have taken an hour and a half or so and then
       the driver went for a walk in Hove Park, across the road from
       the retail park, and for something to drink / eat in the park
       cafe.
       Unbeknownst to them the maximum stay was three hours free
       parking and they overstayed by just over 15 minutes (left
       16:14:10 as per PCN). The registered keeper received a £100 PCN
       in the post dated 18/05/2022
       [img width=1100
       height=1556]
  HTML https://i.imgur.com/jkEOPxh.png[/img]
       The RK appealed via euro car parks appeal process online on
       31/05/2022 using the advice mentioned on pepipoo and the reply
       via email dated 25/06/2022 is below
       [img width=1100
       height=1555]
  HTML https://i.imgur.com/OZhEs53.png[/img]
       [img width=1100
       height=1555]
  HTML https://i.imgur.com/GNbhZ9j.png[/img]
       [img width=1100
       height=1555]
  HTML https://i.imgur.com/t4aWMLV.png[/img]
       [img width=1100
       height=1555]
  HTML https://i.imgur.com/3WvIQdo.png[/img]
       This shows photos of the signage in the retail park in June
       2022.
       The RK subsequently received final notification letters
       [img width=1100
       height=1556]
  HTML https://i.imgur.com/dC4GXA6.png[/img]
       and then from debt recovery plus, now up to £170
       [img width=1100
       height=1556]
  HTML https://i.imgur.com/tk4wgLZ.png[/img]
       and then various letters from ZZPS Limited, GCTT and DCBL (not
       included but can show images)
       A "Letter of Claim" was received dated 18th of October 2024 from
       DCB Legal Ltd which was unfortunately missed in the post
       [img width=1100
       height=1556]
  HTML https://i.imgur.com/WvYyxiX.png[/img]
       and now a claim form has been received HM Courts and Tribunal
       Service, issue date of 20th November 2024 for £290.84
       [img width=1100
       height=1555]
  HTML https://i.imgur.com/pe4Y9j8.png[/img][img
       width=1100
       height=1555]
  HTML https://i.imgur.com/8ABblOG.jpeg[/img]
       with response pack
       [img width=1100
       height=1555]
  HTML https://i.imgur.com/7VLMcis.png[/img][img
       width=1100
       height=1555]
  HTML https://i.imgur.com/0nfwXdR.png[/img][img
       width=1100
       height=1555]
  HTML https://i.imgur.com/Aaauh04.png[/img][img
       width=1100
       height=1555]
  HTML https://i.imgur.com/xoJzNaN.png[/img][img
       width=1100
       height=1555]
  HTML https://i.imgur.com/zNDiBiq.png[/img]
       I have 14+5 days from the 20/11/2024 to respond and would
       greatly appreciate how to proceed on this.
       I am the registered keeper of the vehicle. Thanks in advance
       #Post#: 47270--------------------------------------------------
       Re: Claim Form from Euro Car Parks– parked longer than max perio
       d allowed – Goldstone Retail Park, Hove
       By: b789 Date: November 27, 2024, 8:40 am
       ---------------------------------------------------------
       Welcome. With an issue date of 20th November, you have until Mon
       9th December to Submit your Acknowledgement of Service (AoS).
       Once your AoS is submitted, you then have until 4pm on Monday
       23rd December to submit a defence.
       There is nothing to be gained by delaying the AoS so please
       follow the guidance in this document to submit your AoS:
  HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
       Once you have done that, let us know and we will provide a
       defence to use.
       This is the most likely outcome: The claimant will discontinue
       the claim if it is defended before they have to pay the trial
       fee. I can say with greater than 99% certainty that this will be
       the eventual outcome, some time early next year.
       #Post#: 47297--------------------------------------------------
       Re: Claim Form from Euro Car Parks– parked longer than max perio
       d allowed – Goldstone Retail Park, Hove
       By: bhabob Date: November 27, 2024, 10:32 am
       ---------------------------------------------------------
       Thank you.
       I have submitted the Acknowledgement of Service oh the MCOL
       website, made very easy with your step-by-step guide. It was
       submitted after 4pm so won't be picked up until tomorrow.
       Many thanks and await defence when you have a spare moment.
       Appreciate that I have now until Monday 23rd December to do this
       and appreciate your time on this.
       Kind regards
       #Post#: 47301--------------------------------------------------
       Re: Claim Form from Euro Car Parks– parked longer than max perio
       d allowed – Goldstone Retail Park, Hove
       By: b789 Date: November 27, 2024, 10:47 am
       ---------------------------------------------------------
       Please remind us in a few days to do the defence. Just a bit
       overwhelmed with the amount of claims we are dealing with here
       at the moment.
       It was revealed yesterday that the number of Parking Charge
       Notices issued every day has now risen to over 41,000. Yes, you
       read that number correctly. Potentially earning these
       ex-clampers £4.1 million per DAY!!!
       In the last quarter the numbers are increasing and we only get
       to assist a tiny fraction of those recipients.
  HTML https://www.telegraph.co.uk/news/2024/11/26/parking-warning-christmas-shoppers-record-high-fines/
       #Post#: 48421--------------------------------------------------
       Re: Claim Form from Euro Car Parks– parked longer than max perio
       d allowed – Goldstone Retail Park, Hove
       By: bhabob Date: December 5, 2024, 5:50 am
       ---------------------------------------------------------
       Hi,
       Is there a similar thread on here that I could read to gather my
       defence, to save you some time?
       Thanks in advance,
       #Post#: 48429--------------------------------------------------
       Re: Claim Form from Euro Car Parks– parked longer than max perio
       d allowed – Goldstone Retail Park, Hove
       By: b789 Date: December 5, 2024, 6:25 am
       ---------------------------------------------------------
       Here is the defence and a link to the draft order that goes with
       it. You only need to edit your name, the claim number and to
       sign it by typing your full name for the signature and dating
       it. There is nothing to edit in th e draft order.
       When complete, save both as PDF files and attach them to an
       email addressed to claimresponses.cnbc@justice.gov.uk and CC in
       yourself. Make sure that the claim number is in the email
       subject field and in the body of the email put: "Please find
       attached the defence and accompanying Draft Order in the matter
       of Euro Car Parks Ltd v [your full name] Claim No.: [claim
       number]."
       [quote][center]IN THE COUNTY COURT[/center]
       [right]Claim No: [Claim Number][/right]
       [center]BETWEEN:
       Euro Car Parks Ltd.]

       Claimant
       - and -
       [Defendant's Full Name]
       
Defendant
       [hr]
       DEFENCE[/center]
       1. The Defendant denies any liability for this claim.
       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 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;
       (d) The PoC do not state exactly how the claim for statutory
       interest is calculated;
       (e) The PoC do not state what proportion of the claim is the
       parking charge and what proportion is damages;
       (f) The PoC states that the Claimant is suing the defendant as
       the driver or the keeper. The claimant obviously knows whether
       the defendant is being sued as the driver or the keeper and
       should not be permitted to plead alternative causes of
       action.[/indent]
       4. The Defendant has attached to this defence a copy of an order
       made at another court which the allocating judge ought to make
       at this stage so that the Defendant can then know and understand
       the case which he/she/it faces and can then respond properly to
       the claim.
       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:[/quote]
       Draft Order for the defence
  HTML https://www.dropbox.com/scl/fi/gmpkg6f843yga1sw1iwdo/short-defence-order.docx?rlkey=ppd7dwlale9j25111548n2e1j&st=33ycwyax&dl=0
       #Post#: 112900--------------------------------------------------
       Re: Claim Form from Euro Car Parks– parked longer than max perio
       d allowed – Goldstone Retail Park, Hove
       By: bhabob Date: March 11, 2026, 3:00 pm
       ---------------------------------------------------------
       Just an update on the above.
       You were correct in that DCB Legal discontinued court
       proceedings just a week before they were due to pay the small
       claims court a month before the hearing.
       Just a timeline below if anyone interested
       23/12/2024  Receipt of Defence acknowledged by HM Courts &
       Tribunals
       13/01/2025  DCB Legal advised by letter that their client
       intends to proceed
       20/01/2025  Notice of Proposed Allocation to Small Claims Track
       received by CNBC
       31/01/2025  DQ filed on MCOL website
       01/02/2025  DQ filed by claimant
       03/02/2025  Email notifying date of telephone mediation
       06/03/2025  Telephone mediation - not settled. Agreed to ZERO
       11/03/2025  Notified by CNBC of local County Court for
       Allocation
       26/05/2025  Notification of Small Claims court allocated and
       date of hearing 27/03/2026
       21/10/2025  Offer by letter by DCB Legal of £100 for full and
       final settlement of £290.84
       05/11/2025  Offer by letter by DCB Legal of £60 for full and
       final settlement of £290.84
       02/01/2026  Offer by letter by DCB Legal of £35 for full and
       final settlement of £290.84
       20/02/2026  Letter from DCB Legal discontinuing Court
       proceedings
       27/02/2026  Deadline for DCB Legal to pay court Trial fee passed
       Thank you to all involved, the help that I received and most
       importantly by reading similar examples to mine alleviated the
       anxiety and stress that I was feeling. After visiting this
       website I felt relaxed and confident that nothing would avail.
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