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       #Post#: 80679--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: Paulfamhughes
       Date: July 12, 2025, 5:25 am
       ---------------------------------------------------------
       Morning,
       They have ignored the previous email you advised to send and
       today we received in the post a claim form from the county
       court, what are my next steps and do you need me to upload any
       of the paper work? Also the original letter said £480 and now it
       is showing as £704.34 pluss court fees £844.34 not sure how they
       have added 224.34 Thank you
       #Post#: 80684--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: jfollows
       Date: July 12, 2025, 5:35 am
       ---------------------------------------------------------
       --- Quote from: Paulfamhughes link ---
       >
       > Morning,
       >
       > They have ignored the previous email you advised to send and
       today we received in the post a claim form from the county
       court, what are my next steps and do you need me to upload any
       of the paper work? Also the original letter said £480 and now it
       is showing as £704.34 pluss court fees £844.34 not sure how they
       have added 224.34 Thank you
       >
       --- End Quote ---
       Yes, post the N1SDT form, do not obscure any dates.
       If you’re not sure, post it, but no need to post blank forms.
       #Post#: 80686--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: Paulfamhughes
       Date: July 12, 2025, 5:39 am
       ---------------------------------------------------------
  HTML https://photos.app.goo.gl/pgmyCDnMKLF3dnD27
       
       I have uploaded on the above linked
       #Post#: 80714--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: b789
       Date: July 12, 2025, 8:57 am
       ---------------------------------------------------------
       With an issue date of 9th July, you have until 4pm on Monday
       28th July to submit your defence. If you submit an
       Acknowledgement of Service (AoS) before then, you would then
       have until 4pm on Monday 11th 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
       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 [claimant] v [your full name] Claim no.:
       [claim number]."
       --- Quote ---
       > [center]IN THE COUNTY COURT[/center]
       > [right]Claim No: [Claim Number][/right]
       >
       > [center]BETWEEN:
       >
       > [Claimant]
       > 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 16.7.3(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.[/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#: 80730--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: Paulfamhughes
       Date: July 12, 2025, 10:37 am
       ---------------------------------------------------------
       Thank you, what do you suggest I do I am going abroad next week
       for a couple of weeks am I best doing the AoS to give more time
       or if I submit the defence today it will be a while until I hear
       back?
       #Post#: 80763--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: b789
       Date: July 13, 2025, 3:48 am
       ---------------------------------------------------------
       Only you know what is best for you. Once the defence is
       submitted, the CNBC will send a copy to the claimant. Once the
       claimant has received the defence, DCB Legal will write to you
       confirming that their client intends to proceed and they'll
       include a copy of their N180 DQ form for your records. You will
       need to download and complete your own N180 DQ and send it to
       the CNBC and copy in DCB Legal.
       This will take a few weeks most likely. Once the DQs are
       submitted, you will receive a telephone appointment for
       mediation. this is not part of the judicial process and no judge
       is involved but you must 'attend' the call. It's a complete
       waste of time and all you do is offer £0 and it is over in
       minutes.
       You can check your MCOL history for when your own DQ has been
       sent and simply complete yours online and email it. You can do
       that from anywhere in the world as long as you have internet
       access.
       When the time comes for completing the DQ, just follow these
       instructions:
       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#: 81169--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: Paulfamhughes
       Date: July 15, 2025, 4:04 pm
       ---------------------------------------------------------
       Ok thank you I will just submit the defence and draft as one pdf
       I see I put the claim number and defendants full name, I leave
       claimant as claimant?. I am a little lost with your last reply
       but will that become more clear once I send this defence and
       draft or is that an additional I need to do? Sorry for all the
       questions I want to get this right thank you for your help.
       #Post#: 81360--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: b789
       Date: July 16, 2025, 5:42 pm
       ---------------------------------------------------------
       For now just send the defence and draft order as advised.
       #Post#: 92898--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: Paulfamhughes
       Date: October 5, 2025, 8:05 am
       ---------------------------------------------------------
       Afternoon,
       I have now received N180 I have downloaded from the link you
       have sent, questions:
       E1 for the mediation, the claim is against my partner but can I
       attend the mediation on their behalf due to work commitment's it
       will be harder for them to make the call due to not being able
       to use the phone at work or can I state that in E2 saying
       Tuesday to Friday not available.
       F4 Partner works Tuesday to Friday will they give enough notice
       to be able to book it off or do I put that on the dates not
       available.
       One last thing the letter (N149A) is dated the 30/09/2025, do I
       send back the N180 back whenever or delay until the last day?
       (whatever date that is?)
       Thank you
       #Post#: 92901--------------------------------------------------
       Re: DCBL - G24 Ltd - 2019! homebase carpark BN3 7EX
   DIR By: b789
       Date: October 5, 2025, 8:14 am
       ---------------------------------------------------------
       There is no reason to delay submitting the N180DQ. You do that
       by email as advised.
       Have another read of the instructions for the mediation phone
       call. I believe it says you can nominate someone to take the
       call for you. Also, you can put in the N180 that the defendant
       is not available on any Tuesday or Thursday or whatever.
       It's not rocket science. However, for the mediation cal, here is
       some advice for whoever takes the call:
       --- Quote ---
       > For the mediation call, the only requirement is for you
       "attend" the call. It is not part of the judicial process and no
       judge is involved.
       >
       > This is what I advise you to say when you receive the call
       from the mediator:
       >
       > “Before I set out my position, please confirm from the
       claimant’s side:[/I]
       >
       > [indent][I]• the full name of the person attending for them;
       > • their role/position at their legal representative’s firm;
       and
       > • whether they hold written authority to negotiate and settle
       today.[/indent]
       >
       > Please relay that back to me before we continue.”
       >
       > After the mediator calls back...
       >
       > If identified and authority confirmed:
       >
       > [indent]“Thank you. I’m content to proceed on that basis. My
       settlement offer is £0, or I invite the claimant to discontinue
       with no order as to costs.”[/indent]
       >
       > If no/unclear authority:
       >
       > [indent]“Please record that the claimant’s attendee has not
       confirmed settlement authority. My position remains that
       liability is denied and my offer is £0, subject to prompt
       approval by an authorised solicitor if they choose to
       discontinue.”[/indent]
       >
       > All you need to know is the name and the position of the
       person acting for the claimant and report that back to us. It
       will be over within minutes. Complete waste of time otherwise.
       --- End Quote ---
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