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#Post#: 50725--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: b789
Date: December 22, 2024, 1:16 am
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In which case respond to the LoC with the following:
--- Quote ---
> Dear Sirs,
>
> Re: Letter of Claim dated 4th December 2024
>
> I refer to your Letter of Claim.
>
> I confirm that my address for service at this time is as
follows, and I request that any outdated address be erased from
your records to ensure compliance with data protection
obligations:
>
> [YOUR ADDRESS]
>
> Please note that the alleged debt is disputed, and any court
proceedings will be robustly defended.
>
> I note that the sum claimed has been increased by an excessive
and unjustifiable amount, which appears contrary to the
principles established by the Government, who described such
practices as “extorting money from motorists.” Please refrain
from sending boilerplate responses or justifications regarding
this issue.
>
> Under the Pre-Action Protocol for Debt Claims, I require
specific answers to the following questions:
>
> [indent]1. Does the additional £60 represent what you describe
as a “Debt Recovery” fee? If so, is this figure net of or
inclusive of VAT? If inclusive, I trust you will explain why I,
as the alleged debtor, am being asked to cover your client’s VAT
liability.
>
> 2. Regarding the principal sum of the alleged Parking Charge
Notice (PCN): Is this being claimed as damages for breach of
contract, or will it be pleaded as consideration for a purported
parking contract?
>
> 3. Please state clearly and unequivocally which specific
term(s) of the alleged parking contract the driver is alleged to
have breached, along with evidence of how these terms were
communicated to the driver. Failure to provide such information
will demonstrate that your claim is vague, baseless, and bound
to fail.[/indent]
>
> I would caution you against simply dismissing these questions
with vague or boilerplate responses, as I am fully aware of the
implications. By claiming that PCNs are exempt from VAT while
simultaneously inflating the debt recovery element, your client
– with your assistance – appears to be evading VAT obligations
due to HMRC. Such mendacious conduct raises serious questions
about the legality and ethics of your practices.
>
> Further, it is embarrassing – legally speaking – that a
so-called firm of legal professionals cannot see that this claim
is fundamentally flawed and bound to fail. Your failure to
include any mention of the contractual term the defendant is
alleged to have breached demonstrates a lack of intelligence,
diligence, or both.
>
> The fact that your Letter of Claim and prior correspondence
rely on vague and boilerplate assertions without clearly stating
the basis of liability is not only procedurally improper but
demonstrates disdain for the court process and the legal
profession. As legal representatives, you are officers of the
court and have a duty to uphold the integrity of the legal
process, which includes ensuring that claims are founded on a
proper legal and factual basis. Your failure to identify the
specific contractual term allegedly breached is evidence of a
serious deficiency in process and reflects a disregard for your
obligations under the Civil Procedure Rules (CPR), particularly
CPR 1.3, which requires legal representatives to assist the
court in furthering the overriding objective of dealing with
cases justly and proportionately.
>
> The Letter of Claim itself serves as evidence of your failure
to act as officers of the court, as you ought to know that
presenting a claim without revealing the specific contractual
term allegedly breached is not only deficient but also an abuse
of process. This conduct undermines the principles of fair
litigation and brings the legal profession into disrepute. By
issuing vague and unsupported claims as part of a bulk
litigation model, you fail to discharge your responsibilities to
the court and instead demonstrate a willingness to pursue
meritless claims in the hope of coercing payment.
>
> I will not hesitate to bring these deficiencies to the court’s
attention as part of a robust defence. Furthermore, I will
formally request that the court impose appropriate sanctions
against both the claimant and you as their legal
representatives. This may include cost penalties and/or
referrals to the relevant regulatory authorities for conduct
that fails to meet the standards expected of officers of the
court.
>
> I strongly advise your client to cease and desist. Should this
matter proceed to court, you can be assured that these issues
will be brought to the court’s attention, alongside a robust
defence and potentially a counterclaim for unreasonable conduct.
If you, as the recipient of this letter, are not fully legally
trained, I suggest you escalate this correspondence to a senior
colleague or someone within your firm who is adequately
qualified to understand the serious consequences of failing to
address the deficiencies in your client’s claim and the
professional obligations imposed upon you as officers of the
court.
>
> Yours faithfully,
> [Your Name]
--- End Quote ---
#Post#: 62197--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: _wooky_
Date: March 12, 2025, 4:41 pm
---------------------------------------------------------
I've had no reply to this.
Are there any time limits?
#Post#: 62243--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: b789
Date: March 12, 2025, 10:58 pm
---------------------------------------------------------
There's no time limits but if they issue a claim without
responding, you can use it against and this can be used as part
of a defence argument regarding procedural unfairness and
unreasonable conduct.
Also, you would have to make a formal complaint to the SRA.
For now, just wait and see. Moorside Legal are just a bunch of
incompetent, wannabe legals.
#Post#: 129905--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: _wooky_
Date: September 8, 2026, 8:54 am
---------------------------------------------------------
Fast forward to 30 August 2026 and I’ve received another Letter
of Claim, despite not having had a reply to my letter dated
23/12/2024, which was the response [member=26]b789[/member]
advised me to send. Thanks for that btw. I’ve only just realised
I never acknowledged 🙇‍♂️
imgur says it's 'temporarily over capacity' atm. Is there
another way I can share what I've just received? Or does the
fact they've not responded to my letter of 23/12/24 dictate my
reply to this one?
#Post#: 129907--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: DWMB2
Date: September 8, 2026, 9:00 am
---------------------------------------------------------
Imgur is no longer accessible in the UK without the use of a
VPN. Another decent one is
HTML https://imgbb.com/
HTML https://imgbb.com/
#Post#: 129908--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: jfollows
Date: September 8, 2026, 9:00 am
---------------------------------------------------------
Imgur is blocked in the UK. See
HTML http://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
#Post#: 129910--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: InterCity125
Date: September 8, 2026, 9:03 am
---------------------------------------------------------
HTML https://imgbb.com/
#Post#: 129933--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: _wooky_
Date: September 8, 2026, 10:27 am
---------------------------------------------------------
--- Quote from: _wooky_ link ---
>
> imgur says it's 'temporarily over capacity' atm. Is there
another way I can share what I've just received? Or does the
fact they've not responded to my letter of 23/12/24 dictate my
reply to this one?
>
--- End Quote ---
Letter of Claim -
HTML https://ibb.co/60812XY5
Schedule -
HTML https://ibb.co/7JL0cYcN
Please let me know if you want me to dig out the original LoC
that started this thread.
Interestingly (or not!) the 'additional charges' in the first
LoC was £60 🤔
#Post#: 130086--------------------------------------------------
Re: Letter of Claim from Moorside Legal for PCN from UKPS Ltd
(Eaton House Offices nr Coventry railway station)
DIR By: _wooky_
Date: September 10, 2026, 4:23 am
---------------------------------------------------------
Would this proposed reply help or hinder my case...
--- Quote ---
> Moorside Legal Services
> PO Box 82112
> London
> N17 1LG
>
> [DATE]
>
> Dear Sirs,
>
> Your Ref: 10101246
> Claimant: UKPS Ltd
> Response to Letter of Claim dated 30 August 2026
>
> I acknowledge receipt of your further Letter of Claim dated 30
August 2026.
>
> The alleged debt remains disputed in full.
>
> You previously issued a Letter of Claim concerning the same
alleged parking charge in December 2024. I responded
substantively on 23 December 2024, disputing the alleged debt
and requesting specific information concerning the factual and
legal basis of your client's claim.
>
> I received no substantive response.
>
> Paragraph 5.2 of the Pre-Action Protocol for Debt Claims
provides that where a debtor requests a document or information,
the creditor must provide it, or explain why it is unavailable,
within 30 days of receipt of the request.
>
> Your failure to respond to my requests of 23 December 2024
therefore remains unexplained. The issuing of a further Letter
of Claim approximately 20 months later does not address those
outstanding requests.
>
> For the avoidance of doubt, the information previously
requested remains outstanding. I continue to dispute the alleged
debt and require the following information and documents in
order properly to understand the basis of your client's proposed
claim.
>
> 1. The alleged breach and contractual term relied upon
>
> The notices issued by your client do not adequately identify
the conduct said to have given rise to the parking charge,
instead stating in substance that the vehicle was parked "in a
manner whereby the driver became liable for a parking charge".
>
> This issue was expressly raised in my correspondence of 23
December 2024, when I requested that you identify the specific
contractual term(s) which the driver was alleged to have
breached. You failed to answer that request.
>
> Please now state clearly:
>
> (a) precisely what the driver is alleged to have done or
failed to do;
>
> (b) the precise contractual term allegedly breached; and
>
> (c) where and how that term was communicated to the driver.
>
> Please also explain how your client contends that its notices
satisfy the applicable requirements of Schedule 4 to the
Protection of Freedoms Act 2012 in respect of the description of
the circumstances in which the parking charge became payable.
>
> 2. The contractual signage
>
> Please provide contemporaneous photographs of all signage
relied upon by UKPS Ltd as forming the alleged contract at Eaton
House Offices on 14 January 2023, including entrance signage and
signage applicable to the location in which the vehicle was
parked.
>
> 3. Evidence of the alleged contravention
>
> Please provide copies of all photographs and other evidence
upon which UKPS Ltd intends to rely in establishing that the
identified contractual term was breached.
>
> 4. Authority
>
> Please provide evidence of UKPS Ltd's authority from the
relevant landowner to operate at the location, enter into
parking contracts with motorists and pursue parking charges in
its own name.
>
> 5. Quantum of the claim
>
> Please provide a full explanation and calculation of the £160
now claimed.
>
> The original Parking Charge Notice stated that the parking
charge was £100. Your current Letter of Claim instead identifies
£94 as "Parking Charge Notice(s)" and £66 as "Additional
Charges".
>
> Please explain:
>
> (a) how the original £100 parking charge has become £94;
>
> (b) precisely what the additional £66 represents;
>
> (c) the contractual and/or legal basis upon which the
additional £66 is claimed; and
>
> (d) where in the alleged contract the driver agreed to become
liable for that additional sum.
>
> 6. Previous correspondence
>
> Please provide a copy of any substantive response which you
contend was sent in response to my letter dated 23 December
2024.
>
> If no response was sent, please confirm this and explain why
the information requested was not provided within the period
prescribed by paragraph 5.2 of the Pre-Action Protocol for Debt
Claims.
>
> Paragraph 5.1 of the Protocol provides that where any aspect
of a debt is disputed, including the amount, charges or
compliance with relevant statutes and regulations, the parties
should exchange information and disclose documents sufficient to
enable them to understand each other's position.
>
> Paragraph 4.2 further provides that proceedings should not be
commenced less than 30 days from receipt of a completed Reply
Form or 30 days from the creditor providing documents requested
by the debtor, whichever is later.
>
> I therefore require a substantive response and the requested
information and documents before proceedings are commenced.
>
> Should your client nevertheless commence proceedings without
properly addressing these requests, I reserve the right to draw
this correspondence, my correspondence of 23 December 2024 and
your client's subsequent failure to respond to the attention of
the court when compliance with the Pre-Action Protocol is
considered.
>
> I invite your client to review this matter properly and
discontinue its pursuit of this disputed charge.
>
> Yours faithfully,
>
> Peter Daly-Dickson
--- End Quote ---
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