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       #Post#: 52845--------------------------------------------------
       NCP Birmingham City Centre. Judes Street. Broken Machine but mis
       sed letter
       By: Smartdriver Date: January 10, 2025, 9:13 am
       ---------------------------------------------------------
       I have been a longtime lurker on this forum and its predecessor
       PePiPoo for many years but have never needed to ask for help
       myself until now so I hope you will be able to advise me. I
       recently found a box with a pile of unopened mail in it -
       someone in the house had 'moved it out of the way to deal with'
       and not told me, then forgotten it (yes I know, I know, don't
       ask. Anyway, we are where we are and have to deal with it now.
       I found a letter 25 July 2024 from NCP car parks with a parking
       charge notice for the Birmingham City Centre car park - Judes
       Street. I'm not entirely sure where that is as I've never
       actually parked there myself. It states my vehicle (I am the
       registered keeper) entered the car park at 14.57:34 and left at
       15.10.51 -  a total of just over 13 minutes.
       The circumstances as told to me by the driver (which was not me)
       was travelling with my 13 year old child, entered the car park,
       found a space and went to the machine, the only one in the car
       park, which was out of order. The driver then attempted to pay
       by the app detailed on the signage, but did not get a
       verification code to allow payment. They took a photo of the
       defective machine which was the only machine in the car park so
       there was no alternative way to pay. The driver, realising they
       would be  unable to pay, got back in the car and left the car
       park to find parking elsewhere. A couple of minutes later I
       found a verification code on my phone - I was at home. It seems
       like when using the bank card on the app, the details from the
       bank related to the bank card were linked to my phone number not
       the drivers. I immediately rang the driver to see what was going
       on, but by that point they had already driven out to park
       elsewhere.
       I also found a reminder letter (photo attached) and a number of
       letters from Trace Debt recovery, and now from Moorside Legal.
       They are stating I now owe £170.
       I guess we are now beyond the time of any appeal, so this will
       need to be treated as if it had been ignored (which it had, but
       not intentionally).
       What's the best approach here? Have I go any hope of fighting
       this and if so, what's the best way to go about doing it? (I'm
       assuming its best not to contact the legal people at this
       stage?)
       Thanks for any and all advice!
  HTML https://gbr01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fimgur.com%2Fa%2FpDXEwgn&data=05%7C02%7Csarah.marwick%40nhs.net%7Ce2dce5b915ca437e0c9308dd3188afbe%7C37c354b285b047f5b22207b48d774ee3%7C0%7C0%7C638721185310285100%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=SE5%2FmsqFd8PBxOEoWtdKIAmGkpVGKrV3SKKv2tVZgKQ%3D&reserved=0
  HTML https://gbr01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fimgur.com%2Fa%2FpDXEwgn&data=05%7C02%7Csarah.marwick%40nhs.net%7Ce2dce5b915ca437e0c9308dd3188afbe%7C37c354b285b047f5b22207b48d774ee3%7C0%7C0%7C638721185310285100%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=SE5%2FmsqFd8PBxOEoWtdKIAmGkpVGKrV3SKKv2tVZgKQ%3D&reserved=0
       #Post#: 52851--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: b789 Date: January 10, 2025, 10:14 am
       ---------------------------------------------------------
       Welcome. You are correct that it is now too late to appeal. No
       big deal. If you follow the advice, you won't be paying a penny
       to NCP.
       You can safely ignore any debt collectors or letters demanding
       money unless it is a Letter of Claim (LoC). If Moorside Legal
       are acting as a debt collector, you ignore them, at this stage.
       They will eventually issue an LoC which we need to know about
       but it is not important if it is not responded to.
       What will need to be responded to is the eventual N1SDT Claim
       Form that will come from the CNBC with Moorside Legal acting on
       behalf of NCP. When that is received, show it to us redacting
       only your personal details, the claim number, your VRM and the
       MCOL password. Make sure that the Particulars of Claim (PoC) and
       all dates remain visible.
       Moorside Legal always make a Fata mistake in the PoC of claims
       they issue and that is very valuable for your defence. The most
       likely outcome will be that the claim is struck out at
       allocation stage. Even if it wasn't, the claimant will
       discontinue before it gets to a hearing.
       Moorside Legal are bulk litigator and not a very good one at
       that. Easily beaten.
       So, when you receive the LoC, come back and let us know.
       #Post#: 52982--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: Smartdriver Date: January 11, 2025, 12:28 pm
       ---------------------------------------------------------
       Thank you so much. Really really helpful (and hopeful). So I
       guess I just have to wait now. Do you have any idea how long it
       might take?
       #Post#: 53018--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: b789 Date: January 12, 2025, 3:30 am
       ---------------------------------------------------------
       [quote author=Smartdriver link=topic=4611.msg52982#msg52982
       date=1736620132]
       So I guess I just have to wait now. Do you have any idea how
       long it might take?
       [/quote]
       It may never happen. However, it is more likely to happen sooner
       than later. Exactly how long? Who knows?
       They have up to 6 years to file a claim from the date of the
       alleged contacvention. So, if you change address in the next 6
       years, remember to let them know of your address change.
       #Post#: 55920--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: Smartdriver Date: January 30, 2025, 1:48 pm
       ---------------------------------------------------------
       Hi all.
       I have now received a letter entitled ‘Letter of Claim’ so I
       assume now is the point at which I have to do something.
       I’d very much welcome your advice on the next steps.
       Do you need to see the letter?
       #Post#: 55924--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: DWMB2 Date: January 30, 2025, 2:06 pm
       ---------------------------------------------------------
       Yes, please show us the letter.
       #Post#: 56271--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: Smartdriver Date: February 2, 2025, 2:07 pm
       ---------------------------------------------------------
  HTML https://imgur.com/a/FCmWG39
       Here you go, hope that works
       #Post#: 56325--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: b789 Date: February 3, 2025, 5:24 am
       ---------------------------------------------------------
       Respond as follows:
       [quote]Moorside Legal
       Jade Building
       Albion Mills
       Albion Road
       Greengates
       BD10 9TQ
       By email to: help@moorsidelegal.co.uk
       [Date]
       Dear Sirs,
       Re: Letter of Claim dated 20th January 2025
       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 £70 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?[/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.
       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.
       Yours faithfully,
       
[YOUR NAME][/quote]
       Save as a PDF file and attach to an email addressed to
       help@moorsidelegal.co.uk and also CC in yourself.
       #Post#: 56488--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: Smartdriver Date: February 3, 2025, 6:37 pm
       ---------------------------------------------------------
       Thanks. Should I at this point mention any of the original
       issues with this case? Or just respond in the terms below?
       #Post#: 56518--------------------------------------------------
       Re: NCP Birmingham City Centre. Judes Street. Broken Machine but
        missed letter
       By: b789 Date: February 4, 2025, 4:28 am
       ---------------------------------------------------------
       Just respond with the suggested letter. They are going to issue
       the claim, whatever is said. However, you can rest assured that
       when they do issue the claim, they will fail miserably by not
       complying with CPR 16.4(1)(a) which is most likely going to lead
       to the claim being struck out at allocation stage.
       It never fails to amuse me how incompetent the supposed
       "professional" legals are in fact anything of the sort. They are
       an embarrassment to their profession.
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