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#Post#: 71367--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: b789
Date: May 13, 2025, 12:55 pm
---------------------------------------------------------
The deadline for an amended defence is 4pm on Tuesday 27th May.
If you've not had any response to that email by 27th May, you
can send the following as your amended defence:
--- Quote ---
>
> [quote]
> [center]IN THE COUNTY COURT AT ROMFORD[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> Parking Control Management (UK) Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> AMENDED DEFENCE[/center]
>
> 1.The Defendant denies the claim in its entirety and asserts
that no contract was formed and no debt is owed.
>
> 2. The claim was subject to an unless order dated 30 April
2025, requiring the Claimant to serve compliant particulars of
claim by 4pm within 7 days of service. The Claimant served them
late and did not apply for relief. The claim is therefore struck
out automatically.
>
> 3. Without prejudice to the above, the Defendant responds as
follows:
>
> 4. The further Particulars of Claim (PoC) embarrassingly fail
to fully comply with CPR 16.4 due to the lack of contractual
clarity and vague allegations.
>
> 5. The Defendant notes that the Claimant's Further Particulars
of Claim include evidence and narrative commentary that more
properly belongs in a witness statement. The purpose of
particulars is to set out a concise statement of the facts
relied on, not to present or argue the evidence. The Defendant
reserves the right to object to the Claimant's reliance on this
material at the witness statement stage, and invites the Court
to give directions to exclude any duplication or procedural
advantage the Claimant may seek to gain by conflating pleadings
with evidential submissions.
>
> 6. The Notice to Driver (NtD) evidenced does not specify a
period of parking, only a timestamp. This fails PoFA 7(2)(a), as
confirmed in Brennan v Premier Parking Solutions (2023)
[H6DP632H].
>
> 7. The Notice to Keeper (NtK) also fails PoFA 8(2)(a) for the
same reason. The Claimant cannot rely on PoFA to pursue the
Keeper.
>
> 8. Without a defined period of parking, there is no evidence
that the vehicle remained beyond the minimum consideration
period. No contract could have been formed.
>
> 9. The Claimant has failed to comply with CPR 16.4(1)(a). The
Further Particulars of Claim do not contain a concise statement
of the facts relied on. The only allegation is that the vehicle
was "Parked within a restricted area", which is too vague. There
is no explanation of how the area is "restricted" or what
specific restriction was breached.
>
> 10. The facsimile sign evidenced states "No parking outside of
the marked bays at anytime [sic]". There is no evidence the
vehicle was parked outside of a marked bay or in breach of this
or any other term.
>
> 11. The Claimant has not identified the driver. As the Notices
were defective, there can be no Keeper liability. The Defendant
puts the Claimant to strict proof.
>
> 12. The claim is for £204.22 but the initial charge was only
£100. No explanation or calculation is given for the additional
£104.22. There is no indication if this includes damages, debt
recovery fees, interest or VAT. No breakdown has been provided.
>
> 13. The Claimant provides no evidence of where any sign was
located in relation to the vehicle location. The single
evidential photo of a sign gives no context, is unlit and was
taken at night with flash.
>
> 14. The claim is poorly pleaded, disproportionate, and an
abuse of process. The Defendant invites the court to dismiss it
and to award costs if appropriate.
>
> 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 ---
[/quote]
#Post#: 71471--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: shamzuddin
Date: May 14, 2025, 9:10 am
---------------------------------------------------------
This is very helpful, thank you very much.
I have received this automated email response:
PLEASE TAKE NOTICE OF THE BELOW INFORMATION WITH REGARDS TO
SUBMITTING DOCUMENTS WITH THE COURT–
PLEASE NOTE, FAILURE TO FOLLOW THE BELOW RULES AND GUIDANCE WILL
RESULT IN YOUR CORRESPONDENCE NOT BEING ACTIONED
As of Thursday, 06/02/2025, Romford County Court will be
actively implementing and enforcing the compliance of submitting
documents to Court in accordance with CPR Rules
Any correspondence received via email must include Case/Claim
Number, and hearing date within the subject line
Please note, the Court will not accept any documents received
via email unless you have a hearing within the next 10 working
days. If your hearing is not within 10 working days, this must
be submitted via Royal Mail / DX. Manually submitted documents
must be deposited into the Court Post/Drop box. Under no
circumstances are documents to be handed to Security or staff –
this will be refused. No exceptions will be made.
The Court will only be accepting New Issue Applications and
Appeals via email providing they comply with the following
rules:
2.3 In the County Court—
(a) if a fee is payable in order for an e-mailed application or
other document to be filed with the court, a party must, when
e-mailing the court—
(i) both—
(aa) provide a Fee Account number which the party has authority
to charge for the applicable fee; and
(bb) authorise the court to charge the applicable fee to that
Account; or
(ii) outline the preferred method of payment (credit or debit
card) and provide the court with a contact number to take
payment over the telephone.
(Further information about using the Fee Account service may be
found at:
HTML https://www.justice.gov.uk/courts/fees/payment-by-account)
(b) when printed out on both sides of A4 paper, the following
documents, together, must not exceed 25 sheets of paper in
total—
(i) the e-mail;
(ii) any attachments, including any e-mail or document embedded
in any attachment; and
(iii) copies of the documents in paragraphs (i) and (ii) that
the court will serve where service is requested or required
under the rules;
(c) only one e-mail, including any attachments, may be sent to
the court to take any step in the proceedings and a party may
not send another e-mail or a hard copy of any additional
document as part of that step; and
(d) the total size of an e-mail, including any attachments, must
not exceed 10.0 megabytes.
2.4 The court may refuse to accept any application or other
document, including any attachment, e-mailed to the court where—
(a) the sender has not complied with paragraph 2.2;
(b) a fee is payable pursuant to paragraph 2.3(a) and—
(i) the sender has not complied with paragraph 2.3(a); or
(ii) the sender has complied with paragraph 2.3(a) but the court
has not been able to charge or take the fee; or
(c) the sender has not complied with paragraph 2.3(b) to (d).”
DOCUMENT SERVICE –
The following information with regards to the service of New
Issue / Appeals / Applications:
(a) If you require the Court to serve your application, you
must provide the Court with 3 separate copies of your
application in your email as a PDF attachment – the total number
of pages of all 3 copies, inclusive of your covering email, must
not exceed 75 double sided sheets of paper when printed.
ALTERNATIVELY: -
(b) If you do not require the Court to serve your documents, you
must ensure that this is clearly marked at the top of your
covering email at the time of submission.
PLEASE NOTE, COURT STAFF ARE UNABLE TO PROVIDE LEGAL ADVICE, IF
YOU REQUIRE ASSISTANCE, THE COURT STRONGLY RECOMMENDS CONTACTING
CITIZENS ADVICE BUREAU OR SEEKING PROFESSIONAL, QUALIFIED LEGAL
ADVICE.
#Post#: 71488--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: b789
Date: May 14, 2025, 10:18 am
---------------------------------------------------------
Since there is no hearing within 10 working days, and the email
did not include a new issue, application, or appeal, and the
message was general correspondence seeking clarification, it is
likely the court will not action the email unless an individual
court officer chooses to respond as a courtesy. According to the
rules in the auto-response, the email technically falls outside
what the court has agreed to process by email.
In which case, in order to ensure the court formally processes
your query and places it on the file (especially in case the
claim isn’t yet administratively marked as struck out), you
should send a postal letter to the court including:
[indent]• A brief covering letter referencing the unless order;
• A polite request for confirmation that the claim is struck
out;
• A copy of the claimant's late-served PoC if you wish to
evidence the non-compliance.[/indent]
You can use the following draft which you will then print and
send to the court by First Class post and make sure you get a
free "Proof of Posting" certificate from any post office or
simply drop it off by depositing it into the Court Post/Drop
box:
--- Quote ---
> [Your Full Name]
> [Your Address]
> [Postcode]
>
> [Email Address – optional]
> [Phone Number – optional]
>
> Date: [Insert today's date]
>
> To: The Court Manager
>
> Romford County Court
> 2a Oaklands Avenue
> Romford
> RM1 4DP
>
> Re: Claim No. [insert claim number]
>
> Parking Control Management (UK) Ltd v [Your Full Name]
>
> Unless Order dated 30 April 2025 – Request for Confirmation of
Automatic Strike-Out
>
> Dear Sir/Madam,
>
> I write in respect of the above claim and the unless order
issued by the court on 30 April 2025, which required the
Claimant to file and serve a compliant Particulars of Claim by
4:00pm within 7 days of service of the order.
>
> According to CPR 6.26, the order is deemed served on 2 May
2025, meaning the deadline for compliance expired at 4:00pm on
Friday 9th May 2025. The Claimant’s further Particulars of Claim
are dated 13 May 2025 and were served after this deadline. No
application for relief from sanctions has been received or
notified.
>
> The order clearly stated that if the Claimant failed to
comply, the claim would be struck out automatically and without
further order.
>
> Accordingly, I respectfully request that the court confirm
that the claim stands as struck out in accordance with paragraph
2 of the order and that the court record will be updated
accordingly.
>
> Please confirm in writing whether the court has recorded this
strike-out, or whether any further action is required.
>
> Yours faithfully,
>
> [Signature]
>
> [Your Name]
--- End Quote ---
#Post#: 71738--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: shamzuddin
Date: May 15, 2025, 3:11 pm
---------------------------------------------------------
I have today received this email response from the court:
"Dear Sirs,
With reference to your email below, the claimant having failed
to comply with the unless Order dated 30 April 2025, the claim
stands struck out.
Kind Regards
Romford County Court"
Can I safely assume that this case is now over and done with? Or
should I still send in writing just in case?
#Post#: 71740--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: b789
Date: May 15, 2025, 3:14 pm
---------------------------------------------------------
That's a win!
Just proves the incompetence of the supposed legal professionals
at Moorside Legal who are unable to fulfil a simple court order.
No need to send the letter I suggested yesterday.
#Post#: 71742--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: shamzuddin
Date: May 15, 2025, 3:21 pm
---------------------------------------------------------
You truly are a hero! Thank you very much for all your help,
time and efforts. May you continue to save many others from
these thieving scum. Good day to you sir
HTML https://emoji.tapatalk-cdn.com/emoji1319.png
#Post#: 115418--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: shamzuddin
Date: April 9, 2026, 5:03 am
---------------------------------------------------------
Hello,
I have received this letter in the post relating to a matter
that was thrown out almost a year ago
HTML https://ibb.co/Vc1ddQT2
HTML https://ibb.co/53zxSxC
HTML https://ibb.co/pBBVwMFQ
#Post#: 116687--------------------------------------------------
Parking Control Management PCN - Claim Struck Out - Allocated to
Small Claims
DIR By: shamzuddin
Date: April 22, 2026, 7:00 am
---------------------------------------------------------
Hello Everyone,
I received a PCN back in 2021, I was served with a County Court
Claim in 2025. After excellent help from users of this forum,
the claim was struck out on 10/07/2025.
Please see this thread:
HTML https://www.ftla.uk/private-parking-tickets/parking-control-management-pcn-moorside-legal-county-court-claim/
On 22 March 2026 I was served with a Notice of Allocation to the
Small Claims Track:
HTML https://ibb.co/6cvvXwpG
HTML https://ibb.co/rK83yCxh
HTML https://ibb.co/7d4qz7Pk
Any help regarding this matter will be greatly appreciated
#Post#: 116691--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: DWMB2
Date: April 22, 2026, 7:35 am
---------------------------------------------------------
I would phone the court and try to establish what has gone on.
I would follow this up in writing, ideally in reply to your
email confirming strike out, attaching a copy of this notice of
allocation, asking why you have received a notice of allocation
for a claim you have previously had confirmation has been struck
out.
#Post#: 116700--------------------------------------------------
Re: Parking Control Management PCN - Moorside Legal - County
Court Claim
DIR By: shamzuddin
Date: April 22, 2026, 9:50 am
---------------------------------------------------------
Hello,
This is the email reply I have received from the County Court
today:
On 04/09/2025 14:56:10 litigationteam@moorsidelegal.co.uk wrote:
Dear Sirs
Our Client: Parking Control Management (UK) Limited
Claim Number:
We act for the Claimant in the above matter and confirm that the
Order was complied with and therefore the strike out has been
actioned in error.
Please see below email filing the updated Particulars which were
filed the day the Courts Order was received.
Yours Faithfully
Sally Gravil
On 13/05/2025 14:44:44 litigationteam@moorsidelegal.co.uk wrote:
Dear Sirs
Our Client: Parking Control Management (UK) Limited
Claim Number:
We act for the Claimant in the above matter.
Please find attached the Claimant's Further Particulars of
Claim.
We confirm the same has been sent to the Defendant by way of
service. In compliance with CPR 5.2(b), please find attached the
Claimant's Certificate of Service confirming the same.
Yours Faithfully
Sally Gravil
I can confirm I have received no correspondence from either the
claimant or the court since the claim was struck out on
27/05/2026
HTML https://drive.google.com/file/d/1G7j8T-X8Wo5EcvXWW6zJEbcAGmmjXzMy/view?usp=drive_link
HTML https://drive.google.com/file/d/1gXs772Y7Etah9U8vWdbqEUk96vuoMM9C/view?usp=drive_link
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