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#Post#: 95019--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: b789
Date: October 21, 2025, 9:37 am
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Respond by email to info@dcblegal.co.uk and CC yourself:
--- Quote ---
> Subject: Response to your Letter of Claim Ref: [reference
number]
>
> Dear Sirs,
>
> Your Letter Before Claim contains insufficient detail of the
claim and fails to provide copies of the evidence your client
places reliance upon, putting it in clear breach of the
Pre-Action Protocol for Debt Claims.
>
> As a supposed firm of solicitors, one would expect you to
comply with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol,
and paragraphs 6(a) and 6(c) of the Practice Direction. These
provisions exist to facilitate informed discussion and
proportionate resolution. You may wish to reacquaint yourselves
with them.
>
> The Civil Procedure Rules 1998, Pre-Action Conduct and
Protocols (Part 3), require the exchange of sufficient
information to understand each other’s position. Part 6
clarifies that this includes disclosure of key documents
relevant to the issues in dispute.
>
> Your template letter refers to a “contract” yet encloses none.
That omission undermines the only foundation upon which your
client’s claim allegedly rests. It is not possible to engage in
meaningful pre-litigation dialogue while you decline to furnish
the very document you purport to enforce.
>
> I confirm that, once I am in receipt of a Letter Before Claim
that complies with para 3.1(a), I shall seek advice and submit a
formal response within 30 days, as required. Accordingly, please
provide:
>
> [indent]1. A copy of the original Notice to Keeper (NtK) and
any notice chain relied upon to assert PoFA 2012
liability.

> 2. A copy of the contract you allege exists between your
client and the driver, being an actual photograph of the sign(s)
in place on the material date (not a stock image), together with
a site plan showing the sign locations.

> 3. The precise wording of the clause(s) allegedly breached.
> 
4. The written agreement between your client and the
landowner evidencing standing/authority to enforce and to
litigate.

> 5. A breakdown of the sums claimed, identifying whether the
principal sum is claimed as consideration or damages, and
whether the £70 “debt recovery” add-on includes
VAT.
[/indent]
>
> I am entitled to this information under paragraphs 6(a) and
6(c) of the Practice Direction, and I require it to meet my own
obligation under paragraph 6(b).
>
> If you fail to provide the above, I will treat that as
non-compliance with the PAPDC and Pre-Action Conduct and will
raise a formal complaint to the SRA regarding your conduct. I
reserve the right to place this correspondence before the Court
and to seek appropriate sanctions and costs (including, where
appropriate, a stay and/or other case management orders).
>
> Until your client complies and provides the requested
material, I am unable to respond properly to the alleged claim
or to consider my position. It would be premature and a waste of
costs and court time to issue proceedings. Should you do so, I
will seek immediate case management relief pursuant to paragraph
15(b) of the Practice Direction and an order compelling
provision of the above.
>
> Please note, I will not engage with any web portal; I will
only respond by email or post.
>
> Yours faithfully,
>
> [Your name]
--- End Quote ---
#Post#: 95035--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: AyGee
Date: October 21, 2025, 10:27 am
---------------------------------------------------------
Thank you
Received an automated response
Please note that we will aim to respond to your correspondence
where required as soon as possible. In the meantime, should you
be contacting in relation to a Parking Charge, you can find some
Frequently asked Questions (FAQs) on our website
www.dcblegal.co.uk
Should you wish to make a payment, you can do this by calling
0330 1744 172, visiting
HTML https://dcblegal.co.uk/response/pay-online/
or by bank transfer
to the below bank details. Please ensure your DCB legal
reference number is quoted with any payments made.
Account number: 60964441
Sort Code: 20-24-09
Should you be in receipt of a letter of claim, please visit
www.dcblegal.co.uk/response where you will find further
information and be able to reply to the form accordingly.
Assume that they have an obligation to respond to email and I
don't need to fill out their form.
#Post#: 95045--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: b789
Date: October 21, 2025, 11:34 am
---------------------------------------------------------
Where has anyone mentioned "filling out their form"? You can
trash any forms they included with it.
Yes, they are required to respond.
#Post#: 100661--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: AyGee
Date: December 2, 2025, 6:55 am
---------------------------------------------------------
I have a received a claim form and a WP email from the
solicitors
Dear ,
We act for the Claimant,
It is our position that the Letter of Claim ("LOC") is compliant
with the Pre-Action Protocol for Debt Claims ("the Protocol").
The LOC provides adequate information for you to identify the
debt that our Client is seeking to recover. We respectfully draw
your attention to paragraph 2.1(c) of the Protocol and remind
you that both parties are expected to act reasonably and
proportionately.
When parking on private land, the contractual terms of the site
are set out on the signs. You are entering a contract and
agreeing to the terms by parking and staying on the site.
Parking in breach of the terms as stipulated on the signage
means that you are then breaking the terms of the contract.
The terms and conditions on the signs stated that parking was
permitted for vehicles parked wholly within a marked bay. The
vehicle was not parked within a marked bay as is demonstrated in
the photographic evidence enclosed. The parking charge was
issued correctly.
The amount owed is a genuine pre-estimate of the losses incurred
in managing the parking location to ensure compliance with the
clearly displayed terms and conditions. However, in Parking Eye
Ltd v Beavis, it was found, both at County Court and Court of
Appeal level, that appealing a Parking Charge on the basis that
the amount is not a genuine pre-estimate of loss is, in fact,
not a successful legal defence.
As payment was not made, either within 14 or 28 days, the
creditor was entitled to instruct debt recovery agents and
Solicitors to pursue payment and is entitled to recover the
costs of doing so. It would have been made clear in the terms
and conditions set out in the signs that additional enforcement
costs may be incurred in the event of non-payment.
The Notice to Keeper was issued to you on 24/01/2025. A copy is
attached. You were afforded the opportunity to; appeal the
parking charge, transfer liability to the driver (if it was not
you) or make payment. Neither a successful appeal, nor an
adequate nomination were received, yet payment remains
outstanding.
The Reminder Notice was issued to you on 07/02/2025. A copy is
attached. This notice reiterated that payment was outstanding
and confirmed that legal action may be taken, and additional
costs incurred if the parking charge was not paid.
If there are any documents that you have requested, but that are
not attached, it is because we have deemed the request to be
disproportionate and/or not relevant to the substantive issues
in dispute. We respectfully draw your attention to paragraph
2.1(c) of the Protocol and remind you that both parties are
expected to act reasonably and proportionately.
WITHOUT PREJUDICE SAVE AS TO COSTS
Please note, the Claim was issued on [].
Our Client may be prepared to settle this Claim. I can confirm
our Client would be agreeable to £215.00 in full and final
settlement of the matter. The current outstanding balance is
£266.20.
You now have 7 days from the date of this email to make payment
of £215.00. Failure to make payment may result in the Claim
proceeding to the next stage.
Payment can be made via bank transfer to our designated client
account: -
#Post#: 100676--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: b789
Date: December 2, 2025, 7:56 am
---------------------------------------------------------
What is a "WP" email??? Are you saying that you have received a
response to your requests made in response to their LoC AND also
received a "Claim Form" at the same time?
Why have you not shown the Claim Form? Please don't show us
anything but the N1SDT form with the Particulars of Claim (PoC)
on it. No one needs to see all the other blank forms that come
with it. DO NOT redact any dates or times whatsoever.
#Post#: 100687--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: AyGee
Date: December 2, 2025, 8:34 am
---------------------------------------------------------
WP Letter is the Without Prejudice email I received with the
over of settlement that I enclosed I had copied into my previous
post
HTML https://cdn.imgpile.com/f/ZuVxSqE_xl.jpg
#Post#: 100697--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: b789
Date: December 2, 2025, 9:18 am
---------------------------------------------------------
With an issue date of 27th November, you have until 4pm on
Tuesday 16th December to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Tuesday 30th December to submit your defence.
You only need to submit an AoS if you need extra time to prepare
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
Until very recently, we never advised using the MCOL to submit a
defence. However, due to recent systemic failures within the
CNBC, we feel that it is safer to now submit a short defence
using MCOL as it is instantly submitted and entered into the
"system". Whilst it will deny the use of some formatting or
inclusion of transcripts etc. these can always be included with
the Witness Statement (WS) later, if it ever progresses that
far.
You will need to copy and paste it into the defence text box on
MCOL. It has been checked to make sure that it will fit into the
122 lines limit.
--- Quote ---
> 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 adequately comply
with CPR 16.4.
>
> 3. The Defendant is unable to plead properly to the PoC
because:
>
> (a) The contract referred to is not detailed or attached to
the PoC in accordance with PD 16, para 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.
>
> 4. The Defendant submits that courts have previously struck
out materially similar claims of their own initiative for
failure to adequately comply with CPR 16.4, particularly where
the Particulars of Claim failed to specify the contractual terms
relied upon or explain the alleged breach with sufficient
clarity.
>
> 5. In comparable cases involving modest sums, judges have
found that requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, strike-out was deemed appropriate. 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
due to the Claimant’s failure to adequately comply with CPR
16.4, rather than permitting an amendment. The Defendant
proposes that the following Order be made:
>
> Draft Order:
>
> Of the Court's own initiative and upon reading the particulars
of claim and the defence.
>
> AND the court being of the view that the particulars of claim
do not adequately comply with CPR 16.4(1)(a) because: (a) they
do not set out the exact wording of the clause (or clauses) of
the terms and conditions of the contract which is (or are)
relied on; and (b) they do not adequately set out the reason (or
reasons) why the claimant asserts that the defendant was in
breach of contract.
>
> AND the claimant could have complied with CPR 16.4(1)(a) had
it served separate detailed particulars of claim, as it could
have done pursuant to PD 7C, para 5.2, but chose not to do so.
>
> AND upon the Court determining, having regard to the
overriding objective (CPR 1.1), that it would be
disproportionate to direct further pleadings or to allot any
further share of the Court’s resources to this claim (for
example by ordering further particulars of claim and a further
defence, with consequent case management).
>
> ORDER:
>
> 1. The claim is struck out.
>
> 2. Permission to either party to apply to set aside, vary or
stay this order by application on notice, which must be filed at
this Court not more than 7 days after service of this order,
failing which no such application may be made.
--- End Quote ---
#Post#: 100704--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: AyGee
Date: December 2, 2025, 9:41 am
---------------------------------------------------------
Thank you. What is the process from there and are they likely to
take it any further if they see I am not backing down (which I
have no intention of doing)?
#Post#: 100713--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: b789
Date: December 2, 2025, 9:55 am
---------------------------------------------------------
You can search the forum for any DCB Legal issued claim what the
process is and how it ends. It will be processed all the way to
allocation to your local county court and once a hearing date is
set, there will be a deadline for them to pay the £27 trial fee,
four weeks before the hearing. Just before then you will receive
an N279 Notice of Discontinuance. You are looking at anything
from 6-12 months from now before this ends.
As long as you follow the advice, you will not be paying a penny
to UKPC. DCB Legal's MO is to press on until they discontinue in
the hope that you are low-hanging fruit on the gullible tree and
can be intimidated into paying out of ignorance and fear.
#Post#: 100997--------------------------------------------------
Re: UKPC Parking Notice - Not Parked Correctly within the
Markings - Beckton Triangle Retail Park
DIR By: AyGee
Date: December 4, 2025, 8:51 am
---------------------------------------------------------
Great, that's been filed. I'm also going to ignore the email
they sent over offering me a discounted settlement.
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