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       #Post#: 66713--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: rjcbooth666
       Date: April 12, 2025, 4:42 am
       ---------------------------------------------------------
       If it helps, this is the complaints procedure for RMG, which
       appears to be part of Placed for People:
       -----
       STATEMENT OF INTENT
       All RMG customers on developments RMG manages for Places for
       People will
       have their complaints dealt with under Places for People’s
       complaints process
       which the Housing Ombudsman oversees.
       Complaints may include:
       Delays or failure to provide a service
       Dissatisfaction with our policies and procedures
       Perceived unhelpful behaviour or treatment by staff or
       contractors
       Failure to achieve our published standards
       However, our complaints process is not suitable for determining
       disputes that
       relate to legal obligations between you and our clients or legal
       obligations
       between us and our clients.
       HOW DO I MAKE A FORMAL COMPLAINT?
       If your complaint is not resolved informally, and you feel that
       you need to take the
       matter further and raise a formal complaint, please write to the
       address below
       setting out your concerns together with copies of any
       documentation that will
       help us to investigate.
       Correspondence Address:
       RMG House
       Essex Road
       Hoddesdon
       Hertfordshire
       EN11 0DR
       Email Address: Customerservice@rmguk.com
       PUT IT RIGHT
       When you let us know that you have had a problem with our
       service, our priority
       is to ‘Put It Right’ for you. If the person taking the complaint
       can ‘Put It Right’ for
       you within 24 hours, we will consider your complaint as
       resolved.
       STAGE 1
       Places for People’s objective to resolve your complaint to your
       satisfaction within
       this first stage of the formal complaints procedure. The
       appropriate management
       team will work to address all of your concerns, provide detailed
       explanation to the
       matters raised and, where necessary, offer appropriate
       resolution. At Stage 1,
       complaint correspondence will be acknowledged within 5 working
       days of
       receipt. To allow time for detailed investigation, we will aim
       to provide a response
       within 10 working days.
       PLACES FOR PEOPLE (PFP)
       COMPLAINTS PROCEDURE
       STAGE 2
       In the event that you feel the matter needs to be taken further,
       then upon your
       request the complaint will proceed to Stage 2. Places for People
       will review your
       complaint and provide the final viewpoint and any offer made.
       Places for People
       will acknowledge your complaint within 5 working days of receipt
       and will aim to
       provide a response within 20 working days.
       Places for People is a member of the Housing Ombudsman. As a
       Places for
       People customer if you are still not satisfied following Stage 2
       you can refer your
       complaint to the Housing Ombudsman Service.
       The Housing Ombudsman Service is an independent organisation
       that
       investigates complaints. They are not an advocacy or support
       service (but there
       are other organisations who can help you with advocacy or
       support)
       You can ask the Housing Ombudsman Service to look at your
       complaint if:
       You have gone all the way through Places for People’s complaints
       handling
       procedure
       It is less than 12 months after you became aware of the matter
       you want to
       complain about; and
       The matter has not been (and is not being) considered in court
       The Housing Ombudsman Service will ask you to complete a
       complaint form
       and provide a copy of our final response to your complaint.
       You can do this online at:
       www.housing-ombudsman.org.uk/residents/make-a-complaint
       Or call them on: Free phone 0300 111 3000
       You may wish to get independent support or advocacy to help you
       progress your
       complaint.
       The Housing Ombudsman Service contact details are:
       Housing Ombudsman Service
       PO Box 152
       Liverpool
       L33 7WQ
       #Post#: 66730--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: b789
       Date: April 12, 2025, 7:30 am
       ---------------------------------------------------------
       RMG’s Stage 1 response fails to engage with the central legal
       point of your complaint: that you have a leasehold right to park
       in your space which cannot be overridden by UKCPS or RMG’s
       instructions to them.
       Their response rests on:
       [indent]• The age of the PCN, not the validity of the PCN.
       • An assumption that failure to appeal at the time equals
       forfeiture of rights.
       • A suggestion that you should now negotiate with a debt
       collector rather than RMG addressing its own agent's
       actions.[/indent]
       These are inadequate and misrepresent their responsibility as
       principal to UKCPS's agency.
       Below is a Stage 2 escalation letter, reinforcing your position
       and requesting a proper legal response. It also sets out that if
       not resolved, you will escalate to the Housing Ombudsman.
       --- Quote ---
       > Complaints Department
       > Residential Management Group
       > RMG House
       > Essex Road
       > Hoddesdon
       > EN11 0DR
       >
       > [Date]
       >
       > By email: customerservice@rmguk.com
       >
       > Subject: Escalation to Stage 2 – Formal Complaint Ref:
       04108974
       >
       > Dear Sir or Madam,
       >
       > I am writing to request escalation of my formal complaint
       (Ref: 04108974) to Stage 2 of the Places for People complaints
       procedure.
       >
       > I remain dissatisfied with the Stage 1 response from Jane
       Gillings, which wholly fails to address the substance of my
       complaint—namely, that UKCPS, acting under a contract with RMG,
       issued a Parking Charge Notice to me despite the fact that I was
       parked in my own allocated bay, exercising a leasehold right.
       >
       > As explained previously:
       >
       > [indent]• I am the leaseholder of Flat [flat No.] with an
       associated right to park in bay [bay No.], which forms part of
       the demised or common areas.
       > • This leasehold right to park is not conditional upon the
       display of a permit or compliance with any third-party terms
       imposed by UKCPS.
       > • The introduction of a permit scheme or third-party
       enforcement regime cannot override my legal rights without
       either my written consent or an application to the First-tier
       Tribunal under s.37(5) of the Landlord and Tenant Act
       1987.[/indent]
       >
       > Instead of engaging with these legal issues, the Stage 1
       response merely repeats UKCPS's internal rules and suggests I
       take the matter up with Moorgate Legal. This is both
       inappropriate and unsatisfactory. UKCPS are your appointed
       contractor, and RMG remains responsible for their actions on
       your behalf.
       >
       > I also note and object to your Property Manager’s earlier
       comment that UKCPS issues charges “irrespective of entitlement
       to park.” This statement demonstrates either a clear
       misunderstanding of leaseholder rights or a deliberate disregard
       for them. If RMG does not recognise or protect leaseholder
       rights granted under a lease, this represents a fundamental
       failure in property management standards.
       >
       > I must again insist on the following:
       >
       > [indent]1. That RMG confirm, in writing, that my allocated
       parking space is not and was never subject to enforcement by
       UKCPS;
       > 2. That RMG issue a clear instruction to UKCPS (and any
       subsequent parties, including Moorgate Legal) that this PCN is
       invalid and must be withdrawn;
       > 3. That RMG provide an explanation as to why no such
       instruction was issued earlier despite being made aware of my
       leasehold rights;
       > 4. That RMG acknowledge that my rights under the lease cannot
       be varied without due process under the Landlord and Tenant Act
       1987 and confirm no such variation has occurred.[/indent]
       >
       > If RMG/Places for People cannot or will not resolve this
       matter at Stage 2, I will have no choice but to refer the matter
       to the Housing Ombudsman Service, on the basis that your agents’
       actions have interfered with my quiet enjoyment of the property
       and subjected me to avoidable and unlawful enforcement action.
       >
       > I look forward to your detailed response within 20 working
       days as per your published complaints procedure.
       >
       > Yours faithfully,
       >
       > [Your Name]
       --- End Quote ---
       #Post#: 67039--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: rjcbooth666
       Date: April 14, 2025, 9:05 am
       ---------------------------------------------------------
       Thank you again. I have sent the stage 2 escalation email.
       #Post#: 67067--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: Charitynjw
       Date: April 14, 2025, 10:47 am
       ---------------------------------------------------------
       Derogation from grant is another useful phrase.  ;)
       #Post#: 69205--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: rjcbooth666
       Date: April 29, 2025, 8:34 am
       ---------------------------------------------------------
       Thanks for all your help so far. Here's an update. I sent the
       'escalation to stage 2' email on April 14. I received an
       acknowledgement of receipt email on April 17. This offered to
       provide me with a response within 20 working days.
       Meanwhile I received another letter from Moorside Legal dated
       April 8. It is a Letter of Claim giving me 30 days to return the
       reply form. One of the options on the form is to Dispute the
       debt.
       I've attached a scan. Please could you offer me more advice on
       my next steps.
       Thanks as always.
       [attachment deleted by admin]
       #Post#: 69266--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: b789
       Date: April 29, 2025, 1:34 pm
       ---------------------------------------------------------
       You only need to keep the LoC. You can dispose of all the forms
       that came with it. You don't give these bottom-dwelling
       incompetents any personal information.
       Respond as follows by email to help@moorsidelegal.co.uk and CC
       yourself:
       --- Quote ---
       > Dear Sirs,
       >
       > Re: Letter of Claim dated 8th April 2025
       >
       > I refer to your Letter of Claim, your ref: 10263288
       >
       > 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]
       --- End Quote ---
       #Post#: 69349--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: rjcbooth666
       Date: April 30, 2025, 6:05 am
       ---------------------------------------------------------
       Thank you. I've sent that email.
       Just to confirm, I should keep the LoC but at this stage I do
       not return the reply form outlining the reasons that I dispute
       the claim ie my car being legally parked in my own parking
       space. Is that correct?
       Thanks
       #Post#: 69352--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: b789
       Date: April 30, 2025, 6:22 am
       ---------------------------------------------------------
       All the forms that came with the LoC can be chucked in the bin.
       #Post#: 72909--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: rjcbooth666
       Date: May 23, 2025, 5:42 am
       ---------------------------------------------------------
       Hi again
       So I sent the email exactly as directed and I have just received
       the reply below. I don't know where they get the idea that I am
       seeking debt advice! They don't give up these parasites, do
       they? Please could you advise me on my next move. Your help is
       so appreciated.
       Dear ...
       Our reference: 10263288
       Our client: UKCPS Ltd
       We write further to your recent email.
       Our answers to your questions are as follows:
       The additional charge which has been levied on your Parking
       Charge of £70  is the amount set out in both the British Parking
       Association and International Parking Community Codes of
       Practice as the amount which may be added to a Parking Charge
       when a Parking Charge remains unpaid and when further recovery
       is required. Our Client adheres to the ATA’s Code of Practice.
       The £70 does not represent the cost of recovery but is a
       reasonable amount in relation to the Parking Charge amount, in
       order to encourage early payment of the Parking Charge without
       the need for debt recovery. It is a fair amount set by our
       Client’s government-approved Accredited Trade Association Code
       of Practice. There are however also costs incurred by our client
       in relation to debt recovery services.
       
       By entering and parking the vehicle on our client's private
       land, you agreed to enter into a contract with our client and to
       be bound by the terms and conditions of that contract. The terms
       and conditions were clearly displayed at the entrance and in
       prominent places within the car park. Due to your failure to
       comply with the terms and conditions, our client has issued the
       PCN therefore if we are instructed to issue a claim the reason
       would be for Unpaid parking charges/ breach of contract.
       We have noted on your account you are seeking debt advice and
       have placed the matter on hold for 30-days. If you fail to make
       payment after the 30-day period has lapsed, we may be instructed
       to issue a County Court Claim against you. 
       
       You may wish to seek independent legal advice.
       Yours sincerely
       Moorside Legal
       #Post#: 72941--------------------------------------------------
       Re: UKCPS sent penalty charge for parking in my own space
   DIR By: b789
       Date: May 23, 2025, 9:10 am
       ---------------------------------------------------------
       They are a firm of utter incompetent wannabe supposed legals. I
       suggest you respond with the following and CC in info@ukcps.net
       and yourself:
       --- Quote ---
       > Dear Sirs,
       >
       > Re: Your Reference 10263288 – UKCPS Ltd
       > Letter of Claim dated 8 April 2025
       >
       > I write in response to your email reply following my initial
       letter regarding the above matter. I now address the contents of
       your reply in full and set out further concerns with the conduct
       of this matter.
       >
       > 1. Procedural Background
       >
       > Your Letter of Claim dated 8 April 2025 made a vague demand in
       relation to an alleged parking charge, citing a total sum of
       £170. In response, I wrote to you confirming:
       >
       > [indent]• That the debt is denied;
       > • That my address for service should be updated;
       > • That the £70 surcharge appeared to be unjustified and
       potentially unlawful;
       > • That I required clarification on whether the PCN sum was
       being claimed as damages or as consideration for a contract;
       > • That boilerplate responses would not be accepted.[/indent]
       >
       > In your reply, you attempted to justify the additional £70 by
       reference to BPA and IPC Codes of Practice, asserting it was not
       a cost of recovery but a “reasonable amount” intended to
       encourage early payment. You claimed your client was pursuing a
       claim for unpaid parking charges due to a breach of contract.
       You also confirmed that you had placed the matter on hold for 30
       days on the assumption that I was seeking debt advice.
       >
       > Let me now make it absolutely clear that your Letter Before
       Claim was non-compliant with the Pre-Action Protocol for Debt
       Claims (PAPDC), and that your response has failed to correct or
       address these breaches.
       >
       > 2. Pre-Action Protocol Breaches
       >
       > Your Letter of Claim contained insufficient detail of the
       claim and failed to include copies of evidence your client
       relies upon. This is a breach of:
       >
       > [indent]• PAPDC paragraphs 3.1(a)–(d), 5.1, 5.2
       > • Practice Direction – Pre-Action Conduct, paragraphs 6(a) and
       6(c)[/indent]
       >
       > I remind you that the Protocol is binding on all parties,
       including your client, a serial issuer of consumer claims. Your
       failure to comply with these pre-action duties is unacceptable.
       >
       > 3. Request for Disclosure and Clarification
       >
       > Until your client complies with their obligations under the
       PAPDC, I cannot consider my position or respond substantively to
       the alleged claim. I therefore require the following information
       and documents under paragraphs 6(a) and 6(c) of the Practice
       Direction:
       >
       > [indent]1. An explanation of the cause of action.
       > 2. Whether your client is pursuing me as driver or registered
       keeper.
       > 3. Whether your client relies on Schedule 4 of the Protection
       of Freedoms Act 2012.
       > 4. Details of the alleged contravention: date, time, duration,
       and the calculation of the total sum claimed.
       > 5. If the claim is for breach of contract: the date of the
       contract, parties, and a copy of the alleged contract.
       > 6. Photographic evidence showing the vehicle allegedly in
       breach.
       > 7. If alleging trespass: full particulars and supporting
       authority.
       > 8. A copy of the contract with the landowner granting
       authority to litigate (as required by the Private Parking Single
       Code of Practice).
       > 9. A site plan showing sign placement.
       > 10. Photographs of signage (including font size and mounting
       height) at the time of the alleged contravention.
       > 11. A breakdown of the £170: original PCN sum, interest, admin
       or other charges.
       > 12. Clarification: is the £70 surcharge inclusive or exclusive
       of VAT? If inclusive, why am I as an alleged debtor being asked
       to pay your client’s VAT liability?
       > 13. Clarification: is the principal PCN sum alleged to be
       damages or consideration for a parking contract?[/indent]
       >
       > I remind you again that failure to provide this information
       may lead to an application to stay proceedings, in line with
       authorities such as:
       >
       > [indent]• Webb Resolutions Ltd v Waller Needham & Green [2012]
       EWHC 3529 (Ch)
       > • Daejan Investments Ltd v Park West Club Ltd [2003] EWHC 2872
       > • Charles Church Developments Ltd v Stent Foundations Ltd &
       Peter Dann Ltd [2007] EWHC 855 (TCC)[/indent]
       >
       > 4. Registered Keeper Position – VCS v Edward (2023)
       >
       > I confirm that I am the registered keeper of the vehicle. I
       decline to name the driver. As you are fully aware, there is no
       legal presumption in English law that the keeper of a vehicle
       was its driver.
       >
       > I refer you to the persuasive appellate reasoning in Vehicle
       Control Services Ltd v Ian Mark Edward (2023) [H0KF6C9C]
  HTML https://www.dropbox.com/scl/fi/yvxek3kfwtb3qent3lj6y/VCS-Limited-v-Ian-Mark-Edward-H0KF6C9C.pdf?rlkey=niecohfdtj1n1ysh5prbsp52p&e=1&dl=0,<br
       />in which the judge confirmed this principle.
       >
       > Your client cannot pursue me as the driver without evidence,
       and any reliance on a presumption of driver identity is
       misplaced and contrary to settled authority.
       >
       > 5. £70 Surcharge – VAT and Consumer Protection Concerns
       >
       > Your explanation of the £70 surcharge as an “incentive” to pay
       early is disingenuous. This sum is clearly:
       >
       > [indent]• Not a core term of any contract;
       > • Not proportionate as a pre-estimate of loss;
       > • Likely to be unenforceable under the Consumer Rights Act
       2015.[/indent]
       >
       > You have not answered my legitimate question about whether the
       £70 is VAT inclusive. I repeat: if the principal PCN is claimed
       as VAT-exempt but the £70 includes VAT, then your client’s
       approach raises serious concerns of potential VAT evasion, which
       I reserve the right to report to HMRC.
       >
       > 6. Next Steps
       >
       > As supposed solicitors, you should be well aware that these
       protocols and practice directions bind all potential litigants,
       regardless of the size or type of claim. Their stated purpose is
       to assist parties in understanding the claim, taking stock of
       their positions, and potentially resolving the dispute without
       recourse to litigation. It is frankly embarrassing that a
       regulated firm of solicitors would issue such a vague,
       unevidenced and non-compliant Letter of Claim.
       >
       > I confirm that, once I am in receipt of a Letter of Claim
       which fully complies with paragraph 3.1(a) of the PAPDC, I will
       consider my position and respond formally within 30 days as
       required by the Protocol.
       >
       > Please confirm that your client will not issue a claim until
       they have fully complied with their obligations under the
       Pre-Action Protocol. If a claim is issued prematurely, I will
       seek:
       >
       > [indent]• An immediate stay of proceedings under Practice
       Direction paragraph 15(b);
       > • Sanctions and costs pursuant to CPR 27.14(2)(g);
       > • Further disclosure in line with the above.[/indent]
       >
       > Should your client proceed to issue proceedings in defiance of
       these requests and without proper disclosure, I will assert a
       robust defence and may also consider a counterclaim for
       unreasonable behaviour.
       >
       > Yours faithfully,
       >
       > [Your Full Name]
       --- End Quote ---
       *****************************************************
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