DIR Return Create A Forum - Home
---------------------------------------------------------
FreeTrafficLegalAdvice
HTML https://ftla.createaforum.com
---------------------------------------------------------
*****************************************************
DIR Return to: Private parking tickets
*****************************************************
#Post#: 75597--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: b789
Date: June 9, 2025, 1:51 pm
---------------------------------------------------------
I refer you to this in the opening line in post #19:
--- Quote from: b789 link ---
>
> It's only a POPLA appeal. Even if unsuccessful, it is not
binding and you do not need to pay. It has no bearing on
anything going forwards.
--- End Quote ---
You don't pay. You can safely ignore all debt recovery letters.
Debt collectors are powerless to do anything except to try and
persuade the low-hanging fruit on the gullible tree to pay up
out of ignorance and fear.
COme back when you receive a Letter of Claim (loC).
#Post#: 79567--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: Bobos
Date: July 4, 2025, 8:11 am
---------------------------------------------------------
Hi all
Just received a reminder letter from parking company.
Is there anything of note to be done with this? or just wait for
letter of claim
I presume the statutory wording required under Paragraph 9(2)(f)
of Schedule 4 to the Protection of Freedoms Act 2012, can't be
used here as its a reminder and not the original
I look forward to the replies
[attachment deleted by admin]
#Post#: 79579--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: b789
Date: July 4, 2025, 8:41 am
---------------------------------------------------------
Tha advice has not changed. You are waiting for a Letter of
Claim (LoC). Ignore everything else.
#Post#: 117902--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: Bobos
Date: May 6, 2026, 7:24 am
---------------------------------------------------------
Hi all
After receiving letters from Debt recovery plus then Empira I
now have a letter of claim from Gladstone solicitors.
What is the next step please
#Post#: 118380--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: Bobos
Date: May 12, 2026, 3:33 am
---------------------------------------------------------
Hello again
I would like some advice on the next step anyone?
I have seen some standard replies to send to solicitors just
want to be sure I send the right one. I can show the letter of
claim if needed.
Thanks in advance
#Post#: 118427--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: DWMB2
Date: May 12, 2026, 8:48 am
---------------------------------------------------------
--- Quote from: Bobos link ---
>
> I can show the letter of claim if needed.
>
--- End Quote ---
Yes please, it's hard to advise on a letter we have not seen.
In the meantime, searching to see how others may have responded
to similar letters would be good.
#Post#: 118435--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: Bobos
Date: May 12, 2026, 10:42 am
---------------------------------------------------------
Thank you for reply
I attach the LOC
HTML https://ibb.co/2330rSNf
HTML https://ibb.co/xKHBYzdc
This is the template reply[justify][/justify] is this the
correct one to send for the first direct contact to their
website as stated in letter.
"Dear Sirs,
Your Letter Before Claim contains insufficient detail of the
claim and fails to provide copies of evidence your client places
reliance upon and thus is in complete contravention of the
Pre-Action Protocol for Debt Claims.
As a firm of supposed solicitors, one would expect you to be
capable of crafting a letter that aligns 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 do not exist
for decoration—they exist to facilitate informed discussion and
proportionate resolution. You might wish to reacquaint
yourselves with them.
The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols
(Part 3), stipulate that prior to proceedings, parties should
have exchanged sufficient information to understand each other’s
position. Part 6 helpfully clarifies that this includes
disclosure of key documents relevant to the issues in dispute.
Your template letter mentions a “contract”, yet fails to provide
one. This would appear to undermine the only foundation upon
which your client’s claim allegedly rests. It’s difficult to
engage in meaningful pre-litigation dialogue when your side
declines to furnish the very document it purports to enforce.
I confirm that, once I am in receipt of a Letter Before Claim
that complies with the requirements of para 3.1 (a) of the
Pre-Action Protocol, I shall then seek advice and submit a
formal response within 30 days, as required by the Protocol.
Thus, I require your client to comply with its obligations by
sending me the following information/documents:
1. A copy of the original Notice to Keeper (NtK) that confirms
any PoFA 2012 liability
2. A copy of the contract (or contracts) you allege exists
between your client and the driver, in the form of an actual
photograph of the sign you contend was at the location on the
material date, not a generic stock image
3. The exact wording of the clause (or clauses) of the terms and
conditions of the contract(s) which is (are) relied upon that
you allege to have been breached
4. The written agreement between your client and the landowner,
establishing authority to enforce
5. A breakdown of the charges claimed, identifying whether the
principal sum is claimed as consideration or damages, and
whether the £70 “debt recovery” fee includes VAT
I am clearly entitled to this information under paragraphs 6(a)
and 6(c) of the Practice Direction. I also need it in order to
comply with my own obligations under paragraph 6(b).
If your client does not provide me with this information then I
put you on notice that I will be relying on the cases of Webb
Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch),
Daejan Investments Limited v The Park West Club Limited (Part
20) Buxton Associates [2003] EWHC 2872, Charles Church
Developments Ltd v Stent Foundations Limited & Peter Dann
Limited [2007] EWHC 855 in asking the court to impose sanctions
on your client and to order a stay of the proceedings, pursuant
to paragraphs 13, 15(b) and (c) and 16 of the Practice
Direction, as referred to in paragraph 7.2 of the Protocol.
Until your client has complied with its obligations and provided
this information, I am unable to respond properly to the alleged
claim and to consider my position in relation to it, and it is
entirely premature (and a waste of costs and court time) for
your client to issue proceedings. Should your client do so, then
I will seek an immediate stay pursuant to paragraph 15(b) of the
Practice Direction and an order that this information is
provided.
Yours faithfully,"
Thanks
#Post#: 119071--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: Bobos
Date: May 18, 2026, 9:19 am
---------------------------------------------------------
Hi all
Is there anything I need to add to this reply for the letter of
claim
Is b789 still active on this site?
#Post#: 119580--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: Bobos
Date: May 23, 2026, 10:06 am
---------------------------------------------------------
ill bump this one more time in the hope of a reply
Cheers
#Post#: 119586--------------------------------------------------
Re: Horizon pcn Millenium Retail Park Greenwich
DIR By: jfollows
Date: May 23, 2026, 10:56 am
---------------------------------------------------------
Your response should comply with the practice directions at
HTML https://www.justice.gov.uk/courts/procedure-rules/civil/rules/pd_pre-action_conduct#6.1
--- Quote ---
> the defendant responding within a reasonable time – 14 days in
a straight forward case and no more than 3 months in a very
complex one. The reply should include confirmation as to whether
the claim is accepted and, if it is not accepted, the reasons
why, together with an explanation as to which facts and parts of
the claim are disputed and
--- End Quote ---
If you understand and agree with the template reply you have
posted, that’s fine.
Otherwise modify it to match your understanding and the practice
directions above.
You’re documenting your understanding and engaging with the
process by doing so.
*****************************************************
Page 4 of 4
DIR Previous Page