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       #Post#: 91599--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: b789
       Date: September 26, 2025, 6:24 am
       ---------------------------------------------------------
       You respond to the LoC by email to help@moorsidelegal.co.uk and
       CC yoruself with the following:
       --- 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#: 106511--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: Glitch
       Date: January 19, 2026, 7:25 am
       ---------------------------------------------------------
       I sent the above (excellent) reply and have heard nothing since.
       Almost 4 months now.
       --- Quote ---
       > 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).
       --- End Quote ---
       Should I raise a formal complaint or should we let sleeping dogs
       lie?
       #Post#: 111709--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: Glitch
       Date: March 2, 2026, 4:18 am
       ---------------------------------------------------------
       Another LBA.
       Exactly the same as the previous one.
       Looks like it was triggered automatically by 6 months of nothing
       happening.
       Reply by email and repeat previous response?
  HTML https://i.ibb.co/k2KnTkrs/2nd-LBA-Feb-2026.jpg
  HTML https://ibb.co/Qv9BVzq3
       #Post#: 112400--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: Glitch
       Date: March 7, 2026, 5:08 pm
       ---------------------------------------------------------
       OK unless anyone has any other suggestions I'll get him to send
       them another email pointing out his previous reply still
       applies.
       #Post#: 112403--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: InterCity125
       Date: March 8, 2026, 3:01 am
       ---------------------------------------------------------
       Yes - do exactly that.
       Moorside appear to be in trouble.
       #Post#: 112410--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: DWMB2
       Date: March 8, 2026, 5:32 am
       ---------------------------------------------------------
       This seems to be happening semi regularly now. As I said in
       another post:
       --- Quote from: DWMB2 link ---
       >
       > [quote author=InterCity125 link=topic=4606.msg112288#msg112288
       date=1772816752]
       > Reply with the same text that you used in the previous
       response to the letter of claim.
       >
       --- End Quote ---
       I would add a paragraph pointing out that this is the second
       Letter of Claim they have sent in respect of the same alleged
       debt some [X] months apart. That you have already provided a
       response (which as a courtesy you are also providing again now)
       and that (if true) that they have failed to provide a
       substantive response.
       [/quote]
       #Post#: 115552--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: Glitch
       Date: April 10, 2026, 1:08 pm
       ---------------------------------------------------------
       The automated response to resending the email as follows:
  HTML https://i.ibb.co/60cWZpsB/Whats-App-Image-1-2026-04-08-at-15-31-15.jpg
  HTML https://ibb.co/r2KwtLys
  HTML https://i.ibb.co/kVZHCrtN/Whats-App-Image-2026-04-08-at-15-31-15.jpg
  HTML https://ibb.co/6cQnCpkj
       Seems a bit strange that their Customer Help email address is
       not monitored!
       #Post#: 115784--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: Glitch
       Date: April 14, 2026, 2:18 am
       ---------------------------------------------------------
       Do I ignore this, or call them, use the portal, or write to
       them?
       #Post#: 115785--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: InterCity125
       Date: April 14, 2026, 2:22 am
       ---------------------------------------------------------
       If it were me then I'd ignore this.
       You have responded the first time.
       This is clearly a problem with Moorside.
       #Post#: 115787--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
   DIR By: Glitch
       Date: April 14, 2026, 2:37 am
       ---------------------------------------------------------
       Thanks. That was my initial thought too.
       
       They've changed the automated response.
       First time they said they'd respond within 5 days. 6 months and
       no response. Seems like they can't cope with emails.
       Might still send the response by letter to give them something
       to chew on. They shouldn't get away with the abject LBC and
       might put them off going any further.
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