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       #Post#: 91599--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
       By: b789 Date: September 26, 2025, 6:24 am
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       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][/quote]
       #Post#: 106511--------------------------------------------------
       Re: Parking Control Management - Robert Dashwood Way - SE17
       By: Glitch Date: January 19, 2026, 7:25 am
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       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).[/quote]
       Should I raise a formal complaint or should we let sleeping dogs
       lie?
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