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       #Post#: 59262--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: February 22, 2025, 1:13 am
       ---------------------------------------------------------
       Have been going through all replies and advices here and was
       wondering of the following.
       The response to LoC has been submitted the other day as per kind
       b789 advice.
       Having read estevenin comment about DCBL email of UKCP
       instructions to close this case, I thought is it worthy to send
       another follow up email to DCB Legal with a copy of email from
       DCBL or not worthy at this time?
       I do understand that DCBL (bailiffs) and DCB Legal are “two
       different firms on paper” but work together and therefore should
       know this already too? LoC was sent out by DCB Legal on 27th
       January but email was only sent by DCBL on 29th January.
       The email in a context of something similar like:
       Dear Sirs,
       Following my response to your LoC dated 27th January 2025, I am
       forwarding you a copy of email that was sent by DCBL on 29th
       January 2025. The email clearly states that UKPC instructed
       DCBL to close the case.
       I once again ask you to note that the alleged debt is fully
       disputed, and any court proceedings will be robustly defended.
       Yours sincerely
       [My Name]
       What are your thoughts please?
       #Post#: 59270--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: b789
       Date: February 22, 2025, 4:29 am
       ---------------------------------------------------------
       Do not make any further communication about letters from DCBL.
       Ignore anything and everything from DCBL. Their only job is to
       panic you into making mistakes.
       You seem to be under the misguided impression that there is some
       actual thought and human intervention that is going to step in
       and feel sorry for your plight. Get notion out of your head.
       You are dealing with a largely automated process that uses
       boilerplate templates and churns out hundreds of thousands of
       these LoCs a year. DCB Legal and DCBL are part of the same group
       but are completely separate legal entities. There is no “working
       together”.
       UKPC can instruct DGBL to close their case, as they put it. That
       does not mean that UKPC have closed “their” case. I would go so
       far as to suggest that UKPC have not been involved with this
       since a month after they issued the PCN.
       DCB Legal ARE going to issue a claim, whatever you do now. Wait
       for the claim to be issued. Once you are in receipt of the
       claim, you can SAR both UKOC and DCB Legal to find out exactly
       what correspondence there was between either of them and DCBL.
       It is not going to make any difference to the outcome which is
       going to be a strike out or a discontinuation.
       #Post#: 59304--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: February 22, 2025, 7:47 am
       ---------------------------------------------------------
       Thank you very much b789, my knowledge/experience in this field
       is minimal compared to yours and greatly appreciate your input.
       I can only wish that one day I would have a similar experience
       so could help other motorists to fight this multimillion pound
       industry that cares for nothing. I better start spending more
       time reading through these forums ☺️
       #Post#: 61258--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: March 7, 2025, 4:06 pm
       ---------------------------------------------------------
       So today I have received two replies from DCB Legal. The second
       email asked to ignore the first one and had additional picture
       added to the email. Both emails had pictures of the car parked
       in the spot, my appeal and response to it, and the second email
       had additional picture of the parking sign in the same car park.
       The first email was as follows:
       Dear xxx xxx,
       We write in response to your correspondence received in our
       office dated 18/02/2025.
       We now respond to the same as follows.
       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 due to breach of contract and not for loss or damages.
       The parking charge was issued correctly. See enclosed signage
       and appeal and response.
       The Parking Charge of £100.00 has been issued as per the
       Contract. A charge of £70.00 has been added to the sum as per
       the contractual costs outlined on the signs, as the Claimant has
       had to go to the expense of instructing debt collection agencies
       to recover the debt.
       The HMRC ‘VAT Supply and Consideration manual’ (VATSC06140),
       which was last updated on 02 September 2020, confirmed that
       parking charge notices falls out of the scope of VAT.
       Please note, our Client has not acted in a discriminatory
       manner, any vehicle to have been found in breach of the terms
       and conditions as per the signage would have been issued with a
       Parking Charge.
       You now have 30 days from the date of this email to make payment
       of £170.00. Failure to make payment may result in a Claim being
       issued against you without any further reference.
       Payment can be made via bank transfer to our designated client
       account: -
       Account Name: DCB Legal Ltd Client Account
       Sort Code: 20-24-09
       Account Number: 60964441
       You must quote the correct case reference (xxxxxxx) when making
       payment. If you do not, we may be unable to correctly allocate
       the payment. If further action is taken by us as a result of an
       incorrect reference being quoted, you will be liable for any
       further fees or costs incurred.
       Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to
       make payment over the telephone or online at
  HTML https://dcblegal.co.uk/response/pay-online/.
       
       Kind Regards,
       
       Lorraine Boardman
       Administration Associate
       DCB Legal Ltd
       
       Tel: 0203 434 0433 | DX 23457 Runcorn
       Then the following email was sent 3 minutes later:
       Dear xxx xxx,
       We write in response to your correspondence received in our
       office dated 18/02/2025.
       We now respond to the same as follows.
       Please ignore the previous email.
       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 due to breach of contract and not for loss or damages.
       The parking charge was issued correctly. See enclosed signage
       and appeal and response.
       The Parking Charge of £100.00 has been issued as per the
       Contract. A charge of £70.00 has been added to the sum as per
       the contractual costs outlined on the signs, as the Claimant has
       had to go to the expense of instructing debt collection agencies
       to recover the debt.
       The HMRC ‘VAT Supply and Consideration manual’ (VATSC06140),
       which was last updated on 02 September 2020, confirmed that
       parking charge notices falls out of the scope of VAT.
       Please note, our Client has not acted in a discriminatory
       manner, any vehicle to have been found in breach of the terms
       and conditions as per the signage would have been issued with a
       Parking Charge.
       You now have 30 days from the date of this email to make payment
       of £170.00. Failure to make payment may result in a Claim being
       issued against you without any further reference.
       Payment can be made via bank transfer to our designated client
       account: -
       Account Name: DCB Legal Ltd Client Account
       Sort Code: 20-24-09
       Account Number: 60964441
       You must quote the correct case reference (xxxx) when making
       payment. If you do not, we may be unable to correctly allocate
       the payment. If further action is taken by us as a result of an
       incorrect reference being quoted, you will be liable for any
       further fees or costs incurred.
       Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to
       make payment over the telephone or online at
  HTML https://dcblegal.co.uk/response/pay-online/.
       
       Kind Regards,
       
       Lorraine Boardman
       Administration Associate
       DCB Legal Ltd
       
       Tel: 0203 434 0433 | DX 23457 Runcorn
       Is there any need to reply to this or just wait for their
       further action?
       #Post#: 69860--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: May 3, 2025, 8:53 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > Do not make any further communication about letters from DCBL.
       Ignore anything and everything from DCBL. Their only job is to
       panic you into making mistakes.
       >
       > You seem to be under the misguided impression that there is
       some actual thought and human intervention that is going to step
       in and feel sorry for your plight. Get notion out of your head.
       >
       > You are dealing with a largely automated process that uses
       boilerplate templates and churns out hundreds of thousands of
       these LoCs a year. DCB Legal and DCBL are part of the same group
       but are completely separate legal entities. There is no “working
       together”.
       >
       > UKPC can instruct DGBL to close their case, as they put it.
       That does not mean that UKPC have closed “their” case. I would
       go so far as to suggest that UKPC have not been involved with
       this since a month after they issued the PCN.
       >
       > DCB Legal ARE going to issue a claim, whatever you do now.
       Wait for the claim to be issued. Once you are in receipt of the
       claim, you can SAR both UKOC and DCB Legal to find out exactly
       what correspondence there was between either of them and DCBL.
       >
       > It is not going to make any difference to the outcome which is
       going to be a strike out or a discontinuation.
       >
       --- End Quote ---
       Hi b789,
       You were absolutely right that DCB Legal are going to issue a
       claim. I have now received a Calim Form from Civil National
       Business Centre issued on 22nd April .
       I do understand that I need to notify tribunal court that I
       intend to defend all of this claim. Is there anything I need to
       add to it at this stage or just that notification is enough?
       Also, you mentioned that I can SAR both UKOC and DBC LEgal on
       the receipt of the claim. Should I start preparing the text for
       that now and should I also expand it to DCBL as well, as I have
       an email from their where they stated that UKOC instructed them
       to drop the claim?
       #Post#: 69865--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: b789
       Date: May 3, 2025, 10:27 am
       ---------------------------------------------------------
       Before you do anything, show us the N1SDT Claim Form. We only
       need to see the page with the Particulars of Claim (PoC) on it.
       Only redact your personal info, the claim number and the MCOL
       password. Leave everything else on it visible, especially all
       dates.
       Once I know the actual issue date, I can tell you your deadlines
       and how to respond.
       #Post#: 69870--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: May 3, 2025, 11:13 am
       ---------------------------------------------------------
       Thank you b789.
       The claim form is here
  HTML https://imgur.com/a/MrdAr3X
       #Post#: 69881--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: b789
       Date: May 3, 2025, 11:48 am
       ---------------------------------------------------------
       With an issue date of 22nd April, you have until 4pm on Monday
       12th May to submit your defence. If you submit an
       Acknowledgement of Service (AoS) before then, you would then
       have until 4pm on Tuesday 27th May to submit 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
       Otherwise, here is the defence and link to the draft order that
       goes with it. You only need to edit your name and the claim
       number. You sign the defence by typing your full name for the
       signature and date it. There is nothing to edit in the draft
       order.
       When you're ready you combine both documents as a single PDF
       attachment and send as an attachment in an email to
       claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim
       number must be in the email subject field and in the body of the
       email just put: "Please find attached the defence and draft
       order in the matter of UK Parking Control Ltd v [your full name]
       Claim no.: [claim number]."
       --- Quote ---
       > [center]IN THE COUNTY COURT[/center]
       > [right]Claim No: [Claim Number][/right]
       >
       > [center]BETWEEN:
       >
       > UK Parking Control Ltd
       > Claimant
       >
       > - and -
       >
       > [Defendant's Full Name]
       > 
Defendant
       >
       >
       ---------------------------------------------------------
       >
       > DEFENCE[/center]
       >
       > 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 comply with CPR
       16.4.
       >
       > 3. The Defendant is unable to plead properly to the PoC
       because:
       >
       > [indent](a) The contract referred to is not detailed or
       attached to the PoC in accordance with CPR PD 16(7.5);
       >
       > (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.[/indent]
       >
       > 4. The Defendant attaches to this defence a copy of a draft
       order approved by a district judge at another court. The court
       struck out the claim of its own initiative after determining
       that the Particulars of Claim failed to comply with CPR 16.4.
       The judge noted that the claimant had failed to:
       >
       > [indent](i) Set out the exact wording of the clause (or
       clauses) of the terms and conditions relied upon;
       >
       > (ii) Adequately explain the reasons why the defendant was
       allegedly in breach of contract;
       >
       > (iii) Provide separate, detailed Particulars of Claim as
       permitted under CPR PD 7C.5.2(2).
       >
       > (iv) The court further observed that, given the modest sum
       claimed, requiring further case management steps would be
       disproportionate and contrary to the overriding objective.
       Accordingly, the judge struck out the claim outright rather than
       permitting an amendment.[/indent]
       >
       > 5. 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 for the Claimant’s failure to comply with
       CPR 16.4.
       >
       > Statement of truth
       >
       > I believe that the facts stated in this Defence are true. I
       understand that proceedings for contempt of court may be brought
       against anyone who makes, or causes to be made, a false
       statement in a document verified by a statement of truth without
       an honest belief in its truth.
       >
       > Signed:
       >
       >
       > Date:
       --- End Quote ---
       Draft Order for the defence
  HTML https://www.dropbox.com/scl/fi/tcewefk7daozuje25chkl/Strikeout-order-v2.pdf?rlkey=wxnymo8mwcma2jj8xihjm7pdx&st=nbtf0cn6&dl=0
       #Post#: 69888--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: May 3, 2025, 1:13 pm
       ---------------------------------------------------------
       Thank you very much b789, thank you very much
       #Post#: 78783--------------------------------------------------
       Re: DCB Legal Letter of Claim - Uk Parking Control Limited
   DIR By: robbieuk
       Date: June 29, 2025, 9:26 am
       ---------------------------------------------------------
       So since I have submitted suggested defence I have received an
       email from dcb legal stating that they will take the matter
       further. They say that they have filed N180 - direct
       questionnaire with the court.
       I am now waiting for further documents from the court or
       mediation (?) .
       What surprised me was Section F of their N18. I coy what it said
       -
       F. About the hearing
       Hearing venue
       F1
       At which County Court hearing centre would you prefer the small
       claims hearing to take place and why?
       Claimant's home court
       What would court decide to do if I would ask for the hearing to
       take place at my home court?
       There’s a link to the email and N180
  HTML https://imgur.com/a/bI2LYPM
       *****************************************************
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