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#Post#: 71363--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: May 13, 2025, 12:33 pm
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Just an update. My original email bounced because the email
address was 1 letter off, Gladstones instead of Gladstone.
They've since promptly replied asking for Car Reg, Claim Date
and Postcode, which I shared.
#Post#: 71837--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: May 16, 2025, 11:04 am
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--- Quote from: b789 link ---
>
> What date did you send the DRN and how did you send it? If by
post, did you get a free proof of posting certificate from the
post office? If by email, did you CC in yourself?
>
> What "complaint" did you fail to send to EPS? Are you saying
you failed to request a copy of the original NtK?
>
> You now have a Letter of Claim (LoC) which means that you are
going to receive an N1SDT Claim Form from the CNBC in the post
after 30 days from. the date of the LoC.
>
> If you doubt follow the advice and then come asking for
further advice, why do you expect us to help you?
>
> For now, you respond to the LoC with the following:
>
> [quote]Dear Sirs,
>
> Your Letter Before Claim dated 24th April 2025 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.
>
> I am the registered keeper of the vehicle. I am not obliged to
identify the driver and I decline to do so. As there is no legal
presumption that the keeper of a vehicle was its driver on any
particular occasion, your client cannot pursue me as driver as
per VCS v Edward (20230) [H0KF6C9C].
>
> I will defend any claim vigorously and seek costs in relation
to your client’s unreasonable and vexatious conduct under Part
27.14(2)(g)
>
> As your letter lacks specificity and breaches the requirements
of the Pre-Action Protocol for Debt Claims (paragraphs
3.1(a)-(d), 5.1 and 5.2) as well as the Practice Direction -
Pre-Action Conduct (paragraphs 6(a) and 6(c)), you must treat
this letter as a formal request for all of the
documents/information that the protocol now requires your client
to provide. Your client must not issue proceedings without
complying with that protocol.
>
> As solicitors you must surely be familiar with the
requirements of both the Practice Direction and the Pre-Action
Protocol for debt claims and your client, as a serial litigator
of debt claims, should likewise be aware of them. As you (and
your client) must know, the Practice Direction and Protocol bind
all potential litigants, whatever the size or type of the claim.
Its express purpose is to assist parties in understanding the
claim and their respective positions in relation to it, to
enable parties to take stock of their positions and to negotiate
a settlement, or at least narrow the issues, without incurring
the costs of court proceedings or using up valuable court time.
It is embarrassing that a firm of Solicitors are sending a
consumer a vague and un-evidenced 'Letter Before Claim' in
complete ignorance of the pre-existing Practice Direction and
the Pre-Action Protocol.
>
> 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:
>
> [indent]1. An explanation of the cause of action
> 2. whether they are pursuing me as driver or keeper
> 3. whether they are relying on the provisions of Schedule 4 of
POFA 2012
> 4. what the details of the claim are; for how long it is
claimed the vehicle was parked, how the monies being claimed
arose and have been calculated
> 5. Is the claim for a contractual breach? If so, what is the
date of the agreement? The names of the parties to it and
provide to me a copy of that contract.
> 6. If the claim is for a contractual breach, photographs
showing the vehicle was parked in contravention of said
contract.
> 7. Is the claim for trespass? If so, provide details.
> 8. Provide me a copy of the contract with the landowner under
which they assert authority to bring the claim, as required by
the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
> 9. a plan showing where any signs were displayed
> 10. Photographs of the signs displayed (size of sign, size of
font, height at which displayed) at the time of any alleged
contravention.
> 11. Provide details of the original charge, and detail any
interest and administrative or other charges added
> 12. Am I to understand that the additional £60 represents what
is dressed up as a 'Debt Recovery' fee, and if so, is this nett
or inclusive of VAT? If the latter, would you kindly explain why
I am being asked to pay the operator’s VAT?
> 13. With regard to the principal alleged PCN sum: Is this
damages, or will it be pleaded as consideration for parking?
>
> 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
--- End Quote ---
[/quote]
Hiya,
Okay so they have just replied and and she did not respond to
many of the things requested:
"Dear xxxxx,
Thank you for your email dated 14th May 2025.
Please find attached the Evidence Packs which we trust to be
self explanatory.
Our Client is therefore satisfied the case against you should
proceed unless the debt owing of £160.00 is discharged in full.
To ensure no further action is taken, you should make payment on
or before 14th June 2025.
If you do not make payment, we are instructed to issue legal
proceedings to recover the outstanding balance in full. Should
it become necessary to issue legal proceedings, we suggest you
follow the steps on the claim form upon receipt of the same.
Payment can be made to the account detailed as follows:
Gladstones Solicitors Ltd
Barclays Bank
Account Number: 33028712
Sort Code: 20-24-09
Please quote the above reference number XXXXX when making
payment to ensure the payment can be allocated correctly.
Kind Regards
Legal Assistant "
She attached
1. Time/Dated pictures of the vehicle facing in and out 2.5hrs
apart.
2. Notice to Keeper Top
HTML https://photos.app.goo.gl/pbPzpTwK1j3c4m8x6
Notice to Keeper
Bottom
HTML https://photos.app.goo.gl/fzRdq5bJEcpMG7Fw5
3. PCN Final Reminder Top
HTML https://photos.app.goo.gl/8xgGJYLzucAYQkaw7
PCN Final Reminder
Bottom
HTML https://photos.app.goo.gl/2LeBgPZeVq5KD4Jm9
4. Letter Before Court Action
HTML https://photos.app.goo.gl/h6SzViYzaDt7xkmo9
#Post#: 71873--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: b789
Date: May 16, 2025, 1:49 pm
---------------------------------------------------------
You should respond with a brief email such as:
--- Quote ---
> Subject: Re: Your Letter Before Claim – Non-Compliance
>
> Dear Sirs,
>
> Thank you for your reply dated 14th May 2025.
>
> Unfortunately, your client has failed to rectify the material
non-compliance of your Letter Before Claim with the Pre-Action
Protocol for Debt Claims. The 'evidence packs' do not satisfy
the disclosure requirements set out in paragraphs 3.1, 5.1 and 6
of the Protocol. For example, there is still no cause of action
properly pleaded, no copy of any contract with the landowner, no
explanation of the legal basis for the £60 'debt recovery' sum,
and no indication as to whether your client is pursuing me as
the driver or the keeper.
>
> I repeat my request that your client provide a compliant
Letter Before Claim before commencing proceedings. If your
client issues a claim without doing so, I reserve the right to
seek a stay and invite the court to impose sanctions for failure
to comply with the Protocol.
>
> Yours faithfully,
>
> [Name]
--- End Quote ---
This keeps the pressure on them to act reasonably and gives you
better footing later to request a stay or strike-out, especially
under PD Pre-Action Conduct paras 13–16 and CPR 1.1/1.3
(overriding objective and parties' duty to help the court).
#Post#: 71904--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: May 16, 2025, 5:09 pm
---------------------------------------------------------
Done
#Post#: 77688--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: June 23, 2025, 6:09 am
---------------------------------------------------------
--- Quote from: b789 link ---
>
> You should respond with a brief email such as:
>
> [quote]Subject: Re: Your Letter Before Claim – Non-Compliance
>
> Dear Sirs,
>
> Thank you for your reply dated 14th May 2025.
>
> Unfortunately, your client has failed to rectify the material
non-compliance of your Letter Before Claim with the Pre-Action
Protocol for Debt Claims. The 'evidence packs' do not satisfy
the disclosure requirements set out in paragraphs 3.1, 5.1 and 6
of the Protocol. For example, there is still no cause of action
properly pleaded, no copy of any contract with the landowner, no
explanation of the legal basis for the £60 'debt recovery' sum,
and no indication as to whether your client is pursuing me as
the driver or the keeper.
>
> I repeat my request that your client provide a compliant
Letter Before Claim before commencing proceedings. If your
client issues a claim without doing so, I reserve the right to
seek a stay and invite the court to impose sanctions for failure
to comply with the Protocol.
>
> Yours faithfully,
>
> [Name]
--- End Quote ---
This keeps the pressure on them to act reasonably and gives you
better footing later to request a stay or strike-out, especially
under PD Pre-Action Conduct paras 13–16 and CPR 1.1/1.3
(overriding objective and parties' duty to help the court).
[/quote]
I haven't since heard back from them in the 5 weeks since I sent
them the above response. Do you think I sHould I just wait some
more or send them the email again with myself CC in
#Post#: 77706--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: b789
Date: June 23, 2025, 7:21 am
---------------------------------------------------------
No. The ball is in their court. If you don't receive a response
in the next 6-8 weeks, the remind us.
#Post#: 77722--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: June 23, 2025, 7:58 am
---------------------------------------------------------
oki doki
thank you
#Post#: 99859--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: November 26, 2025, 5:27 am
---------------------------------------------------------
--- Quote from: b789 link ---
>
> No. The ball is in their court. If you don't receive a
response in the next 6-8 weeks, the remind us.
>
--- End Quote ---
Hiya,
I have not had a reply still but I did receive a letter from a
company called PastDueCredit. They didn't say who their client
was but they wanted to know if I lived at the postage address
they wrote to.
There aren't any other things I can think of that might trigger
one of these companies to contact me, so I suspect it is related
to this ticket. Of course I haven't replied to them.
#Post#: 99865--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DWMB2
Date: November 26, 2025, 5:49 am
---------------------------------------------------------
What exactly does that letter say? It sounds like a debt
collector letter, which can be ignored, but I just want to make
sure nothing strange has happened.
#Post#: 99872--------------------------------------------------
Re: Euro Parking Services - Unpaid Parking Charges Notice -
Passed to Empira
DIR By: DontStandForNonsense
Date: November 26, 2025, 6:21 am
---------------------------------------------------------
Addressed to me by name
Talks about the services they offer 'checking addresses of
individuals' for large organisations who've lost touch with
customers who they still need to talk to.
They to say their client has instructed them to verify the
current address of Mr x, whos last address on file was at 'A'
They go on to say they want to make sure they have the right
information and to let them know so that they can go on to share
more details with him.
They apologise if I am not Mr x, and ask me to confirm either
way. If I ignore they will assume it is correct and write again
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