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       #Post#: 90478--------------------------------------------------
       Re: ACE Security Services CN – Not Displaying a Valid Permit –
       The Pelhams 1, Wimbledon, SW19 1NY
   DIR By: tobesb
       Date: September 18, 2025, 5:13 am
       ---------------------------------------------------------
       Hello all. I have only 2 days left to reply. What should I do? I
       was parked on a visitors box!
       So on the BW Legal Reply form, I plan to tick Box D in Section 1
       (I dispute the debt). I will then fill it out saying:
       I dispute the debt because
       1. No Period of Parking Stated and No Evidence of Contract
       Formation and
       2. Incorrect Wording Regarding the 28-Day Period.
       Then in 'Section 4: What documents are you sending with this
       form? What information do you need?'
       I'm presuming I send the quoted text that b789 kindly provided
       in reply #9:
       --- Quote ---
       >
       > Subject: Keeper Appeal – Charge Notice 987187 (Vehicle
       DF14KYP)
       >
       > Dear Sir or Madam,
       >
       > I am the Registered Keeper of vehicle registration DF14KYP
       regarding your Charge Notice 987187.
       >
       > Your Notice to Keeper is fundamentally non-compliant with the
       Protection of Freedoms Act 2012 (PoFA), Schedule 4 and no
       contract could have been formed with the driver, for the
       following reasons:
       >
       > 1. No Period of Parking Stated and No Evidence of Contract
       Formation
       >
       > Your original Notice to Driver failed to specify any “period
       of parking” as required by PoFA paragraph 7(2)(a). Instead, it
       recorded only a single observation time followed by a time of
       issue one minute later. A one-minute snapshot is not a “period
       of parking” and does not satisfy the mandatory requirement under
       PoFA, as confirmed in Brennan v Premier Parking Solutions, where
       the court held that an operator must evidence an actual
       identifiable period of parking, not merely a momentary presence.
       >
       > Moreover, the lack of any proper recorded parking period means
       there is no evidence that the vehicle remained stationary beyond
       the minimum mandatory consideration period required under the
       Private Parking Single Code of Practice (PPSCoP). The driver is
       entitled to enter the site, review the signage, and leave
       without entering into any contract.
       >
       > Since you have provided no evidence that the vehicle remained
       in situ beyond the minimum consideration period, there is no
       basis to suggest that any contractual relationship was ever
       formed between the driver and Ace Security Services.
       >
       > This is not simply a PoFA breach: it is also a breach of the
       Private Parking Single Code of Practice in failing to respect
       the minimum consideration period and issuing a charge when no
       contract could have been created. This breach of the Code of
       Practice also amounts to a breach of the KADOE contract you hold
       with the DVLA.
       >
       > A formal complaint has already been submitted to the DVLA
       regarding these breaches and the misuse of Keeper data.
       >
       > This fundamental defect carries through to your Notice to
       Keeper, which also fails to specify any “period of parking” as
       required by PoFA paragraph 8(2)(a). The NtK simply restates the
       same defective single timestamp without providing any proper
       period of parking as shown in your Notice to Driver.
       >
       > 2. Incorrect Wording Regarding the 28-Day Period
       >
       > Your Notice to Keeper is non-compliant with PoFA paragraph
       8(2)(f) because it misstates the mandatory warning about the
       28-day relevant period.
       >
       > Specifically, your NtK wrongly claims that the Keeper has "28
       days from the date given" to make payment.
       > This is completely incorrect.
       >
       > PoFA paragraph 8(2)(f) expressly requires you to warn the
       Keeper that the 28-day period begins "AFTER" the day on which
       the Notice to Keeper is given (i.e., after it is deemed
       delivered, which is two working days after posting).
       >
       > The use of the word "AFTER" in PoFA is deliberate, precise,
       and critical. It means that the counting of the 28-day period
       does not start on the day the notice is given, but starts on the
       day "AFTER" the notice is deemed given.
       >
       > By incorrectly stating that the Keeper has 28 days from the
       date given, you have misstated the Keeper's legal rights,
       confused the actual payment deadline, and fundamentally failed
       to comply with the requirements of PoFA 8(2)(f). Strict
       adherence to the statutory wording is required for any attempt
       to transfer liability from driver to Keeper. Because you have
       misstated the timing rule by ignoring the crucial word AFTER,
       your NtK is invalid for the purposes of PoFA.
       >
       > Because of these defects, you have failed to meet the
       mandatory conditions under PoFA Schedule 4, and therefore you
       cannot transfer liability to the Keeper. Your claim against the
       Keeper must fail.
       >
       > If you are unable to understand the explanation provided, I
       suggest you pass this appeal to a responsible adult within your
       firm, preferably one who has at least a basic understanding of
       PoFA and contract law and have them explain to you that you have
       no hope of ever recovering a penny from the Keeper and are only
       going to be wasting your firm's money on a wasted IAS appeal or,
       even more on trying to litigate this.
       >
       > Yours faithfully,
       >
       > [Full Name]
       > Registered Keeper
       >
       --- End Quote ---
       However, this is a legal firm. Might they get a bit prickly
       regarding the final paragraph?
       Thank you for any advice!
       Kind regards,
       Tobes
       #Post#: 90492--------------------------------------------------
       Re: ACE Security Services CN – Not Displaying a Valid Permit –
       The Pelhams 1, Wimbledon, SW19 1NY
   DIR By: b789
       Date: September 18, 2025, 7:01 am
       ---------------------------------------------------------
       They may be a 'legal firm' but that does not mean they are
       competent. You DO NOT, I repeat... DO NOT fill out any of those
       forms they sent you with the LoC. You can safely bin them or
       shred them for use as hamster bedding for anyone cares.
       You simply email the following response to  and also CC
       yourself:
       --- Quote ---
       > Subject: Response to your Letter of Claim – Ref: [BW ref / PCN
       987187] – VRM DF14KYP
       >
       > Dear Sirs,
       >
       > Your Letter of Claim is non-compliant with the Pre-Action
       Protocol for Debt Claims (paras 3.1(a)–(d), 5.1 and 5.2) and the
       Practice Direction – Pre-Action Conduct and Protocols (paras
       6(a) and 6(c)). It withholds the key documents you intend to
       rely upon and therefore fails to enable meaningful engagement.
       >
       > Liability is denied.
       >
       > Key issues (case-specific):
       >
       > [indent]1. Keeper liability cannot arise. The Notice to Driver
       and Notice to Keeper each fail to state any period of parking,
       contrary to PoFA Sch 4 paras 7(2)(a) and 8(2)(a). A single
       timestamp followed by an “issue time” one minute later is not a
       period of parking and cannot evidence contract formation.
       > 2. The NtK misstates the mandatory para 8(2)(f) warning by
       saying “28 days from the date given” instead of “28 days after
       the day on which the notice is given”. Strict compliance is
       required; your client therefore cannot transfer liability from
       driver to keeper.
       > 3. There is no evidence the vehicle remained beyond the
       mandatory consideration period required by the Private Parking
       Single Code of Practice. No contract could have been
       formed.[/indent]
       >
       > Documents required (PD para 6(a) & 6(c)):
       >
       > [indent](i) Copies of the NtD and NtK (all pages/sides) relied
       upon, and proof of posting for the NtK.
       > (ii) All contemporaneous images/notes (attendant notes,
       handheld/device logs) evidencing any period of parking on
       13/03/2025 at The Pelhams 1, Wimbledon.
       > (iii) The full signage pack in force on that date: site plan
       showing sign locations and readable close-ups of the exact
       wording.
       > (iv) The unredacted landowner authority/contract showing
       standing to issue charges and to litigate.
       > (v) A breakdown of the sum claimed and the legal basis for
       each element, identifying whether the principal £100 is alleged
       as consideration or damages, and confirming that the added £60
       “debt recovery” is not pursued, as it is unrecoverable.[/indent]
       >
       > If you commence proceedings without Protocol compliance, I
       will seek a stay and costs sanctions pursuant to paragraphs 13,
       15(b)–(c) and 16 of the Practice Direction and paragraph 7.2 of
       the Protocol, relying on Webb Resolutions Ltd v Waller Needham &
       Green [2012] EWHC 3529 (Ch), Daejan Investments v Park West Club
       (Part 20) Buxton Associates [2003] EWHC 2872, and Charles Church
       Developments v Stent Foundations & Peter Dann [2007] EWHC 855.
       >
       > For the avoidance of doubt, no admission is made as to the
       identity of the driver. If you assert PoFA is relied upon
       notwithstanding the above defects, explain how. Otherwise
       confirm you proceed on a driver-only basis.
       >
       > Service and correspondence
       >
       > For the avoidance of doubt, I will not use any online portal.
       Service by portal is not agreed. Please correspond and serve the
       requested documents either (i) by email to [email], or (ii) by
       post to the address below.
       >
       > Yours faithfully,
       >
       > [Name of Registered Keeper]
       > [Postal address]
       > [Email]
       --- End Quote ---
       ANd please, try not to ignore the advice as you did earlier on
       in this where you failed to send the advised email to ACE.
       #Post#: 90508--------------------------------------------------
       Re: ACE Security Services CN – Not Displaying a Valid Permit –
       The Pelhams 1, Wimbledon, SW19 1NY
   DIR By: tobesb
       Date: September 18, 2025, 7:52 am
       ---------------------------------------------------------
       Thank you b789. Yes it was a dumb moment by myself to trust my
       computer calendar to do a reminder. Lesson learnt!
       So I telephoned BW Legal. The employee said they don't have an
       email for contact. LIE. Found this one on MoneySavingExpert:
       disputeresolution@bwlegal.co.uk
       It works too. here's the reply. Posting this here in case anyone
       else runs into this issue about contacting them. I'll let you
       know how I get on.
       Best wishes,
       Tobes
       ---------------------------------------------------------
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