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#Post#: 65061--------------------------------------------------
Claim Form arriving too late
By: gandalf89 Date: March 31, 2025, 2:56 pm
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Hi everyone,
The registered keeper is being chased for private PCNs. The
keeper believes that charges were unfair and there were also
mitigating circumstances. She ignored the PCN and letters from
debt collecting agencies. Today she received a Claim Form dated
11/03 and it looks like it would be too late to acknowledge the
claim. Is there anything she can do? It looks like the deadline
had already passed. She is devastated.
#Post#: 65136--------------------------------------------------
Re: Claim Form arriving too late
By: b789 Date: April 1, 2025, 6:06 am
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Without seeing the claim form, it is difficult to tell you what
to do. Check your MCOL history and if a default CCJ has not yet
been issued, we can provide a defence that can still be
submitted and then go buy a lottery ticket.
If a CCJ has been issued then different rules apply.
Show us the N1SDT Claim Form (no need to show all the other
stuff that came with it). Only redact your personal details, the
claim number and the MCOL password.
READ THIS FIRST - Private Parking Charges Forum guide
HTML https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
#Post#: 65153--------------------------------------------------
Re: Claim Form arriving too late
By: gandalf89 Date: April 1, 2025, 7:54 am
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Thank you for taking your time. I've attached the form. I'll
check the history now.
[attachment deleted by admin]
#Post#: 65156--------------------------------------------------
Re: Claim Form arriving too late
By: gandalf89 Date: April 1, 2025, 8:06 am
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Just checked the history and all it says is: A claim was issued
against you on 11/03/2025. I think that qualifies for a lottery
ticket, right?
#Post#: 65157--------------------------------------------------
Re: Claim Form arriving too late
By: b789 Date: April 1, 2025, 8:08 am
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There is no need to redact Sarah Ensall's name nor the wrong
dates for the issue of the PCNs. I said that you only need to
redact your personal details, the claim number and the MCOL
password.
Please confirm that this is for two PCNs.You can check those
PCNs and that the date noted on the Claim Form in the
Particulars of Claim do not match with the actual "issue date"
of the PCN. Sarah Ensall has, as usual, referred to the date of
the alleged contravention and not the issue date of the PCN.
Anyway... With an issue date of 11th March, you had until 4pm
yesterday, Monday 31st March to submit the defence. If you had
submitted an Acknowledgement of Service (AoS) before then, you
would then have had until 4pm on Monday 14th April to submit
your defence.
With a bit of luck and without delay follow these instructions
right now:
Try to submit an AoS by following the instructions in this
linked PDF:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
As long as your MCOL history does not show that a default CCJ
has been issued you will then have until 4pm Monday 14th April
to submit your defence.
Otherwise, as long as the claimant has not requested a default
CCJ, you can simply send the following defence, immediately, by
following the instructions:
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 MET Parking Services Ltd v [your full
name] Claim no.: [claim number]."
[quote]
[center]IN THE COUNTY COURT[/center]
[right]Claim No: [Claim Number][/right]
[center]BETWEEN:
MET Parking Services Ltd
Claimant
- and -
[Defendant's Full Name]

Defendant
[hr]
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:[/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#: 65160--------------------------------------------------
Re: Claim Form arriving too late
By: gandalf89 Date: April 1, 2025, 8:19 am
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Yes, this is for two PCNs, and you're right about Particulars of
Claim, both dates are contravention dates.
#Post#: 65170--------------------------------------------------
Re: Claim Form arriving too late
By: gandalf89 Date: April 1, 2025, 9:10 am
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I created a 3 pages long pdf file, edited only the defence part
and sent it already via email. Fingers crossed now. Massive
thanks for your help.
#Post#: 71492--------------------------------------------------
Re: Claim Form arriving too late
By: gandalf89 Date: May 14, 2025, 10:56 am
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Hello, we've received a letter from DCBL informing that their
client wants to proceed with the claim. Please see attached a
picture. They also say, that they may be prepared to settle, and
sent us a copy of directions questionnaire. We think it's just
another scare tactic and they hope we give in. Do we need to
reply to them or do we wait for the court letter? Once again,
thanks for any help.
[attachment deleted by admin]
#Post#: 71501--------------------------------------------------
Re: Claim Form arriving too late
By: b789 Date: May 14, 2025, 11:12 am
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Please don't confuse DCBL with DCB Legal. Whilst related, they
are very different arms of the same company and anything from
DCBL can be safely ignored. However, anything from DCB Legal
should not be ignored.
The letter you have received is as expected.
Having received your own N180 (make sure it is not simply a copy
of the claimants N180), do not use the paper form. Ignore all
the other forms that came with it. you can discard those.
Download your own here and fill it in on your computer. You sign
it by simply typing your full name in the signature box.
HTML https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
[indent]• The name of the court is "Civil National Business
Centre".
• To be completed by "Your full name" and you are the
"Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their
evidence at a hearing in person and to expose omissions and any
misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking
case paperwork for a living, having this case heard solely on
papers would appear to put the Claimant at an unfair advantage,
especially as they would no doubt prefer the Defendant not to
have the opportunity to expose the issues in the Claimants
template submissions or speak as the only true witness to events
in question.."
• F1: Whichever is your nearest county court. Use this to find
it:
HTML https://www.find-court-tribunal.service.gov.uk/search-option
• F3: "1".
• Sign the form by simply typing your full name for the
signature.[/indent]
When you have completed the form, attach it to a single email
addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk
and CC in yourself. Make sure that the claim number is in the
subject field of the email.
#Post#: 80195--------------------------------------------------
Re: Claim Form arriving too late
By: gandalf89 Date: July 9, 2025, 2:42 am
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Hi again. We've received an email about mediation phone call,
which is scheduled soon. It says:
"...
Explaining your position
You will need to briefly explain your claim or defence to the
mediator. You should prepare for yourself a brief summary of the
main points.
Negotiating options 
You’re attending mediation with a view to settling
your case. This means negotiating to overcome disputed issues.
The mediator is neutral and helps each party to explore options
and discuss risks. Mediation works when you’re
willing to listen to what the other party has to say, negotiate
and agree a settlement.
Building agreement
Settlement can be in many different forms, for example, payment,
goods or work. Both parties must agree on the outcome and feel
they have reached an acceptable resolution.
Reaching a settlement
The mediator will read the terms of the settlement and confirm
agreement with each party. Once agreed, the settlement is
legally binding and cannot be changed. A copy of
the mediation settlement is sent to both parties and
placed on the court file.
..."
I watched the youtube video they provided in the email, it says
that the call may take up to an hour! Can i ignore the
mediator's questions and just keep saying that "I'm not guilty
and all I'm willing to pay is zero pounds"?
Thanks again, kind regards.
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