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       #Post#: 120220--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: StfuECP
       Date: June 1, 2026, 1:34 am
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       Hi everyone, I need to submit this today or I miss my chance to
       defend.
       Would you leave in the part where I've explained what happened
       to the driver on the day?
       Thanks
       #Post#: 120224--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: InterCity125
       Date: June 1, 2026, 2:44 am
       ---------------------------------------------------------
       I'd personally leave that out for the moment.
       You will still have the chance to submit a witness statement if
       the matter progresses.
       A defence which is short and to the point makes it clear that
       you know where you really stand.
       This is very unlikely to progress to a hearing.
       You are entering a defence purely to avoid a default judgement.
       I'd personally use the defence exactly as I posted previously.
       #Post#: 120225--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: StfuECP
       Date: June 1, 2026, 2:48 am
       ---------------------------------------------------------
       --- Quote from: InterCity125 link ---
       >
       > I'd personally leave that out for the moment.
       >
       > You will still have the chance to submit a witness statement
       if the matter progresses.
       >
       > A defence which is short and to the point makes it clear that
       you know where you really stand.
       >
       > This is very unlikely to progress to a hearing.
       >
       > You are entering a defence purely to avoid a default
       judgement.
       >
       --- End Quote ---
       Thanks.
       Would you include photos of signage and attatch the NtK at this
       stage?
       #Post#: 120226--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: InterCity125
       Date: June 1, 2026, 2:50 am
       ---------------------------------------------------------
       No.
       Just the defence.
       Don't overthink this.
       That I am the named defendant and I deny any liability in this
       matter.
       That the vehicle driver is not known to the Claimant and there
       is no legal requirement for me to identify the driver.
       That the Claimant has provided no evidence as to who the driver
       was.
       That the Claimant's Notice to Keeper does not comply with
       Protection of Freedoms Act (2012)(PoFA) and as such liability
       cannot be transferred myself.
       That, in particular, the Claimant's Notice to Keeper does not
       meet the requirements of PoFA Schedule 4 Paragraph 9(2)(e) - the
       mandatory wording and two limbed legal choice required by the
       paragraph is not present on the Claimant's NtK and, as such,
       total compliance is not achieved.
       That this means that there is no legal route to me being liable
       for the alleged debt.
       #Post#: 120235--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: StfuECP
       Date: June 1, 2026, 4:18 am
       ---------------------------------------------------------
       --- Quote from: InterCity125 link ---
       >
       > No.
       >
       > Just the defence.
       >
       > Don't overthink this.
       >
       >
       > That I am the named defendant and I deny any liability in this
       matter.
       >
       > That the vehicle driver is not known to the Claimant and there
       is no legal requirement for me to identify the driver.
       >
       > That the Claimant has provided no evidence as to who the
       driver was.
       >
       > That the Claimant's Notice to Keeper does not comply with
       Protection of Freedoms Act (2012)(PoFA) and as such liability
       cannot be transferred myself.
       >
       > That, in particular, the Claimant's Notice to Keeper does not
       meet the requirements of PoFA Schedule 4 Paragraph 9(2)(e) - the
       mandatory wording and two limbed legal choice required by the
       paragraph is not present on the Claimant's NtK and, as such,
       total compliance is not achieved.
       >
       > That this means that there is no legal route to me being
       liable for the alleged debt.
       >
       --- End Quote ---
       Thanks. Appreciate the help. These things feel massively
       confusing!
       Defence submitted. Should I expect the N180DQ via email next?
       #Post#: 120247--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: InterCity125
       Date: June 1, 2026, 5:05 am
       ---------------------------------------------------------
       Yes.
       But there's a bit to happen before that.
       As I mentioned before, Moorside would have been hoping that you
       didn't bother entering a defence so they could claim a default
       judgement.
       We estimate that 80% - 90% of parking claims go un-defended (or
       get settled before Court) so it's a statistically beneficial
       business model for them and this is the only reason they exist.
       Moorside are not set up to actually go through with the vast
       majority of these cases - in simple terms they are serial
       litigators who are only interested in the numbers game.
       This is now a defended claim so you just created a mountain of
       'paperwork' for them.
       They will probably carry on with the game for a while and then
       discontinue.
       #Post#: 120258--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: StfuECP
       Date: June 1, 2026, 6:03 am
       ---------------------------------------------------------
       Thanks. Does it matter that the solicitors in this case are DCB
       Legal though? Not Moorside.
       #Post#: 120260--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: jfollows
       Date: June 1, 2026, 6:06 am
       ---------------------------------------------------------
       --- Quote from: StfuECP link ---
       >
       > Thanks. Does it matter that the solicitors in this case are
       DCB Legal though? Not Moorside.
       >
       --- End Quote ---
       No, it’s better, because DCB Legal almost always discontinue in
       the face of a defended claim before they’re required to pay the
       court fee.
       #Post#: 120263--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: InterCity125
       Date: June 1, 2026, 6:12 am
       ---------------------------------------------------------
       --- Quote from: StfuECP link ---
       >
       > Thanks. Does it matter that the solicitors in this case are
       DCB Legal though? Not Moorside.
       >
       --- End Quote ---
       DCB Legal and Moorside operate using the same business model.
       Sorry about the confusion.
       #Post#: 120265--------------------------------------------------
       Re: NtK - Euro Car Parks
   DIR By: StfuECP
       Date: June 1, 2026, 6:16 am
       ---------------------------------------------------------
       No worries, thanks.
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