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       #Post#: 68268--------------------------------------------------
       Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: April 23, 2025, 7:04 am
       ---------------------------------------------------------
       Afternoon All,
       Please could I get some advice on how I could defence this legal
       action.
       I parked in my GP's car park on the 3rd Oct 2023 and I forgot to
       register my car on their tablet when I attended the appointment
       as it booked the same day following the result of a blood test I
       took the day before.
       I received the PCN after and wrote to my GP to confirm the
       appointment which they did via text but I didnt follow this up
       with Euro cars as I have been so unwell for the pass 18 months.
       Euro Car passed it on the DCB  and now it has gone to county
       court claim. I have already submitted an Acknowledgment of
       Service.
       Please find attached copy of the claim form and text from GP
       practice. Is there any way I can dispute the claim?[attachimg=2]
       Thank you in advance.
       [attachment deleted by admin]
       #Post#: 68295--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: b789
       Date: April 23, 2025, 8:46 am
       ---------------------------------------------------------
       Follow the advice and you won't be paying a penny to ECP. You
       should complaint to your surgery management about their unfair
       system which allows a third party, unregulated private parking
       company to issue £100 invoices to their patients. I'd also get
       on social media and websites such as TrustPilot and any others
       and warn everyone about this unfair practice.
       With an issue date of 10th April, you have until 4pm on Tuesday
       29th April to submit your defence. However, having submitted an
       Acknowledgement of Service (AoS) before then, you now have until
       4pm on Tuesday 13th May to submit your defence.
       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 Euro Car Parks Ltd v [your full name]
       Claim no.: [claim number]."
       --- Quote ---
       >
       > [center]IN THE COUNTY COURT[/center]
       > [right]Claim No: [Claim Number][/right]
       >
       > [center]BETWEEN:
       >
       > Euro Car Parks 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#: 68368--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: April 23, 2025, 5:06 pm
       ---------------------------------------------------------
       Thank you so much for this.
       I believe I  also said I was challenging jurisdiction as the
       court is in Northampton and I am in London.  Do I need to add
       anything  else  concerning this?
       So do I need to attach the text message  from my GP surgery to
       the defence ?
       Also, once I email everything over, how long  on average do
       people receive a response?
       #Post#: 68373--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: jfollows
       Date: April 23, 2025, 6:25 pm
       ---------------------------------------------------------
       The court is not in Northampton, it’s just a clearing centre for
       all small claims and a court local to you will be determined and
       allocated later in the process.
       Jurisdiction can often be about Scotland versus England. In your
       case it’s not an issue.
       Don’t overthink this. DCB Legal uses the threat of court to
       scare people into paying. If you defend this and take advice
       here they will eventually give up and discontinue. You just need
       to follow the proper process until they do. They don’t care
       about “mitigation” so I wouldn’t bother with the thing from your
       GP.
       #Post#: 70378--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: May 7, 2025, 6:43 am
       ---------------------------------------------------------
       Thank you for the support, Defence and draft order submitted
       today... Fingers
       crossed
  HTML https://emoji.tapatalk-cdn.com/emoji120.png
       #Post#: 74970--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: June 5, 2025, 11:30 am
       ---------------------------------------------------------
       Just an update|:
       I received this letter following sending in the defence
       letter.[attachimg=2][attach=3]
       [attachment deleted by admin]
       #Post#: 74971--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: June 5, 2025, 11:31 am
       ---------------------------------------------------------
       [attachimg=2][attach=2]
       [attachment deleted by admin]
       #Post#: 80247--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: July 9, 2025, 8:28 am
       ---------------------------------------------------------
       Hi All,
       I received the following today via post. Shall I just complete
       it?
       It states that following:
       1. This is now a defended claim.
       The defendant has filed a denfence.
       2. It appears that this case is suitable for allocation to the
       small claims track
       If you believe that track is not appropriate track for teh claim
       you must complete box C1 on the Small Claims Directions
       Questionnaire 9Form N180) AND EPLAIN WHY.
       3. You must by  15TH jULY 2025 completed the small Claims
       Direction
       Questionnaire.[attachimg=1][attachimg=2][attach=3][attach=3][attachurl=3]
       [attachment deleted by admin]
       #Post#: 80249--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: b789
       Date: July 9, 2025, 8:36 am
       ---------------------------------------------------------
       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#: 81069--------------------------------------------------
       Re: Claim Form received - DCB LEGAL  For Euro Car Parks 
   DIR By: sp21
       Date: July 15, 2025, 7:00 am
       ---------------------------------------------------------
       Thanks for the advice... all submitted now.
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