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       #Post#: 71160--------------------------------------------------
       PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: bertie21980
       Date: May 12, 2025, 7:22 pm
       ---------------------------------------------------------
       Hello, I recently got a PCN in the post about parking in a
       private road along Sopwith Way in the SW11 area of Battersea,
       London. I was parked here as I was picking up a delivery from a
       restaurant near the Battersea power station. Here is my PCN
       letter...
  HTML https://i.ibb.co/n81TXyMW/pcn-chelsea-bridge-wharf-front-edit.jpg
  HTML https://ibb.co/2YMwzr3b
  HTML https://i.ibb.co/MDD5hZ3N/pcn-back.jpg
  HTML https://ibb.co/277Y6WfK
       Here is a street view on google maps of the road where I had
       parked google street view
  HTML https://maps.app.goo.gl/KWGPxN4P6aicDthh7
  HTML https://i.ibb.co/NdJZfCH6/sopwith-way-route-map-pcn.png
  HTML https://ibb.co/wFPM8gxN
       The map above shows the location of my vehicle is shown as a
       blue star on the map. The restaurant is on Archers Lane which is
       inaccessible to motor vehicles, so I have parked on Sopwith Way
       and walk along riverside walk, to get to the restaurant on
       Archers Lane. As I had a big delivery to take, I hac to make a
       few trips back and forth which took over 10 minutes to finish.
       I have used this road to park here numerous times in the past
       when making a delivery in this area but this is the first time I
       have received such a letter. I have yet to make an appeal as
       this is a private road so I know the rules are different here
       than as to parking on a public road. Any advice would be
       appreciated  :)
       #Post#: 71232--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: b789
       Date: May 13, 2025, 6:34 am
       ---------------------------------------------------------
       Do you have evidence that you were “working” as a delivery
       driver and that you were simply loading and unloading at the
       time? If you do, then this is my advice:
       Loading and unloading in the course of your work is not parking
       and is clarified in persuasive case law. However, that is not
       going to help you unless this goes to a claim, which it will.
       No appeal to PCM or the IAS is going to get this cancelled
       although you are free to try and appeal on that basis.
       Personally, I would completely ignore everything from this firm
       of ex-clampers until a Letter of Claim (LoC) is issued.
       An LoC can be responded to and a claim easily defended.
       Everything before that is going to be a wasted effort although
       others on here would advise you to go through the motions of the
       useless appeals process. To be honest, nothing before the LoC
       really matters and would not affect any claim if there was no
       response before litigation commenced. It’s your time that is
       required for a well trodden path of wasted effort.
       Keep evidence of the job. Ignore all debt recovery threats and
       come back when you receive the LoC for advice on how to respond.
       Others may advise differently, but the eventual outcome will be
       identical.
       #Post#: 71405--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: bertie21980
       Date: May 13, 2025, 8:03 pm
       ---------------------------------------------------------
       ok thanks for the reply. I will just leave it until the LOC
       comes and get all the documents ready. I have had experienced
       before with dealing with a private parking issue and I was
       advise to wait until they sent that dreaded LoC. It was quite a
       while ago and I remember responding to it. I think they did
       respond back to me but I don't recall ever getting a court date
       #Post#: 92430--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: bertie21980
       Date: October 1, 2025, 3:11 pm
       ---------------------------------------------------------
       Hi guys, I recently got this 'Letter Before Claim' letter from
       Moorside Legal. Is this the letter I'm suppose to respond to?
       Its not even clear which penalty they are referring to as it
       just says their client is from PCM which I assume is for this
       penalty claim ???
  HTML https://i.ibb.co/mCCNt1BR/moorside-legal-edit.jpg
  HTML https://ibb.co/TBBWRpTw
  HTML https://i.ibb.co/35BBSHs4/moorside-legal-letter-back.jpg
  HTML https://ibb.co/gbzztC7m
       #Post#: 92514--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: b789
       Date: October 2, 2025, 7:08 am
       ---------------------------------------------------------
       Send the following email to help@moorsidelegal.co.uk and CC
       yourself:
       --- Quote ---
       > Subject: Response to your Letter of Claim Ref: [reference
       number]
       >
       > Dear Sirs,
       >
       > Your Letter Before Claim contains insufficient detail of the
       claim and fails to provide copies of the evidence your client
       places reliance upon, putting it in clear breach of the
       Pre-Action Protocol for Debt Claims.
       >
       > As a supposed firm of solicitors, one would expect you to
       comply with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol,
       and paragraphs 6(a) and 6(c) of the Practice Direction. These
       provisions exist to facilitate informed discussion and
       proportionate resolution. You may wish to reacquaint yourselves
       with them.
       >
       > The Civil Procedure Rules 1998, Pre-Action Conduct and
       Protocols (Part 3), require the exchange of sufficient
       information to understand each other’s position. Part 6
       clarifies that this includes disclosure of key documents
       relevant to the issues in dispute.
       >
       > Your template letter refers to a “contract” yet encloses none.
       That omission undermines the only foundation upon which your
       client’s claim allegedly rests. It is not possible to engage in
       meaningful pre-litigation dialogue while you decline to furnish
       the very document you purport to enforce.
       >
       > I confirm that, once I am in receipt of a Letter Before Claim
       that complies with para 3.1(a), I shall seek advice and submit a
       formal response within 30 days, as required. Accordingly, please
       provide:
       >
       > [indent]1. A copy of the original Notice to Keeper (NtK) and
       any notice chain relied upon to assert PoFA 2012
       liability.

       > 2. A copy of the contract you allege exists between your
       client and the driver, being an actual photograph of the sign(s)
       in place on the material date (not a stock image), together with
       a site plan showing the sign locations.

       > 3. The precise wording of the clause(s) allegedly breached.
       > 
4. The written agreement between your client and the
       landowner evidencing standing/authority to enforce and to
       litigate.

       > 5. A breakdown of the sums claimed, identifying whether the
       principal sum is claimed as consideration or damages, and
       whether the £70 “debt recovery” add-on includes
       VAT.
[/indent]
       >
       > I am entitled to this information under paragraphs 6(a) and
       6(c) of the Practice Direction, and I require it to meet my own
       obligation under paragraph 6(b).
       >
       > If you fail to provide the above, I will treat that as
       non-compliance with the PAPDC and Pre-Action Conduct and will
       raise a formal complaint to the SRA regarding your conduct. I
       reserve the right to place this correspondence before the Court
       and to seek appropriate sanctions and costs (including, where
       appropriate, a stay and/or other case management orders).
       >
       > Until your client complies and provides the requested
       material, I am unable to respond properly to the alleged claim
       or to consider my position. It would be premature and a waste of
       costs and court time to issue proceedings. Should you do so, I
       will seek immediate case management relief pursuant to paragraph
       15(b) of the Practice Direction and an order compelling
       provision of the above.
       >
       > Please note, I will not engage with any web portal; I will
       only respond by email or post.
       >
       > Yours faithfully,
       >
       > [Your name]
       --- End Quote ---
       #Post#: 92640--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: bertie21980
       Date: October 2, 2025, 6:06 pm
       ---------------------------------------------------------
       Thank you for the advice, b789. I just sent the email now
       #Post#: 94511--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: bertie21980
       Date: October 17, 2025, 10:49 am
       ---------------------------------------------------------
       Hello everyone, I received an email from Moorside Legal
       yesterday, responding to my previous email. Any idea on how I
       should respond back? I'm guessing I should ignore it.
       --- Quote ---
       >
       > We write in relation to the above matter.
       >
       > The pcn was issued for No valid parking session registered on
       the 4/16/2025.
       >
       > By entering and parking the vehicle on our client's private
       land, you agreed to enter into a contract with our client and to
       be bound by the terms and conditions of that contract. The terms
       and conditions were clearly displayed in prominent places. Due
       to your failure to comply with the terms and conditions, our
       client has issued the PCN.
       >
       >
       >
       >
       >
       > Considering the evidence, we are satisfied that the PCN has
       been issued in line with industry standards and is compliant
       with the International Parking Community’s (IPC) code of
       practice. The signage of the car park also complies with the
       International Parking Community’s Code of Practice.
       >
       > below is a breakdown
       >
       > Why is there an additional £70 added to the PCN amount?
       > Because the Parking Charge remained unpaid after it was due.
       Our Client made you aware that additional charges could be
       applied to the Parking Charge if it was not paid on time. They
       informed you of this on the parking signs and on any notices
       either placed on the vehicle or sent to you by post.
       >
       >
       > How is the £70 made up?
       > £70 is the amount set out in both the British Parking
       Association and International Parking Association Codes of
       Practice as the amount which may be added to a Parking Charge
       when a Parking Charge remains unpaid and when further recovery
       is required. Our Client is a member of ipc which is a government
       approved Accredited Trade Association (ATA) for Private Parking.
       Our Client adheres to the ATA’s Code of Practice. The £70 is a
       charge levied by our Client (the Parking Operator) to protect
       their legitimate interests. (Our Client’s legitimate interests
       for charging and additional fee is to encourage payment when the
       Parking Charge becomes due and to avoid the need for debt
       recovery.)
       >
       >
       >
       >
       > We ask that you make the full payment of £170.00 within 7 days
       of receipt of this email.
       >
       >
       >
       >
       >
       > You can make payment in the following ways:
       >
       > Contact us on 0330 822 9950 (our opening times are Monday-
       Friday 9:00- 17:00);
       > portal.moorsidelegal.co.uk - Login to our portal
       >
  HTML https://pay.moorside.legal
       - Quick Pay
       >
       >
       >
       >
       > If you fail to respond or make payment, we may be instructed
       by our client to issue legal proceedings against you. This will
       incur further costs and fees that will be added to the
       outstanding balance. You may wish to seek independent legal
       advice.
       >
       >
       >
       >
       >
       > Yours sincerely,
       >
       > Moorside Legal
       >
       --- End Quote ---
       #Post#: 94525--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: b789
       Date: October 17, 2025, 12:11 pm
       ---------------------------------------------------------
       That is just a debt recovery letter and it can be safely
       ignored. Come back when they issue a Letter of Claim (LoC).
       #Post#: 110691--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: bertie21980
       Date: February 22, 2026, 9:14 am
       ---------------------------------------------------------
       Hi everyone, I recently received another Letter Before Claim
       from Moorside Legal. Its seems almost exactly the same as my
       previous LBC which is also in this thread.
  HTML https://i.ibb.co/VcsGLBCM/moorside-legal1-edit-16-2-2-26.jpg
  HTML https://ibb.co/S4zg6vmV
       It might even be for another parking claim that I'm going
       through but the reference number is exactly the same as my
       previous one above. Anyway, Im going to reply to them the exact
       same email message as I did before. If anyone thinks otherwise
       that I would welcome the advice
       #Post#: 110706--------------------------------------------------
       Re: PCM - No parking session registered - Chelsea Bridge Wharf,
       Battersea SW11
   DIR By: DWMB2
       Date: February 22, 2026, 2:47 pm
       ---------------------------------------------------------
       If the reference number is the same then it should relate to the
       same claim. If responding again, as well as whatever you're
       planning to respond with, I would also open by pointing out that
       this is the second Letter of Claim they have sent in respect of
       the same claim.
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