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#Post#: 121911--------------------------------------------------
Re: CPM Parking PCN – vehicle not registered – Brindley Estate,
Westminster, London
DIR By: InterCity125
Date: June 16, 2026, 1:59 am
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Brindley Estate Defence.
1. That liability for the debt is completely denied and that no
money is owned by myself to the Claimant.
2. That it is acknowledged that I was the Registered Keeper of
the vehicle in question at the material time.
3. That the vehicle driver is not known to the Claimant.
4. That the Claimant is therefore attempting to use Protection
of Freedoms Act 2012 (PoFA) in order to invoke what is legally
known as 'keeper liability' thereby moving liability from the
unknown driver to myself (the keeper).
5. That, in this instance, the Claimant's Notice to Keeper (NtK)
does not meet all the requirements of PoFA Schedule 4 Paragraph
9(2) and therefore keeper liability cannot be invoked.
6. That with the driver unknown and keeper liability
unavailable, there is no legal route to liability in this
matter.
7. That throughout this matter I have attempted to engage with
the Claimant in order to establish exactly where they allege the
driver parked in relation to their issued PCN NtK.
8. That on each occasion the Claimant has failed to reveal the
precise location of the alleged contravention.
9. That the Particulars of Claim are so vague that it is
impossible to tell exactly what they are claiming for and
therefore this represents a 'skeleton defence'.
10. That an examination of Google Street View shows that the
Claimant appears to manage a gated cap park off Alfred Road on
the Brindley Estate.
11. That at the material time the driver would not be able to
access this gated car park since the driver was not in
possession of an 'electronic key fob' which would allow access.
12. That all other areas surrounding this location are either
public roads or car parks managed by Westminster Council and
therefore not relevant to the claim pleaded.
13. That liability for the debt is therefore denied.
You should be able to submit this through MCOL.
I cannot wait for their witness statement complete with their
pitch-black photos!
#Post#: 123735--------------------------------------------------
Re: CPM Parking PCN – vehicle not registered – Brindley Estate,
Westminster, London
DIR By: ArenJool
Date: July 4, 2026, 7:48 am
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Thanks.
Small update. I had an issue with the online portal so I ended
up posting the defence to the court. the tech support couldn't
help merge my two online accounts but offered an email address
for defence (claimresponses.cnbc at justice.gov to help those in
future).
Anyway, I received a letter today dated 29 June from the court
stating they received my defence and it will be passed on to
claimant and they will have 28 days from receipt of defence to
confirm if they wish to proceed blah blah blah.
Thanks again.
#Post#: 127961--------------------------------------------------
Re: CPM Parking PCN – vehicle not registered – Brindley Estate,
Westminster, London
DIR By: ArenJool
Date: August 16, 2026, 5:08 pm
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Hello all.
Small update.
I received a request from the court to complete an N180 form.
They want to move it to small claims track.
I have also received bw legal's n180 who do not want it moved to
small claims track because they want to cross examine me (lol).
I will send my copy within the time limit using the following
template:
--- Quote ---
> 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:
>
> • 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:
> What is the court name? - Find a Court or Tribunal - GOV.UK
> Tell us if you know the court or tribunal name or address to
find a court or tribunal in England or Wales
> find-court-tribunal.service.gov.uk
>
>
> • F3: "1".
>
> • Sign the form by simply typing your full name for the
signature.
>
> When you have completed the form, attach it to a single email
addressed to both disputeresolution@bwlegal.co.uk and
enquiries@bwlegal.co.uk and CC in yourself. Make sure that the
claim number is in the subject field of the email.
--- End Quote ---
Please let me know if you want any of their N180 answers.
Thanks.
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