URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Private parking tickets
       *****************************************************
       #Post#: 74014--------------------------------------------------
       DCB Legal Issued Claim Form
       By: Warby95 Date: May 31, 2025, 4:57 am
       ---------------------------------------------------------
       Hi all,
       I have received an issued claim form from DCB Legal. It has
       pretty poor Particulars of Claim which I am almost certain do
       not comply with CPR 16.4(1).
       1. The Defendant is indebted to the Claimant for Parking Charges
       issued to vehicle XXXXX at XXXX.
       2. The date of contravention is XXX and the D was issued with
       PCs by the D.
       3. The D is pursued as the driver of the vehicle for breach of
       the terms on the signs (the contract). Reason: Park for longer
       than permitted.
       4. In the alternative the D is pursued as the keeper pursuant to
       POFA 2012, Schedule 4.
       AND THE CLAIMANT CLAIMS
       1. £170 being the total of the PCs and damages.
       2. Interest at a rate of 8% per annum pursuant to s.69 of the
       CCA 1984 from the date hereof at a daily rate of £.02 until
       judgment or sooner payment.
       3. Costs and court fees.
       I was not the driver at the time. Their PoC do not provide
       enough detail. I have filed my AOS and now have some time to
       file my Defence. Could anyone help me with a Defence to file and
       I think a strike out order as their PoC is deficient.
       TIA
       #Post#: 74027--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: RichardW Date: May 31, 2025, 6:22 am
       ---------------------------------------------------------
       Do a search on here, b789 has provided the defence and order
       many times against these rubbish POC!
       #Post#: 74037--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: b789 Date: May 31, 2025, 7:07 am
       ---------------------------------------------------------
       Show us the N1SDT Claim Form that has the Particulars of Claim
       (PoC) on them. Redact your personal info and the claim number
       and MCOL password but leave ALL dates showing, including the
       issue date of the claim.
       READ THIS FIRST - Private Parking Charges Forum guide
  HTML https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
       If you've already submitted the AoS and it was done within 19
       days of the issue date of the claim, you therefore have 33 days
       (plus any weekend or bank holiday days if the 33rd day is on one
       of those) to submit your defence.
       Here is the defence and link to the draft order that goes with
       it. You need to edit the claimants name, 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 [claimant] v [your full name] Claim no.:
       [claim number]."
       [quote][center]IN THE COUNTY COURT[/center]
       [right]Claim No: [Claim Number][/right]
       [center]BETWEEN:
       [Claimant]
       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#: 74085--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: Warby95 Date: May 31, 2025, 1:06 pm
       ---------------------------------------------------------
       This is the claim form received. AOS has been filed a couple of
       days ago.
       [attachment deleted by admin]
       #Post#: 74096--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: Warby95 Date: May 31, 2025, 2:04 pm
       ---------------------------------------------------------
       [quote author=b789 link=topic=6562.msg74037#msg74037
       date=1748693274]
       Show us the N1SDT Claim Form that has the Particulars of Claim
       (PoC) on them. Redact your personal info and the claim number
       and MCOL password but leave ALL dates showing, including the
       issue date of the claim.
       READ THIS FIRST - Private Parking Charges Forum guide
  HTML https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
       If you've already submitted the AoS and it was done within 19
       days of the issue date of the claim, you therefore have 33 days
       (plus any weekend or bank holiday days if the 33rd day is on one
       of those) to submit your defence.
       Here is the defence and link to the draft order that goes with
       it. You need to edit the claimants name, 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 [claimant] v [your full name] Claim no.:
       [claim number]."
       [quote]
       [center]IN THE COUNTY COURT[/center]
       [right]Claim No: [Claim Number][/right]
       [center]BETWEEN:
       [Claimant]
       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
       [/quote]
       Claim form attached
       [attachment deleted by admin]
       #Post#: 74112--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: b789 Date: May 31, 2025, 7:31 pm
       ---------------------------------------------------------
       With an issue date of 15th May, you had until 4pm on Tuesday 3rd
       June to submit your defence. As you have submitted an
       Acknowledgement of Service (AoS) before then, you now have have
       until 4pm on Tuesday 17th June to submit your defence.
       Just do as advised and edit the claimant, your name and the
       claim number and send off.
       #Post#: 75050--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: ticmick66 Date: June 6, 2025, 3:09 am
       ---------------------------------------------------------
       apologies, posted a reply by accident
       #Post#: 75412--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: Warby95 Date: June 8, 2025, 12:38 pm
       ---------------------------------------------------------
       [quote author=b789 link=topic=6562.msg74112#msg74112
       date=1748737916]
       With an issue date of 15th May, you had until 4pm on Tuesday 3rd
       June to submit your defence. As you have submitted an
       Acknowledgement of Service (AoS) before then, you now have have
       until 4pm on Tuesday 17th June to submit your defence.
       Just do as advised and edit the claimant, your name and the
       claim number and send off.
       [/quote]
       Thank you! I have just filed that now by email. I assume the
       Court will serve a copy on the Claimant?
       Thanks
       #Post#: 75415--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: b789 Date: June 8, 2025, 12:51 pm
       ---------------------------------------------------------
       [quote author=Warby95 link=topic=6562.msg75412#msg75412
       date=1749404311]
       I assume the Court will serve a copy on the Claimant?
       [/quote]
       Yes
       #Post#: 104844--------------------------------------------------
       Re: DCB Legal Issued Claim Form
       By: Warby95 Date: January 6, 2026, 3:56 pm
       ---------------------------------------------------------
       Hi, now been listed for a hearing and ordered to file a witness
       statement. Any advice? Will the hearing actually go ahead?
       *****************************************************
   DIR Next Page