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#Post#: 74803--------------------------------------------------
Court claim form
By: KDKM Date: June 4, 2025, 12:28 pm
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Please help :'(
In August 2023 I parked in Euro Parks car park on Rodney Street
Wigan. I visited specifically to take my 4 year old
granddaughter to Clark’s for shoes. I have never been to Wigan
before.
We left the shop, she needed the bathroom and subsequently I got
lost and couldn’t locate the car park.
A passer by helped with directions and I ended up being 18
minutes over the parking time.
The initial fine went to my old address, now corrected.
I ignored the multiple requests from DCBL for £170.
Now I have had a letter of claim from the court.
I have requested an extension of 28 days.
It has taken me 12 years to rebuild my life after a messy
divorce, I’m terrified of getting a CCJ and feel so worried and
stressed.
Thank you in advance of any advice.
#Post#: 74813--------------------------------------------------
Re: Court claim form
By: b789 Date: June 4, 2025, 1:32 pm
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Welcome. Don't panic. I can assure you that if you follow our
advice, you will not be paying a penny to ECP.
Just understand that this will end in either a strike out or a
discontinuation. Without even seeing the N1SDT Claim Form, I can
tell you how to respond but I would need to know the issue date
of the claim in order to let you know the deadlines.
So, please tell us the issue date of the claim and I will then
explain what you should do next and how and by when.
Nothing we advise can lead to a CCJ so get that notion out of
your head for starters.
#Post#: 74825--------------------------------------------------
Re: Court claim form
By: KDKM Date: June 4, 2025, 1:48 pm
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I’m so grateful, thank you
#Post#: 74826--------------------------------------------------
Re: Court claim form
By: KDKM Date: June 4, 2025, 1:50 pm
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That copy is rubbish, the date is 27 May on the form
#Post#: 74828--------------------------------------------------
Re: Court claim form
By: KDKM Date: June 4, 2025, 1:54 pm
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I tried to send a copy of the form but it wasn’t clear, the date
is 27 May.
Thank you for your support
#Post#: 74830--------------------------------------------------
Re: Court claim form
By: b789 Date: June 4, 2025, 1:55 pm
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You need to delete this images of the claim form you posted as
they show the claim number and the MCOL password. I only needed
the issue date of the claim so I've asked a mod to delete the
images.
#Post#: 74831--------------------------------------------------
Re: Court claim form
By: b789 Date: June 4, 2025, 1:57 pm
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With an issue date of 27th Mayy, you have until 4pm on Monday
16th June to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Monday 30th June to submit your defence.
If you want to submit an AoS then follow the instructions in
this linked PDF:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Otherwise, 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
[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#: 74834--------------------------------------------------
Re: Court claim form
By: KDKM Date: June 4, 2025, 2:05 pm
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I’ve deleted them.
I’m really, really grateful. Your help is invaluable.
I will do the defence.
#Post#: 78275--------------------------------------------------
Re: Court claim form
By: KDKM Date: June 26, 2025, 5:25 am
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Hi, I have this morning received an acknowledgment of receipt
of my defence. It says a copy has been sent to Euro Parks who
may contact me to attempt to resolve or proceed to court. Sounds
scary.
I just wanted to thank you again for helping me and let you
know I have followed your advice and keep you updated.
#Post#: 78336--------------------------------------------------
Re: Court claim form
By: b789 Date: June 26, 2025, 11:38 am
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It's all standard template response stuff. You will next receive
a letter from DCB Legal stating that they have received a copy
of the defence and their client intends to proceed. They will
also include a copy of their N180 Directions Questionnaire. Just
file it.
Follow these instructions on how to file your bond N180 DQ:
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.
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