DIR Return Create A Forum - Home
---------------------------------------------------------
FreeTrafficLegalAdvice
HTML https://ftla.createaforum.com
---------------------------------------------------------
*****************************************************
DIR Return to: Private parking tickets
*****************************************************
#Post#: 77176--------------------------------------------------
DCB legal claim in Civil National business Centre
DIR By: Titty
Date: June 19, 2025, 8:43 am
---------------------------------------------------------
Hi Folks. I am new here and hoping for some help.
First of all, I must confess that I am an old disabled woman
with very little and poor computer skills.
In fact, having read all your guidance notes I still cannot work
out how to upload a document or even start a post and having
spent some hours to type all this I hope it will work and get to
the panel attention.
The claim was issued by DBC Legal and is dated 3 June 20225.
I sent back to the Business Centre my Acknowledgment of Service
17 Jun 2025.
I drafted my defence and I would very grateful for advice and
corrections.
The Claimant: UK Parking Control Limited claims £175.52 + Court
Fee35.00+
Legal Representatives £50.00 for a TOTAL of £260.62
Claimant Particular of Claim:
1. The Defendant (D) is indebted to the Claimant (C) for Parking
Charge issued to vehicle (XXXXXXX) at Westway Cross Retail Park
Greeford, London UB6 0UW
2. The date of contravention is 18/12/2024 and (D) was issued
with a PC by the Claimant.
3. The defendant is pursued as the driver of the vehicle for
breach of the terms of the signs (The Contract). Reason: Parked
for longer than permitted.
4. In the alternative the defendant is pursued as the keeper
pursuant to POFA 2012, Schedule 4.
AND THE CLAIMANT CLAIMS:
1.£170 being the total of the of the PC and damage.
2.Interests at the rate of 8% per annum pursuant to s.69 of the
Count Court Act 1984 from the date hereof at a daily rate of
£.02 until Judgement or sooner payment.
3.Costs and Court Fee.
Before I carry on with my defence draft, I would like to point
out that I will defend all the way up to the hearing if the
court will grant them. In 2016 I have done the same against
GLADSTON Solicitors. Their barrister?? attended the court drunk
and scruffy and was thrown out by the judge. Needless to say,
that not only was an unsuccessful claim but the claimant was
also fined.
Does anyone know if UK Parking Control is still banned from
accessing DVLA?
The following is my Defence:
[attachment deleted by admin]
#Post#: 77223--------------------------------------------------
Re: DCB legal claim in Civil National business Centre
DIR By: b789
Date: June 19, 2025, 1:47 pm
---------------------------------------------------------
Hi [member=5919]Titty[/member] and welcome to the forum. Now
that you have figured out how to use the forum, I am happy to
provide advice and guidance on your situation.
Before we go too far, when you sent back the Acknowledgement of
Service (AoS), in what format did you submit that? Did you use
the Money Claims On Line (MCOL) website or did you use the paper
form that came in the Response Pack with the claim? If the
latter, did you post it or did you scan and then email it?
I ask these questions because if you posted it, did you by any
chance get a free certificate of posting from any post office?
There is always the risk that a postal submission gets either
lost in the post or even more likely, lost once it is received
by the CBNC. Not to worry though if you did it that way, as you
could still just do it online or as an email attachment. Once
you let me know which method you used, I can assist.
As for the defence, you will not be using the one you have
prepared. I can guarantee with more than 99% assurance that you
won't be paying a penny to UKPC if you follow the advice on the
defence we provide. Even without seeing your N1SDT Claim Form,
we already know that UKPC are being represented by DCB Legal. As
long as any claim issued by this firm of incompetents is
defended, no matter how poorly breaded, they will discontinue
the claim before they have to pay the £27 trial fee.
What I can say for sure is that as long as the AoS is received
no later than 4pm on Monday 23rd June, the deadline for your
defence will be 4pm on Monday 7th July. However, if you provide
the answers to my questions above, we can have the defence ready
to email them tomorrow.
Can you tell us what answers you put in your AoS? For example,
did you put that you intend to defend all of the claim?
If you want to be sure that your AoS is submitted and received,
although not necessary if we file the defence tomorrow, you can
try and follow the instructions in this PDF file to resubmit
your AoS electronically:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
#Post#: 77345--------------------------------------------------
Re: DCB legal claim in Civil National business Centre
DIR By: Titty
Date: June 20, 2025, 6:22 am
---------------------------------------------------------
when you sent back the Acknowledgement of Service (AoS), in what
format did you submit that? Did you use the Money Claims On Line
(MCOL) website or did you use the paper form that came in the
Response Pack with the claim? If the latter, did you post it or
did you scan and then email it?
I reiterate that I am illiterate in computer. So, I rung first
the Civil National Business Centre and a kind lady suggested me
to fill in the form called Acknowledgement of Service included
in the Response Pack. I ticked only the first box: 1. I intend
to defend all of this claim, then signed it and dated. I scanned
the form only and emailed to - AOS.CNBC@justice.gov.uk
The following is a copy of the Automated Response:
AOS.CNBC
17 Jun 2025, 15:00 (3 days ago)
to me
Thank you for emailing the Acknowledgment of Services Team in
the Civil National Business Centre.
If your email requires a response, this can take 14 days,
although this timeframe varies. Please see our published work
states on GOV.UK for the current timeframes.
HMCTS Civil Business Centre performance information - GOV.UK
(www.gov.uk)
We will not provide an update on emails, forms or applications
already submitted to us.
•
when the work is complete.
•
responsible for that work type.
•
information please use our signposting tool, to ensure you are
directed correctly.
CNBC Signposting Tool
Our staff are not legally trained, if you have concerns, you can
get support from the External Support Services attached to this
mail.
•
Practice Direction 5B
HTML https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part05/pd_part05b
•
if it is over 10MB or 25 printed pages in size.
________________________________________
This e-mail and any attachments is intended only for the
attention of the addressee(s). Its unauthorised use, disclosure,
storage or copying is not permitted. If you are not the intended
recipient, please destroy all copies and inform the sender by
return e-mail. Internet e-mail is not a secure medium. Any reply
to this message could be intercepted and read by someone else.
Please bear that in mind when deciding whether to send material
in response to this message by e-mail. This e-mail (whether you
are the sender or the recipient) may be monitored, recorded and
retained by the Ministry of Justice. Monitoring / blocking
software may be used, and e-mail content may be read at any
time. You have a responsibility to ensure laws are not broken
when composing or forwarding e-mails and their contents.
I noted somewhere that I should contact also DCB legal with a
copy of my defence, but I learned from experience to never
contact bullies by email or phone because you give them other
channels to harass you. Engaging in silly arguments with them is
not worthy my time. It’s already too much aggravation having to
reply to them for any vulnerable person.
[attachment deleted by admin]
#Post#: 77356--------------------------------------------------
Re: DCB legal claim in Civil National business Centre
DIR By: b789
Date: June 20, 2025, 7:00 am
---------------------------------------------------------
Excellent. You have correctly submitted your AoS electronically
and instantly. No need to trudge to the post office and waste
money on postage etc. Everything from here on will be done by
e-mail. If you do struggle with anything, just ask again and we
will try and help you all the way.
As for your defence, this is what I advise you to send. You will
only need to edit your name and the claim number on the defence
itself. Once you have done that, you just safe it as a PDF file.
You then send the PDF of the defence and the draft order as
attachments, exactly the same way you did for the AoS.
When you're ready you combine both documents as a single PDF
attachment (if you know how) 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 UK Parking Control Ltd v [your
full name] Claim no.: [claim number]."
This is the defence you should submit. You only need to edit
your name and the claim number. There is nothing to edit in the
draft order:
--- Quote ---
>
> [center]IN THE COUNTY COURT[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> UK Parking Control 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[/quote]
Remember, you save both documents as PDF files and attach them
in a single email addressed to
ClaimResponses.CNBC@justice.gov.uk and CC yourself. That's it
for now.
*****************************************************
Page 1 of 1