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       #Post#: 82695--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: b789
       Date: July 25, 2025, 10:45 am
       ---------------------------------------------------------
       You can stop panicking. If you follow the advice, you won't be
       paying a penny to (not so) Smart parking.
       Respond to the LoC by email to info@dcblegal.co.uk and CC in
       yourself with the following:
       --- Quote ---
       > Dear Sirs,
       >
       > Your Letter Before Claim contains insufficient detail of the
       claim and fails to provide copies of evidence your client places
       reliance upon and thus is in complete contravention of the
       Pre-Action Protocol for Debt Claims.
       >
       > As a firm of supposed solicitors, one would expect you to be
       capable of crafting a letter that aligns 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 do not exist
       for decoration—they exist to facilitate informed discussion and
       proportionate resolution. You might wish to reacquaint
       yourselves with them.
       >
       > The Civil Procedure Rules 1998, Pre-Action Conduct and
       Protocols (Part 3), stipulate that prior to proceedings, parties
       should have exchanged sufficient information to understand each
       other’s position. Part 6 helpfully clarifies that this includes
       disclosure of key documents relevant to the issues in dispute.
       >
       > Your template letter mentions a “contract”, yet fails to
       provide one. This would appear to undermine the only foundation
       upon which your client’s claim allegedly rests. It’s difficult
       to engage in meaningful pre-litigation dialogue when your side
       declines to furnish the very document it purports to enforce.
       >
       > I confirm that, once I am in receipt of a Letter Before Claim
       that complies with the requirements of para 3.1 (a) of the
       Pre-Action Protocol, I shall then seek advice and submit a
       formal response within 30 days, as required by the Protocol.
       Thus, I require your client to comply with its obligations by
       sending me the following information/documents:
       >
       > [indent]1. A copy of the original Notice to Keeper (NtK) that
       confirms any PoFA 2012 liability
       > 2. A copy of the contract (or contracts) you allege exists
       between your client and the driver, in the form of an actual
       photograph of the sign you contend was at the location on the
       material date, not a generic stock image
       > 3. The exact wording of the clause (or clauses) of the terms
       and conditions of the contract(s) which is (are) relied upon
       that you allege to have been breached
       > 4. The written agreement between your client and the
       landowner, establishing authority to enforce
       > 5. A breakdown of the charges claimed, identifying whether the
       principal sum is claimed as consideration or damages, and
       whether the £70 “debt recovery” fee includes VAT[/indent]
       >
       > I am clearly entitled to this information under paragraphs
       6(a) and 6(c) of the Practice Direction. I also need it in order
       to comply with my own obligations under paragraph 6(b).
       >
       > If your client does not provide me with this information then
       I put you on notice that I will be relying on the cases of Webb
       Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch),
       Daejan Investments Limited v The Park West Club Limited (Part
       20) Buxton Associates [2003] EWHC 2872, Charles Church
       Developments Ltd v Stent Foundations Limited & Peter Dann
       Limited [2007] EWHC 855 in asking the court to impose sanctions
       on your client and to order a stay of the proceedings, pursuant
       to paragraphs 13, 15(b) and (c) and 16 of the Practice
       Direction, as referred to in paragraph 7.2 of the Protocol.
       >
       > Until your client has complied with its obligations and
       provided this information, I am unable to respond properly to
       the alleged claim and to consider my position in relation to it,
       and it is entirely premature (and a waste of costs and court
       time) for your client to issue proceedings. Should your client
       do so, then I will seek an immediate stay pursuant to paragraph
       15(b) of the Practice Direction and an order that this
       information is provided.
       >
       > Yours faithfully,
       >
       > [Your name]
       --- End Quote ---
       #Post#: 82704--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: atousaleila
       Date: July 25, 2025, 11:13 am
       ---------------------------------------------------------
       Thank you so much! I will post on here what their reply will be.
       There aren't enough words to say how thankful and grateful I am
       for this advice! This letter is going to irk them  ;D  :D
       #Post#: 82706--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: b789
       Date: July 25, 2025, 11:16 am
       ---------------------------------------------------------
       Trust me, it won't "irk" them. They will send a boilerplate
       response. However, they will fail to provide all the required
       documents. This can always be used against them at a later date,
       if necessary.
       They will issue a claim and we will provide the defence.
       Eventually, the claim will either be struck out or discontinued.
       #Post#: 88555--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: atousaleila
       Date: September 5, 2025, 8:41 am
       ---------------------------------------------------------
       Hi,
       Driver just received this email from dcblegal.co.uk
       What do I need to do next please?
       They have given the driver 30 days notice to pay.
       There was also a photo attachment of the Driver's car with date
       and time.
       [b]"We write in response to your recent correspondence in
       response to our Letter of Claim (LOC) and will now respond as
       follows.
       
       It is our position that the Letter of Claim (“LOC”) is compliant
       with the Pre-Action Protocol for Debt Claims (“the Protocol”).
       The LOC provides adequate information for you to identify the
       debt that our Client is seeking to recover. We would
       respectfully draw your attention to paragraph 2.1(c) of the
       Protocol and remind you that both parties are expected to act
       reasonably and proportionately.
       
       For the avoidance of doubt, please note that the timeframe in
       which to appeal the Parking Charge has expired. You were given
       the opportunity to lodge an appeal when the initial Notice was
       issued to you. Given that the case has been escalated to this
       firm for recovery action, the time to appeal has now elapsed and
       payment of the Parking Charge(s) is now required.
       
       The amount owed is a genuine pre-estimate of the losses incurred
       in managing the parking location to ensure compliance with the
       clearly displayed terms and conditions. Further, in accordance
       with the British Parking Association (BPA)/International Parking
       Community (IPC) Code of Practice, where the Parking Charge
       becomes overdue and before Court proceedings have commenced, a
       reasonable sum may be added for the debt recovery fees. The
       correct recovery fees have been added and will not be removed,
       for completeness we would advise that the fee is not inclusive
       of any VAT, as it does not pertain to a supply of goods/services
       between you and our Client.
       
       To clarify, when parking on private land, the contractual terms
       of the site are set out on the signs. You are thus entering into
       a contract (by way of conduct) and agreeing to the terms by
       parking and staying on the site. Parking in breach of the terms
       as stipulated on the signage means that you are then breaking
       the terms of the contract.
       
       Attached are copies of evidence pertaining to the matter,
       however, if there are any documents that you have requested, but
       that are not attached, it is because we have deemed the request
       to be disproportionate and/or not relevant to the substantive
       issues in dispute. We respectfully draw your attention to
       paragraph 2.1(c) of the Protocol and remind you that both
       parties are expected to act reasonably and proportionately.
       
       You now have 30 days from the date of this email/letter to make
       payment of the amount as per our Letter of Claim. Failure to
       make payment will result in a Claim being issued against you
       without any further reference.
       
       Payment can be made via bank transfer to our designated client
       account: -
       Account Name: DCB Legal Ltd Client Account
       Sort Code: 20-24-09
       Account Number: 60964441
       
       You must quote the correct case reference (xxxxxxxxxxxx) when
       making payment. If you do not, we may be unable to correctly
       allocate the payment. If further action is taken by us as a
       result of an incorrect reference being quoted, you will be
       liable for any further fees or costs incurred.
       
       We would ask that you kindly furnish us with your most up to
       date telephone number, this can be emailed to us at
       info@dcblegal.co.uk.
       
       Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to
       make payment over the telephone or online at
  HTML https://dcblegal.co.uk/response/pay-online/.
       
       Please note that in the absence of payment in the next 30 days,
       our position remains as previously advised. As such, should our
       client instruct us to proceed with further legal action, we
       reserve the right to do so without any further reference to you.
       
       If you are at all unsure of your legal position, we recommend
       that you seek your own independent legal advice
       Kind Regards,
       
       Isabel Mwamba
       Administration Associate
       DCB Legal Ltd
       
       Tel: 0203 434 0433 | DX 23457 Runcorn"
       #Post#: 88560--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: b789
       Date: September 5, 2025, 8:53 am
       ---------------------------------------------------------
       Where in that LoC does it even mention “driver”? Stop putting
       yourself into self induced panic.
       Even if it did mention “driver”, how do they know who the driver
       is unless you, as the Keeper, blabbed it to them?
       They have given you, the defendant (not the “driver”) 30 days to
       pay. So what?
       I can tell you with greater than 99.9% certainty that this will
       never reach a hearing and will, in due course be discontinued,
       if not struck out first, as long as you follow the advice.
       You can either respond to their response or just ignore it and
       wait for the claim to follow. If you want to respond, just do a
       search of the forum form other recent similar cases and use one
       of those for your own.
       When you receive the claim, come back and show us the a
       particulars of Claim (PoC) and the issue date of the claim.
       Again, just do a search for any other recent DCB Legal issued
       claims to know what is involved.
       No one pays a penny for any defended DCB Legal issued claims to
       if you follow the advice given here.
       #Post#: 88564--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: atousaleila
       Date: September 5, 2025, 9:31 am
       ---------------------------------------------------------
       Thank you so much for your response. Defendant followed your
       advice regarding previous posts and will not respond to dcblegal
       email until a "claim" gets issued by them. Will keep you posted.
       :)
       #Post#: 96257--------------------------------------------------
       Received LETTER OF CLAIM. Please advise!!!
   DIR By: atousaleila
       Date: October 30, 2025, 5:44 pm
       ---------------------------------------------------------
       Driver received a CLAIM FORM. I don't know how to attach the
       copy of the letters. It's from Smart Parking Limited and DCB
       Legal Limited is acting on their behalf. I'm beside myself.
       Please advise!!!
       #Post#: 96258--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: DWMB2
       Date: October 30, 2025, 5:51 pm
       ---------------------------------------------------------
       Does this relate to your ongoing thread - Re: Received LETTER OF
       CLAIM. Please advise!!!
  HTML https://www.ftla.uk/private-parking-tickets/received-letter-of-claim-please-advise!!!/msg88555/#msg88555?
       #Post#: 96259--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: atousaleila
       Date: October 30, 2025, 5:59 pm
       ---------------------------------------------------------
       Yes it is related to my very first post however I struggle
       navigating this site and can't remember how to attach photos. I
       am very worried what is going to happen now. Will appreciate
       advice on this. Happy to give my email if it's easier to
       communicate.
       #Post#: 96260--------------------------------------------------
       Re: Received LETTER OF CLAIM. Please advise!!!
   DIR By: DWMB2
       Date: October 30, 2025, 6:03 pm
       ---------------------------------------------------------
       There's a guide to posting images here: Posting Images
  HTML https://www.ftla.uk/announcements/posting-images/
       I am unable to offer advice via email.
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