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#Post#: 85133--------------------------------------------------
Received letter before claim moorside legal
DIR By: C4060
Date: August 11, 2025, 9:58 am
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Hello,
I was hoping anyone could give me some advice, i have received a
debt recovery letter on 08/05/25 for a parking fine from
18/09/21, which i had no idea about as i was never notified by
the parking company itself. The car in question was owned by my
ex wife. Not sure whos name was on the log book and can not
check as she no longer owns the car.
Received a second letter on 12/06/2025 which i ignored and today
11/08/25 i have received a letter before claim.
Any advise as to my next steps who be very much appreciated
#Post#: 85141--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: b789
Date: August 11, 2025, 10:17 am
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You have to ask whether the address on the V5C at the time of
the alleged contravention had been updated after a previous
move. It's a bit late now but if the operator possibly still
holds an outdated address, they could use that to serve the
claim and you'd be screwed wen you eventually find a CCJ that
was issued in default because you never updated your address
with the claimant.
As you have not show the whole of the Letter of Claim (LoC), we
don't know who their client is. Whoever it is, you should send a
Data Rectification Notice (DRN) to their DPO and also to the
utter incompetents at Moorside Legal, instructing them to update
their records with your current valid address for service and to
erase your old address. The highlighted words are there for a
reason, so use them.
You can simply respond to the LoC by email to
help@moorsidelegal.co.uk and CC 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#: 85347--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: C4060
Date: August 12, 2025, 9:12 am
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Thank you b789
I have sent off the email to Moorside Legal @ London N17 1lg
"As you have not show the whole of the Letter of Claim (LoC), we
don't know who their client is" - no details of client on LOC,
only thing missing off photo is their and my address.
Client is UKPS Ltd 2nd
Location Bermuda Park Nuneaton
Do i need to do anything else ?
#Post#: 85401--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: b789
Date: August 12, 2025, 12:44 pm
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Not for now. Let's see when they fail to comply with the PAP and
we can continue to rattle their cage. The incompetence of this
firm of wannabe legals is a joke for all to observe.
#Post#: 87298--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: C4060
Date: August 26, 2025, 11:14 am
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Hi,
I have received the below, what should i do next ?
We write in relation to the above matter.
Our client has instructed us to collect the outstanding balance
of £170.00 in relation to an unpaid Parking Charge Notice (PCN).
The Terms and Conditions on which UKPS Ltd's services are
provided are clearly displayed throughout the private land.
Please be advised that there are several signs within this
location displaying the terms and conditions, As you breached
the terms and conditions of the car park, this PCN was correctly
issued. Considering the evidence, we are satisfied that the PCN
has been issued in line with industry standards and is compliant
with the International Parking Community’s (IPC) code of
practice. The signage of the car park also complies with the
International Parking Community’s Code of Practice.
By entering and parking the vehicle on our client's private
land, you agreed to enter into a contract with our client and to
be bound by the terms and conditions of that contract. The terms
and conditions were clearly displayed at the entrance and in
prominent places within the car park. Due to your failure to
comply with the terms and conditions, our client has issued the
PCN.
The additional charge which has been levied on your Parking
Charge of £70 is the amount set out in both the British Parking
Association and International Parking Community Codes of
Practice as the amount which may be added to a Parking Charge
when a Parking Charge remains unpaid and when further recovery
is required. Our Client is a member of the International Parking
Community which is a government approved Accredited Trade
Association (ATA) for Private Parking. Our Client adheres to the
ATA’s Code of Practice. The £70 does not represent the cost of
recovery but is a reasonable amount in relation to the Parking
Charge amount, in order to encourage early payment of the
Parking Charge without the need for debt recovery. It is a fair
amount set by our Client’s government-approved Accredited Trade
Association Code of Practice. There are however also costs
incurred by our client in relation to debt recovery services.
It is unclear why you would need to inspect any agreement
between our client and the landowner as you are not party to
that agreement, not could it aid your dispute or any potential
defence.
Please note that we will not be addressing any further
correspondence related to disputes of the same nature, as we
have already provided you with a response. However, should you
wish to raise a new dispute, we will investigate the matter
further and respond accordingly.
We ask that you make the full payment of £170.00 within 7 days
of receipt of this email.
You can make payment in the following ways:
Contact us on 0330 822 9950 (our opening times are Monday-
Friday 9:00- 17:00);
portal.moorsidelegal.co.uk - Login to our portal
HTML https://pay.moorside.legal
- Quick Pay
If you fail to respond or make payment, we may be instructed by
our client to issue legal proceedings against you. This will
incur further costs and fees that will be added to the
outstanding balance. You may wish to seek independent legal
advice.
Yours sincerely,
Moorside Legal
#Post#: 87320--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: b789
Date: August 26, 2025, 1:42 pm
---------------------------------------------------------
Why does it say "Driver details" and name you? Did you give away
the identity of the driver in any representation? The vehicle
was obviously registered to you, irrespective or who "owned" it.
They requested the Keeper data from the DVLA and it must have
been in your name, which is why the Notice to Keeper (NtK) is
addressed to you.
You should respond to the utter incompetents by email with the
following, and CC yourself:
--- Quote ---
> Subject: Your allegation “Non Customer / Unauthorised Parking”
– UKPS Ltd – PCN 1491911
>
> Dear Sirs,
>
> Your client’s stated reasons are “Non Customer Parked in a
Customer Only Car Park / Unauthorised Parking.” The only
“evidence” you rely on is a handful of stills showing entry, the
vehicle parked, and exit. That material proves nothing beyond
presence on site. It does not and cannot establish the status of
any occupant as “non-customer” or “unauthorised”. The burden of
proof is yours. Please explain how a static image of a car
demonstrates the occupiers’ retail status.
>
> If you maintain this allegation, put your client to strict
proof of the following within 30 days:
>
> [indent]1. The exact term allegedly breached, in full, and a
legible photograph of the sign in situ on the material date
showing that term prominently at the entrance and throughout the
site.
> 2. The operational scheme by which “customer” status is
defined, verified, and communicated to motorists (for example,
VRM validation, receipt scanning, or tablet entry), together
with contemporaneous logs showing this VRM was not validated
during the relevant window.
> 3. Evidence capable of proving the negative you assert (that
no occupant was a customer of any on-site business during the
stay). If you intend to rely on store till data or internal
CCTV, identify the lawful basis for processing and
cross-matching such data and provide the DPIA or other
justification relied upon.
> 4. Clarification of whether your case is (a) a contractual
charge for breach of terms or (b) a claim for trespass. If it is
trespass, only the landowner may claim and only for actual loss;
if it is a contractual charge, please explain how a prohibitive
“Customer Only / Unauthorised” notice constitutes a contractual
offer to non-customers.
> 5. A site plan marking each sign and the route a driver would
take, showing that the “customer only” condition was both
unavoidable and unambiguous on approach.[/indent]
>
> As things stand, the allegation is hopelessly vague and
internally inconsistent. “Non customer” presupposes a working,
fair, and transparent verification mechanism and records showing
a failure. You have provided none. “Unauthorised parking” is a
prohibition, not a contractual offer to pay a charge, and if
pleaded as trespass you have not shown the landowner’s title or
any loss. The stills you provided are incapable of discharging
your evidential burden on either footing.
>
> Further, as solicitors you are expected to comply with the
Pre-Action Protocol for Debt Claims. Persisting with payment
demands while withholding the key documents that would allow the
defendant to form a defence (including the Notice to Keeper,
contemporaneous signage, the precise term and alleged breach,
the landowner authority, and a proper breakdown of the sum
claimed) is incompatible with your duties as officers of the
court. If you persist in failing to comply with the Protocol and
to provide those documents, I will not hesitate to report your
conduct to the Solicitors Regulation Authority and will draw
this correspondence to the court’s attention on costs.
>
> Unless you can produce the above key documents and evidence,
you should withdraw this allegation. Any claim founded on “non
customer/unauthorised” accompanied only by entry/exit
photographs will be defended and an application made for
appropriate sanctions for proceeding without a proper evidential
basis.
>
> Yours faithfully,
>
> [Your name]
--- End Quote ---
#Post#: 87388--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: C4060
Date: August 27, 2025, 4:35 am
---------------------------------------------------------
Hi,
Thank you again, at no point have i identified myself as the
driver,
#Post#: 117506--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: C4060
Date: May 1, 2026, 7:32 am
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Hi,
Out of nowhere this has been sent to me
#Post#: 117507--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: DWMB2
Date: May 1, 2026, 7:40 am
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What's "this"?
#Post#: 117508--------------------------------------------------
Re: Received letter before claim moorside legal
DIR By: C4060
Date: May 1, 2026, 7:46 am
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I have received another letter before claim, i cant upload the
letter
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