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       #Post#: 90744--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: b789
       Date: September 20, 2025, 8:39 am
       ---------------------------------------------------------
       All good so far. The ball is now in their court and you are
       waiting for their response to your letter.
       #Post#: 90748--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: Patmoore
       Date: September 20, 2025, 8:45 am
       ---------------------------------------------------------
       Thank you!
       #Post#: 90752--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: b789
       Date: September 20, 2025, 8:52 am
       ---------------------------------------------------------
       As a matter of interest, did you send that by post? If so, did
       you post it first class and get a free certificate of posting
       from any post office?
       We never recommend using post. It is too unreliable and slow.
       You should ALWAYS, if possible correspond by email. You can
       attach any correspondence as a PDF to an email and you have
       proof of sending, proof of delivery and it is instantaneous with
       no trees being harmed in the pro9cess.
       Elms Legal show the following email address which you should
       use:
       info@elm-online.co.uk
       #Post#: 90768--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: Patmoore
       Date: September 20, 2025, 10:19 am
       ---------------------------------------------------------
       Hi - I responded by post, with a certificate of posting as well
       as email!
       #Post#: 96230--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: b789
       Date: October 30, 2025, 2:06 pm
       ---------------------------------------------------------
       FYI, here is a successful defence with costs awarded against VCS
       for exactly the same allegation:
  HTML https://forums.moneysavingexpert.com/discussion/6635565/bristol-airport-no-stopping-fine-case-success-and-724-cost-dcb-legal/p1
       #Post#: 96232--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: Patmoore
       Date: October 30, 2025, 2:35 pm
       ---------------------------------------------------------
       b789
       Hero Member
       Thank you SO much for your ongoing interest and help in this
       case ! I will let you know the outcome in due course? Regards!
       #Post#: 96304--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: InterCity125
       Date: October 31, 2025, 7:12 am
       ---------------------------------------------------------
       This one is also very good as the OP goes to great lengths to
       explain the various processes which he or she goes through;
  HTML https://nationalconsumerservice.co.uk/topic/468850-vcs-cnntk-appealed-paploc-now-claimform-no-stopping-bristol-airport-claim-dismissed/#comments
       #Post#: 100479--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: Patmoore
       Date: December 1, 2025, 5:25 am
       ---------------------------------------------------------
       After having received an LBC and replied back still dipsuting
       but adding that the letter was not compliant (which it wasn't).
       (It is disappointing to note that your letter fails to meet the
       requirements set out in paragraphs 3.1(a)–(d), 5.1, and 5.2 of
       the Protocol, as well as paragraphs 6(a) and 6(c) of the
       Practice Direction. These provisions are not optional; they
       exist to facilitate informed engagement and proportionate
       resolution prior to litigation. I encourage you to review them
       carefully.
       The Civil Procedure Rules 1998, Part 3, Pre-Action Conduct and
       Protocols, require that parties exchange sufficient information
       to understand each other’s position before proceedings are
       issued. Paragraph 6 of the Practice Direction clarifies that
       this includes disclosure of key documents relevant to the
       dispute. Your letter refers to a “contract” yet fails to provide
       one—undermining the very basis of your client’s claim and
       obstructing meaningful pre-litigation dialogue.
       I also note that your Letter Before Claim fails to enclose the
       required Reply Form and Information Sheet, as stipulated under
       paragraph 3.1(a) of the Protocol. Providing only a hyperlink to
       these documents does not satisfy the requirement to include them
       with the letter itself. This omission impedes my ability to
       respond meaningfully and constitutes a procedural defect. I
       request that you remedy this by supplying the required documents
       before any further action is taken.)
       They had set a hold date of the 13th Nov. I have heard nothing
       until today. This seems to be a backward move in the process?
       Any thoughts please? I received a letter from ELMS Legal
  HTML https://ibb.co/DDPPNfKm
       #Post#: 100482--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: InterCity125
       Date: December 1, 2025, 5:34 am
       ---------------------------------------------------------
       It's just another debt collecting letter which you can ignore.
       Whilst it does look like a step backwards in the process, you
       have to remember that these people are incompetent in the
       extreme.
       #Post#: 100525--------------------------------------------------
       Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
       show 23 secs
   DIR By: b789
       Date: December 1, 2025, 8:56 am
       ---------------------------------------------------------
       Whilst I wouldn't normally advise responding to any debt
       recovery letter, in this case, Elms are clearly in breach of the
       DMCC and they should be reported to the CMA and I would suggest
       you email the following to Elms and CC yourself:
       --- Quote ---
       > Subject: Your reference VCS22897672 – Notice of complaint
       under the DMCC and request to return file to client
       >
       > Dear Sirs
       >
       > I refer to your “URGENT: NOTIFICATION OF INSTRUCTION” dated 24
       November 2025 in respect of an alleged Parking Charge Notice
       issued by Vehicle Control Services Ltd (“VCS”) at Bristol
       Airport on 28 March 2025.
       >
       > For the avoidance of doubt, I do not accept that any
       contractual liability exists. The allegation arises from a
       brief, involuntary stall of around 23 seconds at a live
       roundabout while I was attempting to locate a pre-booked
       meet-and-greet facility. The signage relied upon is wholly
       prohibitive (“No stopping”) and offers no contractual licence or
       consideration to motorists. At most, any complaint would sound
       in trespass (for which only the landowner could claim actual
       loss). VCS also seek an additional £70 “costs” on top of the
       £100 parking charge, a sum which is not recoverable in law.
       >
       > In those circumstances, the “debt” you are seeking to recover
       is disputed, is not legally owed, and is based on a speculative
       airport “no stopping” charge on non-relevant land which cannot
       give rise to keeper liability under the Protection of Freedoms
       Act 2012.
       >
       > Notwithstanding the above, your letter presents the sum of
       £170 as a recoverable contractual debt and uses urgent and
       intimidating language that is plainly designed to pressurise
       payment. In my view this conduct amounts to unfair commercial
       practices within the meaning of Part 4, Chapter 1 of the Digital
       Markets, Competition and Consumers Act 2024 (“DMCC”), including:
       >
       > 1. Misleading actions, by giving the false impression that
       there is a valid contractual right to recover £170 from me when
       no such right exists and the £70 add-on is not recoverable.
       >
       > 2. Misleading omissions, by failing to explain the legal
       limitations on liability on airport land and the true status and
       enforceability of the alleged debt.
       >
       > 3. Aggressive practices, by deploying an “URGENT” heading,
       repeated “Action Required” wording and implied threats of
       further costs in circumstances where the existence of any debt
       is highly questionable, thereby exerting undue pressure on a
       consumer.
       >
       > 4. A failure to meet the standard of professional diligence
       reasonably to be expected of a CILEx-regulated legal business
       dealing with consumers in a highly technical area of law.
       >
       > A commercial practice which is misleading, aggressive, or
       contrary to professional diligence, and which is likely to cause
       the average consumer to take a transactional decision they would
       not otherwise have taken (such as paying an unenforceable
       parking charge), is prohibited and unlawful under the DMCC.
       >
       > I therefore put you on notice that:
       >
       > a) I am submitting a formal complaint to the Competition and
       Markets Authority regarding your letter and your firm’s role in
       the wider practice of pursuing unenforceable airport
       “no-stopping” parking charges as alleged contractual debts. I
       will be providing the CMA with copies of your letter, the
       underlying VCS documentation and a summary of why the alleged
       debt is not legally recoverable.
       >
       > b) I am also submitting a complaint to CILEx Regulation on the
       basis that your conduct appears to breach your regulatory duties
       of integrity, transparency and professional diligence when
       dealing with consumers. If any of the individuals responsible
       for this matter are also solicitors regulated by the Solicitors
       Regulation Authority, I reserve the right to raise the same
       concerns with the SRA.
       >
       > c) A separate complaint will be made to the CMA concerning
       VCS’s own conduct and business model in issuing such charges at
       Bristol Airport on a prohibitive signage basis.
       >
       > You will be aware that the CMA now has direct civil
       enforcement powers under the DMCC and can decide for itself
       whether a commercial practice is unfair and, if so, impose
       significant financial penalties, require redress for affected
       consumers and seek enforcement orders and undertakings. I will
       be inviting the CMA to consider whether your standard
       debt-recovery templates and your relationship with VCS form part
       of a wider pattern of unfair commercial practices in the private
       parking sector.
       >
       > In light of the above, I now require you to cease all
       debt-recovery activity on this matter and to return the file to
       your client, Vehicle Control Services Ltd, making it clear that
       I deny any liability. If VCS genuinely consider that they have a
       viable cause of action, they are at liberty to issue a properly
       particularised county court claim which will be robustly
       defended.
       >
       > Please note that any further misleading or aggressive
       correspondence from your firm will be treated as further
       evidence of unfair commercial practices under the DMCC and may
       be relied upon in any court proceedings, regulatory complaints
       or costs applications regarding unreasonable conduct.
       >
       > I look forward to your written confirmation that you have
       closed your file and referred the matter back to your client.
       >
       > Yours faithfully
       >
       > [Name]
       > [Address]
       > [Email]
       --- End Quote ---
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