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#Post#: 100528--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: Patmoore
Date: December 1, 2025, 9:17 am
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Wow, Thank you very much. I will do just that. - Should I
actually follow up and complain to the CMA too?
#Post#: 100538--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: DWMB2
Date: December 1, 2025, 9:52 am
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--- Quote from: Patmoore link ---
>
> Should I actually follow up and complain to the CMA too?
>
--- End Quote ---
If you send correspondence saying you're going to do something,
I would recommend you actually do, so that you don't create the
impression that you are all bluster and no substance.
#Post#: 100539--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: Patmoore
Date: December 1, 2025, 9:55 am
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Ok - Thank you, Can you advise as to how to construct the
complaint to the CMA please? Thanks.
#Post#: 100557--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: b789
Date: December 1, 2025, 11:22 am
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HTML https://www.gov.uk/guidance/how-best-to-make-a-competition-or-consumer-law-complaint-and-what-happens-next
#Post#: 106000--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: Patmoore
Date: January 15, 2026, 6:50 am
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I have received ANOTHER Letter Before Claim from Elms Legal. The
first was received on Aug 12th 24.This was my response the:
Subject: Response to Letter Before Claim – Ref: VCS22897672
Dear Sir/Madam,
I write in response to your Letter Before Claim dated 21 August
2025, concerning an alleged parking charge issued by Vehicle
Control Services Ltd in relation to an incident at Bristol
Airport on 28 March 2025.
I dispute the debt in full and request that no proceedings be
initiated until your client has complied with its obligations
under the Pre-Action Protocol for Debt Claims and the Practice
Direction on Pre-Action Conduct.
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.
I confirm that, upon receipt of a Letter Before Claim that
complies with paragraph 3.1(a) of the Protocol, I will seek
legal advice and provide a formal response within 30 days. To
that end, I request the following documentation:
1.
liability under Schedule 4 of the Protection of Freedoms Act
2012
2.
it and the driver, including a photograph of the signage present
at the location on the material date (not a generic image)
3.
conditions that your client alleges were breached
4.
landowner, establishing authority to enforce and litigate
5.
principal sum is claimed as consideration or damages, and
whether the £70 “debt recovery” fee includes VAT
6.
support of your client’s claim, not merely selected still
images. This evidence is material to the alleged breach and is
required under paragraph 6(a) of the Practice Direction. I am
entitled to review the complete context of the incident in order
to understand your client’s position and respond meaningfully.
This information is clearly required under paragraphs 6(a) and
6(c) of the Practice Direction, and I require it in order to
comply with my own obligations under paragraph 6(b).
Should your client fail to provide this documentation, I will
rely on the authorities of Webb Resolutions Ltd v Waller Needham
& Green [2012] EWHC 3529 (Ch), Daejan Investments Ltd v The Park
West Club Ltd [2003] EWHC 2872, and Charles Church Developments
Ltd v Stent Foundations Ltd & Peter Dann Ltd [2007] EWHC 855 in
seeking a stay of proceedings and appropriate sanctions under
paragraphs 13, 15(b)–(c), and 16 of the Practice Direction, as
referenced in paragraph 7.2 of the Protocol.
Until your client has complied with its pre-action obligations
and provided the requested documentation, I am unable to respond
substantively to the alleged claim. Issuing proceedings at this
stage would be premature and contrary to the spirit and letter
of the Protocol. Should your client proceed regardless, I will
seek an immediate stay and an order compelling disclosure.
Yours faithfully,
Patrick Moore
HTML https://litter.catbox.moe/5kmckpnzwpbrs7ze.jpg
HTML https://litter.catbox.moe/f1c185kyride56ou.jpg
HTML https://litter.catbox.moe/fzzvrcf54wm3svov.jpg
Please advise?
#Post#: 106342--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: InterCity125
Date: January 18, 2026, 3:21 am
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Those images will not load.
Can you re-host on a different provider?
#Post#: 106350--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: Patmoore
Date: January 18, 2026, 5:01 am
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I hope these can be seen. Acopy of the second LbC from Elms
Legal.
HTML https://ibb.co/K30YC8z
HTML https://ibb.co/vpCQTgB
HTML https://ibb.co/9kpyyHYr
#Post#: 106366--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: InterCity125
Date: January 18, 2026, 6:21 am
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Perfect - yes they now load.
Okay, so I would write back to them and ask why they have issued
a second LBC (some months apart) when they haven't yet responded
to your response to the original LBC. Be sure to point out that
behaviour is becoming unreasonable and in clear breach of of
pre-action protocol for debt claims.
See what they come back with.
They really are incompetent idiots.
#Post#: 106383--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: Patmoore
Date: January 18, 2026, 8:23 am
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I have made it very clear to them that their actions are not
within the protocol especially given that there is a second LbC
which still does not comply with the Protocol. Furthermore, I
clearly restated my stance as in previous correspondence and
questioned why there has been no replies to my clear responses
to their first LbC.
This is part of my reply
"Repeated and Material Non‑Compliance with the Protocol:
This second letter repeats the same fundamental defects as your
first letter of 21 August 2025. It remains non‑compliant
with the mandatory requirements of the Protocol:
Ignoring Pre-Action Correspondence: Your letter makes no
reference to the extensive pre-action correspondence between us
from September to December 2025 (enclosed in my comprehensive
court bundle, prepared in anticipation of proceedings). In that
correspondence, I:
Formally disputed the debt.
Provided detailed grounds for my defence (de minimis, no breach
of contract, disproportionate charge, unfair term under the
Consumer Rights Act 2015, inadequate signage).
Repeatedly requested key evidence (unredacted landowner
contract, full CCTV, contemporaneous signage), which your client
refused to provide.
Completed and returned the Reply Form on 19 September 2025.
Your client's failure to engage with these substantive points
and its refusal to provide evidence are documented and
demonstrate a failure to comply with the spirit and purpose of
the Pre-Action Protocol."
#Post#: 106388--------------------------------------------------
Re: PCN for stall at roundabout at Bristol Airport, CCTV stills
show 23 secs
DIR By: Dave65
Date: January 18, 2026, 9:08 am
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This letter is from "Elms Legal" as a letter before claim and
they say they will pass it on to Elms Legal Ltd.
Different Departments?
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