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       #Post#: 101591--------------------------------------------------
       MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: December 8, 2025, 3:06 pm
       ---------------------------------------------------------
       Hi there,
       I would appreciate some advice on this case. I've had a look
       through the internet and on this forum and appreciate this
       appears to be a particularly prominent car park where MET
       Parking Services are issuing people with tickets for basically
       nothing and then attempting to intimidate them into paying
       through veiled threats of legal action and debt recovery via
       different letterhead letters. I note that numerous of these
       incidents have been highlighted in the mainstream media
       including newspaper and online articles as well as TV shows, (Jo
       Lucett), unfortunately discovered all these post PCN.
       From what I read in the online content there seemed little point
       in the appeal process so have taken the stance of completely
       ignoring all correspondence so far up to now without replying,
       (PCN + 9 letters). However, have just received a "Letter of
       Claim", which I believe requires a response?
       PCN was apparently issued on 30/12/24 for parking incident on
       22/12/24. Didn't receive PCN until 08/01/25 (after the 14 days),
       but not sure that can be proved. On 22/12/24 the driver entered
       the car park at 23:53:10 and parked outside Starbucks, Southgate
       Park with the intention of using the store to make a purchase
       for food and drink and use the facilities. However, once parked
       it was found that Starbucks was actually closed, which was not
       initially clear due to driving and time of night /weather. On
       checking the signage it indicated that there was free 1 hour
       parking for customers.
       As Starbucks was closed and the McDonalds immediately next to it
       in the same site was open the driver walked the very short
       distance to McDonalds where a purchase was made as a customer
       and the facilities were used. At 00:49:01, 55 minutes later the
       driver drove out of the car park within the 1 hour limit. A PCN
       was later received addressed to the registered keeper which
       indicated the vehicle had remained on the site on the date for
       "55 minutes, being longer than the period of parking that had
       been paid for or without authorisation" and apparently "in
       breach of the t&c's displayed on signs in prominent places".
       I have since read articles online where it appears people have
       had the exact same situation and where MET Parking Services
       claim the car parks for Starbucks and McDonalds are separate
       businesses / car parks and marked as such, (which clearly is not
       true). It was cold, wet and dark at the time of the visit and
       the signage was vague and poorly lit but indicated in large
       writing there was free parking for 1 hour for customers. There
       was no indication that Starbucks and McDonalds would be treated
       separately as they were in the same car / retail park and there
       was no clear indication in the car park of any meaningful
       separation between either establishment
       I have also seen other articles suggesting when the store is
       open there is a screen inside Starbucks to enter vehicle
       registration details when using the store, but even this isn't
       clear as a requirement and people have received tickets when
       parking in the car parkand using Starbucks. Obviously as it was
       closed there was no option to enter vehicle details or ask
       anyone permission to park there nor was there a facility to
       enter vehicle details in Mcdonalds. It certainly was not clear
       that in making a purchase in McDonalds you would not be classed
       as customer and the suggestion would be you were in a separate
       car park, (especially when there is one shared entrance / exit).
       I enclose a copy of the PCN and latest letter of claim as well
       as some pictures and would appreciate advice how best to
       proceed.
       Thanks
  HTML https://i.postimg.cc/6ppWX49r/MET_PCN_(edit).png
  HTML https://i.postimg.cc/9FnmcFrG/PCN_Letter_of_Claim_(edit).png
  HTML https://i.postimg.cc/26jZWSmQ/Venue.jpg
  HTML https://i.postimg.cc/RhkhgSrn/Signage.jpg
  HTML https://i.postimg.cc/nrDcjysK/Signage-2.jpg
  HTML https://i.postimg.cc/KY07cH3V/Map.jpg
       #Post#: 101593--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: jfollows
       Date: December 8, 2025, 3:12 pm
       ---------------------------------------------------------
       The real issue is that this is not “relevant land” for the
       purposes of the legislation (PoFA 2012,
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4)
       which
       can otherwise be used to transfer liability from the unknown
       driver to the registered keeper of the vehicle. As long as the
       driver is not identified, the registered keeper can not be
       liable although the process will take several months with MET
       claiming otherwise and threatening court, as can be seen in
       other cases here.
       #Post#: 101595--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: December 8, 2025, 3:20 pm
       ---------------------------------------------------------
       Thanks - I did read something in another thread about that (and
       METPS contesting it). Do you think just send a reply on that
       point? Has there been cases that have found on this basis (or
       have they not gone to court?). The Driver has not been declared
       / identified.
       #Post#: 101597--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: jfollows
       Date: December 8, 2025, 3:25 pm
       ---------------------------------------------------------
       Just search the forum for
       Stansted
       and there are lots of cases and responses, for example
       --- Quote ---
       > I am the registered keeper. MET cannot hold a registered
       keeper liable for any alleged contravention on land that is
       under statutory control. As a matter of fact and law, MET will
       be well aware that they cannot use the PoFA provisions because
       Stansted Airport is not 'relevant land'.
       >
       > If Stansted Airport wanted to hold owners or keepers liable
       under Airport Bylaws, that would be within the landowner's gift
       and another matter entirely. However, not only is that not
       pleaded, it is also not legally possible because MET is not the
       Airport owner and your 'parking charge' is not and never
       attempts to be a penalty. It is created for MET's own profit (as
       opposed to a bylaws penalty that goes to the public purse) and
       MET has relied on contract law allegations of breach against the
       driver only.
       >
       > The registered keeper cannot be presumed or inferred to have
       been the driver, nor pursued under some twisted interpretation
       of the law of agency. Your NtK can only hold the driver liable.
       MET have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       But you’re past this now, so need to reply to the Letter of
       Claim for now.
       For example, as in
  HTML https://www.ftla.uk/private-parking-tickets/met-victim-dcb-legal-letter-of-claim-stansted-southgate/msg94737/#msg94737<br
       />but I haven’t checked this in detail.
       #Post#: 101600--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: December 8, 2025, 3:40 pm
       ---------------------------------------------------------
       Thanks for info - I'll give it a try.
       #Post#: 101601--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: December 8, 2025, 3:51 pm
       ---------------------------------------------------------
       They have requested response via www.dcblegal.co.uk/response and
       to complete a financial statement. Should I be responding via
       this method or letter via registered post or does it matter?
       #Post#: 101623--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: jfollows
       Date: December 9, 2025, 1:40 am
       ---------------------------------------------------------
       They can request what they want but, no, you can reply in any
       way that reaches them, and you can ignore the “financial
       statement”, what right do you think they have to receive this
       information? This is only slightly relevant if you’re intending
       to pay them, but if you’re going to tell them you will defend
       any claim then it’s completely irrelevant.
       #Post#: 101723--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: b789
       Date: December 9, 2025, 9:57 am
       ---------------------------------------------------------
       This could have been put to bed at POPLA. However, you are where
       you are. At least the drivers identity has not been blabbed,
       which is the strongest point.
       I can tell you with greater than 99.9% certainty that as long as
       you follow the advice you are receiving here, you will not be
       paying a penny to MET. As long as they have, in desperation,
       used DCB Legal to issue the claim, as long as it is defended
       when it comes, irrespective of all the winning points you have
       up your sleeve, it will either be struck out or discontinued
       before it ever reaches a hearing.
       FOr now, simply respond to DCB Legal with the following email to
       info@dcblegal.co.uk and CC yourself:
       --- Quote ---
       > Subject: Response to your Letter of Claim Ref: [reference
       number]
       >
       > Dear Sirs,
       >
       > Your Letter Before Claim contains insufficient detail of the
       claim and fails to provide copies of the evidence your client
       places reliance upon, putting it in clear breach of the
       Pre-Action Protocol for Debt Claims.
       >
       > As a supposed firm of solicitors, one would expect you to
       comply 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 exist to facilitate informed discussion and
       proportionate resolution. You may wish to reacquaint yourselves
       with them.
       >
       > The Civil Procedure Rules 1998, Pre-Action Conduct and
       Protocols (Part 3), require the exchange of sufficient
       information to understand each other’s position. Part 6
       clarifies that this includes disclosure of key documents
       relevant to the issues in dispute.
       >
       > Your template letter refers to a “contract” yet encloses none.
       That omission undermines the only foundation upon which your
       client’s claim allegedly rests. It is not possible to engage in
       meaningful pre-litigation dialogue while you decline to furnish
       the very document you purport to enforce.
       >
       > I confirm that, once I am in receipt of a Letter Before Claim
       that complies with para 3.1(a), I shall seek advice and submit a
       formal response within 30 days, as required. Accordingly, please
       provide:
       >
       > [indent]1. A copy of the original Notice to Keeper (NtK) and
       any notice chain relied upon to assert PoFA 2012
       liability.&#8232;
       > 2. A copy of the contract you allege exists between your
       client and the driver, being an actual photograph of the sign(s)
       in place on the material date (not a stock image), together with
       a site plan showing the sign locations.&#8232;
       > 3. The precise wording of the clause(s) allegedly breached.
       > &#8232;4. The written agreement between your client and the
       landowner evidencing standing/authority to enforce and to
       litigate.&#8232;
       > 5. A breakdown of the sums claimed, identifying whether the
       principal sum is claimed as consideration or damages, and
       whether the £70 “debt recovery” add-on includes
       VAT.&#8232;[/indent]
       >
       > I am entitled to this information under paragraphs 6(a) and
       6(c) of the Practice Direction, and I require it to meet my own
       obligation under paragraph 6(b).
       >
       > If you fail to provide the above, I will treat that as
       non-compliance with the PAPDC and Pre-Action Conduct and will
       raise a formal complaint to the SRA regarding your conduct. I
       reserve the right to place this correspondence before the Court
       and to seek appropriate sanctions and costs (including, where
       appropriate, a stay and/or other case management orders).
       >
       > Until your client complies and provides the requested
       material, I am unable to respond properly to the alleged claim
       or to consider my position. It would be premature and a waste of
       costs and court time to issue proceedings. Should you do so, I
       will seek immediate case management relief pursuant to paragraph
       15(b) of the Practice Direction and an order compelling
       provision of the above.
       >
       > Please note, I will not engage with any web portal; I will
       only respond by email or post.
       >
       > Yours faithfully,
       >
       > [Your name]
       --- End Quote ---
       Do not use their portal. Do not use any forms that came with the
       Letter of Claim (LoC). Everything is going to be by email.
       Nothing is sent by snail mail post.
       #Post#: 102062--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: December 11, 2025, 10:49 am
       ---------------------------------------------------------
       Thanks so much for the template and the advice.
       I have copied and e-mailed them the response you set out, to dcb
       legal today and will await their reply.
       I'm sure they will carry on with the intimidating letters but
       will pop back for more advice once I hear anything back.
       Thanks again - you guys give me faith there are decent,
       knowledgeable people out there willing to help those that need
       it to stand up to these highway robbers.
       CD
       #Post#: 102132--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: b789
       Date: December 12, 2025, 4:53 am
       ---------------------------------------------------------
       The debt recovery letters are only "intimidating" if you do not
       understand that there is absolutely nothing these debt
       collectors can do. They are powerless. They are not a party to
       the contract allegedly breached by the driver.
       As long as you are aware of that, then those letters should
       never be "intimidating" ever again. Use the free paper as
       kindling or shred it to make hamster bedding. Win win.
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