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       #Post#: 111399--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: February 27, 2026, 10:51 am
       ---------------------------------------------------------
       Thanks for the reassurance - much appreciated. I will wait for
       some input how best to proceed.
       CD
       #Post#: 111447--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: jfollows
       Date: February 28, 2026, 1:18 am
       ---------------------------------------------------------
       The form tells you what next to do.
       You have 5+14 days from the date on the N1SDT form to file
       either an Acknowledgment of Service or a defence. If the former,
       then you have an additional 14 days for the defence.
       14 & 28 March I believe. You use the online MCOL service for
       both.
       #Post#: 112005--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: CD
       Date: March 4, 2026, 4:33 am
       ---------------------------------------------------------
       Thanks for clarification - all a bit new to me and out of my
       comfort zone. I've created an online account today and completed
       an acknowledgement of service online, indicting I will dispute
       the claim.
       I would really appreciate some assistance on what to set out as
       my defence case for my situation.
       Once I have replied with a defence case does the HM Courts and
       Tribunals Service review the defence or do they have to set a
       court date?
       Do DCB Legal have to decide whether to proceed after the defence
       has been issued or are they already committed to the process?
       Thank You.
       CD
       #Post#: 112007--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: jfollows
       Date: March 4, 2026, 4:48 am
       ---------------------------------------------------------
       You really need to search the forum for lots of cases at the
       same place, see the defences they used, and then modify and post
       here before submitting.
       If you search for DCB Legal also you will see that they proceed
       until having to pay the court fee in 99% of cases.
       #Post#: 112018--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: InterCity125
       Date: March 4, 2026, 6:23 am
       ---------------------------------------------------------
       We can probably come up with a location specific defence for
       this claim.
       Can you confirm that the driver has never been revealed in any
       appeal etc?
       #Post#: 112135--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: InterCity125
       Date: March 5, 2026, 2:49 am
       ---------------------------------------------------------
       These are the bulk of the defence points which should be
       included.
       As already advised, please read through some other threads which
       deal with providing a defence submission.
       Please ensure that you are vaguely familiar with the process
       since it is not entirely complex and is designed for a litigant
       in person rather than a legal professional.
       Give it a few days for others to add further if needed - in my
       opinion, this is a decent skeleton defence - more can be added
       in the Witness Statement if needed.
       I strongly suspect that the parking operator will NOT want to
       provide the official plan since such a plan would destroy their
       business at this location.
       Southgate Park Defence Points
       That the claim is denied in its entirety and that no debt is
       owed.
       It is acknowledged that I am the Registered Keeper of the
       vehicle specifically mentioned in the Claim Form.
       In the first instance, the vehicle driver is not known by the
       claimant.
       That this is a contract dispute and, as such, there is
       absolutely no legal requirement for a Registered Keeper to
       reveal driver details to an unregulated private parking
       contractor.
       As such, I will not be providing any driver details and no
       presumption can be drawn from me simply exercising my legal
       right.
       That the land, mentioned by he Claimant, at Southgate Park,
       Stansted is clearly inside the boundary of the Stansted Airport
       Area.
       That all the land inside the Stansted Airport Area is
       designated, by the Government, as being Land Under Statutory
       Control and, as such, PoFA 2012 Schedule 4 cannot be used at
       this particular location as this location is not 'relevant land'
       as defined under PoFA 2012.
       That a Statutory Instrument exists and is legally in place.
       That this Statutory Instrument is known as 'The Stansted -
       London Byelaws'.
       That the Statutory Instrument sets out parking controls within
       the Land Under Statutory Control.
       That the 'Statutory Control' mentioned in the term 'Land Under
       Statutory Control' is the Statutory Instrument and, as such, by
       definition, the Statutory Instrument covers the entire area of
       Land Under Statutory Control.
       That while the land at Southgate Park is privately owned, it
       remains within the official Airport Area and therefore remains
       under the control of the Statutory Instrument.
       The Claimant has stated (in previous communications) that the
       land at Southgate Park is no longer within the designated area
       under statutory control and that, consequently, PoFA 2012 can in
       fact be used to establish Keeper Liability at the location.
       That I therefore put the Claimant to STRICT PROOF to provide, to
       the Court, a formal Airport Plan document provided by either the
       LOCAL AUTHORITY or the GOVERNMENT which shows the claimed
       revised airport area boundary which specifically excludes the
       land at Southgate Park.
       That the airport plan often used, by the claimant, in the
       parking appeals process will not be accepted since that plan
       specifically excludes land not owned by the airport operator -
       meaning; that even if the land at Southgate Park was inside the
       Airport Area it would never be shown on that particular plan.
       That, as PoFA 2012 cannot be used at Southgate Park, the
       Claimant is unable to move liability from the unknown driver
       onto the Registered Keeper.
       That, with both the driver unknown and, no keeper liability,
       there is no legal route by which the Claimant can hold me
       liable.
       The Claim is therefore denied in its entirety.
       Additional defence points which the Court should be made aware
       of;
       That the Claimant's issued Parking Charge Notices (PCNs) are in
       clear breach of the parking operators Code of Practice since the
       PCNs specifically mention PoFA Keeper Liability.
       The operators Code of Practice EXPRESSLY PROHIBBITS operators
       specifying keeper liability under PoFA 2012 when PoFA cannot
       apply.
       A breach of the Code of Practice is automatically a breach of
       the operator's KADOE Agreement with the DVLA since that
       agreement specifically requires that the operator agree to
       follow the Code of Practice.
       My details have therefore been obtained in breach of the KADOE
       Agreement.
       That this also constitutes a misuse of personal data.
       #Post#: 112136--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: jfollows
       Date: March 5, 2026, 3:02 am
       ---------------------------------------------------------
       Just spelling - KADOE - Keeper At Date Of Event
       #Post#: 112137--------------------------------------------------
       Re: MET Parking Services - Alleged Overstay - Southgate Park,
       Stansted
   DIR By: InterCity125
       Date: March 5, 2026, 3:05 am
       ---------------------------------------------------------
       Amended.
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