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#Post#: 103518--------------------------------------------------
Urgent help-Letter Before Claim-Moorside Legal on Behalf of NCP
Gatwick
DIR By: Learner1
Date: December 21, 2025, 8:32 pm
---------------------------------------------------------
Dear all,
I would appreciate your help with this matter.
The vehicle is registered with NCP at Gatwick Airport under
Autopay. On this occasion, the ANPR system failed to capture the
number plate, and a PCN was issued in error.
As the registered keeper (RK) was away at the time, they were
unable to appeal or have the issue corrected by NCP.
Subsequently, multiple letters were received from Marston
Recovery, followed by a Letter Before Claim from Moorside Legal
a couple of days ago.
The Letter Before Claim does not specify a deadline for
contacting or anything, but it requests payment.
Please could you advise on the next steps the RK should take to
respond?
Thank you very much
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#Post#: 103527--------------------------------------------------
Re: Letter Before Claim-Moorside Legal on Behalf of NCP Gatwick
DIR By: InterCity125
Date: December 22, 2025, 2:43 am
---------------------------------------------------------
They're probably fishing for liability.
Given your wording, can we assume that the driver has never been
identified?
As LoC's go, that one is a shocker and totally non-compliant
with the required protocol.
#Post#: 103562--------------------------------------------------
Re: Letter Before Claim-Moorside Legal on Behalf of NCP Gatwick
DIR By: Learner1
Date: December 22, 2025, 7:58 am
---------------------------------------------------------
--- Quote from: InterCity125 link ---
>
> They're probably fishing for liability.
>
> Given your wording, can we assume that the driver has never
been identified?
>
> As LoC's go, that one is a shocker and totally non-compliant
with the required protocol.
>
--- End Quote ---
Thank you for your response, InterCity125
No, RK did not communicate with NCP, so the driver was never
identified.
I was wondering what response I should send to Moorside Legal at
this stage.
#Post#: 103563--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: Learner1
Date: December 22, 2025, 8:08 am
---------------------------------------------------------
This is the orignal PCN received:
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#Post#: 103565--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: Learner1
Date: December 22, 2025, 8:12 am
---------------------------------------------------------
After searching the forum, I came up with this response; please
advise if this is the correct one. I would appreciate your
input.
''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
intends to rely upon. It is therefore non‑compliant with
the Pre‑Action Protocol for Debt Claims (PAPDC). 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, proportionate
resolution, and I suggest you reacquaint yourselves with them.
The Civil Procedure Rules 1998, Pre‑Action Conduct and
Protocols (Part 3), require each party to exchange sufficient
information to understand the 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 very basis upon
which your client’s claim allegedly rests. It is not possible to
engage in any form of meaningful pre‑litigation dialogue
while you refuse to furnish the documents you purport to
enforce.
I confirm that, once I am in receipt of a Letter Before Claim
that complies with paragraph 3.1(a), I shall seek advice and
submit a full response within 30 days. Accordingly, please now
provide:
1. A copy of the original Notice to Keeper and the full notice
chain relied upon to assert any alleged PoFA 2012 liability.
2. An actual photograph of the sign(s) in situ on the material
date (not stock images), together with a contemporaneous site
map showing sign locations.
3. The precise wording of the contractual term(s) your client
alleges were breached.
4. The written agreement between your client and the landowner
evidencing authority to manage, enforce and litigate in their
own name.
5. A clear breakdown of the sums claimed, identifying whether
the principal amount is alleged consideration or damages, and
clarifying the legal basis and VAT position of the Ł70
add‑on.
These documents are required under paragraphs 6(a) and 6(c) of
the Practice Direction to enable me to meet my obligation under
paragraph 6(b).
Your letter’s attempt at intimidation
I also note that your accompanying schedule manages to refer to
a “CCJ” four times, in what is clearly intended as a coercive
device rather than legitimate legal information. The repetition
is telling: it demonstrates not confidence in your client’s
position, but reliance on fear as a substitute for substance.
To be clear: I am fully aware that a County Court Judgment only
arises after your client wins a claim (which is unlikely on the
facts), and even then, any judgment paid within one calendar
month is removed from the register and has no impact on credit.
Your overuse of the term “CCJ” is therefore not only pointless
but improper.
Your firm is on notice that this conduct will now be reported
to:
• the Solicitors Regulation Authority, for use of misleading and
oppressive tactics contrary to the SRA Code of Conduct; and
• the Competition and Markets Authority, under the Digital
Markets, Competition and Consumers Act 2024, given the statutory
prohibition on coercive and misleading commercial practices.
If you proceed to issue a claim without first providing the
documents and information required under the PAPDC and
Pre‑Action Conduct, I will draw your non‑compliance
to the Court’s attention and seek appropriate sanctions,
including a stay and case‑management orders pursuant to
paragraph 15(b) of the Practice Direction. Any unreasonable
conduct by you or your client will be relied upon in support of
an application for costs.
For the avoidance of doubt, I will not engage with any web
portal. I will respond only via email or post.
Yours faithfully,
[Your Name]''
Thank you very much
#Post#: 103581--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: InterCity125
Date: December 22, 2025, 10:32 am
---------------------------------------------------------
Hold off sending that for the moment and wait for further
advice.
The LoC is only dated 10th Dec 2025 so plenty of time.
Given that this is airport land there is no keeper liability. Of
course the original PCN does not convey this information as it
is not in their interest to present a balanced legal view of the
situation. Instead they deliberately imply that the keeper could
be pursued. They also specify that you must either pay the
charge yourself or name the driver - there is no such legal
requirement whatsoever.
With that in mind, others may suggest an amendment to the PoC
response which makes it clear that keeper liability is denied.
Wait for further comments which may take slightly longer than
normal due to Christmas commitments etc.
#Post#: 103604--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: b789
Date: December 22, 2025, 1:58 pm
---------------------------------------------------------
You can stop panicking. This is a standard “fishing” exercise
designed to make the registered keeper either pay or name the
driver.
1. No keeper liability at Gatwick Airport
Gatwick Airport land is subject to statutory control (airport
byelaws). That means it is not “relevant land” for the purposes
of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA).
Without relevant land, PoFA cannot transfer liability from the
unknown driver to the registered keeper. In plain terms: if the
driver has not been identified, they cannot hold the keeper
liable. That is why the original NCP letter tries to pressure
the keeper with “pay or name the driver” wording. There is no
legal obligation to name the driver.
So provided the keeper has not identified the driver at any
point, this matter is fundamentally stuck for them. They can
only pursue the driver, and they do not know who that is.
2. The Moorside “Letter Before Claim” is not a proper Letter of
Claim
That letter from the utter incompetents at Moorside is a
template demand. A compliant Letter of Claim under the
Pre-Action Protocol for Debt Claims must contain proper detail
of the cause of action, a clear breakdown of the sum claimed,
and the key documents they intend to rely upon (such as
signage/terms and proof of landowner authority). What you have
been sent does not do that. It reads like a payment invitation,
not a protocol-compliant Letter of Claim.
3. Even if they issued a claim, it has minimal to zero chance of
going to go to a hearing
They would have to plead a coherent cause of action against the
keeper. Moorside are too incompetent and intellectually
malnourished to do that properly. They cannot rely on PoFA,
because Gatwick is not relevant land. If they try anyway, you
defend on that basis and it is dead on arrival. This sort of
case collapses long before any hearing because the keeper
liability route is closed and they do not want the scrutiny of a
defended claim where their paperwork and compliance will be
examined.
4. What the Keeper should do now
Do NOT use their portal and do not ring them. Do NOT say who was
driving. Do NOT get drawn into explaining the trip.
You should send a short, firm written response to Moorside along
these lines:
[indent]• deny any keeper liability
• state the location is airport land subject to byelaws and
therefore not relevant land under PoFA, so the keeper cannot be
liable
• confirm the driver will not be identified
• state their letter is not compliant with the Pre-Action
Protocol for Debt Claims and request they either close the file
or issue a compliant Letter of Claim with the required documents
(signage terms in force, site plan, landowner authority, full
breakdown of sums and the legal basis for any add-ons)
• require all further contact in writing[/indent]
That is enough. You are not trying to “argue the whole case”
now. You are putting them on notice that (a) Keeper liability is
denied and (b) you will not be naming the driver.
5. What NOT to do
[indent]• Do not pay “to make it go away” (that is what the
template is designed to achieve).
• Do not say “I wasn’t the driver” or give any narrative that
hints who was.
• Do not be tempted into long complaints about ANPR failures or
autopay at this stage. The winning point is simpler: no keeper
liability.[/indent]
Bottom line
If the driver is not identified, this is not something to worry
about. They are posturing. The keeper’s position is strong
because airport land blocks PoFA keeper liability entirely, and
Moorside’s letter is not a proper protocol Letter of Claim. If
they were stupid enough to litigate against the Keeper, it is
readily defensible and very unlikely to ever reach a hearing.
Send the following email response to the morons at Moorside to
help@moorsidelegal.co.uk and CC yourself. If it bounces back
with a "not monitored" response, just send it again until it
does not receive that fake bounce response:
--- Quote ---
> Subject: Response to your Letter Before Claim – Ref:
[________] – National Car Parks Limited
>
> Dear Sirs,
>
> I am the registered keeper. Liability is denied. Any claim
issued against the registered keeper will be defended in full as
having no real prospects of success
>
> 1. No keeper liability (Gatwick Airport = non-relevant land)
> Your client’s allegation concerns Gatwick Airport land, which
is subject to statutory control and is not “relevant land” for
the purposes of Schedule 4 of the Protection of Freedoms Act
2012. Accordingly, there is no lawful mechanism to transfer
liability from an unidentified driver to the registered keeper.
The driver will not be identified.
>
> Your assertion that the keeper must either pay or name the
driver is legally wrong and misleading. There is no legal
obligation upon a keeper to identify a driver.
>
> 2. Your “Letter Before Claim” is non-compliant with the
Pre-Action Protocol for Debt Claims
> Your letter is a bare payment demand. It contains no
meaningful detail of the alleged cause of action and encloses
nothing at all.
>
> In particular, you have failed to enclose the mandatory PAPDC
documents (Information Sheet, Reply Form and Financial
Statement) and you have provided none of the key documents which
the Protocol requires a creditor to supply so that a debtor can
understand the claim and obtain advice (including the
contract/terms relied upon, evidence of signage, and proof of
your client’s standing/authority at the location). This is not a
compliant Letter of Claim.
>
> 3. Required action
> Within 14 days of the date of this letter, you must either:
>
> [indent](a) confirm in writing that the matter is closed and
that no further action will be taken against the registered
keeper; or
>
> (b) serve a fully compliant Letter of Claim, including the
mandatory PAPDC enclosures, and providing (as a minimum) the
following:
>
> [indent](i) your pleaded legal basis for pursuing the
registered keeper despite PoFA being inapplicable on airport
land;
> (ii) copies of the Notice to Keeper and the full notice chain
relied upon;
> (iii) the precise contractual term(s) alleged to have been
breached and an explanation of the alleged breach;
> (iv) contemporaneous photographs of the signage in situ on the
material date and a site plan showing the sign locations and the
alleged location of the vehicle;
> (v) the written agreement/chain of authority showing your
client’s standing to operate, enforce and litigate in its own
name at that precise location;
> (vi) a full itemised breakdown of the sum demanded and the
legal basis for any added sums.[/indent][/indent]
>
> 4. Regulatory notice/further conduct
> You are now on notice that continuing to pursue the registered
keeper where no keeper liability can arise, and/or continuing to
state or imply that the keeper is required to pay or identify
the driver, will be treated as improper conduct. If you persist,
I will submit a report to the Solicitors Regulation Authority
and will rely upon your pre-action non-compliance and misleading
assertions in any proceedings, including on the issue of costs
and case management.
>
> I will not engage via any portal. All correspondence must be
in writing to the address above and/or by email to [your email
address].
>
> Yours faithfully,
>
> [Name]
> [Address]
> [Date]
--- End Quote ---
#Post#: 104052--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: Learner1
Date: December 30, 2025, 5:46 am
---------------------------------------------------------
--- Quote from: InterCity125 link ---
>
> Hold off sending that for the moment and wait for further
advice.
>
> The LoC is only dated 10th Dec 2025 so plenty of time.
>
> Given that this is airport land there is no keeper liability.
Of course the original PCN does not convey this information as
it is not in their interest to present a balanced legal view of
the situation. Instead they deliberately imply that the keeper
could be pursued. They also specify that you must either pay the
charge yourself or name the driver - there is no such legal
requirement whatsoever.
>
> With that in mind, others may suggest an amendment to the PoC
response which makes it clear that keeper liability is denied.
>
> Wait for further comments which may take slightly longer than
normal due to Christmas commitments etc.
>
--- End Quote ---
Dear InterCity125
Thank you so much for the response and for pointing out that the
keeper's liability is denied.A sigh of relief.
#Post#: 104061--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: Learner1
Date: December 30, 2025, 6:39 am
---------------------------------------------------------
--- Quote from: b789 link ---
>
> You can stop panicking. This is a standard “fishing” exercise
designed to make the registered keeper either pay or name the
driver.
>
> 1. No keeper liability at Gatwick Airport
> Gatwick Airport land is subject to statutory control (airport
byelaws). That means it is not “relevant land” for the purposes
of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA).
Without relevant land, PoFA cannot transfer liability from the
unknown driver to the registered keeper. In plain terms: if the
driver has not been identified, they cannot hold the keeper
liable. That is why the original NCP letter tries to pressure
the keeper with “pay or name the driver” wording. There is no
legal obligation to name the driver.
>
> So provided the keeper has not identified the driver at any
point, this matter is fundamentally stuck for them. They can
only pursue the driver, and they do not know who that is.
>
> 2. The Moorside “Letter Before Claim” is not a proper Letter
of Claim
> That letter from the utter incompetents at Moorside is a
template demand. A compliant Letter of Claim under the
Pre-Action Protocol for Debt Claims must contain proper detail
of the cause of action, a clear breakdown of the sum claimed,
and the key documents they intend to rely upon (such as
signage/terms and proof of landowner authority). What you have
been sent does not do that. It reads like a payment invitation,
not a protocol-compliant Letter of Claim.
>
> 3. Even if they issued a claim, it has minimal to zero chance
of going to go to a hearing
> They would have to plead a coherent cause of action against
the keeper. Moorside are too incompetent and intellectually
malnourished to do that properly. They cannot rely on PoFA,
because Gatwick is not relevant land. If they try anyway, you
defend on that basis and it is dead on arrival. This sort of
case collapses long before any hearing because the keeper
liability route is closed and they do not want the scrutiny of a
defended claim where their paperwork and compliance will be
examined.
>
> 4. What the Keeper should do now
> Do NOT use their portal and do not ring them. Do NOT say who
was driving. Do NOT get drawn into explaining the trip.
>
> You should send a short, firm written response to Moorside
along these lines:
>
> [indent]• deny any keeper liability
> • state the location is airport land subject to byelaws and
therefore not relevant land under PoFA, so the keeper cannot be
liable
> • confirm the driver will not be identified
> • state their letter is not compliant with the Pre-Action
Protocol for Debt Claims and request they either close the file
or issue a compliant Letter of Claim with the required documents
(signage terms in force, site plan, landowner authority, full
breakdown of sums and the legal basis for any add-ons)
> • require all further contact in writing[/indent]
>
> That is enough. You are not trying to “argue the whole case”
now. You are putting them on notice that (a) Keeper liability is
denied and (b) you will not be naming the driver.
>
> 5. What NOT to do
>
> [indent]• Do not pay “to make it go away” (that is what the
template is designed to achieve).
> • Do not say “I wasn’t the driver” or give any narrative that
hints who was.
> • Do not be tempted into long complaints about ANPR failures
or autopay at this stage. The winning point is simpler: no
keeper liability.[/indent]
>
> Bottom line
> If the driver is not identified, this is not something to
worry about. They are posturing. The keeper’s position is strong
because airport land blocks PoFA keeper liability entirely, and
Moorside’s letter is not a proper protocol Letter of Claim. If
they were stupid enough to litigate against the Keeper, it is
readily defensible and very unlikely to ever reach a hearing.
>
> Send the following email response to the morons at Moorside to
help@moorsidelegal.co.uk and CC yourself. If it bounces back
with a "not monitored" response, just send it again until it
does not receive that fake bounce response:
>
> [quote]Subject: Response to your Letter Before Claim – Ref:
[________] – National Car Parks Limited
>
> Dear Sirs,
>
> I am the registered keeper. Liability is denied. Any claim
issued against the registered keeper will be defended in full as
having no real prospects of success
>
> 1. No keeper liability (Gatwick Airport = non-relevant land)
> Your client’s allegation concerns Gatwick Airport land, which
is subject to statutory control and is not “relevant land” for
the purposes of Schedule 4 of the Protection of Freedoms Act
2012. Accordingly, there is no lawful mechanism to transfer
liability from an unidentified driver to the registered keeper.
The driver will not be identified.
>
> Your assertion that the keeper must either pay or name the
driver is legally wrong and misleading. There is no legal
obligation upon a keeper to identify a driver.
>
> 2. Your “Letter Before Claim” is non-compliant with the
Pre-Action Protocol for Debt Claims
> Your letter is a bare payment demand. It contains no
meaningful detail of the alleged cause of action and encloses
nothing at all.
>
> In particular, you have failed to enclose the mandatory PAPDC
documents (Information Sheet, Reply Form and Financial
Statement) and you have provided none of the key documents which
the Protocol requires a creditor to supply so that a debtor can
understand the claim and obtain advice (including the
contract/terms relied upon, evidence of signage, and proof of
your client’s standing/authority at the location). This is not a
compliant Letter of Claim.
>
> 3. Required action
> Within 14 days of the date of this letter, you must either:
>
> [indent](a) confirm in writing that the matter is closed and
that no further action will be taken against the registered
keeper; or
>
> (b) serve a fully compliant Letter of Claim, including the
mandatory PAPDC enclosures, and providing (as a minimum) the
following:
>
> [indent](i) your pleaded legal basis for pursuing the
registered keeper despite PoFA being inapplicable on airport
land;
> (ii) copies of the Notice to Keeper and the full notice chain
relied upon;
> (iii) the precise contractual term(s) alleged to have been
breached and an explanation of the alleged breach;
> (iv) contemporaneous photographs of the signage in situ on the
material date and a site plan showing the sign locations and the
alleged location of the vehicle;
> (v) the written agreement/chain of authority showing your
client’s standing to operate, enforce and litigate in its own
name at that precise location;
> (vi) a full itemised breakdown of the sum demanded and the
legal basis for any added sums.[/indent][/indent]
>
> 4. Regulatory notice/further conduct
> You are now on notice that continuing to pursue the registered
keeper where no keeper liability can arise, and/or continuing to
state or imply that the keeper is required to pay or identify
the driver, will be treated as improper conduct. If you persist,
I will submit a report to the Solicitors Regulation Authority
and will rely upon your pre-action non-compliance and misleading
assertions in any proceedings, including on the issue of costs
and case management.
>
> I will not engage via any portal. All correspondence must be
in writing to the address above and/or by email to [your email
address].
>
> Yours faithfully,
>
> [Name]
> [Address]
> [Date]
--- End Quote ---
[/quote]
Dear b789
Apologies for the delay in responding.
I am very grateful for your thorough and detailed response. It
helped me understand the whole situation.
I emailed the above-suggested response to Moorside Legal and am
currently dealing with their bounce-back auto-response nonsense.
Any idea how many attempts it would take until their automated
message stops coming back? I am replying to their message with
the response above, but not with a new email each time. I hope
it makes sense to you.
Thank you
#Post#: 104125--------------------------------------------------
Re: Urgent help-Letter Before Claim-Moorside Legal on Behalf of
NCP Gatwick
DIR By: b789
Date: December 30, 2025, 4:24 pm
---------------------------------------------------------
Try sending it to litigation@moorsidelegal.co.uk.
At the same time also try sending to help@moorsideleagl.co.uk
but with the following as the subject:
--- Quote ---
> Data Subject Rights – [Your Name]
--- End Quote ---
Add this at the very beginning (before “Dear Sirs,”). It creates
a specific UK GDPR request they must action, not a general
complaint:
--- Quote ---
> DATA PROTECTION NOTICE (UK GDPR): I dispute the accuracy and
lawfulness of your processing insofar as you are asserting or
implying registered keeper liability for an airport-land charge.
This letter constitutes (i) a request for restriction of
processing under UK GDPR Article 18 pending
verification/correction of the accuracy of your records, and
(ii) an objection to processing under UK GDPR Article 21 in
relation to any continued pursuit of me as keeper. Your
published DPO email help@moorsidelegal.co.uk is deliberately
bouncing; therefore you must confirm in writing within 7 days
that (a) processing has been restricted as requested, and (b)
this notice and the substantive response below have been
forwarded to the appropriate department. Failing that, I will
escalate to the ICO.
--- End Quote ---
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