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       #Post#: 112778--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: InterCity125
       Date: March 11, 2026, 2:48 am
       ---------------------------------------------------------
       --- Quote from: NandoChutney link ---
       >
       > I should point out that the line about there not being clear
       signage might not work, because there are massive red and white
       signs that say "No stopping" in letters the size of my head and
       "£100 charge if you stop" in letters not that much smaller. You
       can see them on Street View.
       >
       --- End Quote ---
       We haven't said 'unclear signage'.
       We ARE saying 'contradictory markings', namely; double yellow
       lines which allow brief stops for picking up / dropping off.
       If they want a no stopping zone then double reds are required.
       #Post#: 120829--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: ChrisS
       Date: June 5, 2026, 5:16 am
       ---------------------------------------------------------
       It was all too quiet....
       So this popped through the letterbox yesterday. As previously,
       any help / guidance as to how to complete the claim response
       would be most gratefully received. Thank you in advance.
  HTML https://imgpile.com/p/oOiCCKc#3tCf9Uy
       #Post#: 120837--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: InterCity125
       Date: June 5, 2026, 6:09 am
       ---------------------------------------------------------
       It was expected and is part of the process.
       Nothing to worry about.
       Your defence is very simple.
       No need for an AOS - Just log onto MCOL and submit the
       following;
       Leeds Railway Station defence.
       1. This claim is denied in its entirety and no debt is owed to
       the Claimant.
       2. It is acknowledged that I was the Registered Keeper of the
       vehicle at the material time.
       3. That the driver of the vehicle is not known to the Claimant
       and that there is absolutely no legal requirement for me to
       reveal the drivers details to an unregulated private parking
       contractor.
       4. That no assumption of who was driving can be drawn from me
       simply exercising my right to say nothing in a situation where
       the law does not require me to disclose driver information.
       5. That the Claimant is using a 'Boiler-plate' Particulars of
       Claim which lacks accuracy and relevance to the particular
       matter.
       6. That with the driver not known to the Claimant, the Claimant
       is attempting to use Protections of Freedoms Act (2012)(PoFA) in
       order to invoke what is known legally as 'Keeper Liability'.
       7. That the attempt to use PoFA Keeper Liability is not
       applicable to this specific location since the location is not
       classed as 'relevant land' under the legislation - the location
       at Leeds Railway station is subject to Railway Byelaws and
       therefore it is excluded from PoFA.
       8. That the Claimant's own Parking Charge Notice (PCN) Notice to
       Keeper (NtK) specifies, ironically, in large bold print, that
       the NtK is "Non-PoFA".
       9. That PoFA Keeper Liability is therefore not available to the
       Claimant.
       10. That with both the driver unknown and no Keeper Liability
       available, there is no legal route to liability in this matter.
       11. That liability is therefore denied.
       Additional Defence Points;
       12. That it is not possible for the Claimant to have formed a
       contract with the driver in any circumstance since a driver
       would never consider that the Claimant's signage constituted an
       offer of contract since the signage simply resembles normal road
       signage.
       13. That, in law, in order for a contract to have been formed
       there would need to be 'clear intent on the part of both parties
       to form a legal relationship' - it therefore stands that no
       contract can be formed in a situation where the driver does not
       recognise that a contract is being offered.
       14. That the road markings and signage demonstrated in the
       parking operators evidence are contradictory in nature and are
       therefore in breach of the Parking Operators own industry Code
       of Practice.
       15. That whilst some signage specifies, "No Stopping" there are
       additional road markings such as double yellow lines which allow
       brief stops for dropping off and picking up passengers.
       16. That in order to be compliant, No Stopping signage can only
       be supported by double red lines.
       17. That in previous correspondence, the Claimant's legal
       representatives have consistently sent me legal letters which
       attempted to completely misrepresent their true legal position
       in an attempt to pressure me into paying.
       #Post#: 120848--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: DWMB2
       Date: June 5, 2026, 6:59 am
       ---------------------------------------------------------
       --- Quote ---
       > 7. That the attempt to use PoFA Keeper Liability is not
       applicable to this specific location since the location is not
       classed as 'relevant land' under the legislation - the location
       at Leeds Railway station is subject to Railway Byelaws and
       therefore it is excluded from PoFA.
       --- End Quote ---
       One might argue it is overkill, but I would add to this point
       why the existence of railway byelaws means it is not relevant
       land. Namely, that these byelaws meant that the parking of
       vehicles on the land was subject to statutory control.
       May also be worth being explicit about the dates, I.e. That the
       alleged contravention took place before the recent change to the
       railway byelaws.
       #Post#: 120851--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: ChrisS
       Date: June 5, 2026, 7:53 am
       ---------------------------------------------------------
       Thank you very much for the speedy responses, I feel somewhat
       calmer now and will respond as you have advised.
       Watch this space, and my thanks again.
       #Post#: 126008--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: ChrisS
       Date: July 28, 2026, 7:02 am
       ---------------------------------------------------------
       Hello again, well the saga continues, came back to some new
       correspondence on return from holiday (was half expecting TBH).
       Attached are the letters received. I have also received a copy
       of the Directions Questionnaire completed by UKCPS. Please let
       me know if this needs to be shared, details appear quite
       generic.
       As always, any advice / guidance or direction would be greatly
       appreciated.
  HTML https://imgpile.com/p/JvhOM4K
       #Post#: 126014--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: jfollows
       Date: July 28, 2026, 7:31 am
       ---------------------------------------------------------
       Monitor MCOL for notification that the court has sent you a N180
       Directions Questionnaire to complete, in the meantime search the
       forum for "N180" for advice on how to complete your own in due
       course.
       Their DQ is unimportant because as a defendant in person your
       preferences for a hearing in person at a court local to you
       override theirs.
       #Post#: 126037--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: ChrisS
       Date: July 28, 2026, 9:07 am
       ---------------------------------------------------------
       Hi, thank you. I've done some searching on the forum for
       guidance on how to complete the form N180 and have only been
       able to find one post with specifics for how to answer some of
       the less obvious questions.
       Is this the best guidance for completion or if there is better,
       please could you signpost?
       Screenshot of form post link below for ref.
  HTML https://imgpile.com/p/CGuw4LL
       #Post#: 126043--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: jfollows
       Date: July 28, 2026, 9:31 am
       ---------------------------------------------------------
       Yes that's the advice.
       #Post#: 126047--------------------------------------------------
       Re: Guidance Needed Please - UKCPS - No Stopping - Leeds Railway
       Station - Moorside Legal
   DIR By: ChrisS
       Date: July 28, 2026, 9:49 am
       ---------------------------------------------------------
       Perfect, thank you.
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