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Claim Form Received from County Court Business Centre- for private parking charge notice
MajAmin
post Sun, 23 Sep 2018 - 18:42
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Hi,
First of all, thank you for the support you all provide through this site.

I have received a parking charge Notice from CPM (UK Car Park Management) for 'Unauthorised Parking' in a small car park. The bays are unmarked and the signs are barely readable attached high on the walls in small prints. I am the registered keeper but not the driver of the time.

The issue date was last year June 17 and was for £100 or reduced to £60 if payed in 14 days. It was sent to me in post with two pictures of my car in the letter. The reason was 'unauthorised parking'. Since then, I received another letter called 'Formal Demand' roughly after 40 days of the first letter where it says to pay £100.

Then I started receiving 3 DRP letters (2 in sept and 1 in Oct 17) asking to settle payment of £160. Following that, I received a letter from Gladstone Solicitors in Nov 17 asking me to settle payment of £160 and then another 'Letter before claim' in June 18.

Taking advice from other forums, I decided ignore them and I never contacted or reply to any correspondence thinking that they will stop.

Now (Sept 2018), I have received a claim form from county court Business Centre, Northampton asking to pay CPM £174.67 + £25 court fee + £50 legal rep fee total of £249.67.

I have kept all evidence of letters and pic of the car park including the sign they have up.

I need advise on what to do next. I have read different threads and you tube videos and all saying this is fake court. The court logos are blurred out and looks like the letter has been copied. Is this a actual court? The letter contains moneyclaimicon.gov password.

Please can you offer me advise om what to do next? I have 14 days to acknowledge of service then submit my defense. I can upload pics of letters and photos upon request.

Please speak to me in layman's term as I don't fully understand the process.

Questionnaire:
1 Date of the infringement[s] - 23/06/2017

2 Date on the NTK [this must have been received within 14 days from the 'offence' date]
- 10/07/2017

3 Date received 13/07/2017

4 Does the NTK mention schedule 4 of The Protections of Freedoms Act 2012? [y/n?]
- not anywhere in the letter far as I can see

5 Is there any photographic evidence of the event? - They took two pictures of my car and printed them in the letter

6 Have you appealed? {y/n?] post up your appeal]
Have you had a response? [Y/N?] post it up
- I did not respond at all

7 Who is the parking company? CPM

8. Where exactly [carpark name and town] - 93-101 Greenfield Road, London




Thank you in advance
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post Sun, 23 Sep 2018 - 18:42
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kommando
post Sun, 23 Sep 2018 - 18:49
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A genuine claim form from Northampton does look like a schoolboys attempt at printing so assume it's genuine until you can post it for confirmation.

By acknowledging but leaving the defence box completely blank this adds 14 days to the time allowed to file your defence.
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Redivi
post Sun, 23 Sep 2018 - 20:09
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Can you confirm the dates of the parking event and the NtK ?

You say at one point that it was issued 10th July (and already too late to recover payment from the registered keeper)
You say earlier in the threads that it was issued in June

The letter in November was almost sent by DRP on Gladstones paper
Compare the reference numbers and who it tells you to pay

Even if UKCPM sent a valid NtK and on time, it cannot recover the DRP charges
POFA only allows it to recover the original parking charge

We have seen OPs who thought the amateurish appearance of the court papers meant they were a scam, ignored them and had default judgments as a result

This post has been edited by Redivi: Sun, 23 Sep 2018 - 20:11
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nosferatu1001
post Mon, 24 Sep 2018 - 10:52
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You MUST acknowledge the claim, ONLINE, today.
Do not contest jurisdiction unless you live outside E&W
Do NOT start the defence.
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MajAmin
post Tue, 25 Sep 2018 - 13:13
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Hi Redivi, here are my answers


QUOTE (Redivi @ Sun, 23 Sep 2018 - 21:09) *
Can you confirm the dates of the parking event and the NtK ?
So from the first letter I recieved which was the parking charge notice it said, Issue date 10th July 2017 and Incident Date 23rd June 2017


You say at one point that it was issued 10th July (and already too late to recover payment from the registered keeper)
You say earlier in the threads that it was issued in June
I think it meant that the Parking charge notice was issued on 10th July but the parking incident took place on 23rd June. So they issued the letter 17 days later.

The letter in November was almost sent by DRP on Gladstones paper
Compare the reference numbers and who it tells you to pay
- You are right. The Nov letter uses DRP reference number and asking me to pay DRP.

Even if UKCPM sent a valid NtK and on time, it cannot recover the DRP charges
POFA only allows it to recover the original parking charge
- ok Thanks for letting me know

We have seen OPs who thought the amateurish appearance of the court papers meant they were a scam, ignored them and had default judgments as a result


I will do.

Also - I have now submitted the AoS. Please let me know of next steps.

thanks
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nosferatu1001
post Tue, 25 Sep 2018 - 13:34
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Well your next step is you MUST construct a defence and submit it by the deadline - 33 days from DATE OF ISSUE, CALENDAR days not working - whihc you will do via email to the courts

So you need to get a wiggle on and show us your draft defence

GOOGLE search MSE NEWBIES THREAD
Read post 2
Read post 2 again
Read it a third time.
Bookmark the page


That is your go to. It tells you every step of the process and does so with no ambiguity at all.
Once you have done so you will have a good idea on how to start your defence, common arguments - including lack of standing, signage, no keeper liability - and be able to consturct a defence.
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MajAmin
post Sun, 14 Oct 2018 - 16:53
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Hi Guys,
here's my first stab at the defence. I need to submit this by 20th Oct so would love some feedback.
thanks for all your help so far smile.gif





IN THE COUNTY COURT BUSINESS CENTRE
Claim No.: #########

Between

UK CAR PARK MANAGEMENT LIMITED
(Claimant)

-and-


#############
(Defendant)

_________________________________________________________________________

DEFENCE
_________________________________________________________________________


I assert that I am not liable to the Claimant for the sum claimed, or any amount at all, for the following reasons:

1. The defendant, Mr #########, residing at ############, at the time of the alleged infringement is the registered keeper of the vehicle registration marked ######## which is the subject of these proceedings.
2. It is denied that any 'parking charges’ are owed and any debt is denied in its entirety.
3. No enforceable contract offered at the time by claimant so no cause for action can have arisen.
4. No keeper liability so no cause for action against the defendant
5. The claimant has failed to show locus standi so the defendant does not believe they have a right to bring an action against anyone.

Statement of Truth: I confirm that the contents of this defence are true to the best of my knowledge and belief.



………………………………………………………. ………………………
(Defendant) (Date)



This post has been edited by MajAmin: Mon, 15 Oct 2018 - 10:10
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nosferatu1001
post Mon, 15 Oct 2018 - 10:07
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First worrying aprt is you called it a defence *statement*. It isnt.
It suggests you found an older defence


Did you find the sample defence on MSE Forum newbies thread?
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MajAmin
post Mon, 15 Oct 2018 - 10:13
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Hi,

I have edited the defence, see above.

yes, I went with a defence from the MSE Forum newbies thread

I have removed the word 'statement'.

what do you think of this version?
thank you
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nosferatu1001
post Mon, 15 Oct 2018 - 13:16
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That this fails to adequately give a defnece, and has a great chance of being thrown out.
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MajAmin
post Thu, 18 Oct 2018 - 15:33
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Hi Guys,
thanks for all your support so far. much appreciated!
I have submitted the following defence.
smile.gif

'It is denied that any 'parking charges’ are owed and any debt is
denied in its entirety because no keeper liability so no cause for
action against the defendant. The claimant has failed to show
locus standi so the defendant does not believe they have a right
to bring an action against anyone. No enforceable contract offered
at the time by claimant so no cause for action can have arisen.'
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nosferatu1001
post Thu, 18 Oct 2018 - 15:45
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OK

Not sure why you rushed.

I hope you have read MSE FORUM NEWBIES THREAD, POST 2, by now?
Yes or No?

You will need to prepare a PROPER witness statement. Start working on it now.
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MajAmin
post Tue, 6 Nov 2018 - 19:38
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QUOTE (nosferatu1001 @ Thu, 18 Oct 2018 - 16:45) *
OK

Not sure why you rushed.

I hope you have read MSE FORUM NEWBIES THREAD, POST 2, by now?
Yes or No?

You will need to prepare a PROPER witness statement. Start working on it now.


Hi,

I was getting nervous about the deadline and I was flying out of the country for an urgent family matter. sorry if I rushed it but I did wait for everyone's responses. I have read the Newbies Thread post 2 and I am aware of the fact that I will need to do a proper witness statement.

thanks for your help

Hi Guys,
Since I have posted the defence, I had the following:

1. Email one from Gladstone:
'Dear___
We write further to the attached correspondence. Please be aware CPR 31.14 is not applicable to small claims, the track this case will inevitably be allocated to however, in an effort to settle the matter please find attached evidence we currently have access to. Your Defence will be considered in due course.'
The have attached the PCN letter, the Overdue PCN letter and 2 pictures which are identical take 4 seconds apart.

2. Email two from Gladstone:
'Dear____
UK Car Park Management Limited
-v-
_________

We act for the Claimant and have notified the Court of our Client’s intention to proceed with the claim.
Please find attached a copy of our Client’s completed Directions Questionnaire, which will be filed with the court upon their request. You will note we intend to request a special direction that the case be dealt with on the papers and without the need for an oral hearing
This request is sought simply because the matter is in our Client’s opinion relatively straightforward and the costs incurred by both parties for attending an oral hearing would be disproportionate.
You will note our Client has elected not to mediate. Its decision is not meant to be in any way obstructive and is based purely on experience, as mediation has rarely proven beneficial in these types of cases. Notwithstanding this, our Client would be happy to listen to any genuine payment proposals that you wish to put forward.'
They attached N180 Directions questionnaire, REQUEST FOR SPECIAL DIRECTION PURSUANT TO PD27 which says the below:
We kindly request that the Court send the N159 form (a redacted example of which is attached) to the Defendant for their consideration and, upon the Defendant consenting to the case being heard on the papers alone, the Judge makes the following direction;
“The matter will be considered on paperwork without a hearing. The parties attendance is not required and the Judge will determine the matter based upon the documents and evidence supplied and any written representations received.”

3. I have also received a letter from court which says that it acknowledge receipt of my defence.

4. I have also received a letter which says 'notice of proposed allocation of the small claims track' and with it was a form called 'direction questionnaire' which is asking me complete by 16th Nov.

Next step - I understand that I need to complete this direction form. Do you guys have any advice on how I should complete this form? There are couple of questions which I am not sure what to answer.

Thanks for all your support so far.
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ostell
post Tue, 6 Nov 2018 - 22:16
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Do a search for "Gladstomes" and "relatively straightforward" so that you can pen a suitable response to that. You do not want a paper hearing, you want a hearing at your local court.
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MajAmin
post Mon, 12 Nov 2018 - 11:50
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Thanks Ostell for responding. I will ask for a court hearing. smile.gif
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Redivi
post Mon, 12 Nov 2018 - 12:02
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You'd better

That defence has no chance with a hearing on the papers
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SchoolRunMum
post Mon, 12 Nov 2018 - 21:26
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You need a far better Witness Statement and evidence, and must attend the hearing to have a decent chance, in your case and given that defence, as Redivi says!
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MajAmin
post Thu, 28 Feb 2019 - 12:05
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Hey guys,
The date for the court hearing has been confirmed. It's on the 26th of March 2019. Just want to say a massive thank you for all the help so far, I really appreciate your help. Without this forum, I probably would have gotten frightened and paid it by now.
I am on the process of writing the witness statement which I will share with you shortly.
Just to recap on what happened so far:
• Parking Charge Notice issued on June 17 for £100 by UK CPM for ‘unauthorised parking’. The NTK was sent 17 days after the incident occurred
• The formal demand letter was received on July 17
• Two DRP letters received on Sept 17 for £160
• Another DRP letter on Oct 17
• DRP sent a letter using Gladstone letter heading received on Nov 17
• Letter before claim received on June 18
• I didn't receive a PAP letter
• County Court claim form received Set 18 for £249.67
• Acknowledgment of service done
• Defence submitted (see above)
• The direction of questionnaire completed with a request for an oral court hearing in oppose to gladstones’s paper hearing.
• Received Acknowledgment of defence from the court
• I sent a subject access request to UK CPM and they have replied with – a copy of the parking charge notice, formal demand letter, two pictures of the car and a screenshot of their system where it shows their activity i.e. PCN issued, a letter sent, referred to DRP etc.
• I also sent Gladstones a CPR 31.14 Request and they have replied back saying CPR isn’t applicable in small claims
• I have also asked them to erase my email address as I had put it in the direction questionnaire without realising. They have replied to say they have legitimate grounds to hold my email address.
• Letter received from the court to say the case has been transferred to my local court
• The general form of order received from the court
• Notice of allocation to the small claims track (hearing) letter received.

I have taken pictures of the car park as evidence where it has no signs at entry and no marking on the floor. Also, the signs are blocked by a barrier, so you can’t get very close to reading the small prints.

I will share the draft witness statement soon to get your feedback.

Thank you again for all your help
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MajAmin
post Sun, 3 Mar 2019 - 23:35
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Hi Guys,
I have been working on it all weekend. I honestly tried my best. I hope you guys don't think its too awful. Any feedback will be greatly appreciated. thank you so much!

In the County Court at
Mayors and City of London Court

Claim No. XXXXXXXX

Between
UK Car Park Management Limited (UK CPM) (Claimant)

and
XXXXXXXXX (Defendant)


Witness statement of Mr XXXXXXX XXXXX, Address: XXXXXXXXXX, date of birth XXXXXXX

1. I am the defendant in this matter, I am unrepresented, with no experience of Court procedures. If I do not set out documents in the way that the claimant may do, I trust the Court will excuse my inexperience. Any evidence to my statement will be referred to the attached documents as Exhibit MA1, Exhibit MA2 and so on.
2. In this Witness statement, the facts and matters stated are true and within my own knowledge, except where indicated otherwise.
3. I assert that I am the registered keeper of the vehicle in question in this case. I was not the driver when the charge occurred.
4. I am not liable to the claimant for the sum claimed, or any amount at all and this is my Witness Statement in support of my defence as already filed:
4.1. I deny keeper liability so no cause for action against me. The claimant has failed to show locus standi so I do not believe they have a right to bring an action against me.
4.2. No enforceable contract offered at the time by claimant so no cause for action can have arisen.
5. Whilst I was the Registered Keeper of the vehicle XXXXXX at the time of this parking incident, there is no evidence of the driver and as this event has been resurrected from over a years ago, it is not possible to expect a keeper to recall who might have been driving.
6. I deny being the driver at the time of the supposed event and therefore puts UK CPM to strict proof that any contract can exist between them and myself which they claim has been breached.
7. At the time of the charge in 2017, the car was used by a number of family and friends who I have no obligation to name to a private parking firm. It remains the burden of the Claimant to prove their case.
8. According to the notice to the keeper, the charges were for an ‘unauthorised parking’ on XX.06.2017 at XX:XX on 93-101 Greenfield Road, London. UK CPM issued a parking charge notice letter to me on XX.07.2017 as the registered keeper of the vehicle. No windscreen ticket in this case. Copy of the notice to the keeper is attached as Exhibit MA1.
9. The claimant then sent a follow on ‘formal demand’ letter issued on XX.08.2017. See Exhibit MA2
10. Following that, I received three ‘notice’ letters from a third-party organisation called ‘Debt Recovery Plus Limited’ for the sum of £160. The letters repeatedly state threatening the use of language such as ‘you owed’, ‘you haven’t paid’ and repeatedly threatened that court actions can be taken against me. See Exhibit MA3
11. I then received a letter from ‘Gladstones Solicitors’ on XX.11.2017 stating that they have been instructed by UK CPM in relation to this debt. This letter again uses threatening language and assumptions such as ‘It is our client's case that you are liable for these charges’. This letter repeatedly states that I need to contact the client (UK CPM) and their agent (Debt Recovery Plus Limited) however, it is obvious to notice that this letter isn’t from Gladstones Solicitors. It looks like the Debt Recovery Plus Limited using Gladstones letter headed paper and signature to threaten the keeper. The evidence is in the reference number on this letter, which is the same reference as the previous three letters from Debt Recover Plus Limited. See Exhibit MA4
12. Seven months later I received the ‘letter before claim’ from Gladstones Solicitors, this time with a different reference number on the letter than the previous one. See Exhibit MA5
13. I did not respond to the brightly-coloured alarmist Notices sent to me by the claimant and their agents because I believed they were spam (this sort of scam had been exposed on Watchdog). Also, as I was not the driver and these were not offence or fine from an Authority like a Council or Police. so there was no reason or obligation upon a registered keeper to ‘appeal’ to what appeared to be junk mail.
14. The Notice to Keeper was issued on the XX.07.2017, 17 days after the alleged parking charge date. This is a clear indication that the claimant has not obliged with the following:
Failure to comply with the International Parking Community (IPC) Code of Practice
15. As the claimant is a member of the IPC, they are required to subscribe to the AOS and adhere to this Code which defines the core standards necessary to ensure transparency and fairness. The terms and condition are clearly stated in Part A of the IPC Code of Practice. The claimant did not comply with the Part C point 5 of the code of practice where it says:
‘5.1 The Notice to the Keeper must;
(m) Be given to be received by the keeper within 14 days beginning the day after the specified period of parking.’
16. As the claimant is obliged by the compulsory Code of Practice of its own Accredited Trade Association, IPC, in order to pursue the keeper, the claimant must have compiled with POFA 12 Schedule 4.
I have attached a copy of the IPC Code of Practice as Exhibit MA6
Failure to comply with Protection of Freedoms Act 2012 ("POFA 12") - Schedule 4
17. It is also denied that the claimant has complied with Schedule 4, POFA 12 schedule 4 9(5) as the Notice to Keeper was issued 17 days after the alleged parking charge date. The letter was received by the keeper on day 20 following the parking charge (3 days after it was issued). Schedule 4 paragraphs 9(5) specify the time limits for serving a Notice to Keeper. If this is not complied with then the registered keeper cannot be held to account for the alleged debt of the driver. This paragraph clearly instructs the claimant that where no notice to the driver has been served (e.g. ANPR is used), the notice to keeper must be served no later than 14 days after the vehicle was parked. I have attached a copy of the POFA 12 schedule 4 as Exhibit MA7
18. No evidence has been supplied by this claimant as to who parked the vehicle. Under the POFA 12 schedule 4, there is no presumption in law as to who parked a vehicle on private land nor does there exist any obligation for a keeper to name a driver. I choose to defend this claim as the registered keeper, as is my right.
19. The claimant has provided no evidence (in pre-action correspondence or otherwise) that the I was the driver. The claimant is therefore limited to pursuing the keeper in these proceedings under the provisions set out by statute in the POFA 12 schedule 4.
20. I submit that, as a registered keeper who was not driving and who only received non-POFA 12 schedule 4 Notices to Keeper which were never my concern nor liability, these are better described as ‘irrelevant notices’. The claimant chose to issue non-POFA PCNs and was aware this risked a DVLA ban for misleading keepers re: liability for non-POFA PCNs. Now, this claimant seeks to bring me to Court as if I am liable for non-POFA PCNs!
The claimant also failed to comply IPC Code of Practice ‘PART E Schedule 1 – Signage’
21. I was never shown the alleged signage contract photos (not even the original ‘PCNs’ showed the purported signs. As a registered keeper, I never saw the ‘contract’ they are trying to hold me liable for.
22. The claimant stated in the particulars of claim that ‘the driver of the vehicle incurred the parking charges for breaching the terms of the parking’.
23. I have visited the location of the alleged parking charge and have found that the signage did not comply with the requirements of the Code of Practice of the IPC.
24. It is denied that there was any ‘'relevant contract' relating to any single parking event. Notwithstanding the provisions of the POFA 12 schedule 4 and/or the existing easements, it is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event.
25. Referring to the two pictures that were attached to the notice to the keeper, it is apparent that the vehicle was parked in an area where there are no marked bays and did not have any adjacent sign with the full terms of the car park in the pictures.
26. The signage was deficient in number, distribution, tiny wording and lighting to reasonably convey a contractual obligation. It is impossible to see the signs during the night as there is no light on that road or beside the signage. See Exhibit MA8
27. There was no signage at the entrance of the road that indicates to the driver that they are entering private land. See Exhibit MA9
28. Around twenty feet into the road, there is a sign on the left-hand side (facing sideways to the road), about 12 feet high which can barely be noticed or read even if one is standing underneath it let alone driving past it while focused on the road ahead. See Exhibit MA10
29. Following a close inspection of the road, three further signage were noticed along with other posters/advertisement on the wall, but they were impossible to get close to within 10 feet due to obstructions of cars, dust bins, bush, other obstacles, and a metal barrier. It is now apparent that it is not possible for a driver to notice these signs let along be able to read them. See Exhibit MA11
30. It is denied that the signs used by this claimant can have created a fair or transparent contract with a driver in any event. The signs were insufficient in terms of their distribution hence incapable of binding the driver, which distinguishes this case from the Beavis case:
31. The signs are believed to have no mention of any debt collection additional charge, which cannot form part of any alleged contract. See Exhibit MA12
32. The claimant has provided no evidence the vehicle is indeed parked and not waiting/giving way to pedestrians or vehicles. The claimant has also failed to provide if any of these signs were up on the day of the ‘parking charge notice’ occurred and what physical conditional they were at.
33. The claimant has not provided any evidence of a contract with the landholder that demonstrated that UK CPM had any authority to operate in the land per to the IPC Code of Practice Part B 1. - 1.1.
34. Conclusion – failure to comply with IPC Code of Practice and POFA 12 schedule 4 on inadequate signage and so no keeper liability.
35. My DVLA data was supplied for the single strict purpose of enquiring who was driving, not for storing the data and then suing me as if I can now be held liable, in the hope I will not defend/will have lost the paperwork/will have moved house, or even better, that I will be so scared that I will pay almost £250 including what was apparently an unproven £60 charge, allegedly incurred by another party (Debt Recover Plus LTD), if incurred at all.
36. I am no more liable now than I was then, but this unwarranted harassment and baseless litigation has caused me significant alarm and distress, such that I intend to report the claimant to the Information Commissioner for misuse of my data, obtained from the DVLA in 2017. I will also complain about the claimant to the DVLA and IPC for not complying with their Code of Practice.
37. It is apparent from court records reported in the public domain that this claimant has been obtaining payments from keepers under false pretences - using the court as a cheap form of debt collection from the wrong 'registered keeper' parties - and has obtained default CCJs in the hundreds, despite never complying with the POFA 2012 schedule 4 and even bringing pre-POFA cases to the Courts, as here.
38. The Court is invited to dismiss this Claim and to allow my wasted costs which will be submitted separately and in a timely manner, depending upon whether a hearing takes place. I firmly believe that to pursue me as a registered keeper when the claimant has no such right and to submit such incoherent particulars and lacking ‘evidence’ is wholly unreasonable and vexatious.
Statement of Truth
39. I believe that the facts stated in this witness statement are true.

Signature
Date
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nosferatu1001
post Mon, 4 Mar 2019 - 10:13
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1) delete up to the bit describing how your exhibits are givne.

INITIALS/001 is the better index to use. It means that document 11 will not get ordered before document 2 by computers...

3) Provide proof to back up yor assertion. As much as possible. If you do this later on, why? Do it at the first instance.
4.1 and 4.2 - how are these facts in your own knowledge? Is this not just a repeat of your defence? You dont repeat the defence, you provide facts that support and confirm your defence.

5) Ah so now you repeat 3, and add that "over a years ago" (?? over A year ago, or over X yearS ago?) so you dont know? This is a contradiciton to 3.
I fyou were NOT the driver, state so and provide any proof you can do so. Your statement is SOME proof but hinges on your credibility. If you contradict yourself, which you do here, you lose credibility. I presume this was merely a copy and paste error? If so BE MORE CAREFUL. I do NOT recommend copying and pasting a witness statement, as this is a good example of where you can fall down.

Ensure whatever you put hgere does not contradict your defenc,e and if it does realise this NOW and expalin WHY youve changed your mind. Again, makung amistake happens, but being seen to be evasive or clouding is not going to do you any fvours.

6) Yet another repeate of 3), ofr some reason, and still contradicts 5!!!!

7) OK this provides more detail for 5, which would support WHY you oculd not recall. State HOW MANY were in regular use. 2? 5? 10?

10) I dont entirley see the relevance of the DRP letters, un;less you are counterclaiming? They are stnadard debt collector letters.
11) Ah now I see. Point out it also states to pay DRP, when no solicitor would have you pay someone else!
14) I would lead with POFA. Thats real law, not a code of practice, personally. I owuld reorder and have the POFA points first, THEN the failure to abide by IPC code of conduct. Mention that in Beavis the supreme court said compoiance with the code of practice was required in order to disengage the penalty rule. If they have not complied, the amount i s a penalty and likely cannot be recovered.
16) rmeove, its a muddle as you then talk about POFA, the sentence doesnt make sense

18) this is about the 10th time youve stated this. Stop. Dont keep on repeating ad infinitum/.
19) Basically the same. Why not add that the very first time, of 10, you deny being the driver? Or not, you then say you dont know if you were the driver as it iould have been one of n people...
20) Just rmeove. Not helpful, yet nother contradiction and im now muddled as to whether you dney or not being the drier, as you keep changing your mind.
end of 20 makes no sense at all, given what edlse you have written in 20. Literally none.
21) Mkae this shorter. you have not seen any phoots of the alleged contract the driver supposedly entered into, as this has not been included on any correspondence from the Claimant. Aside: did you ask the claimant for this? If so, then state "despite asking on X, Y< z (see exhiibit ...) the claimant failed to / refused to provide copies of the supposed contract"

23) How has it failed to meet it? You asserted a fact, what is your proof of this fact?
24) what easements? First time youve mentioned them.
26) first time youve mentioned night. Maytbe sy this first, otherwise it just appears out hte blue!
28) There is a sign that is 12 foot high, or there is a sign that is affixed 12 foot off the ground? Because the sentece you actually wrote states it it is a 12 foot high sign. thats quite a big sign, and hard to miss!
29) ..but it was not possible to get within 10 feet of the sign due to... and at this distance the tiny / illegibl/ whatedver terms could not be read.
30) random colon at the end. Im pretty sure youve just repeated your assertion of failure again.
Do it once, not multiple times. Your point does NOT get stronger just because youve stated the same thing over and over and over!
31) dont say that
State that, from inspection of the signs as best you could, you could find no mention of thealleged "debt collection charges", which are anyway not your concern as you cannot be liable for more than the sum on the NtK, even if the claimant had complied iwth POFA2012, which is denied for the reaosns set out above.
32) Giving way to pedestrians? Really? This looks a complete copy and paste, and I dont like it. I thought it was clearly parked, not on a road et?

Again, DONT JUST COPY AND PASTE
This to me sounds like something from nowehere and makes me wonder what else youve copied in that might have no relevance at all.

34) delete. you dont conclude in a WS

35) I would just delete. Its a rant
36) Irrelevant. Delete
As an aside: why do you think a court would care that you intend to make a complaint to someone? Whoop-de-doo!
37) What proof have you given of this?> None? then take it out. Again, its a rant, and doesnt help you
38) Not a fna of this, as you dont ask for costs in a WS. arguing unreasonable behaviour is best done seperatel y as well.
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