PePiPoo Helping the motorist get justice Support health workers

Welcome Guest ( Log In | Register )

County Court Claim form Excel Parking/BW Legal
madpotter
post Sat, 10 Mar 2018 - 11:26
Post #1


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



I am very worried regarding a County Court Claim Form relating to alleged PCN on the 27/03/2012 at the Walk, Ebbw Vale.
The driver was taking an elderly person with mobility problems to the bank. They parked in a disabled space, clearly displaying the blue badge. The driver did not see anything clearly displayed either at the disabled bays or the entrance to the car park stating that disabled persons now had to pay for parking. As I result the driver and disabled person went straight to the bank (which was closed) and returned within 20 minutes to the car and left for home. The driver had parked there on previous occasions and had no letters or complaints. Had the driver known that a fee applied this would have been paid quite happily as the parking fee was only 20 or 30 pence.
The registered keeper received various letters and as the advice given at the time was to ignore these, this was the action taken. These letters were thrown away when the registered keeper moved house. The registered keeper now has a County Court Claim form sent to their new address, issue date 07/03/2018 and would like advice on how to proceed.
In addition, the County Court is in Northampton, which will be difficult to travel to as the registered keeper has no access to public transport and to go by car is a journey of over 3 hours.
Any help will be appreciated. Thank you.

This post has been edited by madpotter: Sun, 11 Mar 2018 - 19:09
Go to the top of the page
 
+Quote Post
4 Pages V  < 1 2 3 4 >  
Start new topic
Replies (20 - 39)
Advertisement
post Sat, 10 Mar 2018 - 11:26
Post #


Advertise here!









Go to the top of the page
 
Quote Post
nosferatu1001
post Wed, 14 Mar 2018 - 07:56
Post #21


Member


Group: Members
Posts: 28,687
Joined: 27 Nov 2007
Member No.: 15,642



Can you deny you weere the driver? If youre not sure, you can state that the D cannot confirm the identity of the driver, due to the number of years that have elapsed.
Go to the top of the page
 
+Quote Post
madpotter
post Wed, 14 Mar 2018 - 22:59
Post #22


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



QUOTE (nosferatu1001 @ Wed, 14 Mar 2018 - 07:56) *
Can you deny you weere the driver? If youre not sure, you can state that the D cannot confirm the identity of the driver, due to the number of years that have elapsed.


Thank you. I cannot confirm or deny I was the driver as as the vehicle in question was used frequently by other drivers at the time of the alleged incident and also as a result of the time elapsed.
Go to the top of the page
 
+Quote Post
Redivi
post Thu, 15 Mar 2018 - 00:03
Post #23


Member


Group: Members
Posts: 4,126
Joined: 31 Jan 2018
Member No.: 96,238



You can phrase that in a defence ( amending Para 2?) along the lines of :

The Defendant can neither confirm or deny that he was the driver.
It is impossible after six years to identify which of at least three possible persons was the driver at the time.
The Claimant cannot assume it was, on the balance of probability, the Defendant as the registered keeper


I would also harden up #7 but remove the part about the loss which allows a judge to tick the Beavis box
The Claim doesn't include costs for Excel's own staff so I wouldn't give them the opportunity to justify it
Something along the lines :

7. a)The Claimant has grossly inflated the claim with charges that the Defendant has the reasonable belief have not been incurred.
These have been described at various times as contractual charges and legal costs
The Defendant puts the Claimant to proof that they have been invoiced and paid
The Defendant believes that they are in fact indemnity charges and puts the Claimant to proof that the facts of this case are exceptional and that the costs were reasonably and proportionately incurred in accordance with CPR 44.3
b) Notwithstanding the above comments, legal costs cannot be recovered in the Small Claims Court.
The Defendant has the reasonable belief that describing them as "Contractual charges" is a cynical attempt by the Claimant to inflate the claim and circumvent (CPR 27.14)
c) Furthermore interest of £43.42 has been added. This would have been avoided if court action were issued in 2012
The defendant feels this delay is a punitive measure, the claimant waiting the maximum allowed time from the date of the alleged contravention in order to claim a large amount of interest.


This post has been edited by Redivi: Thu, 15 Mar 2018 - 00:03
Go to the top of the page
 
+Quote Post
madpotter
post Thu, 15 Mar 2018 - 07:50
Post #24


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



QUOTE (Redivi @ Thu, 15 Mar 2018 - 00:03) *
You can phrase that in a defence ( amending Para 2?) along the lines of :

The Defendant can neither confirm or deny that he was the driver.
It is impossible after six years to identify which of at least three possible persons was the driver at the time.
The Claimant cannot assume it was, on the balance of probability, the Defendant as the registered keeper


I would also harden up #7 but remove the part about the loss which allows a judge to tick the Beavis box
The Claim doesn't include costs for Excel's own staff so I wouldn't give them the opportunity to justify it
Something along the lines :

7. a)The Claimant has grossly inflated the claim with charges that the Defendant has the reasonable belief have not been incurred.
These have been described at various times as contractual charges and legal costs
The Defendant puts the Claimant to proof that they have been invoiced and paid
The Defendant believes that they are in fact indemnity charges and puts the Claimant to proof that the facts of this case are exceptional and that the costs were reasonably and proportionately incurred in accordance with CPR 44.3
b) Notwithstanding the above comments, legal costs cannot be recovered in the Small Claims Court.
The Defendant has the reasonable belief that describing them as "Contractual charges" is a cynical attempt by the Claimant to inflate the claim and circumvent (CPR 27.14)
c) Furthermore interest of £43.42 has been added. This would have been avoided if court action were issued in 2012
The defendant feels this delay is a punitive measure, the claimant waiting the maximum allowed time from the date of the alleged contravention in order to claim a large amount of interest.


Thank you - I will make those amendments. Your help is much appreciated.
Go to the top of the page
 
+Quote Post
madpotter
post Thu, 12 Apr 2018 - 18:15
Post #25


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



Thanks for your help. Defence has been submitted and I now have received Notice of Proposed Allocation to Small Claims Track.
The questionnaire asks if I agree to referral to Mediation Service. I am assuming that I say no. Is this correct? Thank you.
Go to the top of the page
 
+Quote Post
nosferatu1001
post Thu, 12 Apr 2018 - 18:34
Post #26


Member


Group: Members
Posts: 28,687
Joined: 27 Nov 2007
Member No.: 15,642



Say no unless you want to be pressured into settling for basically the full amount

Th3 mediation service is on their side, and they get marked on how many cases they stop reaching court. Guess who is an easy target here?
Go to the top of the page
 
+Quote Post
madpotter
post Thu, 12 Apr 2018 - 20:34
Post #27


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



QUOTE (nosferatu1001 @ Thu, 12 Apr 2018 - 18:34) *
Say no unless you want to be pressured into settling for basically the full amount

Th3 mediation service is on their side, and they get marked on how many cases they stop reaching court. Guess who is an easy target here?

Thank you
Go to the top of the page
 
+Quote Post
madpotter
post Sun, 27 May 2018 - 17:53
Post #28


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



I now have a court date and feel fairly confident regarding putting together the necessary documentation thanks to you chaps. However, I do have a quick query. The directions received with the Notice of Allocation to the Small Claims Track encourage the parties to contact each other to attempt to settle the case. I am concerned that if I do so this could be construed as an admission of guilt - especially as I believe Excel to be in the wrong. Also neither Excel or BW legal have made any move towards contacting myself with regards to negotiation. Am I right in not contacting either Excel or BW Legal or should I make some move towards at least appearing willing to negotiate. Thank you.
Go to the top of the page
 
+Quote Post
nosferatu1001
post Mon, 28 May 2018 - 21:21
Post #29


Member


Group: Members
Posts: 28,687
Joined: 27 Nov 2007
Member No.: 15,642



You could tell them - you have no case, and you 'now it. Despite the costs I've incurred in defending this baseless claim, I'm still wailling to accept a drop hands offer. This offer is open for 7 days. After this date I will apply to the court for my full costs, st the LIP rate

Head it "without prejudice save as to costs"
Go to the top of the page
 
+Quote Post
SchoolRunMum
post Mon, 28 May 2018 - 23:10
Post #30


Member


Group: Members
Posts: 18,751
Joined: 20 Sep 2009
Member No.: 32,130



QUOTE
I am concerned that if I do so this could be construed as an admission of guilt - especially as I believe Excel to be in the wrong. Also neither Excel or BW legal have made any move towards contacting myself with regards to negotiation. Am I right in not contacting either Excel or BW Legal or should I make some move towards at least appearing willing to negotiate.


Do not worry about not trying Mediation - standard advice is NOT TO.

With a fake PCN from a notorious PPC, we (posters here) are always right and they are always wrong, there is nothing to mediate.
Go to the top of the page
 
+Quote Post
madpotter
post Tue, 29 May 2018 - 08:33
Post #31


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



Thank you both. I refused mediation on your advice, but noted that BW Legal did tick the mediation box. I will contact them with regard to accepting a drop hands offer. That way I can tell the court I have attempted to negotiate (thus saving their time/money) without compromising the fact that I am in the right.
Go to the top of the page
 
+Quote Post
nosferatu1001
post Tue, 29 May 2018 - 13:56
Post #32


Member


Group: Members
Posts: 28,687
Joined: 27 Nov 2007
Member No.: 15,642



You offer a drops hand, theynthe decide whether to accept or not.
They won't
Go to the top of the page
 
+Quote Post
madpotter
post Wed, 30 May 2018 - 08:01
Post #33


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



I expect you are right I do not think they will even acknowledge my e mail. However I can now say I made the effort. It is a matter of weeks until court and I will let you know the outcome. Thanks again.
Go to the top of the page
 
+Quote Post
madpotter
post Thu, 31 May 2018 - 09:32
Post #34


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



QUOTE (madpotter @ Sat, 10 Mar 2018 - 12:26) *
I am very worried regarding a County Court Claim Form relating to alleged PCN on the 27/03/2012 at the Walk, Ebbw Vale.
The driver was taking an elderly person with mobility problems to the bank. They parked in a disabled space, clearly displaying the blue badge. The driver did not see anything clearly displayed either at the disabled bays or the entrance to the car park stating that disabled persons now had to pay for parking. As I result the driver and disabled person went straight to the bank and returned within 20 minutes to the car and left for home. The driver had parked there on previous occasions and had no letters or complaints. Had the driver known that a fee applied this would have been paid quite happily as the parking fee was only 20 or 30 pence.
The registered keeper received various letters and as the advice given at the time was to ignore these, this was the action taken. These letters were thrown away when the registered keeper moved house. The registered keeper now has a County Court Claim form sent to their new address, issue date 07/03/2018 and would like advice on how to proceed.
In addition, the County Court is in Northampton, which will be difficult to travel to as the registered keeper has no access to public transport and to go by car is a journey of over 3 hours.
Any help will be appreciated. Thank you.

Go to the top of the page
 
+Quote Post
madpotter
post Thu, 31 May 2018 - 09:43
Post #35


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



I have drafted my witness statement and collected my evidence. I looked at a number of witness statements and found they varied from being very a very short description of what happened to a long detailed document referencing a variety of rulings. I have tried to say what happened and include relevant details only. I would very much welcome any comment. Thank you.

In the County Court at ………... Claim Number: …………..

Parties: Excel Parking Services Ltd. Claimant
Defendant

Witness Statement

1. I, …………………. of ………………... am the defendant in this claim. The facts in this statement come from my personal knowledge. Where they are not within my own knowledge they are true to the best of my information and belief.

2. I am an unrepresented defendant who has never attended the County Court before.

3. 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. I assert that I was the registered keeper of the vehicle in question at the time of the alleged contravention.

5. At the time of the alleged contravention the defendant's elderly mother lived next door. The family took her out regularly to a number of places for various reasons. Her mobility was limited and her blue badge used for parking.

6. On occasion (approximately every 4 – 6 months) a family member would take the defendant's mother to her bank in Ebbw Vale to carry out her business. On these occasions the disabled spaces in The Walk were used, there being a manageable distance between these spaces and the bank for the defendant's mother to walk. The blue badge would have been clearly displayed. It is unlikely that the car would have been parked for more than 20 minutes. These were the only occasions on which The Walk car park was used by the defendant or family.

7. As far as the defendant and her family were aware disabled parking was free up until and at the time of the alleged contravention. They were not aware that parking charges applied in disabled spaces until after the PCN was issued.

8. Following receipt of the PCN the defendant visited The Walk car park and after searching on foot found limited signage stating that there was a charge for disabled parking. This was not in a position nor clear enough to have been seen from entering the car park, parking in a disabled space, exiting or entering the car park by foot or by car. (Exhibit showing photographs of signage at time (from internet) and plan of car park)

9. In preparation for the court appearance the defendant visited The Walk car park on the 22/04/2018. It was noted that signage had been updated since the time of the alleged contravention inasmuch as the penalty and parking charges had been increased and there were more signs. However the signs remained difficult to read were of a similar design to those present at the time of the alleged contravention and remained difficult to read. (Exhibit showing own photographs)

10. The defendant did not respond to the notices sent by Excel and then from BW Legal because the advice at the time was to ignore these ( for example they had been described as a scam on Watchdog). The defendant felt that these notices were threatening in nature and of a style designed to intimidate the recipient into paying an exorbitant sum of money. In addition, and of great concern, the defendant's husband (…………...) received telephone calls from BW Legal who refused to divulge how they had obtained his private mobile number and who continued to call despite being informed that it was not the defendant's phone (Exhibit Witness statement from defendant's husband).

11. After receiving a number of notices from Excel and then from BW Legal nothing was received for some years until after the defendant had moved to a new address. Again the tone of the letters was designed to intimidate and mislead. (exhibit letters from BW legal). The defendant therefore|researched to prepare for a court hearing and was able to identify the following reasons why this claim has no basis:

12. The alleged contravention took place prior to the enactment of the Protection of Freedoms Act 2012. There is therefore no keeper liability and the claimant has no right to pursue the registered keeper. The claimant cannot assume that the registered keeper was the driver. This is supported by the ruling in the case of Excel Parking v Mr C (Stockport) C8DP37F1 and confirmed by Michael Henry Greenslade (Barrister and previous POPLA Lead Adjudicator) in 2015 who stated that “It cannot be presumed that the keeper of a vehicle is also the driver” After 6 years neither the defendant or her family is able to remember who was driving at the time of the alleged contravention. After that time they are unable to access any documentation which could help to identify the driver for example work or personal diaries.

13. The claimant is not the landowner and suffers no loss whatsoever as a result of a vehicle parking at the location in question.

14. Excel Parking Services Ltd were in contravention of the BPA Code of Practice in issuing a vehicle displaying a blue badge with a PCN (exhibit relevant page from BPA CoP v2, web page BPA identifying this as applicable version)

15. At the time of the alleged contravention there was inadequate signage at the site. There were no clear signs at the entrance of the car park or at the disabled bays stating that blue badge holders were now subject to a charge for car parking in disabled bays. Signage failed to make the terms and conditions clear and prominent. Excel Parking is known for providing incoherent and sparse signage incapable of forming a contract. To this day signage at the site remains inadequate (exhibit photographs of signage at the time of incident and as it is now)

16. The charge is a penalty and thus an unfair consumer charge. The claimant has not met the conditions stated in ParkingEye v Beavis for the penalty too be disengaged.

17. The claimant has grossly inflated the claim with charges that the defendant has the reasonable belief have not been incurred. These have been described at various times as contractual charges and legal costs.

18. There has been concern for some years regarding the behaviour of private car parking companies. In 2012 Excel Parking Services Ltd. was banned by the DVLA for a 3 month period from access to keeper data for “Stating or implying on their documentation/signage that the vehicle owner/keeper is liable for the payment of charges imposed in respect of parking contraventions, or that the vehicle owner/keeper had a legal responsibility to provide information as to who the driver was” and for complaints regarding their signage. (exhibit DVLA letter to Mr Thorn) The Government is currently supporting a bill to introduce legislation to regulate the private parking industry. A number of MPs are supporting these changes (exhibit copy of report from BBC website).

19. The Particulars of Claim are vague and disclose no cause of action which would enable the defendant to prepare a specific defence. It was not signed by a legal person, but by BW Legal Services Limited. This is a failure to comply with CPR 16.4 Contents of the particulars of claim and Practice Direction 16 paras 7.3 – 7.5. The Claimant is known to be a serial issuer of generic claims similar to this one. The term robo-claims has been coined to describe this business model. The defendant believes that vague Particular of Claims are deliberately submitted to make it difficult for defendants to prepare a defence.

20. In accordance with directions received with Notice of Allocation to the Small Claims Track "The parties are encouraged to contact each other with a view to trying to settle the case or narrow the issues" the defendant has e mailed BW Legal stating that she would be willing to accept a drop hands offer. So far the e mail has not even been acknowledged (exhibit e mail).

21. The defendant believes that this claim is unreasonable and vexatious, a result of the robo-claims business model and that its purpose is to distress and frighten the defendant into making an artificially inflated payment which is in fact not owed. The defendant will submit her wasted costs separately and in a timely manner to the Court.

22. I believe that the facts stated in this witness statement are true.


Signed:


Dated:






Go to the top of the page
 
+Quote Post
madpotter
post Thu, 31 May 2018 - 12:40
Post #36


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



As an update - I have received 2 letters from BW Legal today.

The first is a reply to my e mail offering a discount on the balance due as gesture of goodwill as they remain confident the court will find in their favour! The letter is dated 29/05 and the offer expires 12/05!! I plan to refuse this offer.

The second sets out their response to my correspondence alluding to my reasons for disputing the PCN - I have not entered into any direct correspondence with either BW Legal or Excel regarding this! I did assume the information they are using is from my defence statement, but there are inconsistencies.
To summarise:
1. They state that the claim is for damages as a direct breach of their terms and conditions.
2. They have provided a written summary of the terms and conditions on their signage.
3. They state they are engaged by the landowner to manage and enforce the parking conditions. They have provided a leaseholder witness statement signed by Excel's commercial director and stating they have the right to undertake parking management activities and issue PCNs and enforce these as if they were the landowner. It states this authority is contained in an agreement running from 26/09/2011 to 25/09/2016. They have not provided any copy of this agreement. However this statement is not signed by the landowner but by Excel themselves. It is dated 2015, 3 years following the PCN. They do not identify the landowner or provide any documentation written by or signed by the actual landowner. Can I contest this? I would really welcome your comments.
4. They state that their signs are prominent and terms and conditions clearly displayed and the motorist would have the opportunity to read and understand these and by parking the driver accepts the terms and conditions. They have provided 3 photos signs dated 23/05/2012 taken approx 2 months following the PCN. All are some distance from the disabled bays. They are the usual Excel signs with a lot of small writing white on blue, yellow on blue, blue on yellow etc. I will be providing my own photos.
5. They state I have made an allegation I was not the driver on the contravention date (untrue- I stated on my defense statement I could not remember). They state that as the registered keeper of the vehicle and given that I had not provided the full name and serviceable address of the driver within 28 days from the date of the PCN they are able to hold me liable on the reasonable presumption that the driver had either actual or ostensible authority to enter into a contract with Excel in relation to parking on my behalf. They state this is supported by Combined Parking Solutions v AJH Films Ltd (2015) EWCA 1453. I would really welcome your comments on this one in particular as a large chunk of my defence relys on the alleged contravention being prior to POFA 2012!
6. They state the 100 pound charge (on their other correspondence this is 90) is regarded as a charge for contravening the t and cs and a core term of Excels contract with myself.
7. They state it is irrelevant whether the charge bears any relation to the cost for parking even if no cost is involved. They rely on the leading authority of Beavis v Parking Eye (2015) UKSC 67 where the supreme court held that PCN charges serve a commercial legitimate interest. They state the relevant CoP gives guidance that 100 pounds is a reasonable charge. I will check the relevant CoP myself but would really value advice re challenging Beavis.
8. They have provided 2 pictures of the front and back end of the car entering and leaving the car park. The number plate is the only thing that is clear. Driver cannot be seen.

I would really welcome comments on the above from you chaps as I am feeling a bit bogged down in legalese at the moment.

I will include these letters in my defense papers and add comments regarding them to my witness statement.
Thanks again
Go to the top of the page
 
+Quote Post
Jlc
post Thu, 31 May 2018 - 13:02
Post #37


Member


Group: Members
Posts: 41,510
Joined: 25 Aug 2011
From: Planet Earth
Member No.: 49,223



QUOTE (madpotter @ Thu, 31 May 2018 - 13:40) *
They state this is supported by Combined Parking Solutions v AJH Films Ltd (2015) EWCA 1453. I would really welcome your comments on this one in particular as a large chunk of my defence relys on the alleged contravention being prior to POFA 2012!

The AJH case has no relevance here - that's in relation to a company car being used for those purposes... They usually try Elliott v Loake but the bottom line is that they need to aver evidence as to the driver. There is no presumption.


--------------------
RK=Registered Keeper, OP=Original Poster (You!), CoFP=Conditional Offer of Fixed Penalty, NtK=Notice to Keeper, NtD=Notice to Driver
PoFA=Protection of Freedoms Act, SAC=Safety Awareness Course, NIP=Notice of Intended Prosecution, ADR=Alternative Dispute Resolution
PPC=Private Parking Company, LBCCC=Letter Before County Court Claim, PII=Personally Identifiable Information, SAR=Subject Access Request

Private Parking - remember, they just want your money and will say almost anything to get it.
Go to the top of the page
 
+Quote Post
nosferatu1001
post Thu, 31 May 2018 - 13:31
Post #38


Member


Group: Members
Posts: 28,687
Joined: 27 Nov 2007
Member No.: 15,642



This is all standard BW rubbish

You should,know the cps case from your research. Parliament clearly decided the only way to hold. A private keeper liable was through pofa, which was enacted after this ticket. The keeper is not liable.

Re contract - just in icurt state a ws isn't sufficient. It doesn't show theynhave the requisite authority and is, frankly, meaningless. You put them to strict proof, onlynthe actual contact matters

This post has been edited by nosferatu1001: Thu, 31 May 2018 - 13:32
Go to the top of the page
 
+Quote Post
madpotter
post Thu, 31 May 2018 - 18:24
Post #39


Member


Group: Members
Posts: 40
Joined: 10 Mar 2018
Member No.: 96,952



Thanks again. I was really feeling bogged down with it all. I am amending my witness statement accordingly.
Go to the top of the page
 
+Quote Post
ManxRed
post Fri, 1 Jun 2018 - 08:34
Post #40


Member


Group: Members
Posts: 9,985
Joined: 20 Aug 2008
Member No.: 21,992



QUOTE (madpotter @ Thu, 31 May 2018 - 13:40) *
3. They state they are engaged by the landowner to manage and enforce the parking conditions. They have provided a leaseholder witness statement signed by Excel's commercial director and stating they have the right to undertake parking management activities and issue PCNs and enforce these as if they were the landowner. It states this authority is contained in an agreement running from 26/09/2011 to 25/09/2016. They have not provided any copy of this agreement. However this statement is not signed by the landowner but by Excel themselves. It is dated 2015, 3 years following the PCN. They do not identify the landowner or provide any documentation written by or signed by the actual landowner. Can I contest this? I would really welcome your comments.


Who is the landowner? Is it Excel themselves? If not, why is Excel's Comm Director signing the witness statement? You want to see the contract.


--------------------
Sometimes I use big words I don't understand in an effort to make myself sound more photosynthesis.
Go to the top of the page
 
+Quote Post

4 Pages V  < 1 2 3 4 >
Reply to this topicStart new topic
1 User(s) are reading this topic (1 Guests and 0 Anonymous Users)
0 Members:

 



Advertisement

Advertise here!

RSS Lo-Fi Version Time is now: Friday, 29th March 2024 - 10:48
Pepipoo uses cookies. You can find details of the cookies we use here along with links to information on how to manage them.
Please click the button to accept our cookies and hide this message. We’ll also assume that you’re happy to accept them if you continue to use the site.
IPS Driver Error

IPS Driver Error

There appears to be an error with the database.
You can try to refresh the page by clicking here