Letter received from BW Legal in response to the defence. Intention to proceed. BW Legal defence response.pdf

No, I tried logging in using the reference number and my registration but it errors to say there was a problem obtaining these details. I'd assume it would just be the same photos they provided in the response pack

Letter received from the court acknowledging the defence Court defence acknowledgement.pdf

The first photo is a parking sign from Google to show what was on the sign. The second attachment with photos is what BW responded with after I sent the CPR

Defence has been submitted on the MCOL

Thank you for the reminder. I’ve been looking at the template on the sticky post, is it correct that I just use the following as the defence and don’t put particulars about there not actually being a requirement for a permit as I used the shops in the parade? I note I can flesh out points 2 and 4 if it progresses further but just curious The Defendant contends that the particulars of claim are vague and generic in nature which fails to comply with CPR 16.4. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 1. The Defendant is the recorded keeper of [motor vehicle]. 2. It is denied that the Defendant entered into a contract with the Claimant. 3. As held by the Upper Tax Tribunal in Vehicle Control Services Limited v HMRC [2012] UKUT 129 (TCC), any contract requires offer and acceptance. The Claimant was simply contracted by the landowner to provide car-park management services and is not capable of entering into a contract with the Defendant on its own account, as the car park is owned by and the terms of entry set by the landowner. Accordingly, it is denied that the Claimant has authority to bring this claim. 4. In any case it is denied that the Defendant broke the terms of a contract with the Claimant. 5. The Claimant is attempting double recovery by adding an additional sum not included in the original offer. 6. The Particulars of Claim is denied in its entirety. It is denied that the Claimant is entitled to the relief claimed or any relief at all.

Unfortunately it’s not local, I was on a break away

Correct, no windscreen PCN left.

I've had response to the CPR 31.14 request. I'll redact and post the paperwork now. They claim I've breached their terms due to 'No permit being displayed' but all the signs at the location state 'private parking for customers using a shop in this parade'. The signs are even in the photo's they have supplied. I've attached the sign for reference. They've provided a photo in an attempt to show there is no permit on my windscreen. @LookingForInfo Thanks for the heads up, I'll definitely add that to my to do list. Their reply does say they got my details and address from the DVLA. They have sent copies of the letters but no proof of postage. Parking sign.pdf

Thanks all. Assuming I should wait until we're near the the defence submission date to complete that to see if they reply to the CPR first?

Thank you so much for the guidance. The Acknowledgement of Service has been submitted successfully. CPR 31:14 request sent 1st Class on Monday and have proof of postage this time. I'm really sorry but I don't have the exact letter any more but I knew not to use terms to confirm I was the driver and state it was an alleged contravention. It was along the lines of "The vehicle was parked in accordance with the terms on the signage which is displayed in your photo so I regard this matter as closed." I've received another letter from the solicitors today which I've also attached. bwlegal_030823.pdf

Which Court have you received the claim from ? Northampton County Court Business Centre Name of the Claimant : Countrywide Parking Management Limited Claimants Solicitors: BW Legal Date of issue – 17th July 2023 Date for AOS - 7th August 2023 Date to submit Defence - 18th August 2023 What is the claim for – 1.the Claim is for the sum of £172.92 being due from the Defendant in respect of a Parking Charge Notice (PCN) for a contractual breach which occurred on 30/08/2022 in the private car park/land at 7-11 Provost Street Fordingbridge SP6 1AY in relation to a <make & model of my car> registration <my registration>. 2. The PCN was issued as the driver failed to comply with the terms and conditions, as displayed. 3. Despite demands, the charge remains unpaid. 4.The claim also includes Statutory Interest pursuant to section 69 of the County Courts Act 1984 at a rate of 8% per annum (a daily rate of £0.04) from 30/08/2022 to 18/07/2023 being an amount of £12.92. The Claim also includes £60.00 recovery costs as set out in the Terms and Conditions and in the ATA AoS Code of Practice. What is the value of the claim? £257.92 Amount Claimed £172.92 court fees £35.00 legal rep fees £50.00 Total Amount £257.92 Have you moved since the issuance of the PCN? No Did you receive a letter of Claim With A reply Pack wanting I&E etc about 1mth before the claimform? No

I haven't and that's why I was shocked by this progressing. There was no ticket on my car as I was parked correctly as per the signage. The first letter I received was the 'Final Notice' ~first week of November. I sent Countrywide Parking Management a letter stating this is a mistake as I was parked correctly as I was using one of the shops and I regarded the matter as closed. I received a Trace Debt Recovery Letter on 9th November which I ignored assuming an overlap with my letter which I know was naïve. This is now the first correspondence I've had since. 1 Date of the infringement 30/08/2022 2 Date on the NTK [this must have been received within 14 days from the 'offence' date] 26/10/2022 - Final Notice Letter. PDF attached 3 Date received I don't recall exact date but would have been before week ending 4/11/22 4 Does the NTK mention schedule 4 of The Protections of Freedoms Act 2012? [Y/N?] No 5 Is there any photographic evidence of the event? Yes 6 Have you appealed? [Y/N?] post up your appeal] Yes - Letter sent explaining I used one of the shops which permits parking and regarded the matter as closed. Have you had a response? [Y/N?] No 7 Who is the parking company? Countrywide Parking Management 8. Where exactly [carpark name and town] 7-11 Provost Street, Fordingbridge, SP6 1AY For either option, does it say which appeals body they operate under. No If you have received any other correspondence, please mention it here: Trace Debt Recovery letter received just after sending my letter. PDF attached. Notice.pdf Trace notice.pdf

Hi all, I've received a court claim form for a PCN I received last year. Attached is the the redacted first page from the claim form with full details. Have you moved since the issuance of the PCN? No Did you receive a letter of Claim With A reply Pack wanting I&E etc about 1mth before the claimform? No There was signage at the location to show parking was permitted for anyone using the shops at the location which I did. I'll be sending a CPR 31.14 request to the solicitor today. I hope this is the all of the information for the topic but please just let me know if anything else is required. Thank you in advance. claim.pdf

I had a security company come to install an additional motion sensor in my garage. Despite warning, he continued walking through a cable which was lay on the floor and pulled a network switch off a shelf on to my motorbike causing damage to the fairings and paint. I raised a complaint which they said wouldn't progress and stated I was lucky the engineer wasn't injured and a claim filed against myself. I reconfirmed the engineer was told to stop multiple times when I seen he walking towards the cable but he kept walking five feet which caused it to fall. I also queried if the engineer had a requirement to assess the working environment before commencing with any work. I've now had an email from their insurer denying liability and that they believe a court would find under Occupiers Liability Act 1957 I had a duty of care and was fortunate no injury was sustained. They say the damage was caused entirely of my own negligence as I failed to warn and didn't cordon the area where the cable was. If I don't accept this then I must seek representation from a solicitor. Can anyone please help or advise where I stand and what next steps I could take without approaching legal representation or my bike insurance yet? It sounds like I was expected to cordon off all areas of my garage but I believe I'm not at fault and would like to progress this as I did warn the engineer before he walked near the cable and there must be some liability for him not assessing his working surroundings?