I’ve sent the defense let’s see what happens now Thanks for the help I’ll keep here updated Andrew

They’ve claimed on the moneyclaims site the following Amount Claimed £177.44 Court Fee £35.00 Solicitor Costs £50.00

Hi thanks FTMDave Yes I’ve got the claim number and amount from moneyclaims site when I acknowledged the claim in the template do I put a bit in about sending the CPR 31.14 Request and with you asking about the amount claimed do I need to put that in the defense too? Thanks Andrew

Hi everyone I received a claimform from ParkingEye at the end of Jan 2023. I acknowledged it and have sent off a CPR 31.14 Request. I’ve been going though a house move so haven’t had time to post up here but I’ve now hit a problem. I’ve looked on here and can see the defence isn’t meant to not give much away I was going to use the standard template that’s on the page with the parking CPR Request. But in the move I’ve lost my claimform ,not sure how to word the defence now because I can’t find my particulars of claim. Any help would be much appreciated Andrew

Hi Dx Sorry I’m not sure what you mean it says the TE3 form is from the Liverpool city council but it says court registration fee of £9 so I thought it was in the court. Who should I contact and should be still be doing the PE2/3 or explain I’ve been sent the TE3 form a month later then it’s dated

Hi Dx I’m sorry I completely got court up in changing jobs and now with the move I completely forgot about it until I got the form in the post yesterday. Should I contact the court and ask for more time to respond since it clearly arrived a month later.

Hi everyone I’m going to be honest I completely forgot about this with having so much going on. We’ve been given a section 21 notice so going though a move very soon and I’ve had to find other work with the company in question on this charge folding and going bust. I never received the PCN and I’ve only got in the post the TE3 form today. It says I had until the 15/12/2022 to pay or respond but I’m guessing with the post strikes it got last with it being over a month late. I don’t know what to do because the company is nearly struck off from company house with it having its first GAZETTE NOTICE. 03/01/2023. And it’s only address is my current address that I’ll possibly be moving out from in early Feb. It doesn’t have my name on the form and only uses the old company name which won’t exist on the 03/03/2023. Any help would be much appreciated Thanks Andrew

Thanks Dx ill get it sent tonight when I get home

Updated would this be okay to send now Dx? Defence 1.The Defendant contends that the particulars of claim are vague and generic in nature. 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. 2.Paragraph 1 is denied. Whilst I have had dealings with Morses Club and BT in the past I cannot recall the specifics of the alleged agreements. 3.Paragraph 2 is denied. I am not aware of any service of a Default Notices or Termination Notices by either of the original creditors nor have I been provided with any Notice of Assignments pursuant to the Law of Property Act 1925. 4. On receipt of this claim I requested information pertaining to this claim from Overdales Solicitors Ltd by way of a CPR 31:14 request sent via 1st class with proof of postage on 01/09/2022. Further to the above I sent Lowell Portfolio I Ltd a section 78 request via 1st class with proof of postage on 03/09/2022. To date, neither Overdales Solicitors nor Lowell Portfolio I Ltd have yet to furnish me with the requested information and therefore remains in default of said request and unable to enforce the alleged agreements until such time it can comply. 6.Therefore with the court’s permission the Claimant is put to strict proof to:- a) show and disclose how the Defendant has entered into an agreements; b) show and disclose how the Claimant has reached the amount claimed for; c) show and evidence the nature of breach and service of a Default Notices pursuant to Sec 87 (1) CCA1974. d) show how the Claimant has the legal right, either under statute or equity to issue a claim; 7. As per Civil Procedure Rule 16.5 (4) it is expected that the Claimant prove the allegation that the money is owed. 8. On the alternative, if the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer crediticon Act 1974.6. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.

Yes he moved in 2020, 2017 and 2015 and didn’t update anyone. But if the claim form was sent to a different address why was the notice it was sent from Overdales sent to the right address? Thanks Andrew

Updated defence Defence 1.The Defendant contends that the particulars of claim are vague and generic in nature. 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. 2.Paragraph 1 is denied. Whilst I have had dealings with Morses Club and BT in the past I cannot recall the specifics of the alleged agreements. 3.Paragraph 2 is denied. I am not aware of any service of a Default Notice or Termination Notice by either of the original creditors nor have I been provided with any Notice of Assignment pursuant to the Law of Property Act 1925. 4. On receipt of this claim I requested information pertaining to this claim from Overdales Solicitors Ltd by way of a CPR 31:14 request sent via 1st class with proof of postage on 01/09/2022. Further to the above I sent Lowell Portfolio I Ltd a section 78 request via 1st class with proof of postage on 03/09/2022. To date, neither Overdales Solicitors nor Lowell Portfolio I Ltd have yet to furnish me with the requested information and therefore remains in default of said request and unable to enforce the alleged agreement until such time it can comply. 6.Therefore with the court’s permission the Claimant is put to strict proof to:- a) show and disclose how the Defendant has entered into an agreement; b) show and disclose how the Claimant has reached the amount claimed for; c) show and evidence the nature of breach and service of a Default Notice pursuant to Sec 87 (1) CCA1974. d) show how the Claimant has the legal right, either under statute or equity to issue a claim; 7. As per Civil Procedure Rule 16.5 (4) it is expected that the Claimant prove the allegation that the money is owed. 8. On the alternative, if the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974.6. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief. Please let me know if I need to change anything I want to send it tonight so it’s out the way Thanks Andrew

Hi everyone My brother just told me he’s had a letter from the court saying judgment for claimant (in default) dated the 11/08/2022 saying he didn’t reply to the claim form. He is adamant that he has not received a claim form after looking through his mail he found some letters about the claim but no claim form. He found a notice of claim issued from Overdales dated 28/06/2022. He also found a county court judgment has been entered from overdales dated 15/08/2022. I know he’s messed up but could he get it set aside since he never got the claim form? The default says he can pay instalments of £100 a month. He’s willing to pay that if that’s the best he can do but is there anything he could do? Thanks Andrew

I thought I only had to send a cpr with it being a doorstep loan and broadband. And didn’t know broadband had default notices. Wish I knew was a pain taking them out I’ll put them back in and get a cca sent off tomorrow Thanks Andrew

Hi Dx im sending out the cpr tomorrow and i think I’ve finished the defence. Please take a look and let me know if I need to add anything. Thanks Andrew Defence 1.The Defendant contends that the particulars of claim are vague and generic in nature. 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. 2.Paragraph 1 is denied. Whilst I have had dealings with Morses Club and BT in the past I cannot recall the specifics of the alleged agreements. 3.Paragraph 2 is denied. I am not aware of any service of Termination Notice by either of the original creditors nor have I been provided with any Notice of Assignment pursuant to the Law of Property Act 1925. 4. On receipt of this claim I requested information pertaining to this claim from Overdales Solicitors Ltd by way of a CPR 31:14 request sent via 1st class with proof of postage on 01/09/2022. To date, Overdales Solicitors have yet to furnish me with the requested information and therefore remains in default of said request and unable to enforce the alleged agreement until such time it can comply. 6.Therefore with the court’s permission the Claimant is put to strict proof to:- a) show and disclose how the Defendant has entered into an agreement; b) show and disclose how the Claimant has reached the amount claimed for; c) show how the Claimant has the legal right, either under statute or equity to issue a claim; 7. As per Civil Procedure Rule 16.5 (4) it is expected that the Claimant prove the allegation that the money is owed. 8. On the alternative, if the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974.6. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.

Hi dx So do I get the company declared insolvent as this is the only debt the company has and the company has no money in its bank account. Or do I use the PE3 because I’ve had nothing in the post besides this. I don’t no if the letters from the rental company have got lost or something but this to my knowledge is all I’ve had in the post. And if I need to use the PE3 it says it goes to the court and needs to be signed by someone from the court. Do I wait to see if they bother taking it to court? Because with what you said it doesn’t sound like they would bother taking it to court. Thanks Andrew

Hi Dx It’s a limited company I was told to set it up that way for a bit of protection because it was courier work. Should I write a letter explaining why I’ve waited this long not thinking I needed to pay or does the debt die with the company? Thanks Andrew

Hi can anyone help me on what letters to send out? I know the Morses Club is a loan so it needs both letters but BT is broadband so it doesn’t apply does it?

Right I’ve messed up royally then I thought since it was rented in the companies name is was the company liability not mine. What’s the point of a limited company if any debt incurred by the company still becomes your own liability if the company can’t pay? That’s the only reason I didn’t pay when I got the notice because I didn’t no I was liable to pay. You said the council should have reset the timeline to pay the reduced amount when they located me. Should I write to them asking to pay the reduced sum since I wasn’t given the new timeline? I only didn't pay because I was under the false impression I wasn’t the one to pay the sum. I’m a complete novice to how companies work so I didn’t purposely miss the deadline

No I was the renter at the time of the pcn but the van was rented to the company which doesn’t have any money and hasn’t traded since May this year

I didn’t know about the pcn until a month after I gave the van back. The van was rented under the limited company name I set up. The work dried up in May and it’s not traded since. I’ve not closed the company down yet because I don’t know how to. I thought you just waited until it got kicked off company house since it didn’t even make any profit to pay any tax. Theres no money in the company bank account as I was putting money in to try and keep it going but when the work stopped I give up and stopped renting the van. I let go the guy I had working for the company and about a month or two later I got the pcn in the post.

Which Court have you received the claim from ? Name County Court Northampton N1 Name of the Claimant ? Lowell Portfolio I Ltd Date of issue – . 09 AUGUST 1) Particulars of Claim What is the claim for – Agreements the Defendant entered into: a. BT ple with reference 000000000 and current balance of £481.99 b. Morses Club with reference 00000000 and current balance of £160.00 The Agreements were terminated as payments were not maintained and subsequently assigned to the Claimant And the Claimant claims: a) The total of the said sums being £631.99 b) Interest pursuant to s09 County courts Act 1984 at the rate of 8% per annum from the date of assignment to the date of issue, but limited to one year, being £50.66 c) Costs The Claimant claims the sum of £682.55 What is the total value of the claim? £822.55 Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) No Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? Yes Did you inform the claimant of your change of address? No Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? Doorstep loan & internet BT When did you enter into the original agreement before or after April 2007 ? After Do you recall how you entered into the agreement...On line /In branch/By post ? Online Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? Yes Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. Account assigned Were you aware the account had been assigned – did you receive a Notice of Assignment? Can’t remember Did you receive a Default Notice from the original creditor? Can’t remember Have you been receiving statutory notices headed “Notice of Sums in Arrears” or " Notice of Arrears "– at least once a year ? No Why did you cease payments? Couldn’t afford it What was the date of your last payment? can’t remember Was there a dispute with the original creditor that remains unresolved? No Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? Yes I called many times to get a reduced monthly payment ................... Hi everyone I’ve received a N1 Northampton claim form from Lowell Portfolio I Ltd for BT PLC and Morses Club. I’ve acknowledged the claim and I’m typing up the request forms I need to send which I’ll put in tomorrow’s post. I’m a bit late in acting as I’ve had a lot of work stuff going on but I’m still in time with the deadlines. Any help with this would be much appreciated I’ll upload a dedicated copy of the form to this post. Thanks Andrew

Hi everyone Im not sure what to do with this charge. I set up a company last November 2021 to do courier work. I rented a van though the company but gave it back in May after the work dried up I haven’t told HMRC yet that I stopped trading because I thought you just wait until the company gets kicked off company house. The company didn’t make a profit in its 5 months of trading, didn’t think I needed to fill anything out. A the company I rented the van off sent me a letter saying the van got a parking ticket. I didn’t do anything because the company hasn’t any money left and isn’t trading . I’ve now been sent a charging certificate from the council. Do I just tell the council the company isn’t trading anymore or do I need to tell company house to take me off or something? Any help would be much appreciated Andrew 2020-08-09 liverpool charge certificate.pdf

Hi can no one help me here? I don’t know what to do should I call them up and explain I can’t pay in all one go? Should I leave it to go to court? Any help would be much appreciated I really don’t know what to do with this Andrew

Bump

Hi I’m getting worried as I’m very close to the day I need to pay. And still haven’t got a hope in paying in full on time. I’ve tired family and friends but everyone is skint which everything going on. Should I just ring up the people and see if they’ll take some sort of half payment now or something? I don’t want this to go any further but I don’t have the money to pay in full. Thanks Andrew