Hi All I've had a response to the letter I sent and have attached it here. Any thoughts would be welcome but it looks like they are awaiting further instruction from VCS. img026.pdf

Letter sent! Fingers crossed! Thanks so much everyone for your help it's been invaluable. Thank God for this Forum.

Thanks dx100uk. Hopefully this will be the end of it but as Arnie nearly said 'I may be back'.

Thanks Honeybee for your reply, I've amended slightly and will send this evening by Registered Post to ensure it arrives tomorrow before 1pm. Thanks all for all your help, much appreciated.

Hi I found another thread very similar to my situation in which they were advised to send the following by the talented ericsbrother, would it be OK for me to send the same or is that not done? Unfortunately for you I wasn’t born yesterday so I won’t be paying the demand to your client as both you and they know what I know and that there is no liability in this matter because the land is covered by its own byelaws, the signage is prohibitive and not an offer of a contract so none has been breached and anyway the POFA limits any charge to the specified sum so your demand for £160 is just a nonsense. As VCS has been spanked at court on this very same thing several times before I suggest that you tell your client to discontinue this foolishness and that way you will at least obey the SRA rules of conduct and obey Civil Procedure as well. I know that may well be a first for you but call it your new year's resolution. Should they decide to continue then I shall be asking for a full costs recovery order for unreasonable behaviour and then seek damages for breach of the DPA as per VCS v Philip, Liverpool CC Dec 2016. Even Will and John, the parking worlds’ worst solicitors seem to have got fed up with Simple Simon's stupidity and greed and presumably that is why you are wasting your ink on his behalf. Any thoughts greatly appreciated. Dee

Apologies disgruntled2007 I didn't realise I needed to refresh my screen for responses to appear.

Hi ericsbrother the defence I intend to make is as follows: 1 There is no keeper liability as VCS have failed to follow POFA protocols to create one. 2 No contract was offered by their signage so there has been no breach to create a cause for action. The demand is thus a penalty with no attempt to create terms with the only possible effect being deterrence. 3 VCS do not own the land, it is owned by the airport and is covered by it's own airport byelaws. Do I complete the income & expenditure forms? Any help/editing greatly appreciated.

Hi dx100uk I don't want to mither but I only have 3 days left to respond, did you manage to knock anything up for me?

Thanks dx100uk, hubby keeps wanting to cave!

The reply form is blank Would it be worth me writing to JLA directly disputing the claim?

So is there anything I do in the meantime, ie. complete the forms or reply? Thanks

Hi Letter of Claim attached. Thanks Letter Of Claim.pdf

Hi I've now received a Letter of Claim enclosing a reply form and income & expenditure form. They do not acknowledge my two liner to them. Any help would be much appreciated.

I have sent the two liner today as recommended. I have also completed the questions below: 1 Date of the infringement 28th May 2016 2 Date on the NTK [this must have been received within 14 days from the 'offence' date] not sure I threw it in the bin 3 Date received I assume it was within the 14 days 4 Does the NTK mention schedule 4 of The Protections of Freedoms Act 2012? [y/n?] n 5 Is there any photographic evidence of the event? y 6 Have you appealed? {y/n?] post up you appeal]n Have you had a response? [Y/N?] post it up 7 Who is the parking company? VCS Ltd 8. Where exactly [carpark name and town] Liverpool outside John Lennon Airport For either option, does it say which appeals body they operate under. IPC There are two official bodies, the BPA and the IAS. If you are unsure, please check HERE If you have received any other correspondence, please mention it here 1. Your account has been passed to our legal team 9/10/17 2. BW Legal 1st letter 9/10/17 3. BW Legal Final Notice 7/11/17

I have received a PCN from VCS Ltd for stopping for 8 seconds on 28 May 17 to pick up my distraught Sister-In-Law at Liverpool Airport. She didn't go to the pick up point as arranged but thought it better to start walking towards the main road. I received the initial notice from VCS Ltd but ripped it up and binned it (so I don't know if it was within the 14 days timeframe). I then ripped up and threw away their second letter. The first letter from BW Legal came in the same envelope as a letter from VCS saying my account had been passed to their legal team. The second one says its a 'FINAL NOTICE' saying their client has instructed them to commence County Court Proceedings against me for the recovery of the Balance. I'm not quite sure what to do at this stage, I have read through lots of the forum threads and am thinking of sending BW a letter telling them I am not paying and to leave me alone. Any help would be greatly appreciated. The following is a letter I'm thinking of sending to them, any thoughts anyone ???? Dear BW Legal Re: Your Ref: VCS/TXXXXXXX I write in response to your final notice which I take to be a letter before action dated 7th November 2017, the contents of which are noted. As the pre action protocols expect us to exchange sufficient information to understand each other’s position please forward to myself the original parking charge notice and a picture of the signs at the location as well as the operators contract which allows them to operate at the site (or indeed confirmation they own the land in question). As well as the information already requested please answer the following questions:- 1 Is this land part of the Airport as defined in the byelaws? 2 What type of car park is it? 3 What contravention gives a cause of action? 4 Who contravened your rules? 5 Who you are pursuing? 6 How is the £160 made up? Not only will this information help comply with the pre action protocols it will also help achieve the overriding objective. Having done some research on your claims I request that if you ignore my requests for information that your claim complies with CPR 16 Contents of the claim form 16.2 (1) The claim form must – (a) contain a concise statement of the nature of the claim Contents of the particulars of claim 16.4 (1) Particulars of claim must include – (a) a concise statement of the facts on which the claimant relies; Practice direction 16 Other matters to be included in particulars of claim 7.5 Where a claim is based upon an agreement by conduct, the particulars of claim must specify the conduct relied on and state by whom, when and where the acts constituting the conduct were done. Practice direction 22 Who may sign the statement of truth 3.1 In a statement of case, a response or an application notice, the statement of truth must be signed by (2) the legal representative of the party or litigation friend. 3.7 Where a party is legally represented, the legal representative may sign the statement of truth on his behalf. The statement signed by the legal representative will refer to the client’s belief, not his own. In signing he must state the capacity in which he signs and the name of his firm where appropriate. 3.9 The individual who signs a statement of truth must print his full name clearly beneath his signature. 3.10 A legal representative who signs a statement of truth must sign in his own name and not that of his firm or employer. Practice direction 7E Signature 10 Any provision of the CPR which requires a document to be signed by any person is satisfied by that person entering their name on an online form. I await your response. Yours sincerely D Bxxxx

Hi I also received a PCN from VCS Ltd for stopping for 8 seconds on 28 May 17 to pick up my distraught Sister-In-Law at Liverpool Airport. She didn't go to the pick up point as arranged but thought it better to start walking towards the main road. I received the initial notice from VCS Ltd but ripped it up and binned it (so I don't know if it was within the 14 days timeframe). I then ripped up and threw away their second letter. The first letter from BW Legal came int he same envelope as a letter from VCS saying my account had been passed to their legal team. The second on says its a 'FINAL NOTICE' saying their client has instructed them to commence County Court Proceedings against me for the recovery of the Balance. I'm not quite sure what to do at this stage, I have read through lots of the forum threads and am thinking of sending BW a letter telling them I am not paying and to leave me alone. Any help would be greatly appreciated