UKPC / DCB Legal Help with defence please

[suze200]

Hi des8 thank you for the defence template. I have just recived an email from DCB Legal It says
"We act for the Claimant.
We note your Disclosure request pursuant to CPR 31. We would like to respectfully inform you that CPR 31 for Disclosure does not refer to matters allocated to the Small Claims Track.
We can however, provide the evidence that we currently hold on file in relation to
the matter.
Please find the evidence attached.
We respectfully remind you that the deadline to respond to the Claim is 22/06/2025 and should a response not be received within this time, Judgment in default can be entered against you.
We look forward to hearing from you.
Kind Regards,
Name Name
Solicitor Apprentice"

The evidence is pretty much the same as the POPLA bundle with added stock images of the NO UNAUTHORISED PARKING signs. Also my initial appeal to UKPC and a copy of my bank statement showing payment to Superbowl. There is no site plan of where the signs were and no contract. Not really surprised about the contract given it cancelled by Superbowl because of UKPC's behavior

[suze200]

Does what they say about CPR 31 change the wording of the defence?

[des8]

So I would be tempted to write back to them and express surprise regarding their position over CPR31,
pointing out a firm of solicitors should know that the case has not yet been allocated to the small claims track and therefore the request is valid

However, don't because not complying with the CPR request is in your favour as your defence is partially that they are not cooperating to enable you sort the matter out without going to court.
They also need to prove they had the right to issue parking tickets, and you should have the opportunity to check that they were operating within the terms of their authority

Really just shows what a shower DCBLegal is !

[suze200]

Thank you des8. Well they obviously take the whole thing seriously and have given an apprentice the job of responding.
One interesting thing they sent is the "no unauthorised parking" sign proof which has no instructions for how to register and an undated photo, showing some writing stuck on (presumably the instructions for how to register) . This could have been taken at a different car park, its just a sign on a brick wall

[suze200]

des8 Sorry to be a pain but I'm not sure how to number the paragraphs, this is the bit I'm confused about " all references to paragraph numbers are to paragraph numbers in the Particulars of Claim" Do I add the relevant PoC number to headings in the defence? There are more headings than paragraphs in the PoC and the paragraph numbers themselves under the heading LIABILITY AS THE DRIVER OF THE VEHICLE go up to 8


Also the documents sent by DCB Legal include my initial online appeal to UKPC where ID myself as the driver. Does that matter?

[des8]

Didn't realise you had identified yourself as the driver.
This makes a difference as the defence begins by denying every allegation unless otherwise stated in the defence and is then signed with a statement of truth.
It is not a good idea to be untruthful in court!

I would suggest point 1 under section LIABILITY AS THE DRIVER OF THE VEHICLE is deleted and replaced with

"it is admitted the Defendant was the driver of the vehicle with registered number xxxxxxx at the time of the event"

Don't worry about the numbering. You could delete "all references to paragraph numbers are to paragraph numbers in the Particulars of Claim" as it only matters if such references are made and is a fairly standard wording put at the front in case such references are made.

[suze200]

des8 Thank you I am very grateful for your help

[suze200]

des8 I hope you dont mind me asking for help again. I filed a defence based on the one you kindly provided. The Claimant has not discontinued and a date has been set for a hearing. A witness staement filed by 15 Jan 2026. I am stuggling to know what to include in the witness statement. Do I need to say something about each point in the defence and what could be used as exhibits?

[des8]

Your witness statement is solely your account of what has occurred.

There are some examples in this thread: https://legalbeagles.info/forums/for...ness-statement.
and fuller advice here (chapter11, page63) https://www.judiciary.uk/wp-content/..._in_Person.pdf

The main body will explain how you drove into the car park, which you used previously without problems, were not informed by staff about the changes, saw no signs.
You received the charge notice and returned to the site to note the poor signage etc etc. (detail how the signs failed to comply with the code of practice , small hidden font etc0

If you want you may post up a redacted copy of your WS for checking

[suze200]

Thank you des8

[suze200]

des8 Result ! They have discontinued. My laptop failed when I was still working on the witness statement and it's being repaired So this is great news. Thank you again for your help.

[des8]

well done and thanks for letting us know