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Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

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  • Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

    Hello everyone, I am new to the sight and would appreciate some help.
    I have received a summons in relation to my wife overstaying in a co op car park in Shepton Mallet by 20 minutes. There is 2 hours free parking according to signs. It was January 11th 2012 at 18:56 hrs. My wife didn't see the signs and was oblivious to any rules at this car park. In her defence it was very dark and foggy. The reason for staying in the car park was meeting work colleagues at an Indian restaurant which backs onto the car park. I received letters from CEL about six in total and a couple from Debt Enforcement & Action LTD. and ignored all of these until I received an official court summons which I replied with a defence put together from reading various threads. The claimant wanted the hearing in Barnet but the Judge referred it to the County Court of Bath which is 12 miles from my home. That's obviously good for me but the claimant wants to add travel costs to overall claim. I have received Notice of Allocation to the small claims track. By the 9th March I have to present anything I will rely on at the final hearing which is 5th May 2015. I also have to send copies of these details to the Claimant. Since receiving these papers, I have received the claimants defence and an invitation to settle the original amount of £215.00 or face the potential £545.00 for their costs and travel to the court. May I ask if there is anyone willing to look at this for me in the timescales presented? Best Regards, Barney.
    Tags: None

  • #2
    Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

    I assume this is a private action by someone claiming to represent the land-owner, brought against you because you are the registered keeper of the car. The claim will ordinarily be based upon contract, but because of the Protection of Freedoms Act 2012 you are in the frame because of a statutorily impose form of 'strict liability'. If you were not with the car when it was parked then it cannot be said that you accepted any contractual terms constituted by the notice in question, but the question will no doubt arise as to whether the notices of potential liability were clearly worded and reasonably visible to your wife.

    You will need your wife to be present at the hearing to give evidence of these aspects.

    There may be a subsidiary argument that the entity who has purported to 'fine' (or invoice) you (a) had no sufficient interest in the land to maintain a parking charge for it; (b) suffered no loss or damage by reason of your car being parked; (c) is purporting to levy an illegal penalty entirely disproportionate to any loss it may claim to have suffered by your car (a) parking (b) over-staying. The more arguments the merrier!
    Last edited by KEITH WHITEHORN; 26th February 2015, 14:44:PM.

    Comment


    • #3
      Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

      Dear Keith, thank you very much for your input. The land is owned by the Co-operative group and use the company CEL who in turn use number plate recognition cameras. The rest I'm sure you know. I did write to the main chap at Co-op ltd and his PA replied there is nothing they can do at this stage so I have since stopped shopping at any co-op

      would you happen to know anyone on this site that would be willing to write a defence if I emailed all the details?

      kindest Regards,

      Barney



      Originally posted by KEITH WHITEHORN View Post
      I assume this is a private action by someone claiming to represent the land-owner, brought against you because you are the registered keeper of the car. The claim will ordinarily be based upon contract, but because of the Protection of Freedoms Act 2012 you are in the frame because of a statutorily impose form of 'strict liability'. If you were not with the car when it was parked then it cannot be said that you accepted any contractual terms constituted by the notice in question, but the question will no doubt arise as to whether the notices of potential liability were clearly worded and reasonably visible to your wife.

      You will need your wife to be present at the hearing to give evidence of these aspects.

      There may be a subsidiary argument that the entity who has purported to 'fine' (or invoice) you (a) had no sufficient interest in the land to maintain a parking charge for it; (b) suffered no loss or damage by reason of your car being parked; (c) is purporting to levy an illegal penalty entirely disproportionate to any loss it may claim to have suffered by your car (a) parking (b) over-staying. The more arguments the merrier!

      Comment


      • #4
        Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

        My understanding is that the Co-op & CEL have had a falling out. Also they need to take the driver to Court and as I assume because this was so long ago you cannot remember who that is - if you see what I am saying. Even if you did know the driver there is nothing that says you have to tell them anyway..

        I believe Mystery1 is the person you need here to help you.

        Comment


        • #5
          Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

          Dear Ploddertom, Hi and thank you. With regards to the driver, it is my understanding that the law changed so it was the registered keeper that can be taken to task irrespective of who was driving. Is this still the case?

          Comment


          • #6
            Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

            He is being taken to court as the registered keeper i would assume as PoFA was alive and kicking by 2014.

            What is needed to be sent depends on what your defence is. If the signage was poor/non existent then your wife would be a witness so a witness statement is needed from her. If you went to see the signs afterwards that goes in your own witness statement. If the original notices are non compliant with PoFA you need to send copies etc etc.

            I am guessing since you haven't posted much

            M1

            Comment


            • #7
              Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

              Dear M1
              Here is my original defence sent in response to the original summons.


              DEFENCE


              To the Northampton County Court

              Claim Number. xxxxxxxx

              xxxxxxxxx - Defence.

              Soon after the 11th January 2012, the company, Civil Enforcement Limited which is a company that issues parking fines on "private land" issued the driver of car xxxxx a parking fine in the post. In this case, the private land is a supermarket car park owned by the Co-Operative grocer chain which the driver at the time understood to be free. No contact was made with this company as the driver was advised to ignore the fine by the Citizens Advise Bureau and on-line solicitors until such time a court summons was raised. The reason for this is, only the police and council can enforce car parking fines or NPC's or was thought to be the case. It is claimed that the company had signage to say parking was a limited time and once entering the car park, one is entering into a contract with this company.

              The defence is as follows:


              1. No contract
              There was no contract between the driver and Claimants client, Civil Enforcement Limited neither did the driver see any notices at the time pertaining to the offence. According to the Private Parking Firm, Civil Enforcement Limited, the date and time 11th January 2012 at 18:56hrs, on this month at this time, I put it to the court and the Claimant, visibility could have been poor at best but also if it was foggy, snowing, raining etc. signs would not be clearly visible. Any driver could be forgiven that car parks in the small town of Shepton Mallet would be free after 18:00hrs in any case. When parked and at that time the driver had no idea any charge whatsoever would ensue. So the requirements of forming a contract such as a meeting of minds, agreement, certainty of terms, etc were not satisfied. Had the driver known when parked, that there were restrictions, these would have been abided in the same way that if the council ran the car park and charged £1.50 per hours parking, the driver would have paid this. There were not clearly displayed instructions or signage therefore the driver had no reason to think there would be restrictions and/or penalties at this car park.

              2. Trespass
              If there was no contract, then at most The driver was guilty of a civil trespass (though this is neither admitted nor denied). If this was the case, the driver would be liable to damages. Given that the driver did no damage to the car park and furthermore that the car park was not full when the driver parked and also neither when left, I would suggest that there was therefore no loss at all.

              3. Punitive/unfair/unreasonable
              Without prejudice to the foregoing, even if there was a contract (which is denied):
              a. Punitive
              The charge that you are levying is punitive and therefore void (i.e. unenforceable) against the driver. The original charge of £90 is arbitrary and in no way proportionate to any alleged breach of contract even at half this price, £45 if settled early within an outlined 14 days. Nor does it even equate to local council charges (which in any event are completely different). This is all the more so for the additional charge of £45 which the claimant say's accrues after seven days of non-payment. This would also apply to your mention of any costs incurred through debt recovery unless it followed a court order.

              b. Unfair
              The charge being levied is an unfair term (and therefore not binding) pursuant to the Unfair Terms in Consumer Contracts Regulations 1999. In particular, Schedule 2 of those Regulations gives an indicative (and non-exhaustive) list of terms which may be regarded as unfair and includes at Schedule 2(1)(e) "Terms which have the object or effect of requiring any consumer who fails to fulfil his obligation to pay a disproportionately high sum in compensation." Furthermore, Regulation 5(1) states that: "A contractual term which has not been individually negotiated shall be regarded as unfair if, contrary to the requirement of good faith, it causes a significant imbalance in the parties' rights and obligations arising under the contract, to the detriment of the consumer" and 5(2) states: "A term shall always be regarded as not having been individually negotiated where it has been drafted in advance and the consumer has therefore not been able to influence the substance of the term."

              c. Unreasonable
              The charge you are levying is an unreasonable indemnity clause pursuant to section 4(1) of the Unfair Contract Terms Act 1977 which provides that: "A person cannot by reference to any contract term be made to indemnify another person (whether a party to the contract or not) in respect of liability that may be incurred by the other for negligence or breach of contract, except in so far as the contract term satisfies the requirement of reasonableness.”

              Further information to the Claimant.
              Please take this letter to constitute a written defence in accordance with your Court Order. I also make the following points. I would be grateful for answers to all questions raised and in this respect remind you of the obligations set out in the Practice Direction on Pre-Action Conduct (http://www.justice.gov.uk/courts/procedure-rules/civil/rules/pd_pre-action_conduct).

              1. Your cause of action: please make this clear. If you claim that I entered into a contract, please send me a complete breakdown of all the terms and conditions of that contract to which you say I agreed.

              2. Your loss: please give me a full breakdown as to the actual loss you say was suffered by either Civil Enforcement Limited or The Co-Operative Group Limited between the hours of 18:56hrs and 21:20hrs.

              3. Your Appeal Process when issuing tickets: please send me a copy of the procedure which you follow, along with setting out what factors are taken into account, who is the judge or arbitrator and whether they are independent, whether you require oral submissions, whether it is governed by the Arbitration Act 1996 and any other relevant factors. In addition, please give me disclosure of any arguments being put by yourselves on this matter in the Appeal so that I might reply to any new issues which are raised. If you decide to take full court action, please send me the full reasoning in relation to each of the specific points raised in this letter.

              4. Timescales for an appeal on a ticket issued. Your original parking charge notice says: ‘Appeals/challenges received after 7 (seven) days will not be upheld or considered unless in extreme circumstances, and at the Company’s discretion.’ Please tell me how you say this complies with the Practice Direction on Pre-Action Conduct (above)?

              5. Your 'Parking Charge Notice': what do you say is the status of this document? Do you claim it is an invoice pursuant to a contract (in other words an invoice which would generally get declared to the Inland Revenue) or does it have some other status? If it is the latter, please clarify exactly what you say it is?

              6. Your status. Your Parking Charge Notice simply mentions Civil Enforcement Limited and your current correspondence uses the name, Debt Enforcement & Action Limited. Is this the same company? Please tell me who exactly is making this charge? Are you a limited company?

              7. Fake Documents. Why did your company Debt Enforcement & Action Limited send fake court documents on the 15th September threatening to take the owner, Mr xxxxxx to court and advise him you would lodge a summons date on 24/09/2014?Furthermore there was no claim number and the costs outlined in this spurious form amounted to £255.00 which are different to the costs you are currently claiming for i.e £215.00. I spoke to the court regarding this document and they had no record of this information and I put it to your company that you are using scare mongering techniques in order to falsely claim money by deception and preying on people's ignorance and vulnerability. I would also like Civil Enforcement Limited to tell the Court Service of your company's false witness statements given in other Court Summons by a then current employee, Mr Ashley Coen who was in fact an employee of Civil Enforcement and had falsified a witness statement to again, try and incriminate an unsuspecting motorist. I request these details are also sent to me for my further defence.

              8. What is the relationship between Civil Enforcement Limited and Debt Enforcement & Action Limited as it is alleged these companies are in actual fact the same? Please provide names and credentials of Directors and/ owners for both companies including all registered offices both working, PO Box and multi drop address's.

              9. Your company claim to use ANPR camera's (automatic number plate recognition) therefore a photograph may have been taken of the vehicle P200 GAP for evidential value and will be stored in accordance with the Company's Data Protection procedures'. Please send me a copy of those procedures. Furthermore, pursuant to section 7 of the Data Protection Act 1998 please send me a copy of any such photo along with a copy of any other data which you hold relating to the driver. Please also send calibration certificates noting the accuracy of time regarding the number plate recognition equipment as I will need proof that the times outlined are accurate and I would ask how one would know they are completely accurate and functioning properly and when these machines are calibrated and at what intervals?

              10. Please send me details of any Codes by which you claim to comply and any governing body or other such organisation of which you are a member.

              11. Please provide me with the name and address of your solicitors (if any) in the event I need a lawyer to disclose a further defence and subsequent counter claim for time lost at work and stress related disorders for harassment that the driver has endured over the last 2 years 11 months.

              12. FAO: Civil Enforcement Limited and Debt Enforcement & Action Limited, for the avoidance of doubt (and without suggesting that you would), please do not do the following:

              a. Send me any document purporting to be from the County Court unless it is a valid Claim Form duly issued.
              b. Write to me threatening to send round bailiffs without first going through the process of issuing a Claim Form and obtaining judgment.
              c. Send me any standard letters either from yourselves or debt-collectors without addressing the specific points raised in this response.
              d. I note that your original Notice of Parking Charge was issued 11th January 2012 (nearly 3 years ago) and on the ticket you advised court action would pursue if payment was not received within 28 days. If you advise that all notices issued are pursued to the issue of a court summons within 28 days then please provide evidence of this as the driver advises no summons were received and when something that looked like a summons arrived, it was fake. Please can you confirm that this is accurate and tell me how many claims you have pursued to a court hearing? Are there any Notices you have issued which have not been enforced? I note in this respect that media coverage of your company and Internet blogs on your company have revealed no court action has been pursued or awarded as it is felt your company operates through loop holes in British Law which enable you to obtain money by deception and through people's ignorance and vulnerability. May I also point out to the court that your company has been investigated by the television program "Watchdog" and various other television and current affairs programs in which both lawyers and solicitors on the program have advised consumers to ignore all Notice of Parking Charges from your company until such time a real court summons is issued?

              13. Please note:
              a. I reserve the right to add further arguments to my Defence.
              b. Please rest assured that this case will be vehemently defended against any decision to enforce this parking fine upon me as the registered keeper of the vehicle which may be actioned by either Civil Enforcement Limited or Debt Enforcement & Action Limited.

              c. May I humbly ask the court, should they find my defence made here, fair and just, to instruct Civil Enforcement Limited and/or Debt Enforcement & Action an advise in writing that this penalty notice is quashed and no further action should be taken should the court see in my favour.


              Yours Sincerely,




              xxxxxxx
              Last edited by mystery1; 26th February 2015, 16:06:PM. Reason: Personal info

              Comment


              • #8
                Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                Original Post lists this as being from Jan 2012 so pre POFA.

                Comment


                • #9
                  Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                  Originally posted by ploddertom View Post
                  Original Post lists this as being from Jan 2012 so pre POFA.
                  Indeed, that's what happens if you read without concentrating.

                  M1

                  Comment


                  • #10
                    Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                    Originally posted by BCD1 View Post
                    Dear M1
                    Here is my original defence sent in response to the original summons.


                    DEFENCE


                    To the Northampton County Court

                    Claim Number. xxxxxxxx

                    xxxxxxxxx - Defence.

                    Soon after the 11th January 2012, the company, Civil Enforcement Limited which is a company that issues parking fines on "private land" issued the driver of car xxxxx a parking fine in the post. In this case, the private land is a supermarket car park owned by the Co-Operative grocer chain which the driver at the time understood to be free. No contact was made with this company as the driver was advised to ignore the fine by the Citizens Advise Bureau and on-line solicitors until such time a court summons was raised. The reason for this is, only the police and council can enforce car parking fines or NPC's or was thought to be the case. It is claimed that the company had signage to say parking was a limited time and once entering the car park, one is entering into a contract with this company.

                    The defence is as follows:


                    1. No contract
                    There was no contract between the driver and Claimants client, Civil Enforcement Limited neither did the driver see any notices at the time pertaining to the offence. According to the Private Parking Firm, Civil Enforcement Limited, the date and time 11th January 2012 at 18:56hrs, on this month at this time, I put it to the court and the Claimant, visibility could have been poor at best but also if it was foggy, snowing, raining etc. signs would not be clearly visible. Any driver could be forgiven that car parks in the small town of Shepton Mallet would be free after 18:00hrs in any case. When parked and at that time the driver had no idea any charge whatsoever would ensue. So the requirements of forming a contract such as a meeting of minds, agreement, certainty of terms, etc were not satisfied. Had the driver known when parked, that there were restrictions, these would have been abided in the same way that if the council ran the car park and charged £1.50 per hours parking, the driver would have paid this. There were not clearly displayed instructions or signage therefore the driver had no reason to think there would be restrictions and/or penalties at this car park.

                    2. Trespass
                    If there was no contract, then at most The driver was guilty of a civil trespass (though this is neither admitted nor denied). If this was the case, the driver would be liable to damages. Given that the driver did no damage to the car park and furthermore that the car park was not full when the driver parked and also neither when left, I would suggest that there was therefore no loss at all.

                    3. Punitive/unfair/unreasonable
                    Without prejudice to the foregoing, even if there was a contract (which is denied):
                    a. Punitive
                    The charge that you are levying is punitive and therefore void (i.e. unenforceable) against the driver. The original charge of £90 is arbitrary and in no way proportionate to any alleged breach of contract even at half this price, £45 if settled early within an outlined 14 days. Nor does it even equate to local council charges (which in any event are completely different). This is all the more so for the additional charge of £45 which the claimant say's accrues after seven days of non-payment. This would also apply to your mention of any costs incurred through debt recovery unless it followed a court order.

                    b. Unfair
                    The charge being levied is an unfair term (and therefore not binding) pursuant to the Unfair Terms in Consumer Contracts Regulations 1999. In particular, Schedule 2 of those Regulations gives an indicative (and non-exhaustive) list of terms which may be regarded as unfair and includes at Schedule 2(1)(e) "Terms which have the object or effect of requiring any consumer who fails to fulfil his obligation to pay a disproportionately high sum in compensation." Furthermore, Regulation 5(1) states that: "A contractual term which has not been individually negotiated shall be regarded as unfair if, contrary to the requirement of good faith, it causes a significant imbalance in the parties' rights and obligations arising under the contract, to the detriment of the consumer" and 5(2) states: "A term shall always be regarded as not having been individually negotiated where it has been drafted in advance and the consumer has therefore not been able to influence the substance of the term."

                    c. Unreasonable
                    The charge you are levying is an unreasonable indemnity clause pursuant to section 4(1) of the Unfair Contract Terms Act 1977 which provides that: "A person cannot by reference to any contract term be made to indemnify another person (whether a party to the contract or not) in respect of liability that may be incurred by the other for negligence or breach of contract, except in so far as the contract term satisfies the requirement of reasonableness.”

                    Further information to the Claimant.
                    Please take this letter to constitute a written defence in accordance with your Court Order. I also make the following points. I would be grateful for answers to all questions raised and in this respect remind you of the obligations set out in the Practice Direction on Pre-Action Conduct (http://www.justice.gov.uk/courts/procedure-rules/civil/rules/pd_pre-action_conduct).

                    1. Your cause of action: please make this clear. If you claim that I entered into a contract, please send me a complete breakdown of all the terms and conditions of that contract to which you say I agreed.

                    2. Your loss: please give me a full breakdown as to the actual loss you say was suffered by either Civil Enforcement Limited or The Co-Operative Group Limited between the hours of 18:56hrs and 21:20hrs.

                    3. Your Appeal Process when issuing tickets: please send me a copy of the procedure which you follow, along with setting out what factors are taken into account, who is the judge or arbitrator and whether they are independent, whether you require oral submissions, whether it is governed by the Arbitration Act 1996 and any other relevant factors. In addition, please give me disclosure of any arguments being put by yourselves on this matter in the Appeal so that I might reply to any new issues which are raised. If you decide to take full court action, please send me the full reasoning in relation to each of the specific points raised in this letter.

                    4. Timescales for an appeal on a ticket issued. Your original parking charge notice says: ‘Appeals/challenges received after 7 (seven) days will not be upheld or considered unless in extreme circumstances, and at the Company’s discretion.’ Please tell me how you say this complies with the Practice Direction on Pre-Action Conduct (above)?

                    5. Your 'Parking Charge Notice': what do you say is the status of this document? Do you claim it is an invoice pursuant to a contract (in other words an invoice which would generally get declared to the Inland Revenue) or does it have some other status? If it is the latter, please clarify exactly what you say it is?

                    6. Your status. Your Parking Charge Notice simply mentions Civil Enforcement Limited and your current correspondence uses the name, Debt Enforcement & Action Limited. Is this the same company? Please tell me who exactly is making this charge? Are you a limited company?

                    7. Fake Documents. Why did your company Debt Enforcement & Action Limited send fake court documents on the 15th September threatening to take the owner, Mr xxxxxx to court and advise him you would lodge a summons date on 24/09/2014?Furthermore there was no claim number and the costs outlined in this spurious form amounted to £255.00 which are different to the costs you are currently claiming for i.e £215.00. I spoke to the court regarding this document and they had no record of this information and I put it to your company that you are using scare mongering techniques in order to falsely claim money by deception and preying on people's ignorance and vulnerability. I would also like Civil Enforcement Limited to tell the Court Service of your company's false witness statements given in other Court Summons by a then current employee, Mr Ashley Coen who was in fact an employee of Civil Enforcement and had falsified a witness statement to again, try and incriminate an unsuspecting motorist. I request these details are also sent to me for my further defence.

                    8. What is the relationship between Civil Enforcement Limited and Debt Enforcement & Action Limited as it is alleged these companies are in actual fact the same? Please provide names and credentials of Directors and/ owners for both companies including all registered offices both working, PO Box and multi drop address's.

                    9. Your company claim to use ANPR camera's (automatic number plate recognition) therefore a photograph may have been taken of the vehicle P200 GAP for evidential value and will be stored in accordance with the Company's Data Protection procedures'. Please send me a copy of those procedures. Furthermore, pursuant to section 7 of the Data Protection Act 1998 please send me a copy of any such photo along with a copy of any other data which you hold relating to the driver. Please also send calibration certificates noting the accuracy of time regarding the number plate recognition equipment as I will need proof that the times outlined are accurate and I would ask how one would know they are completely accurate and functioning properly and when these machines are calibrated and at what intervals?

                    10. Please send me details of any Codes by which you claim to comply and any governing body or other such organisation of which you are a member.

                    11. Please provide me with the name and address of your solicitors (if any) in the event I need a lawyer to disclose a further defence and subsequent counter claim for time lost at work and stress related disorders for harassment that the driver has endured over the last 2 years 11 months.

                    12. FAO: Civil Enforcement Limited and Debt Enforcement & Action Limited, for the avoidance of doubt (and without suggesting that you would), please do not do the following:

                    a. Send me any document purporting to be from the County Court unless it is a valid Claim Form duly issued.
                    b. Write to me threatening to send round bailiffs without first going through the process of issuing a Claim Form and obtaining judgment.
                    c. Send me any standard letters either from yourselves or debt-collectors without addressing the specific points raised in this response.
                    d. I note that your original Notice of Parking Charge was issued 11th January 2012 (nearly 3 years ago) and on the ticket you advised court action would pursue if payment was not received within 28 days. If you advise that all notices issued are pursued to the issue of a court summons within 28 days then please provide evidence of this as the driver advises no summons were received and when something that looked like a summons arrived, it was fake. Please can you confirm that this is accurate and tell me how many claims you have pursued to a court hearing? Are there any Notices you have issued which have not been enforced? I note in this respect that media coverage of your company and Internet blogs on your company have revealed no court action has been pursued or awarded as it is felt your company operates through loop holes in British Law which enable you to obtain money by deception and through people's ignorance and vulnerability. May I also point out to the court that your company has been investigated by the television program "Watchdog" and various other television and current affairs programs in which both lawyers and solicitors on the program have advised consumers to ignore all Notice of Parking Charges from your company until such time a real court summons is issued?

                    13. Please note:
                    a. I reserve the right to add further arguments to my Defence.
                    b. Please rest assured that this case will be vehemently defended against any decision to enforce this parking fine upon me as the registered keeper of the vehicle which may be actioned by either Civil Enforcement Limited or Debt Enforcement & Action Limited.

                    c. May I humbly ask the court, should they find my defence made here, fair and just, to instruct Civil Enforcement Limited and/or Debt Enforcement & Action an advise in writing that this penalty notice is quashed and no further action should be taken should the court see in my favour.


                    Yours Sincerely,




                    xxxxxxx

                    WHy did you not include that you were not the driver ? (as Ploddertom rightly points out)

                    I've seen worse defences but half of that is ranting and questions. At least you have the penalty issue :okay:

                    M1

                    Comment


                    • #11
                      Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                      Thanks M1, are you able to assist further in providing bullet points more subjective to my defence. Would you be prepared to look at the Claimants case if I can manage to scan and attach it here?
                      Kindest Regards, Barney

                      Comment


                      • #12
                        Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                        Sure, i am watching footie at 6 and working tomorrow though.

                        M1

                        Comment


                        • #13
                          Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                          Hi,
                          many thanks, files attached and two more pages to come.
                          best Regards. Barney
                          Attached Files

                          Comment


                          • #14
                            Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                            Hi,
                            Last remaining attachments.
                            regards, Barney
                            Attached Files

                            Comment


                            • #15
                              Re: Parking ticket from CEL/Debt Enforcement& Action Ltd from Jan 2012 court summons.

                              Hi BCD1,

                              I am a SMTC councillor and am helping a few people with court claims from this particular car park (in a personal capacity, not on behalf of the town council).
                              We currently have two hearings scheduled in Bath at the beginning of May.
                              Please get in touch if you want help or support - you can PM me and I'll give you my email.

                              Comment

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