**DISCONTINUED!!** PCN received from parking cowboys advice needed

[ostell]

Re: PCN received from parking cowboys advice needed

Having a working login means you can keep check on what is happening to the claim.

[upsadaisy]

Re: PCN received from parking cowboys advice needed

Ok will do , thanks again

[Kati]

Re: PCN received from parking cowboys advice needed

[MENTION=5354]mystery1[/MENTION]

[upsadaisy]

Re: PCN received from parking cowboys advice needed

Hello , sorted on line problem so that's done acknowledge of service done , I was trying to get thro but held in que gave up , posted form, proof of post , managed then to find online address , sent message , about login ect , quick reply so I'll now wait for any news from Northampton , what will be next step ? Thanks

[mystery1]

Re: PCN received from parking cowboys advice needed

Next step will be to communicate with the claimant and ask them to replead and comply with the rules. I'll sort something soon.

In the meantime phone them and see if they'll give you an email address to save on postage.

M1

[upsadaisy]

Re: PCN received from parking cowboys advice needed

I've got address , I sent question of login and they have replied , CCBC@HMCTS.GSI.GOV.UK.

[mystery1]

Re: PCN received from parking cowboys advice needed

That's the court, not the claimant

M1

[upsadaisy]

Re: PCN received from parking cowboys advice needed

Sorry , misunderstood , you mean MIL

[mystery1]

Re: PCN received from parking cowboys advice needed

:okay:

M1

[upsadaisy]

Re: PCN received from parking cowboys advice needed

All lower key cs@milcollections.co.uk

[mystery1]

Re: PCN received from parking cowboys advice needed

Dear MIL collections,

I am in receipt of a court claim issued by yourselves dated xxxxxxx.

Sadly the particulars of claim do not comply with the court rules.

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.


Your particulars do not contain from whom this so called debt was purchased, whether your pursuit is against the driver or keeper, whether POFA 2012 has been utilised, how long the overstay was, how long the time allowed was, how the breach was discovered, how the original charge was communicated and how the terms and conditions were communicated. Further your particulars do not contain a cause of action. I request that you replead your case in accordance with the civil procedure rules.

In order to comply with the over riding objective i would seek further information from yourselves.

1. A copy of the deed of assignment. Lord Denning Van Lynn Developments v Pelias Construction Co Ltd 1968 agrees that this is a must.

2. A copy of the sign of the site.

3. A copy of the contract which allowed the company from which you made your purchase to operate at that site.

I remind you of the words of LJ Rix in Expandable Ltd & Anor v Rubin [2008] EWCA Civ 59 (11 February 2008)

The general ethos of the CPR is for a more cards on the table approach to litigation. If a party thinks it worthwhile to mention a document in his pleadings, witness statements or affidavits, I do not see why, subject as I say to the question of privilege, the court should put difficulties in the way of inspection. I look upon the mention of a document in pleadings etc as a form of disclosure. The document in question has not been disclosed by list, or at any rate not yet, but it has been disclosed by mention in what, for the purposes of litigation, is another important and formal category of documents. If so, then the party deploying that document by its mention should in principle be prepared to be required to permit its inspection, and the other party should be entitled to its inspection. What in such circumstances is the virtue of coyness?


Should you wish extra time to deal with these matters please confirm an agreement pursuant to CPR 15.5 for an extension of 28 days for me to file my defence.

Further i draw your attention to cpr 27.14 (2) (g) such further costs as the court may assess by the summary procedure and order to be paid by a party who has behaved unreasonably.

Given your history of discontinuing claims you are already at that risk should you continue your path.

MIL -v- Mrs S. D., Case No. C0QZ173C


MIL -v- Mr S. C., Case No. C8QZ540N


MIL -v- Mr S. H., Case No. C1QZ911D


MIL -v- Mr R. M, Case No. C3QZ569P


MIL -v- Mrs G. D., Case No. C7QZ8344


MIL -v- Mr P. V., Case No C8QZ707N


MIL -v- Mr M. O. Case No. B6QZ3H7A


MIL -v- C Ltd, Case No. B8QZ0K4T


MIL -v- Mr C. H., Case No. C6QZ220N


MIL -v- M M. A., Case No. C9QZ531N


I should also make you aware that i consider your claim champterous.



I look forward to you response.

Yours sincerely

M1

[upsadaisy]

Re: PCN received from parking cowboys advice needed

Hello mi1 , thank you again , shall I email to MIL after putting in info at *****. Thanks again

[upsadaisy]

Re: PCN received from parking cowboys advice needed

Hello m1 , all done and dusted went at 16.34 according to records , how long do we give them and what if they don't reply , thanks

[mystery1]

Re: PCN received from parking cowboys advice needed

About a week i'd say. Then we'd phone them and see what they say and if not enter a defence on what we have.

M1

[upsadaisy]

Re: PCN received from parking cowboys advice needed

If they won't play ball , does it all go against them , I was looking a reviews online , Mil difficult to deal with and don't turn up to court , or give short notice , like worst 15 minutes before court , excuse car broke down and court case was in Truro were they are based