I need help writing up a CP 31.14 (newbie)

[ridjuan98]

Hello guys hope all is well, I'm a little confused on how to go about the CP 31.14 as it's my first time do anything of the sort. I would really appreciate if someone could help as i'm confused about what to write in the particulars sections of the template CP 31.14 in the shortcuts. this is where I get confused about what to include:

*start of template*
NB: ONLY LIST HERE DOCUMENTS THAT ARE MENTIONED IN THE PARTICULARS OF CLAIM ON THE FRONT OF THE CLAIM FORM – eg. IF THEY DON’T MENTION ‘ DEFAULT NOTICE’ YOU CANNOT ASK FOR IT UNDER CPR 31.14, IF THEY MENTION CONTRACT rather than AGREEMENT – ask for the CONTRACT…IF IN DOUBT TYPE OUT THE PARTICULARS OF CLAIM AND ASK ON THE FORUM.( and remove this paragraph too!!!!)
for EXAMPLE
1. Agreement / Contract
2. Default Notice
3. Notice of Assignment
*end of template*

I am attaching images of my letter of claim notice from dcb legal so if anybody could point me out what particulars to include in the CP 31.14 request I'd be extremely grateful. Thanks guys.
https://ibb.co/TqSpCSq
https://ibb.co/jZGMsRw
https://ibb.co/TwLHcpH
https://ibb.co/gZPCgFg

[ridjuan98]

ostell

[ostell]

The PCNs, the signs that created the contract, definition of who they are claiming from either the driver or the keeper, proof of authority of the claimant obviously not the landowner to operate and bring claims

[ridjuan98]

ostell Thank you so much, so do I just say “the pcn’s” and “the signs that created the contract” or do I actually go and quote the actual pcn’s and the signs that created the contract? E.g PCN number 638292 and sign 63828 for example? Thanks again

[ridjuan98]

First Parking has sent all documents I asked for in the SAR this morning (all of which I have no recollection of receiving) I have also sent them a CCA request with the Ł1 fee and I have sent their solicitors DCB Legal a CPR 31.14 both in the post. Now I am waiting for their replies and i'm pretty nervous. Is there anything I should be doing in the meantime?? Should I reply anything to the SAR documents sent by first parking? should I wait for a reply to my CCA from first parking and wait for the reply for the CPR31.14 I sent to DCB Legal? What is the next step right now, i've checked the newbies thread but i'm still confused. Thank you to everyone i'll appreciate any help at all!

[ridjuan98]

ostell

[ostell]

There is no CCA therefore no need to request any or send Ł1. The te plate was written to support debt claims hence the mention of CCA

So what does the NTK in the SAR say about the alleged parking breach? Post it up, suitably redacted but leave dates.

DCBL will probably not supply, they have a history of refusing. When you get the refusal complain to the Solicitors Regulation authority and send copies of the request and response

[ridjuan98]

Dear ostell , to my shock, DCBL had repled to me on the 22nd of March, I was expecting them to reply by post as I had sent them the request for CPR31.14 by post and now it has been over 30 days since they've replied to my CPR31.14 request. This is the reply I got from them on the 22nd of March:

***start of message***

Dear Muhammed Ahmed,
DCB Legal Ltd are now in receipt of recent correspondence.
We note you have stated you have received a County Court claim form in relation to this matter, and you intend to defend this. Please note, we have not issued legal proceedings on this matter at this stage. Therefore, no form from the Court has been sent to you in relation to this matter. You may wish to discuss this with the Court.
We also note you have requested any evidence in relation to the Parking Charge Notices (PCNs) outlined in the Letter of Claim (LoC) dated 17^thFebruary 2021.
Please find attached all relevant requested documentation. DCB Legal Ltd have been informed your vehicle (VRM: RR10DDD) was parked on site (The University of Hertfordshire, Blue Zone D) without a valid ticket or permit. The terms and conditions on the signs stated that parking was permitted for vehicles with a valid permit/ticket, or otherwise a parking charge notice would be issued. Please find attached examples of these signs on site.
Our client utilises Automatic Number Plate Recognition (“ANPR”) technology on the land where the parking charge notice was issued in order to manage the parking. This means that cameras capable of accurately recognising the vehicle registration number of a vehicle are constantly monitoring the entrance and exit to the land. A photograph is taken of each vehicle as it enters and exits the land. Any vehicle found to have breached the terms of parking will be issued with a parking charge notice via the post.
Upon issuing a PCN our Client applied to the DVLA for the details of the Registered Keeper of the Vehicle. Your name and address were provided. A Notice to Keeper was issued to you on each occasion. Copies are attached. You were afforded the opportunity to; appeal the parking charge, transfer liability to the driver (if it was not you) or make payment. Neither a successful appeal, nor an adequate nomination were received, yet payment remains outstanding. We would also like to point out these were all sent to the same address our Letter of Claim was issued to.
DCB Legal Ltd have been instructed as all other attempts to recover the balance have been unsuccessful. You now have 30 days from the date of this letter to pay the outstanding balance of Ł560.00. Failure to do so will result in a claim being issued against you without further notice. For the purpose of clarity, you are being pursued as the Registered Keeper under schedule 4 (4)(1) of the Protection of Freedoms Act 2012.
Payment can be made via bank transfer to our designated client account: -
Account Name: DCB Legal Ltd Client Account
Sort Code: 20-24-09
Account Number: 60964441
You must quote the correct case reference 100720.5670D when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred.
Alternatively, you can contact DCB Legal Ltd on 0203 434 0424 to discuss payment over the telephone.
Kind regards,
Jonathan Worthington
DCB Legal Limited

***end of message***

i've attached to this post the reply sent to me by DCBL in reply to my crp request to them, they sent the contracts which are dated in 2017 (they also sent screenshots of each pcn letter that was apparently sent to me, which I have never received)

now that's it's been over 30 days they have now created a claim against me which has got me worried, I was really expecting them to reply by post by they replied by email which I did not even notice until I got sent the actual court claim in the mail to which I immediately searched my mail and found they ahd sent it on the 22nd. I really don't know what to do at this stage and now I have about 9 days to reply to them until further action is taken.

once again ostell thank you so much for your help I appreciate it a lot.

[ostell]

Please use PDF or JPG, I don't open ZIP files.

Use a hosting site such as imgur to upload your files and put the link on here.

[ridjuan98]

dear ostell , apologies, here is the imgur link https://imgur.com/a/KXoEGAP

[ostell]

Need the NTK not the claim form

[ridjuan98]

ostell Sorry this might seem like a really stupid question but what is the NTK? Thanks

[ridjuan98]

ostell sorry here is the link to all notices to keeper! https://imgur.com/gallery/rLZHy8Q

[ostell]

All the notices either fail 8 (2) (e) or 9 (2) (e) and no period of parking

[ridjuan98]

ostell thank you so much, so should I email DCBL about this and tell them about this? Also, what do I reply to the claim form, it says I need to reply to the claim form on moneyclaim.gov.uk so should I write that the notices either fail 8 (2) (e) or 9 (2) (e) and there is no period of parking or should I write something else in rely to the claim form? I have about 7 days left to reply until automatic judgement is taken and i'm pretty worried. Thanks once again