IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN: -

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

THE FIRST WITNESS STATEMENT OF WALTON WILKINS

I, Walton Wilkins, of Office 3, Block 4 Mint Drive, Hockley, Birmingham, B18 6EA, state as follows: -

1. I am a Sole Trader, employed by Walton Wilkins T/a Premier Parking Logistics (“my Company”). I
am duly authorised to make this Statement on my Company’s behalf.

2. I make this Statement in support of the Claimant’s Claim and in response to the Defence.

3. The facts and matters set out in this statement are within my own knowledge unless I state otherwise.
I believe them to be true. Where I refer to information supplied by others, the source is identified.
Facts and matters derived from other sources are true to the best of my knowledge and belief.

Parties

4. My Company provides private car park management services to private landowners, to manage the
way motorists are permitted to park on their private land. My Company does so by issuing parking
charge notices to any vehicle parked in a way the landowner does not permit.

5. The Defendant is the recipient of a parking charge notice (“PCN”) issued by my Company. The
details are set out herein.

6. At all material times, my Company was accredited by the Accredited Trade Association (“ATA”)
known as the International Parking Community (“IPC”). The IPC has a Code of Practice (“Code”)
that its members are expected to adhere to, or otherwise face potential sanctions. My Company
operates in accordance with the Code

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7. In order to obtain Registered Keeper details from the Driver and Vehicle Licensing Agency
(“DVLA”) my Company must be a member of an ATA. It is therefore essential for my Company to
comply with the Code.

Background

8. My Company issued a PCN (“Charge”) to the Vehicle (“Vehicle”) with details listed below:

TABLE 1

PCN No. Location (“Land”) VRN Issue Date Reason for Issue
300640 Gateley Road, Oldbury, B68 0NR SV63MHN 12/02/2018 No Permit

9. At the time of issue, my Company was instructed by the owner of the Land (“Landowner”) to
manage parking on the Land. A copy of my Company’s agreement with the Landowner
(“Landowner Agreement”) is exhibited to this Statement at “EXHIBIT 1”.

Contract

10. At the time of issue, my Company was prominently displaying signs on the Land setting out the
Terms of parking. A copy of the content of the signs is exhibited to this Statement at “EXHIBIT 2”.
The signs formed the basis of the Contract with the driver (“Contract”).

11. The following was a term of the Contract: -

“Parking is permitted for vehicles: displaying a valid permit within the windscreen with permit
clearly on view”.

12. In parking the Vehicle on the Land, the driver accepted the Contract, with the license to park being
the Consideration. It is evident from the photographic evidence exhibited to this Statement at
“EXHIBIT 3” that the Vehicle was parked on the Land.

13. The Contract provides that a charge is payable by the driver upon breach, with payment falling due
within 28 days.

14. A plan of the Land (“Plan”) showing the positioning of the signs is exhibited to this Statement at
“EXHIBIT 4”.

15. A copy of the Notice to Keeper is exhibited to this Witness Statement at “EXHIBIT 5”.

Defendant’s Liability

16. Pursuant to the Contract; the Driver was liable to pay the Charge within 28 days of issue.

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17. In order to issue, my Company requests the details of the Registered Keeper from the DVLA. Upon
receipt of those details, a Parking Charge Notice is sent to the Keeper via the post in accordance with
Section 9 of Schedule 4 of the Protection of Freedoms Act 2012 (“POFA”). Because the Driver
failed to respond or make payment, my Company issued a Notice to Keeper. Copies are exhibited at
“EXHIBIT 5”.

18. The Defendant admits being the Driver of the Vehicle. My Company has complied with POFA and
can pursue the Defendant as Keeper in the alternative.

Defence

19. The case is simple. The Vehicle was recorded on the Land without displaying a valid permit and was
therefore parked in breach of the Terms of parking on the Land which state, “parking is permitted
for vehicles: displaying a valid permit within the windscreen with permit clearly on view”. There can
be no reason, other than to frustrate the matter, why the Defendant has submitted an 18 paragraph
legally complex defence in response to that.

20. The Defendant was afforded a 21-day period in which they could appeal, and I am instructed they
did not. The potential next step was clearly communicated to the Defendant in notices. It is
respectfully submitted that if the Defendant genuinely believed the Charge had been issued
incorrectly, they would have engaged with the appeals process further.

21. If there was any doubt regarding their liability, the Defendant has had ample time to challenge the
Charge or request evidence in support. Despite correspondence being sent to the Defendant by a debt
collection agency and a Letter of Claim being issued in accordance with the Pre-Action Protocol for
Debt Claims, no challenges have previously been raised. A copy of the Letter of Claim is exhibited
at “EXHIBIT 6”.

22. The Defendant responded to the Letter of Claim and was given 30 days from the date of DCB
Legal’s response to pay the outstanding balance. Copies of the correspondence is exhibited at
“EXHIBIT 7”. The Defendant failed to address the matter despite having further time to do so.

23. The Defendant has filed a widely available templated Defence, rather than dealing with the
substantive issues. It is submitted the this is disingenuous and a waste of both the Court’s and my
Company’s time.

24. Notwithstanding the above, I respond to the issues raised in the Defence by way of sub-headings as
follows (as the defence is quite repetitive, I will only deal with each point once, but for the avoidance
of doubt nothing within the defence is accepted unless I specifically state otherwise): -

The Contract

i. The Defendant alleges that there is no contract between them and my Company. It is my
Company’s position that there is and the details of which are set out above. Parking Eye -v-
Beavis established that this form of contract is perfectly workable;

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Defendant’s Allegations

ii. The Defendant alleges they were unaware of the parking restrictions on the Land. It is not
unreasonable for my Company to expect the Defendant to exit their Vehicle to familiarise
themselves with the Terms of parking. The signs can be seen in close proximity to the
Vehicle in the image at “EXHIBIT 3”;

Signs / Unfair Contract Terms

iii. The Terms on the signs were adequate in respect of overall size, font size, plain English,
location and content. The Plan demonstrates where the signs were located and it is submitted
they are adequate to constitute notice of the Terms to the Driver. If the Defendant did not
understand the Terms on the signs, they should have exited the land and found alternative
parking;

iv. The signs clearly outlined the Terms of parking and the Defendant was on notice of the
Terms upon entering the Land. By parking on the Land, the Defendant accepted the Terms.
These Terms state that if breached, the Defendant agrees to pay within 28 days of issue;

v. In respect of the ‘rules’, as per Schedule 2 of the Consumer Right Act 2015, specifically
referred to: -

Rule 6 – It is submitted the sum is not disproportionate for the reasons set out within the
‘amount claimed’ section of this Statement, nor is it ‘compensation’.

Rule 10 – As is evident from the Plan, signs were displayed throughout the Land. The
Driver was aware of the fact that parking was managed from the point of entering the
Land and could leave if they did not agree to the Terms. It is not unreasonable for the
Driver to need to potentially walk no more than 10 meters to fully familiarise
themselves with the full Terms. This would have all happened before the conclusion of
the contract.

Rule 14 – The price is stated on the sign.

Rule 18 – The fact the Driver was able to park means my Company fulfilled its
obligations.

vi. The Terms clearly stated what would happen if payment was not made: -

“Non-payment will result in additional charges which will be added to the value of the
charge and for which the driver will be liable on an indemnity basis”.

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 With no concession made in this regard, if a Driver ever does not understand the Terms on
the signs, they can exit the land and find alternative parking. They are under no obligation to
park on the Land.

vii. The phrase ‘double recovery’ suggests the same amount is being recovered twice. This is not
what is claimed, as explained later in this Statement

CPR Compliance

viii. The Defendant questions whether the Particulars of Claim comply with the Civil Procedure
Rules. I submit that the Claim was issued via the County Court Business Centre and in this
regard, I refer to Practice Direction 7E (“the PD”) which specifically provides the guidelines
for doing so. I respectfully submit that the Particulars of Claim (“the Particulars”) are in
keeping with the PD. The following sections are of relevance: -

5.2(1) provides a limited character count for the Particulars of Claim; and

5.2A stipulates that the requirement in paragraph 7.3 of Practice Direction 16 for
documents to be attached to the particulars of contract claims does not apply to claims
started using an online claim form.

ix. It is my Company’s position that the Particulars were sufficient to allow the Defendant to
identify the subject matter of the Claim. The Defendant could not have submitted a Defence
with the detail it contains if the Particulars were so insufficient as to prevent them from
understanding the claim. Further, with respect, if the Defendant were of the genuine belief
that the Particulars of Claim were insufficient, the correct procedure would have been to
make an Application to the Court. The Defendant has chosen not to do so;

x. In addition to the above, I also refer to CPR 1 and respectfully remind the Defendant of their
obligation to deal with the case justly and at proportionate cost. Bearing in mind the claim
amount, my Company has taken proportionate steps to recover the debt;

Penalty / Amount Claimed

xi. In respect of the Defendant’s allegation that the claim is a penalty, my Company is not
seeking more than the original charge as the core debt. The core charge remains the same for
each PCN (i.e. £100); however, my Company is now also seeking further costs/damages;

xii. My Company is instructed to manage the Land, the Landowner agreement previously
referred to in this statement confirms this. My Company’s legitimate interest is to fulfil this
obligation. The Landowner’s legitimate interest in managing the Land is parking is permitted
for valid permit holders only. Because there is a clear legitimate interest/commercial
justification, the same as that established in ParkingEye -v- Beavis [2015], this case does not
fall foul of the penalty rules established in that case;

5
xiii. The amount charged is in line with the guidelines given by the ATA. Part E, Schedule 5 of
the COP states “Parking charges must not exceed £100 unless agreed in advance with the
IPC”. It is my Company’s position there is no requirement for the amount of the charge to
bear any relevance to the actual or potential cost of parking. The PCN is a fee charged by my
Company for providing the service and it stays within the guidelines given by the ATA. As
with many other ‘services’; the service provider is entitled to charge as they deem
appropriate;

xiv. The PCN was not paid within the prescribed 28 days or indeed at all. In view of this the sum
of £60 is also claimed as a contractual cost pursuant to the Contract which states “non-
payment will result in additional charges which will be added to the value of the charge and
for which the driver will be liable on an indemnity basis”. The Defendant was on notice of
the fact that the outstanding amount may increase as a result of any necessary debt recovery
action. In support I draw the Court’s attention to paragraph 45 of Chaplair Limited v Kumari
[2015] EWCA Civ 798 whereby, when considering contractual indemnity costs, it was stated:
-
“There is nothing … which enable[s] the rules to exclude or override that contractual
entitlement and I therefore agree with Arden LJ that the judge had the jurisdiction to
assess the costs free from any restraints imposed by CPR 27.14”;

xv. The sum added is a contribution to the actual costs incurred by my Company as a result of
the Defendant’s non-payment. My Company’s employees have spent time and material
attempting to recover the debt. This is not my Company’s usual business and the resources
could have been better spent in other areas of the business, generating profit. Had the
Defendant of paid as per the Contract, there would have been no need for recovery action so
the amount due would not have increased;

xvi. With respect of Parking Eye -v- Beavis [2015], whilst it is accepted the original charge is
designed to include the ‘operational costs’; this was with reference to maintaining the land,
taking payment or sending the relevant POFA compliant notices. It was never intended to
include the need to pursue the debt in Court to recover it. If that were the case, it would
override the Civil Procedure Rules (allowing fixed costs and recovery of court fees) which of
course is not the case. The Defendant has misunderstood the phrasing ‘operational costs’;

xvii. Within paragraph 16 of the Defence, the Defendant alleges my Company has failed to adhere
to the Landowner's definitions, exemptions, grace period, hours of operation and instructions
to cancel charges due to complaints. The Defendant is a third party to the Landowner
Agreement. Privity of contract applies;

Dismissal of Claim

xviii. The recent successful appeal in Britannia Parking Group Ltd v Semark-Jullien [2020] EW
Misc 12 (CC) (29 July 2020) found that the inclusion of the debt recovery charge in the
claim does not fall foul of the decision of Parking Eye Ltd v Beavis [2015] UKSC 67,

6
 because that was not the point in discussion in that case. The appeal also concluded that the
inclusion of such a charge in a claim of this type does not constitute an abuse of process that
would allow for the entire claim to be struck out.

25. In view of the above, it is my Company’s position that the Defendant breached the Contract as set
out in this Statement and as such the Defendant is liable.

Conclusion

CPR Costs

26. My Company claims the claim issue fee, fixed costs pursuant to CPR 45, and the hearing fee in any
event.

27. In the alternative to the contractual costs set out above, my Company reserves the right to claim
additional costs pursuant to CPR 27.14(2)(g). This claim was issued as a last resort, and given the
robust appeals procedure in place, should not have been necessary. It is my Company’s position that
this is unreasonable behaviour and it is respectfully requested that the Court considers whether they
conclude the same.

28. It is my respectful submission that the Defence is entirely without merit and as such it is requested
that the Defence is struck out and Judgment awarded in favour of my Company, payable forthwith.

29. I may not be able to attend the hearing. Should this be the case, I will instruct an advocate to attend
on my behalf and ask that the Court accepts this as my written notice given pursuant to CPR 27.9(1).
Should I be unable to attend, I request the Court decides the claim in my absence, taking into account
this Statement and any other evidence I may file. This paragraph demonstrates my compliance with
paragraphs (a) and (b) of CPR 27.9(1).

30. In the event an advocate does attend the hearing, I request their fee be added to the amount sought.

7
IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 1 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

9
 10

1
 11

2
 12

3
 13

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IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 2 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

14
 I

ffi ffiI
Premier Parking Logistics

PRIVATELAND
CONTROLLED PARKING ZON E 24HR OPERATION
THIS SITE IS MANAGED AND OPERATED BY PREMIER PARKING LOGISTICS
PARKING IS PERMITTED FOR VEHCLES:

DISPLAYING A VALID PERMIT WITHIN THE WINDSCREEN WITH

PERMIT CLEARLY ON VIEW.

DISABLED BAYS - BLUE BADGE HOLDERS ONLY -

Blue Badge MUST be on
Display in the windscreen. Blue badge holders must still purchase a valid
Permit.

,NO
PARKING'ZONES MUST BE ADHERD TO. NO PARKING ON YELLOW I
RED LINES OR IN AN AREA MARKED RESERVED. NO OBSTRUCTIVE OR
INCONVENIENT PARKING.

Breach of ANY term or condition will result in the driver being liable for a

PARKING CHARGE OI f 1OO

By entering or remaining on this land you agree to abide by all of the
Terms and Conditions

Parking charges are to be paid within 28 days. Additional parking charges apply for each 24 hour period, or part
thereof, that the vehicle remains in breach or if it returns at any time. Terms and conditions apply 24 hours a day, all
year round. Where a parking charge becomes due an application may be made to the DVLA for the keeper's details.
Non-payment will result in additional charges which will be added to the value of the charge and for which the driver
will be liable on an indemnity basis. Automatic Number Plate recognition may be in use. lmages may be captured and
retained for enforcement purposes. We are not liable for any loss or damage howsoever caused to any person or
property whilst on this site save under any statutory exceptions,

Managed by: Walton Wilkins Trading as [Premier Parking Logistics, 759 The Big Pegg, 120 Vyse Street, Birmingham,
Telephone [0121 235 1878].
B18 6NFl. Website: wvUyt,plgglg1pCfbllCleC1stiqs.lo.4

15

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IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 3 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

16
17
IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 4 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

18
 19

1
IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 5 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

20
 Parking Charge Notice
DO NOT IGNORE THIS NOTICE

Parking Charge Details

Reference Number: 300640
Vehicle Registration: SV63MHN
Jordan Ette Issued Date: 12th February 2018
2 Glendore Way
Incident Time/Date: 08:39 02/02/2018
Salford
M5 5EY
Amount Due:
Within 28 days £100.00

Dear Jordan Ette

We have issued Parking Charge Notice (PCN) 300640 to your vehicle because it
was parked in a manner whereby the driver became liable for a parking charge
at Gateley Road Oldbury B68 0NR that we are authorised to manage on the
2nd February 2018 at 08:39. The terms and conditions of parking on this
private land are clearly set out on the signage installed within the car park. By
parking within this car park the driver is bound to these terms and conditions and
liable to pay a charge if they breach these terms and conditions.

A discounted charge of £60.00 applies if this Parking Charge Notice is paid

within 14 days of issue. If you choose to not pay at this amount, the full value of
£100.00 will be due.

We have requested your details from DVLA as the registered keeper of the
vehicle (through the Reasonable Cause criteria of pursuing an outstanding
parking charge).The reason we issued the PCN to the vehicle is as follows: No
Permit

We, the Creditor, now request this amount is paid using one of the payment
methods described overleaf. If you were not the driver of the vehicle, you may
notify us (in writing using the form attached) of the name of the driver and a
current address for service for the driver and pass this Notice on to the driver.

You are advised that if, after the period of 28 days beginning with the day after
that on which this notice is given – the amount of the unpaid parking charge
specified in this notice has not been paid in full, and we do not know both the
name of the driver and a current address for service for the driver, under
Paragraph 9(2)(f) of Schedule 4 of the Protection of Freedoms Act 2012 we will
have the right to recover from the keeper so much of that parking charge amount
as remains unpaid. The case will then be passed to our Debt Recovery Agent
which may escalate to court proceedings to recover the amount owed.

Operating in accordance with the International

Parking Community’s Code of Practice

Payment Slip I enclose a cheque/postal order

Return with payment to: Premier Parking Logistics, Unit 713, The Big Peg, for the amount of:
120 Vyse Street, Birmingham, B18 6NF
£
Parking Charge Notice Number: 300640 made payable to:
Premier Parking Logistics
Vehicle Registration: SV63MHN
Do not send cash in the post.
Notice Issue Date: 12/02/2018 21
 How to Pay
You will need both the Parking Charge
Reference Number and Vehicle
Registration to hand when paying.
Online
www.PAYPPL.co.uk
Please follow online instructions.
By Phone
0844 304 0103
Credit and Debit card payments can
be made by calling our 24 hour
telephone line
By Post
Please complete the Payment Slip on
the front of this letter and enclose a
Cheque made payable to
“Premier Parking Logistics”
or Postal Order for the amount shown
and send to the following address:
Premier Parking Logistics,
Unit 713, The Big Peg,
120 Vyse Street,
Birmingham,
B18 6NF
Please write the reference number and
vehicle registration on the back of all
cheques and postal orders.
Do not send cash by post.
We will send you a receipt for your
payment if you request one.
Contact us
Email:
info@premierparkinglogistics.com
Phone: 0121 236 1878
Premier Parking Logistics
Unit 713, The Big Peg, 120 Vyse Street
Birmingham, B18 6NF
Useful Information
Following the landmark Supreme Court ruling of Parking Eye v Beavis, it has now been established that
a Parking Charge Notice issued on Private Land is enforceable. The Court rejected claims that such
charges are extravagant, exorbitant or unconscionable and advised that such charges act as a
necessary deterrent for breach of contract. If you feel you have sufficient grounds to appeal this notice,
full details of the appeals process can be found below.
Vehicle Hire Firms
If you are a vehicle-hire firm and the vehicle was hired out at the time the parking took place, please let
us know and provide us with a copy of the hire agreement and a copy of a statement of liability signed
by the hirer under that hire agreement.
Contesting this Parking Charge
Write to Premier Parking Logistics, Unit 713, The Big Peg, 120 Vyse Street, Birmingham, B18 6NF
In the event that you wish to dispute liability for this parking charge, within 21 days (beginning with the
day after that on which this notice is given) please provide your full name and address, vehicle
registration number and the parking reference at the top of this notice providing your full reasons.
Appeal decisions should be provided within 28 days. In the event that your appeal is unsuccessful then
we will provide you with the appropriate details enabling you to lodge an appeal to the Independent
Appeals Service (IAS). Details of the appeal procedure can be found at www.theIAS.org. The IAS
provides an Alternative Dispute Resolution scheme for disputes of this type. We will engage with the
IAS Standard Appeals Service providing you comply with our internal appeals procedure as detailed
herein and that thereafter you lodge an appeal to the IAS within 21 days of rejection. If you do appeal
and do not hear from us within 28 days then please contact us, do not assume that your appeal has
been successful. Please be advised that if you choose to appeal to the IAS and your appeal is
unsuccessful, you will lose the right to pay at the reduced amount.
Due to legal procedures, it is difficult for Premier Parking Logistics (PPL) to submit verbal evidence
before the court. We therefore regret that we are unable to deal with telephone enquiries with regard to
the issue of this PCN. All enquiries must be forwarded in writing. This charge has been lawfully issued
and the collection process will be carried out in accordance with The Administration of Justice Act 1970.
Complaints
Please note: If you wish to challenge the validity of this charge then you must use the Appeals
Procedure detailed above. Other issues can be dealt with under the complaints procedure.
If you wish to complain, you MUST complain to us directly in the first instance by writing to us at the
address at the top of this letter. If you are not satisfied with our response then you may refer your
complaint to the IPC. Further details can be found at www.theipc.info
Data Protection
PPL and its agents will process your information for the operation of their parking enforcement scheme.
Processing may include the use of cameras to record data. Your information may be disclosed to, or
requested from the DVLA. Records are made available to them thus ensuring the DVLA is satisfied that
all data is expedited in the manner agreed and to ensure security of storage and access so as to
comply with the Data Protection Act 1998. Data may be shared with third parties in relation to the issue
of a PCN in order to assist with appeals. PPL may also disclose data to a third party on the institution of
legal proceedings. If you believe your data has been used inappropriately, you should notify us
immediately and you can also notify the Information Commissioner and/or the DVLA by writing to the
relevant address shown below:
The Information Release of Information
Commissioner’s Office England/Wales/Scotland
Wycliffe House Paying Enquires Section
Wycliffe Lane, Wilmslow, DVLA
Cheshire, SK9 5AF Swansea, SA99 1AJ
www.ico.org.uk www.dvla.gov.uk
Walton Wilkins the proprietor trading as Premier Parking Logistics

PCN Reference: 300640 Vehicle Registration Number: SV63MHN

If you were not the driver of the vehicle stated when the vehicle was parked in the above manner, or you were the keeper of the vehicle
stated when the vehicle was parked in the above manner but it was in the possession of another person (either with or without your consent),
please provide any information that will lead to the true identification of the driver responsible by completing the following section and
returning it to: Premier Parking Logistics, Unit 713, The Big Peg, 120 Vyse Street, Birmingham, B18 6NF within 28 days of this notice.
Please mark the statement(s) below that apply to you. At the time the vehicle was parked in the above manner, I confirm that:
I was the keeper of the vehicle stated, but the vehicle was Leased / Hired to the person named below. X
I was the keeper of the vehicle stated, but the vehicle was in the possession of the person named below. X
To the best of my knowledge, the driver of the vehicle is the person named below. X
Name:

Address:

Post Code:

Your Name: Signed: Date: 22

 NOTICE TO KEEPER
DO NOT IGNORE THIS NOTICE

Date: 13th March 2018

Parking Charge Details

Reference Number: 300640
Jordan Ette Vehicle Registration: SV63MHN
Issued Date: 12th February 2018
2 Glendore Way
Issued Time: 23:23
Salford
M5 5EY Amount Due: £100.00
Payment options and instructions can be
found overleaf.

Dear Jordan Ette

Payment for the Parking Charge Notice 300640 is overdue.
Please pay the amount of £100.00 now.

We recently issued Parking Charge Notice (PCN) 300640 to your vehicle because on 2nd February 2018 at
08:39 it was parked in a manner whereby the driver became liable for a parking charge at Gateley Road,
Oldbury B68 0NR that we are authorised to manage by our client. This PCN was issued on the 12th
February 2018 and has not been paid. The reason we issued the PCN to the vehicle is as follows: No
Permit.

A Parking Charge Notice (Notice to Driver) was affixed to the windscreen of the vehicle at the Issued Time.
This charge relates to the period of parking that immediately preceded the issue of that Notice, the charge
having been incurred for the reason as stated above and liability for the same having been brought to the
attention of the driver by clear signage in and around the site at the time of parking. We have requested
your details from DVLA as the registered keeper of the vehicle (through the Reasonable Cause criteria of
pursuing an outstanding parking charge).

We, the Creditor, now request this amount is paid using one of the payment methods described overleaf. If
you were not the driver of the vehicle, you should notify us (in writing using the form attached) of the name
of the driver and a current address for service for the driver and pass this notice on to the driver.

You are advised that if, after the period of 28 days beginning with the day after that on which this notice is
given – the amount of the unpaid parking charge specified in this notice has not been paid in full, and we do
not know both the name of the driver and a current address for service for the driver, under Paragraph
9(2)(f) of Schedule 4 of the Protection of Freedoms Act 2012 we will have the right to recover from the
keeper so much of that parking charge amount as remains unpaid. The case will then be passed to our Debt
Recovery Agent which may escalate to court proceedings to recover the amount owed. The overdue charge
will increase to £160.00 in the first instance of further action.
Operating in accordance with the International
Parking Community’s Code of Practice.

Payment Slip I enclose a cheque/postal

Return with payment to: Premier Parking Logistics, Unit 713, The Big Peg,
order for the amount of :
120 Vyse Street, Birmingham, B18 6NF
£
Parking Charge Notice Number: 300640
made payable to:
Premier Parking Logistics
Vehicle Registration: SV63MHN
Do not send cash in the post.
Notice Issue Date: 12/02/2018 23
 How to Pay
You will need both the Parking Charge
Reference Number and Vehicle
Registration to hand when paying.
Online
www.PAYPPL.co.uk
Please follow online instructions.
By Phone
0844 304 0103
Credit and Debit card payments can
be made by calling our 24 hour
telephone line
By Post
Please complete the Payment Slip on
the front of this letter and enclose a
Cheque made payable to
“Premier Parking Logistics”
or Postal Order for the amount shown
and send to the following address:
Premier Parking Logistics,
Unit 713, The Big Peg,
120 Vyse Street,
Birmingham,
B18 6NF
Please write the reference number and
vehicle registration on the back of all
cheques and postal orders.
Do not send cash by post.
We will send you a receipt for your
payment if you request one.
Useful Information
Following the landmark Supreme Court ruling of Parking Eye v Beavis, it has now been established that
a Parking Charge Notice issued on Private Land is enforceable. The Court rejected claims that such
charges are extravagant, exorbitant or unconscionable and advised that such charges act as a
necessary deterrent for breach of contract. If you feel you have sufficient grounds to appeal this notice,
full details of the appeals process can be found below.
Vehicle Hire Firms
If you are a vehicle-hire firm and the vehicle was hired out at the time the parking took place, please let
us know and provide us with a copy of the hire agreement and a copy of a statement of liability signed
by the hirer under that hire agreement.
Contesting this Parking Charge
At the time the charge was incurred, the driver was offered the opportunity to appeal within 21 days
from its imposition. This opportunity has now lapsed and we regret the ability to appeal against this
charge is no longer available. If you consider there to be exceptional circumstances as to why you
should be allowed to appeal outside of this period please
write to: Premier Parking Logistics, Unit 713, The Big Peg, 120 Vyse Street, Birmingham, B18 6NF
All correspondence must include your name, serviceable postal address, the vehicle registration and
notice reference number, together with any evidence which may support your position. If we reject the
appeal, you will be provided with the contact details of the Independent Appeals Service. Please be
advised that if you choose to appeal to the Independent Appeals Service and your appeal is
unsuccessful, you will lose the right to pay at the reduced amount.
Due to legal procedures, it is difficult for Premier Parking Logistics (PPL) to submit verbal evidence
before the court. We therefore regret that we are unable to deal with telephone enquiries with regard to
the issue of this PCN. All enquiries must be forwarded in writing.
This charge has been lawfully issued and the collection process will be carried out in accordance with
The Administration of Justice Act 1970.
Complaints
Please note: If you wish to challenge the validity of this charge then you must use the Appeals
Procedure detailed above. Other issues can be dealt with under the complaints procedure.
If you wish to complain, you MUST complain to us directly in the first instance by writing to us at the
address at the top of this letter. If you are not satisfied with our response then you may refer your
complaint to the IPC. Further details can be found at www.theipc.info
Data Protection
PPL and its agents will process your information for the operation of their parking enforcement scheme.
Processing may include the use of cameras to record data. Your information may be disclosed to, or
requested from the DVLA. Records are made available to them thus ensuring the DVLA is satisfied that
all data is expedited in the manner agreed and to ensure security of storage and access so as to
comply with the Data Protection Act 1998. Data may be shared with third parties in relation to the issue
of a PCN in order to assist with appeals. PPL may also disclose data to a third party on the institution of
legal proceedings. If you believe your data has been used inappropriately, you should notify us
immediately and you can also notify the Information Commissioner and/or the DVLA by writing to the
relevant address shown below:

Contact us The Information Release of Information

Email: Commissioner’s Office England/Wales/Scotland
info@premierparkinglogistics.com Wycliffe House Paying Enquires Section
Wycliffe Lane, Wilmslow, DVLA
Phone: 0121 236 1878 Cheshire, SK9 5AF Swansea, SA99 1AJ
Premier Parking Logistics www.ico.org.uk www.dvla.gov.uk
Unit 713, The Big Peg, 120 Vyse Street
Birmingham, B18 6NF Walton Wilkins the proprietor trading as Premier Parking Logistics

PCN Reference: 300640 Vehicle Registration Number: SV63MHN

If you were not the driver of the vehicle stated when the vehicle was parked in the above manner, or you were the keeper of the vehicle
stated when the vehicle was parked in the above manner but it was in the possession of another person (either with or without your consent),
please provide any information that will lead to the true identification of the driver responsible by completing the following section and
returning it to: Premier Parking Logistics, Unit 713, The Big Peg, 120 Vyse Street, Birmingham, B18 6NF within 28 days of this notice.
Please mark the statement(s) below that apply to you. At the time the vehicle was parked in the above manner, I confirm that:
I was the keeper of the vehicle stated, but the vehicle was Leased / Hired to the person named below. X
I was the keeper of the vehicle stated, but the vehicle was in the possession of the person named below. X
To the best of my knowledge, the driver of the vehicle is the person named below. X
Name:

Address:

Post Code:

Your Name: Signed: Date: 24

IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 6 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

25
 Direct House, Greenwood
Drive, Manor Park, Runcorn,
Cheshire, WA7 1UG

E: info@dcblegal.co.uk
T: 
DX: 23457 Runcorn

DCB002/LBA-606/005860/56

Jordan Ette
79 NEW COPPER MOSS
ALTRINCHAM
CHESHIRE
WA15 8EG

Our Ref: 101789.1405D

12 October 2020

LETTER OF CLAIM

RE: OUR CLIENT: Walton Wilkins T/a Premier Parking Logistics

PCN REFERENCE: 300640
AMOUNT DUE: £160

We act on behalf of Walton Wilkins T/a Premier Parking Logistics and write in respect of an unpaid
parking charge(s). This is a formal Letter of Claim in accordance with the Pre-Action Protocol for Debt
Claims.

BASIS OF CLAIM
We act on behalf of nothing being populated and write in respect of an unpaid parking charge(s).
The vehicle with registration number SV63MHN ("the Vehicle") was parked on private land ("the Land")
This isora managed
owned formal Letter of Claim
by our Client.inThe
accordance with the
signs displayed onPre-Action
the Land setProtocol
out thefor Debtand
Terms Claims.
Conditions of
parking (i.e. "the Contract"). The Vehicle was parked on the Land in breach of the Contract and as such a
BASISCharge
Parking OF CLAIM Notice(s) ("PCN") was issued. It is our Client's position that you are liable as the Keeper or
Driver. The details of the PCN(s) can be found in the PCN schedule.
The vehicle with registration number nothing populated (“the Vehicle”) was parked on private land
Pursuant to the Contract, payment of the PCN(s) was due within 28 days of issue, yet it currently remains
(“the Land”) owned or managed by our Client. The signs displayed on the Land set out the Terms
outstanding.
and Conditions of parking (i.e. “the Contract”). The Vehicle was parked on the Land in breach of the
ContractOF
AMOUNT and as such a Parking Charge Notice(s) (“PCN”) was issued. It is our Client’s position that
CLAIM
you are liable as the Keeper or Driver. The details of the PCN(s) can be found in the PCN schedule.
The sum claimed is a total of £160; which includes the parking charge(s) and costs (per charge).
Pursuant to the Contract, payment of the PCN(s) was due within 28 days of issue, yet it currently
Should it become necessary to issue a claim; further costs will be sought, together with accrued interest
at remains
the rate outstanding.
of 8% per annum under Section 69 of The County Courts Act 1984.

ToAMOUNT
ensure noOF CLAIMaction will take place please make immediate payment by calling 0203 434 0424
further
using reference number 101789.1405D.
The sum claimed is a total of £583.06; which includes the parking charge(s) and £60 remove this –
some are £70! costs (per charge).

Should it become necessary to issue a claim; further costs will be sought, together with accrued
interest at the rate of 8% per annum under Section 69 of The County Courts Act 1984.

To ensure no further action will take place please make immediate payment via our 24-
hour payment line on 01302 897 022 using reference number CPP2045777CPP1.

DCB Legal Ltd is a limited company registered in England and Wales with number 10633864 and is authorised and regulated by the Solicitors
Regulation Authority under SRA registration number 638321. ICO Reg: ZA279934. V.A.T Reg. No: 281 2789 78
26
 Direct House, Greenwood
Drive, Manor Park, Runcorn,
Cheshire, WA7 1UG

E: info@dcblegal.co.uk
T: 
DX: 23457 Runcorn

NEXT STEPS

We expect you to pay the debt in full within 30 days of the date of this letter; or alternatively
acknowledge this letter within the same timeframe. Failure to do so will result in a claim being issued
against you without further notice. Should you wish to discuss the matter; please contact us on 0203 434
0424 quoting the reference number at the top of this letter.

Your attention is drawn to the Civil Procedure Rules 1998 and in particular the Court's power to impose
sanctions if you fail to comply with the above. If you ignore this letter or fail to complete the Reply Form
within 30 days, Court proceedings will be issued against you and this letter will be brought to the
attention of the Court when considering costs. Your non-compliance with the Rules may increase your
liability for costs.

We enclose an Information Sheet. You can visit our website at www.dcblegal.co.uk/response to

complete the Reply Form and Financial Statement. Alternatively, to request a paper copy of the Reply
Form and Financial Statement, complete the slip at the bottom of this letter and return it via post to the
address in the header of this letter.

ALTERNATIVE DISPUTE RESOLUTION

Our client is prepared to consider mediation, or another form of dispute resolution, prior to issuing Court
proceedings. Should you wish to engage; please provide your proposed steps for doing so within the
30-day deadline.

We strongly suggest you deal with this matter urgently to avoid a claim being issued against you. If you
do not understand the content of this letter you may wish to seek independent advice from a Solicitor or
We free
other act on behalfadvice
money of nothing being populated
organisation, andCitizens
such as the write inAdvice
respect of an unpaid parking charge(s).
Bureau.
This is a formal Letter of Claim in accordance with the Pre-Action Protocol for Debt Claims.
Yours faithfully,
BASIS OF CLAIM

DCBTheLegal
vehicle with registration number nothing populated (“the Vehicle”) was parked on private land
(“the Land”) owned or managed by our Client. The signs displayed on the Land set out the Terms
and Conditions of parking (i.e. “the Contract”). The Vehicle was parked on the Land in breach of the
-------------------------------------------------------------------------------------------------------------------------------------------
Contract and as such a Parking Charge Notice(s) (“PCN”) was issued. It is our Client’s position that
you are
NAME: liableEtte
Jordan as the Keeper or Driver. The details of the PCN(s) can be found in the PCN schedule.

Pursuant to the Contract, payment of the PCN(s) was due within 28 days of issue, yet it currently
REFERENCE:101789.1405D
remains outstanding.
I request that a copy of the Reply Form and Financial Statement is sent to the following address:
AMOUNT OF CLAIM
.........................................................................................................................................................................
The sum claimed is a total of £583.06; which includes the parking charge(s) and £60 remove this –
some are £70! costs (per charge).
.........................................................................................................................................................................
Should it become necessary to issue a claim; further costs will be sought, together with accrued
interest
SIGNED at the rate of 8% per annum under Section 69 of TheDATE
....................................................................................... County Courts Act 1984.
..........................................................

To ensure no further action will take place please make immediate payment via our 24-
hour payment line on 01302 897 022 using reference number CPP2045777CPP1.

DCB Legal Ltd is a limited company registered in England and Wales with number 10633864 and is authorised and regulated by the Solicitors
Regulation Authority under SRA registration number 638321. ICO Reg: ZA279934. V.A.T Reg. No: 281 2789 78
27
 Direct House, Greenwood
Drive, Manor Park, Runcorn,
Cheshire, WA7 1UG

E: info@dcblegal.co.uk
T: 
DX: 23457 Runcorn

INFORMATION SHEET

You have received this notice because a business intends to take you to court in relation to a debt. This
notice tells you what to do next, including how to avoid court action. Please read it carefully.

What should I do now to make sure I am not taken to court unnecessarily?

Read the enclosed letter from the business very carefully. Think about whether you owe the debt and
whether the amount is correct. The letter should provide information about how much money you
owe and any interest and fees added to the debt. If it doesn’t, ask the business for more information.

Once you have read the letter, consider the following options.

Seeking debt advice.

If you are in financial difficulty or need advice to help you work out whether you owe the debt, or how
you might pay the debt, contact a debt advisor (particularly if you haven’t been in contact with the
business for a number of years).

The following organisations offer free, impartial and non-judgemental advice:

Citizens Advice 03444 111 444 (England) www.citizensadvice.org.uk

03444 772 020 (Wales)
Civil Legal Advice 0345 345 4345 www.gov.uk/civil-legal-advice

StepChange Debt Charity 0800 138 1111 (Freephone) www.stepchange.org

National Debtline 0808 808 4000 (Freephone) www.nationaldebtline.org

We act on behalf of nothing being populated and write in respect of an unpaid parking charge(s).
AdviceUK 0300 777 0107 www.adviceuk.org.uk
This is a formal Letter of Claim in accordance with the Pre-Action Protocol for Debt Claims.
Christians Against Poverty 0800 328 0006 (Freephone) www.capuk.org
BASIS OF CLAIM

The
It vehicle with registration
is recommended number
that you get debt nothing
advice ifpopulated (“thedoubt
you have any Vehicle”)
aboutwas parkedyou
whether on private
owe the land
debt
or
(“thewhether
Land”)you can or
owned paymanaged
it now. by our Client. The signs displayed on the Land set out the Terms
Ifand
youConditions
don’t haveofaparking
copy of(i.e.
the “the
agreement (contract)
Contract”). between
The Vehicle wasyou and the
parked business
on the and
Land in you need
breach of thethis
to decide what to do next or to help you get debt advice, you can ask the business to provide you
Contract
with and as such a Parking Charge Notice(s) (“PCN”) was issued. It is our Client’s position that
a copy.
you are liable as the Keeper or Driver. The details of the PCN(s) can be found in the PCN schedule.
Speaking to the business.
IfPursuant
you agree you Contract,
to the owe the debt and want
payment of thetoPCN(s)
talk towas
the due
business
withinabout payment
28 days terms,
of issue, yet itorcurrently
if you have
any questions or
remains outstanding. concerns, get in touch with the business as soon as possible. Their contact details
should be in the letter they sent you.
AMOUNT
Filling OFReply
in the CLAIMForm.
If you have not been able to resolve the matter by speaking to the business, you should fill in the Reply
Form
The sumthatclaimed
was provided withofthe
is a total letter from
£583.06; the
which business,
includes theand then charge(s)
parking send it back
andto£60
theremove
business. You
this –
should complete the Reply Form with as much information as possible to avoid court action being
some are £70! costs
taken against you. (per charge).

Should it become necessary to issue a claim; further costs will be sought, together with accrued
interest at the rate of 8% per annum under Section 69 of The County Courts Act 1984.

To ensure no further action will take place please make immediate payment via our 24-
hour payment line on 01302 897 022 using reference number CPP2045777CPP1.

DCB Legal Ltd is a limited company registered in England and Wales with number 10633864 and is authorised and regulated by the Solicitors
Regulation Authority under SRA registration number 638321. ICO Reg: ZA279934. V.A.T Reg. No: 281 2789 78
28
 Direct House, Greenwood
Drive, Manor Park, Runcorn,
Cheshire, WA7 1UG

E: info@dcblegal.co.uk
T: 
DX: 23457 Runcorn

How long do I have to fill in the Reply Form?

You only have 30 days from the date at the top of the letter from the business to send back the Reply
Form. If the business does not get your Reply Form within 30 days, it could take you to court in relation
to the debt. Make sure you allow time for posting.

If a court orders you to pay an amount of money (called "having judgment entered against you"),
details of the judgment will usually be entered on the Register of Judgments, Orders and Fines. Most
entries stay on the Register for six years unless you pay the amount you owe within one month of the
judgment.

Organisations such as banks, building societies and credit companies use the information on the
Register when someone applies for credit, such as a loan or overdraft. It helps them decide whether or
not that person would be able to pay off a debt.

What happens if I fill in and return the Reply Form in time?

If you return the Reply Form within 30 days, you and the business will have at least a further 30 days
to discuss the debt, or for you to seek debt advice, before the business takes you to court. During that
time you should discuss with the business how you can resolve the matter, ideally without going to
court.

If you request more information in the Reply Form, the business must wait at least 30 days after it
gives you that information before taking you to court.

Where can I find out more?

This Information Sheet is a summary of your rights and responsibilities under the Pre-Action Protocol
for Debt Claims. Where a business and an individual disagree about a debt claim, the Protocol tells
them what they should do before they go to court. If you want to know more, the full Protocol is
We act onat:behalf
available of nothing being populated and write in respect of an unpaid parking charge(s).
https://www.justice.gov.uk/courts/procedure-rules/civil/protocol.
This is a formal Letter of Claim in accordance with the Pre-Action Protocol for Debt Claims.
PCN Schedule
BASIS OF CLAIM
ISSUE DATE(S) LOCATION(S) REASON(S)
The vehicle with registration
12/02/2018 number
Gateley Rd nothing populated
- Gateley No Permit(“the Vehicle”) was parked on private land
(“the Land”) owned or managed by our Client. The signs displayed on the Land set out the Terms
and Conditions of parking (i.e. “the Contract”). The Vehicle was parked on the Land in breach of the
Contract and as such a Parking Charge Notice(s) (“PCN”) was issued. It is our Client’s position that
you are liable as the Keeper or Driver. The details of the PCN(s) can be found in the PCN schedule.

Pursuant to the Contract, payment of the PCN(s) was due within 28 days of issue, yet it currently
remains outstanding.

AMOUNT OF CLAIM

The sum claimed is a total of £583.06; which includes the parking charge(s) and £60 remove this –
some are £70! costs (per charge).

Should it become necessary to issue a claim; further costs will be sought, together with accrued
interest at the rate of 8% per annum under Section 69 of The County Courts Act 1984.

To ensure no further action will take place please make immediate payment via our 24-
hour payment line on 01302 897 022 using reference number CPP2045777CPP1.

DCB Legal Ltd is a limited company registered in England and Wales with number 10633864 and is authorised and regulated by the Solicitors
Regulation Authority under SRA registration number 638321. ICO Reg: ZA279934. V.A.T Reg. No: 281 2789 78
29
IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

Exhibit “EXHIBIT 7 to the

1st Witness Statement of
Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

30
Ref number - 101789.1405D
jordanantonyette@gmail.com
Sent: 13/11/2020 11:24
To: info@dcblegal.co.uk

To whom it may concern,

I have recently received a Letter of Claim from your company. It states the document was
sent to me on October 12th 2020 yet I didn't receive it until the beginning of this week (9th
November 2020).

The letter relates to a £160 parking fine I have supposedly received.

As I am unaware of any type of fine in my name, I am requesting proof of this claim with
proof of all charges.

Upon researching, it appears that £60 of this supposed fine is "not recoverable" and is
considered Abuse Of Process under the protection of freedoms act 2012. Because of this, I
would also like to request that you can provide me with documentation and proof that you
have the authority to circumvent the law (POFA2012) and the courts own double recovery
rules.

Thank you very much.

Kind regards,

Jordan Ette
jordanantonyette@gmail.com

PCN REFERENCE - 300640

79 New Copper Moss

Altrincham
Cheshire
WA15 8EG

31
DCB Legal Ltd - Ref: 101789.1405D
locreplies@dcblegal.co.uk
Sent: 25/11/2020 14:11
To: jordanantonyette@gmail.com
Attachments: image001.png;PCN - Ette.pdf;NTK - Ette.pdf;image002.png

Dear Jordan Ette,

We write in response to your email dated 13th November 2020.

DCB Legal Ltd note you have stated you are unaware of the Parking Charge Notice (PCN)
outlined in our Letter of Claim and have requested further evidence to support this claim.

Please note the Parking Charge Notice was issued to you on 12th February 2018 . A copy is
enclosed. 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.

The Notice to Keeper was also issued to you on 13th March 2018. A copy is enclosed.
You were again afforded the opportunity to make payment at this point. As payment
remained outstanding DCB Legal Ltd have now been instructed to recover the
outstanding balance.

We also note you have stated the £60.00 added to the original balance is not recoverable
and considered an “abuse of process” under POFA 2012.

Please note In accordance with the recent appeal decision made on 29th July 2020 in
Britannia Parking Group Ltd v Semark-Julien [2020] EW Mis 12 (CC) the Judge held that the
debt recovery charge does not fall foul of the decision of Parking Eye Ltd v Beavis [2015]
UKSC 67; thus, we submit that this is not an abuse of process as alleged. We suggest you
seek independent legal advice if you are unable to access relevant and up to date appeal
information and legislation.

You now have 30 days from the date of this letter to pay the outstanding balance of £160.00.
Failure to do so will result in a claim being issued against you without further notice.
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 101789.1405D 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 make payment over
the telephone.

Kind Regards,

32
Jonathan Worthington
DCB Legal Limited

Tel. 0203 434 0424

DX 23457 Runcorn
Fax 01606 783 702

33
DCB Legal Ltd - Ref: 101789.1405D
jordanantonyette@gmail.com
Sent: 04/12/2020 14:30
To: info@dcblegal.co.uk

79 New Copper Moss

Hale
Altrincham
WA15 8EG

04/12/2020

To whom it may concern,

I am writing to inform you that I am seeking debt advice regarding the PCN Reference
300640 and as a response to the email I received with the Reference 101789.1405D.

I deny any debt and the case must be put 'on hold' for no less than 30 days under the PAP for
debt claims 2017.

As well as seeking debt advice, I have also sent your client Premier Parking Logistics a SAR.

Thank you.

Jordan Ette
jordanantonyette@gmail.com
--

34
RE: 101789.1405D
locreplies@dcblegal.co.uk
Sent: 10/12/2020 11:17
To: jordanantonyette@gmail.com
Attachments: image001.png;image003.png

Dear Mr Ette,

We write further to your email received in our office on 4th December 2020.

The Letter of Claim provided you with 30 days to make payment, seek independent legal
advice or respond to the Letter of Claim. The 30 days led to 11th November 2020, however
we received your email response to the Letter of Claim on 13th November 2020 which was
out of time.

We still responded to your email on 25th November 2020 and provided another 30 days from
this date to make payment of the full outstanding balance of £160.00. For the purpose of
clarity, this leads to 24th December 2020. We will not be offering any further hold for this
matter as it has now been 59 days since the original Letter of Claim was issued.

Failure to make the payment in full by the specified date may result in legal proceedings
being issued against you, as per the Letter of Claim.

Kind regards,

Kirsty Unsworth
DCB Legal Limited

Tel. 0203 434 0424

DX 23457 Runcorn
Fax 01606 783 702

35
IN THE COUNTY COURT AT MANCHESTER CLAIM NUMBER: H0KF6760

BETWEEN

WALTON WILKINS T/A PREMIER PARKING LOGISTICS

CLAIMANT

-V -

JORDAN ETTE
DEFENDANT

1st Witness Statement of

Walton Wilkins

DCB Legal Limited

Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

Ref: 101789.1405D

Solicitors for the Claimant

36