Quote:FAO: ParkingEye Legal/Litigation Department

Claimant: ParkingEye Ltd  
Defendant: [Full name] 
ParkingEye Reference: 388857/564384 
County Court Claim Number: To be confirmed 
Vehicle Registration: [VRM] 
Parking Location: Crowne Plaza, Stratford-upon-Avon 
Parking Event: 20 August 2025 
Default Judgment: 4 August 2026 – £237

Dear Sir/Madam,

FORMAL REQUEST FOR CONSENT TO SET ASIDE DEFAULT JUDGMENT – CPR 13.2

I write regarding the above matter, following my recent discovery that ParkingEye Ltd obtained a default County Court Judgment against me on 4 August 2026.

I first became aware of these proceedings in October 2026, upon receiving correspondence from Direct Collection Bailiffs Ltd (DCBL) demanding payment of £307 in respect of an unpaid CCJ.

Until that correspondence arrived, I had no knowledge that proceedings had been issued, let alone that judgment had been entered against me.

1. Defective service of proceedings

I ceased residing at 19 Crisp Road, London W6 9RL in April 2026.

ParkingEye subsequently issued proceedings on 6 July 2026, approximately three months after I had vacated that address. The Civil National Business Centre (CNBC) has confirmed that the claim form was sent to my former address.

Consequently, I did not receive the Letter of Claim, the N1SDT Claim Form or any subsequent court correspondence. I was therefore deprived of the opportunity to acknowledge service, submit a defence or otherwise participate in the proceedings.

CPR 6.9(3) requires a claimant who has reason to believe that a defendant no longer resides at an address to take reasonable steps to ascertain their current address before serving proceedings. Please confirm what reasonable address-verification enquiries ParkingEye undertook before issuing the claim on 6 July 2026, and provide copies of any relevant records.

2. Mandatory set-aside under CPR 13.2

Where a claim form has not been validly served and the conditions for obtaining default judgment have not been satisfied, CPR 13.2 requires the court to set aside the judgment. I contend that the judgment was improperly obtained following service at an address where I no longer resided, and I intend to seek a mandatory set-aside under CPR 13.2.

If necessary, I will also rely upon CPR 13.3 in the alternative.

3. Formal request for set-aside by consent at ParkingEye's expense

Before incurring the expense of a contested application, I am providing ParkingEye with an opportunity to resolve this matter by consent, subject to the following express conditions:

1. ParkingEye must agree to the default judgment dated 4 August 2026 being set aside in its entirety, without requiring any payment or admission of liability from me.

2. ParkingEye must bear the full £126 court application fee, together with any costs associated with preparing and submitting the consent order. I will not contribute towards those costs.

3. Any proposed consent order MUST be provided to me in draft for examination and approval before submission to the court. The entire wording of the order, including every provision concerning costs, the underlying claim and any consequential directions, must be expressly agreed by me in writing beforehand.

4. ParkingEye must NOT file, submit or otherwise seek approval of any proposed consent order without first obtaining my express written agreement to its complete terms. My willingness to consider a set-aside by consent does not constitute advance consent to any draft order prepared by ParkingEye.

5. The consent order must not contain any provision prejudicing my legal position, including any admission of liability, obligation to pay the underlying parking charge, contribution towards ParkingEye's costs, waiver of my rights or restriction upon my ability to defend the original claim should proceedings continue. Any proposed directions concerning the future conduct or disposal of the claim must also be expressly agreed in writing.

6. ParkingEye must immediately instruct DCBL to suspend all debt collection and enforcement activity and confirm in writing that no further enforcement action will be undertaken pending resolution of the set-aside application.

7. ParkingEye must cooperate promptly in obtaining the court order setting aside the judgment and ensure that the court is requested to notify the Register of Judgments accordingly.

For the avoidance of doubt, I will not accept any consent order containing undisclosed, unilateral or subsequently introduced conditions. Any material amendment to an agreed draft must be referred back to me for further written approval before submission.

If ParkingEye is unwilling to agree to these conditions, I will proceed with a contested application under CPR 13.2, seeking an order for reimbursement of the application fee and any other recoverable costs.

My proposal is intended to avoid unnecessary contested proceedings. It must not be construed as an admission of liability or an agreement to compromise my defence to the underlying claim.

4. Costs consequences of refusing consent

The present court fee for an application by consent is £126, compared with £321 for a contested application on notice.

Should ParkingEye refuse this reasonable opportunity to resolve the matter, or fail to respond within the deadline specified below, I intend to proceed with a contested application using Form N244. In that event, I will ask the court to order ParkingEye to reimburse the application fee and any further recoverable costs, drawing the court's attention to this attempt to resolve matters without contested proceedings.

ParkingEye should carefully consider whether opposing an application arising from the circumstances of service described above is a proportionate or reasonable use of court resources.

5. Deadline for response

Given that an outstanding CCJ is already registered against me, this matter is urgent.

I require your written confirmation of agreement within seven working days of receipt of this email. If satisfactory confirmation is not received within that period, I reserve the right to proceed with the N244 application without further notice. I also reserve the right to apply sooner if enforcement activity makes that necessary.

Please also provide the actual County Court claim number and confirm that my current address, as supplied separately to your Data Protection Officer, is recorded as my sole address for service.

I trust ParkingEye will recognise that resolving this matter by consent, at its own expense, is preferable to incurring the additional costs of a contested application.

Yours faithfully,

[Defendant's full name] 
[Current postal address] 
[Email address]

Quote:Dear Data Protection Officer,

Re: ParkingEye Reference 388857/564384

I am writing to exercise my rights under Articles 16 and 17 of the UK GDPR.

My previous address was:

[indent]19 Crisp Road 
London W6 9RL
I vacated this address in April 2026. My current and sole address for service and all correspondence is:

[INSERT FULL CURRENT ADDRESS]

I require ParkingEye to:

1. Immediately update all records to reflect my current address, including those held by your litigation and debt recovery departments.
2. Erase my former address from all active correspondence and service records, retaining it only where strictly necessary to comply with a legal obligation or establish, exercise or defend legal claims.
3. Notify all third parties to whom my former address has been disclosed, including DCBL and any legal representatives, of this rectification in accordance with Article 19 UK GDPR.
4. Confirm that all future correspondence, including legal proceedings, will be sent exclusively to my current address and that my former address will not be used for service.

Please confirm in writing that these instructions have been implemented.

Yours faithfully,

[Full name] 
[Current address] 
[Vehicle registration]