Quote:Claim No: [second claim number]
Related Claim No: [first claim number]
Parties: [Claimant] v [Defendant]

Dear Sir or Madam,

Please find enclosed the Defendant’s completed Directions Questionnaire in respect of the above claim.

The Defendant also respectfully draws the Court’s attention to the fact that this is a second claim issued by the same Claimant against the same Defendant concerning the same vehicle and the same location, namely Aspire Leisure Centre, Stanmore, whilst a previous claim is already live under claim number [first claim number].

The Defendant’s position is that this later claim is duplicative and abusive. It appears that the Claimant, a serial bulk litigant acting by solicitors who issue parking claims in bulk, has chosen to split matters across multiple separate claims rather than bring them together, if at all. That approach places the Defendant under unnecessary additional burden and is contrary to the proper and efficient conduct of litigation.

The Defendant respectfully asks that this letter be placed on the court file and that the Court note the existence of the earlier live claim when considering directions and allocation in this second matter.

Yours faithfully,

[Defendant’s name]
[Defendant’s address]
[Defendant’s email]

Quote:Subject: URGENT – Claim No. [NUMBER] – ParkingEye Ltd v [DEFENDANT] – Apparent Error in Notice of Allocation/Request for Urgent Judicial Review of Directions

Dear Sir/Madam,

I am the Defendant in the above proceedings, listed for hearing at Dartford County Court on 4 September 2026.

I write to draw the Court's urgent attention to what appears to be an obvious error in the Notice of Allocation dated 12 March 2026.

Paragraph 8 of the Order directs the parties to provide documents including:

• repair estimates and invoices;
  
• car-hire invoices;
  
• a police accident report;
  
• plans of the accident scene; and
  
• photographs of accident damage.
  

This is not a road traffic accident claim. It is a contractual private parking claim brought by ParkingEye Ltd.

I therefore respectfully request that the Notice of Allocation and the court file be placed urgently before a District Judge so that the apparent error may be considered and the appropriate directions clarified or corrected.

This is particularly important because there is an unresolved preliminary issue expressly raised in my Defence.

The Claimant's Particulars merely allege that the vehicle:

   "Remained On Private Property In Breach Of The Prominently Displayed Terms And Conditions."

They do not identify the contractual term allegedly breached or adequately plead what conduct constituted the alleged breach. My Defence expressly pleaded that the Particulars fail to comply with CPR 16.4(1)(a) and invited the Court to strike out the claim. No further or more detailed Particulars have subsequently been served.

I am now required by the same Order to prepare and serve a witness statement and evidence despite still not knowing with sufficient particularity the contractual and factual case which the Claimant says I must answer.

Given the apparently erroneous directions contained in the Order, I respectfully ask that, when reviewing the Order, the Judge also consider the preliminary pleading issue already raised in my Defence and whether it is appropriate for the Defendant to be required to serve her witness evidence before that issue has been resolved.

I respectfully invite the Court, if appropriate, to exercise its own-initiative case-management powers either:

1. to strike out the claim for the pleading failures already identified in the Defence; or alternatively
   
2. to require the Claimant first to serve compliant Particulars identifying the contractual term relied upon and the factual basis of the alleged breach, with consequential directions allowing the Defendant a proper opportunity thereafter to respond.
   

I am not seeking to disregard or unilaterally vary the existing Order and understand that its present deadlines remain effective unless the Court directs otherwise.

I would be grateful if this correspondence could be referred urgently to a District Judge given the imminent witness statement deadline and hearing date.

This correspondence is copied to DCB Legal Ltd on behalf of the Claimant.

Yours faithfully,

[DEFENDANT]
Defendant

CC: DCB Legal Ltd