Reproduced courtesy of PT2537
This is a standard defence when the CPR is not adhered to...please read it through...
In the xxxxxxxx County Court
Claim number
Between
xxxxxxxxxxx- Claimant
and
- Defendant
Defence
1. I xxxxxxxxx of xxxxxxxxxxxxx am the defendant in this action and make the following statement as my defence to the claim made by xxxxxxxxxxxx
2. Except where otherwise mentioned in this defence, I neither admit nor deny any allegation made in the claimants Particulars of Claim and put the claimant to strict proof thereof.
4. Notwithstanding point 3,the claimants' particulars of claims do not appear to disclose any legal cause of action and they are embarrassing to the defendant as the claimant's statement of case is insufficiently particularised and does not comply or even attempt to comply with CPR part 16. In this regard I wish to draw the courts attention to the following matters;
a) The Particulars of Claim are vague and insufficient and do not disclose an adequate statement of facts relating to or proceeding the alleged cause of action. No particulars are offered in relation to the nature of the written agreement referred to, the method the claimant calculated any outstanding sums due, or any default notices issued or any other matters necessary to substantiate the claimant's claim.
b) A copy of any evidence of both the scope and nature of any default, and proof of any amount outstanding on the alleged accounts, has not been served attached to the claim form.
c) No copies of statements relating to any accounts have been included with the claim form and no particulars have been offered supporting the claimants claims of my indebtedness to them
6. Further to the case, on xx/xx/2007 I requested the disclosure of information pursuant to the Civil Procedure Rules, which is vital to this case from the claimant. The information requested amounted to copies of the Bank Statements and/or Credit Agreement referred to in the particulars of claim and any default or termination notices, a transcript of all transactions, including charges, fees, interest, alleged repayments made by myself and payments made by the original creditor. Also any other documents the Claimant seeks to rely on, including any default notices or termination notice, and a copy of the Deed of assignment and Notice of assignment
7. The claimant has failed to comply with my request for disclosure entirely and it is suggested that such failure highlights that there is no case for me to answer
8. Since the claimant has failed to comply with the request for disclosure as outlined in point 6, it is requested the court consider striking out the claimant statement of claim as failing to disclose reasonable grounds for bringing the claim and there is no case to answer
9. I further ask the court consider striking out the claimants case as it fails to comply with part 16 and practice direction 16 insofar that no documents have been supplied and fails to show any consideration to the overriding objective to allow the court to deal with this case justly
10. Alternatively, if the court is not in agreement with points 8 and 9,I respectfully request a stay in proceedings until such time as the claimant complies with the requests outlined in point 8 above or until the court orders its compliance with the same. I will then be in a position to file a fully particularised defence and counterclaim and will seek the courts permission to amend my statement of case accordingly.
Statement of Truth
I xxxxxxxxxxx, The Defendant, believe the above statement to be true and factual
Signed ..................... date...................
HELP; non comply of request of information under Civil procedures Rule **WON CASE STRUCK OUT 
much appreciated, took your advice but I guess pt... is soooooooooo busy