yes number logically

you can refer to the ruling/past cases etc.

I don't think you would need to inc [if large ALL of the old case notes] but certainly the sections you rely upon.

see what andy thinks

those ruling are quite well known in these cases.

Responding to your PM.

Does the court directions ask you to submit a statement as well as disclosure ?

Andy

it only asks for original documents and witness statements which of course do not apply for my claim. Having read it again I don't have to get my documents to the court etc for another month.

Yes it does - ' ....... must include the statements of all witnesses (including the parties themselves.)' Rushing too much. Keep breathing

All claims involve each party submitting a statement in support of their claim/defence...which then in turn affects your disclosures...because you will have exhibits referred to within your statement that will become part of your disclosure list.

In short you cant complete your disclosures until you have finalised your statement.

So it is really a statement referring to the rulings I am relying on and using my documents and their responses to back it up? Is there a previous claim you recommend I look at to make mine comprehensible. I'm thinking it doesn't have to be book length

What date must you exchange statements by ?

The deadline on the documents is the 21st.

So you have time yet to receive the defendants statement which would give you a heads up on the points of law they will rely on and you can can counter respond their arguments.

Make a start on your statement but allow for changes should you receive theirs in time.

Well I didn't receive anything from them and we are in court on Thursday. I have rung the court to advise no witness statement has been received by me and they confirm the same for the court.

I will be sending an email to the courts so the judge is now aware of this and I was told it will be up to the judge on Thursday as to whether or not he allows their witness statement to be allowed as evidence.

I did receive an 'without prejudice save as to costs' letter today from the solicitors offering roughly half the outstanding balance again stating they do not agree with the provisions of the limitations act and stating that the compound interest part of my claim is denied.

In my witness statement I stated the facts of the correspondence between me and them, mentioned Kleinwort Benson and also Sempra metals regarding restitution. I also copied the monthly statements showing the charges, all letters and hsbc terms and conditions.

If I turn up with all of this on Thursday plus Sempra ready to state my understanding of restitution does anyone think I have a chance of putting my case across. I will also take my recorded delivery receipt of my witness statement.

The only foolish thing I did was send my final letter back in October offering to settle before the further court costs were paid by myself to the defendant and NOT the solicitors so they say they did not have sight of that till it was in my witness statement.

i think you have every chance...given that they cannot use or rely on any documents to support their defence...make the judge fully aware of this at the start of the hearing...verbally.

They have failed to comply with directions and therefore their defence should be struck out.