This is the defence I have received. I'm posting it in the hope that its not held as contempt of court in any way.

I will post the request form as soon as i've typed it out.

Btw. I gave all the correct info on the Moneyclaim form as suggested on this site.

DEFENCE

1. This defence is filed and served without prejudice to the Defendant's case that the Particulars of Claim do not disclose reasonable grounds for bringing a claim against the Claimant to recover the bank charges (and interest thereon) referred to in the Particulars of Claim or any other sum(s). In the event that the Claimant does not properly particularise his claim then the Defendant will apply to strike out the claim and/or for summary judgement in respect of the same.

2. No admissions are made as to what charges have been debited to the Claimant's bank account.

3. The Claimant refers under paragraph 3 of the Particulars of Claim to having provided the Defendant with a copy of his list of charges. The defendant has not yet received a copy of this list.

(in fact I have provided them with 2 copies)

The claimant is therefore put to to strict proof of each and every charge the subject of the claim and must identify in respect of each charge (a) the date the same was debited, (b) the amount of the same and © the description applied to the charge.

4. In relation to the allegation that the contractual provisions pursuant to which charges have been applied are unenforceable by virtue of the unfair Contract Terms Act 1977 (UCTA 1977') and/or the Unfair Contract Terms in Consumer Regulations 1999 ('the Regulations') and/or the common law, the claimant is required to identify:

4.1 (a) the section(s) of the Unfair Contract Terms Act 1977

(b) the regulations of the Unfair Contract Terms in Consumer Regulations 1999 and © the principles of common law relied upon by the Claimant in alleging that the contractual provision(s) referred to are unenforceable and

4.2 the contractual provision(s) that the Claimant allege are invalid by referrence to UCTA 1977 and/or the Regulations.

Until such time as these sections/regulations/provisions are identified the Defendant cannot (save as appears below) plead to the allegation referred to in paragraph 4 above. The Defendant therefore reserves its right to plead further to the allegation once (and if) the Claimant identifies the relevant contractual information.

5. In relation to the case of the Claimant that the charges are unreasonable within the meaning of section 15 of the Supply of Goods and Services Act 1982 ('SGCA') the Defendant pleads as follows:

5.1 The Claimant is required to plead and prove the necessary factors (referred to in section 15 SGSA) concerning the contract between the Claimant and the Defendant which mean that pursuant to SGSA section 15 there is an implied term that the Claimant pay a reasonable charge for the service under the contract.

5.2 Further, the Claimant is required to plead and prove (a) that the bank charges which have been debited are unreasonable; (b) all facts and matters relied upon by the Claimant in support of this case and © what charges would have been reasonable.

5.3 In the circumstances no grounds are disclosed for a claim that the Defendant has acted in breach of SGSA section 15.

5.4 In the circumstances (save as appears below) the Defendant is unable to plead to this allegation beyond denying that it has acted in breach of SGSA section 15 as alleged or at all. The Defendant reserves its right to plead further to this allegation once (and if) the defects in the pleaded case referred to in paragraphs 5.1-5.3 are addressed.

5.5 It is the case of the Defendant that the contract between the Claimant and the Defendant does not fall within SGSA section 15 because (a) the consideration for the servicewould be determined by the contract between the Claimant and the Defendant and (b) was not left to be determined in a manner agreed by the contract or determined by the course of dealings between the Claimant and the Defendant.

6. The Claimant's claim for costs not being suffiently particularised, the Defendant is unable to plead and reserves the right to plead upon further particulars.

7. To assist the Claimant with the proper particularisation of his claim(s), the Defendant serves with this defence a request made pursuant to CPR Part 18. If the Claimant fails to provide the particulars requested in the time stipulated and/or the defects with the claim(s) (referred to in paragraph 1 above) remain then Defendant will apply to the Court for (among other things) an order striking out the claim.

8. Pending the proper particularisation of the claim(s) the Defendant is unable to plead to the Claimant's claim(s) beyond at this stage denying that the Defendant is liable to the Claimant as alleged in the Claim or at all. The Defendant reserves its right to ammend this Defence to plead further to the Claimant's claim(s) once or if the Claimant properly particularises the same.

9. Save as hereinbefore appears the Defendant joins issue with the Claimanton his claim(s) and denies that it is liable to the Claimant as alleged or at all.