Ok thanks Andyorch. Will do that. What should I do regards a defence for my Ex? Post the same text? Or edit to suit? I presume I simply copy and paste the defence (in my case) onto MCOL.. Hers will have to be sent by the Court PDF forms via email?? Nearly there StephenXL

Thanks Andyorch much appreciated. However, I posted this (above) yesterday. Is that in conflict with the statement made in item 1 of the defence you have so kindly put together? Just asking. Thanks StephenXL

PDF? Understood. GDPR was a general question I'm cool with that.

Ok. How do I disable that per info feature ? I have just been on the phone to CCBC again for the defence deadline to be comfirmed. Without my prompt they confirmed 4pm Monday 17th. On the GDPR issue. Would it be fair to ask if SW are in breach of holding incorrect information about me? Who gave it to them? I'm not on the electoral role at the claim address. Have'nt been for over a decade.

Sorry, have I screwed up again?

Get a felling you will need more info. Let me know Andyoch please stephenXL My Defence. · I have not been Resident at claim address since 2010 · Therefore, do not consider myself having any liability related to this claim · All billing periods prior to January 2014 should be held to be Statute Barred · Account billing wrongly assessed due to consumption estimates. · Consumption of water and sewerage limited to 1 adult( co-defendant) and 1 child when visiting/ temporarily residing at claim address . Partners defence. · All billing periods prior to January 2014 should be held to be Statute Barred · Account billing wrongly assessed due to consumption estimates. · Consumption of water and sewerage limited to 1 adult and my child when visiting/ temporarily residing at claim address. Just for information Andyorch It has to be pointed out that co-defendant (my ex) suffers with chronic mental health issues. Often receives assistance from paramedics due to panic attacks. Generally, under of lot of clinical interventions. Has physical disabilities recovery from broken limbs as a result of falling over causing the injuries. Managed to gain council tax relief after GP wrote to City council highlighting her inability to manage financial affairs appropriately.

Thanks Andyorch, I guess the next move will be to prepare and file the defences? Would appreciate help on how to start that process. Just 30 mins ago my daughter dropped off to me, a Letter Before Court Action from Shulmans dated 20/11/2019 addressed to Me and My ex partner. First time I've become aware of of this. (Feel like I'm fighting a fire which is already out of control). Help needed with defence please Thanks StephenXL

Just trying to follow advice. Tried speaking to SW legal team earlier in the week. Just kept being re-directed to UK Search. (they have no reference for the CC claim number, customer number etc..) not sure whether I should be even talking to UK Seach to be honest. If I call SW and ask to speak to supervisor (as DX suggested) what do I ask?

CPR 31:14 x two sent to Shulmans (both co-defendants) They will arrive special delivery tomorrow. Spoke to County Court to confirm that we have until4pm Monday 17th February to file defence. I will file using MCOL, co-defendant will have to be via email. Still attempting to speak with Southern Water to discuss their POC and ask questions regarding their charges outside time limit etc., (statute barred) just keep re-directing me to UK Search. (Get the impression that this is all being handled from a call-centre from up north.) Trying to find a number for SW office in Worthing without any success. Will seach on here for Water utility defences Best way forward please.

Cool, thanks. I'll get these off right away. One last thing Address on CPR letter to Southern Water but send off to Shulmans?

Apologies for failed protocols. Please find the attached. Will I need to provide a postal with each request? CPR proof.docx

Reponse to your post highlighted in red. I used to be good at all this, so thanks for your help. I'll need some I'm sure StephenXL

Yes. I haven't lived at the address on the claimform since effectively 2009/10. I remain on the council tenancy aggreement of address on claimform due to Family Court Orders granted in 2011. It's complicated I'd guess. Not much I can say on an open forum to be honest. Form a my previous post: They wanted to know if I had legal proof that I do not live at claim address. I do but can't provide such proof without going back to court to grant disclosure.

I will also be sending a CPR in my ex partners name too. (she has granted permission)

Okey doke. One other question. Which address do I use? The address used on the claim form? Then request at the end to send all paperwork to my current address? Or both?

Please treat this letter as my request made under CPR 31.14 for the disclosure and the production of a verified and legible copy of [each of the following / the] document(s) mentioned in your Particulars of Claim: There are no documents mentioned in their POC. Should I simply delete: mentioned in your Particulars of Claim: Then? Just list and request copies of all Bills/Invoices, statements of accounts, Calculations of water consumption/sewage disposal. Copies of all written/ recorded comunications undertaken between Southern Water Services Limited conducted or addressed to myself and the co-defendant in this case.

So.......Just spent the last 35 minutes on the phone to Southern Water Services (allegedly), operator took details accessed Water account confirmed some details (nothing apparently on Southern Water account/customer system regards any pending legal action) (operator suggested that my ex partner is charged just 20% of any rate) then responded to my request to attempt to speak with their Litigation department. Put on hold for 5 minutes. Then given a number to ring. Number discontinued. Redirected to the same number I called originally. Again put on hold....when answered by alleged litigation department, I gave what I believe was a valid customer number, they insisted on a customer reference number, which I seemingly don't have. They wanted to know if I had legal proof that I do not live at claim address. I do but can't provide such proof without going back to court to grant disclosure. after some toing and froing it became clear that I was talking to someone (possibly firewalling) at UK Search. At this point I politely ended the call, restating that I had asked to speak directly with someone at Southern Water suggesting I would seek out alternative approach. Attempting to get my ex to undertake exactly what I do will be pretty difficult. I will do my best though. I will now complete the CPR 31:14 which I am assuming I should fire off to Shulmans. Copy to Southern Water?? Not sure, need advice.

why has your ex not been ever paying the water bills? My ex has ongoing mental heath issues. We moved into the address March 2009: After 3 months my daughter and I had to seek refuge from her mother(my ex). We were asked to return for a few months in 2010. Had to flee again soon after. I had set up all other utilities right at the start, had to flee before getting round to arranging WS utility. I assumed that she had set it up, in her own right. AOS,CPR,N180,N157,WS etc etc. I have been very ill over the past couple of days with COPD strapped to an oxygen bottle. Anything I should not say to Southern Water when I can contact them? I used to be much better at this, any quick links to templates for the above please? My ex has had a letter yesterday from Shulmans (addressed to both of us) asking to arrange a settlement to avoid judgement. I have spoken to her to say do not contact them to respond. Thanks StephenXL

Name of the Claimant ?Southern Water Services Limited Date of issue: 13 January 2020 Particulars of Claim 1.The Claimant is a statutory water and sewerage undertaker pursuant to the Water Industry Act 1991 (the Act). 2.The Claimant claims the sum of £3698.11 for unpaid water and/or sewerage charges payable under s. 142-144 of the Act and the Claimants Charges Scheme. The sum of £3698.11 is for water and/or sewerage service provided to the defendants(s) at (address in Brighton) for the period 01/04/2012 to 31/03/2020 3.The claimant claims interest under section 69 of the County Courts Act 1984 at the rate of 8% a year from 01/04/2019 to 10/01/2020 on £230.19 and also interest at the same rate up to the date of judgement or earlier payment at a daily rate of £0.81. What is the total value of the claim? 4193.30 Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC ( Pre Action Protocol) ? I have not been aware of any such debt against me in regard to this account. There are two defendants listed on the claim (My ex Partner and Myself) I have not resided at the address since late 2010. (I am listed as a tenant at that address. More info can be provided via PM, there are other legal matters related here). PM would help fill in some the ambiguities. Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? YES (PM for details if necessary Did you inform the claimant of your change of address?NA Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? water bills When did you enter into the original agreement before or after April 2007 ? NA Do you recall how you entered into the agreement...On line /In branch/By post ? NO, I was never aware of being participant to any supply aggreement. Is the debt showing on your credit reference files (Experian/ Equifax /Etc...) ?Not showing as yet. Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. Sourhern Water Services Ltd Were you aware the account had been assigned – did you receive a Notice of Assignment?NA Did you receive a Default Notice from the original creditor?NA Have you been receiving statutory notices headed “Notice of Sums in Arrears” or " Notice of Arrears "– at least once a year ? Why did you cease payments?NA What was the date of your last payment?Unknown Was there a dispute with the original creditor that remains unresolved? Unknown Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? At no time have I been involved in matters relating to this alleged debt. The first I ever saw or heard about this claim was 6 days after the Issue Date, when my ex-partner called to inform me of impending Court Judgement.

Thanks. I will do as you suggest. Not sure how to copy and paste to my thread though, I' ll give it a go. Will try to get it done this evening

Just filed "Acknowledgment of Service" on-line via MCOL. (Deadline 4pm tomorrow) I ticked the box to defend all of the claim. Question: Do I have to send "Defence N9B" off now as well? Or do I get time to file this later next week? Be very grateful for any help StephenXL

Thanks. I will take a look to see whether the particular feature is switched on or not. A while ago I read an article where Apple were in fact taken to task over their marketing/purchasing methods (wish I had kept a copy) The outcome of the article caused Apple to refund and compensate the complainants. Thanks Stephen

That is quite upsetting. I will take a look at the article thoroughly.

Yes

I need to know how to deal with Apple corp when it comes to making a complaint about drawing my children into downloading apps which uiltimately cost a lot of money. My bank contacted me earleir today asking if two transaction were fraudulent ie am I aware of them? One for £44.99 and another £38.99. Got them stopped, card cancelled, new one in the post. One of the call handlers informed me that even if I change my visa debit card, Apple corp can still grab the money by applying to visa for my banking details. Can that be case? If anyone can advise me I would appreciate it . Many Thanks