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  1. Update, got letter reply saying they are going to continue the claim. they have included the notice of assignment from Barclays and will be in touch when all the other paperwork is received.
  2. Brilliant, thank you do I need to write that up in the box provided in the claim form or can I just send it as part of the defence email?
  3. As I am having to use the email method, can I just add that defence text to the email or do I need to manually write it on the form and scan that? (as mcol doesn't work)
  4. Ok, is this good? Have removed the default notice part and just acknowledged that point. Do I need to mention the short agreement/reference number? Defence 1.The Defendant contends that the particulars of claim are vague and generic in nature.The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 2.Paragraph 2 is denied. Whilst I have had dealings with Barclaycard in the past I cannot recall the specifics of the alleged agreement. 3.Paragraph 3 is acknowledged 4. It is denied that any amounts are due under any agreement. 5. On receipt of this claim I requested information pertaining to this claim from PRA group (UK) Ltd by way of a CPR 31:14 request sent via 1st class recorded post on 27/06/2022.Further to the above I sent PRA group (UK) Ltd a section 78 request via 1st class recorded post on 27/06/2022. To date, PRA Group Ltd are yet to furnish me with the requested information . 6.Therefore with the court’s permission the Claimant is put to strict proof to a) show and disclose how the Defendant has entered into an agreement; b) show and disclose how the Claimant has reached the amount claimed for; c) show and evidence the nature of breach and service of a Default Notice pursuant to Sec 87 (1) CCA1974. d) show how the Claimant has the legal right, either under statute or equity to issue a claim; 7. As per Civil Procedure Rule 16.5 (4) it is expected that the Claimant prove the allegation that the money is owed. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.
  5. Great, I’ll get the defence rewritten based on the above and submit tomorrow. will have to be via email as mcol could not sort out my account
  6. The Claimant claims the sum of £13,359.31 for an outstanding debt owed. On 22/10/2017 the Detendant entered into an agreement with Barclays Bank UK PLC for a Credit Card under reference 4XXXXXXXXXXX. On 29/09/2021 the Defendant detaulted on the agreement with an outstanding balance of £13,580.50. On 15/10/2021 the debt of £13,580.50 was assigned to PRA Group (UK) LTD. Notices of assignment were sent to the Defendant in accordance with S136 Law of Property Act 1925. Adjustments have been applied in the sum of £221.19. AND THE CLAIMANT CLAIMS 1 The sum of £13,359.31 Will remove the default notice part from the defence as well dx, the reference is only 12 characters long
  7. Thanks Andy regarding the agreement number, they did provide a reference number but it looks like the forum has removed that probably to avoid personal Information. so does item 2 still stand? if so thanks very much, will get it filed.
  8. No I did not Is that going to cause us problems in the defence? And sorry for the delayed response
  9. No they never sent any documents apart from the PAP notice and then the actual claim form. have requested the documentation as per CCA and CPR 31:14
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