Many thanks, just wanted to check. Preparing to send this afternoon. .............. Defence has been successfully submitted by both of us. I guess now a waiting game. Hopefully we can find a middle ground amicably and reach agreement. We have already demonstrated our willingness, despite various threats via e-mail last year including forfeiture of the lease. Thanks for the help so far and will keep you updated. Have a nice weekend 1Penny

Please could I check this point b) That the money for major works was legally demanded by way of Section 20 Notices as per the Landlord and Tenant Act 1985; should this be as per the Commonhold And Leashold Reform act 2002 ?

Hello Andyorch / Lolerz I cannot thank you both enough for your time, effort and support so far. When I can I will be making a donation to this site. The revised defence reads well and I better understand the angle that is being aimed. Regarding the coming years service charge all residents of the block are meeting to discuss further as we are all unhappy with the continued high cost and lack of service provided.Hopefully we will come up with a plan as suggestions have already been made. I think service charges for leaseholders are making the headlines a lot in the news recently. I will arrange for both of us to proceed and submit the defence and will fill any missing gaps. Thanks 1Penny

Hello Andyorch Many thanks also.Sry our responses crossed. The amount in the POC of the claim form is also wrong as the solicitors failed to include the last payment made.But I guess we use this later during the process ?

Hello Lolerz Many thanks. So it sounds like we might be better to keep the defence as is ? Is it interesting that the solicitor will not provide a copy of the lease as part of the CPR31:14 ? 1Penny

Hello Andyorch Many thanks for your response. I was just in the process of submitting the defence but haven't done so yet. How would you suggest that I reword the response to their paragraph 1. I really appreaciate the help. I am feeling so anxious. 1Penny

Ok many thanks, really appreciate your help. I will send today before I go to work and will advise my partner to send too. 1Penny

Regarding point 3 : 3. The Defendant upon receipt of the Claim Form sent the Claimants Solicitor a CPR 31:14 request on 28th February 2024. To date, the claimant has failed to respond to his request. Should I amend to read "To date, the claimant has failed to fulfill this request" Since they did provide a response ?

Hi Lolerz No further post regarding CPR request so will submit the proposed defence in post 83 tomorrow. 1Penny

Ok sounds good

Another thing I noticed is that the figure in the poc is slightly different to the balance on the statement of account by £100 as it looks like they didn't include the last payment that was made. Also they claim interest of just over £1000 going back to 2019 and then they repeat themselves and want to claim interest on the arrears plus the interest going back to 2019 ? Have they badly worded their poc re the amount that they are claiming re the interest ? Regards 1Penny

Ok understood. Many thanks.

Hello Lolerz Many thanks, I was aiming to send the defence by this Friday. Many thanks for your draft. I will give another couple of days for documents to arrive if they do... After the defence is sent how long does the next process take.Will both parties be able to communicate with each other ? I just cannot afford to get a CCJ otherwise my job will be finished. Really appreciate your help and support.

Hello I returned last night to a letter from the solicitors in relation to our CPR 31:14 request. They ask us to serve our defence. In relation to the CPR 31:14 that was sent they have responded as follows : please note that item 1 you refer is your lease. Entirely without prejudice to our clients position we will voluntarily supply items 2-5 referred to in your letter thereafter.The cost will be 25p plus vay per A4 sheetof paper,however you will already have been in receipt of all of the documentsyou refer to at 2-5 of your letteras these would have been supplied by the managing agents, and you have correspondence from us relating to the arrears also. They also refer to an e-mail last year in which I conceded that service charges were payable by the leaseholders, but I never admitted to the amount due which the solicitors were pressurising me to do. My point is that the lessor is in breach of its covenant to repair the common parts and fabric of the building regularly which has increased the lessees’ bills. We just received advanced notice of the coming service charge which is nearly £4,500. Not feeling well today, I think because I am anxious and feeling depressed about things. I don't want to lose our family home where we have been living for 19 years. I know I need to file my defence by next Monday latest. Thanks 1Penny

Hello Lolerz Many thanks for your edits, really appreciated.I will take a look. @Andyorch - many thanks for your input too. Just to clarify our defence needs to be submitted by 18th March,so I guess that we wait until closer to that date before submitting the defence ? I will advise if any response to CPR 31:14. Many thanks for your help and guidance so far, it is really appreciated. Have work committments over the next few days so might not be online so often. 1Penny