Just submitted the following as my defence. Got no response from my requests.
I deny any indebtedness to the claimant.
I put forward that this claim is statute barred pursuant to the provisions of section 5 of the limitation act 1980. If, which is denied, the claimant contends that the Defendant is in breach of the alleged contract, in excess of 6 years have elapsed since the date on which any cause of action for breach accrued for the benefit of the Claimant.
Also, I have sent the solicitor for the claimant a CPR31.14 request for the documents relied upon in the Particulars of Claim. Until I receive these documents I am unsure as to exactly what the claimant's claim is for and am finding it difficult to file a full and complete defence under the circumstances.
The Defendant respectfully requests that the Court stay (Suspend) the proceedings under Practice Direction 4.6 (1) until the claimant complies with the defendants CPR31.14 request. The defendant respectfully requests that the court impose a time scale of fourteen (14) days upon the claimant to comply with the defendant's rightful entitlement to inspect the documents that the claimant's claim is to rely on, and that should the claimant fail to comply with the court's order, then the defendant respectfully requests that upon notification by the defendant to the court of the claimant's failure to comply with the Practice Direction sanctions imposed by the court, that the court makes the motion to strike out the claimant's claim on the grounds that the claimant is unable to substantiate the claim.
The Defendant also makes a respectful request to the court for the court's consideration, to permit the defendant to submit an amended defence if the claimant supplies the requested documents mentioned.
Thanks for the help so far!