Good-doer
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Posts
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Hi ibberty bibberty, many thanks. I have added the amendments, laws and authorities as you've suggested. Pls a few more final touches: 1) Is it ok that I can plead the unfair communication and false use of authority by the defendant at this stage, even though that was not on the Claim Form? Any specific laws or authorities? 2). The cause of action took place in January 2000. The FSMA 2000 came into force on 14/06/2000. Will that affect our pleading? Finally, the Court will accept filing by email so that's very helpful. We will call the defendant on Monday if they will also accept email or fax. Initially the defendant was handling the case by their in-house paralegal staff or lawyers. But just 2 days ago, we've received a letter from a very well known law firm that they are now handling the case and will represent them in Court. Well, that was a bit of a surprise to us. But we are not too scared. My wife and I will press on. I will be her Lay Representative in Court. Thank once again. I didn't know I have to make an application (N244). The last time she just wrote a letter and also made that as part of her Witness Statement. But as you've reminded us, we will get that done asap. Regards, Good-doer.
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Thanks ibberty bibberty. I am thinking I will not be able to meet Monday's deadline if I want rewrite the whole Reply, post here, get a feedback and refine before I submit it on Monday. But if I can get the 'foundation' right, then the rest of the structures will fall in place. So what I done is to post the Concise Statement of the Facts (CSF) here in PDF for your perusal, comments and amendments. If I can get the CSF right, then the details will just be a matter of adding the facts, which are almost there in the CSF. I hope these help. Thanks to all in advance. Good-doer.
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Thanks ibberty bibberty. Indeed, you've demonstrated how to particularise the case. That's another answer you've provided. How to particularise the Claim has been one main thing in the defence that we did not fully know what else the Defendant was looking for. Having read your example, I got it now. I may have to re-write the Reply, which is now about 17pages. I am struggling to reduce the pages, not wanting to leave out key facts. Pls any idea about the maximum pages allowed in the county courts? Thanks. Good-doer.
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Hi dx100uk, thanks for your PDF info. I have now attached the docs in PDF. Although they are a bit faint, I hope you all enlarge the pages to be able to read them. pls remember the date to submit the Reply is this Monday coming, 17/08/15. Thanks to you all. Good-doer
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Thanks ibberty bibberty. You've brought up some key points that are very crucial to the Reply. I will add them. I've scanned and attached the docs as requested. But it looks like they too small. I do not know how to send by PDF. I will send pm to dx100uk to get that done asap. Many thanks. Good-doer.
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Hi BankFodder, thanks for your requests. I have now attached all pages of the claim and defence. Looking forward for your thoughts on them soon. Thanks. Good-doer.
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Please find attached the claim and defence (pgs 3 & 4 are next). Thanks. Good-doer
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Thanks again, Honeybee13. I've got it. I now know what PM is. Cheers.
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Ok thanks, Honeybee13. In the meantime, what is PM?
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I am new to this Forum. Thanks for the great works you all do here. This is my first post. I am helping my wife who made a claim against Lloyds Bank plc, for refund of mis-sold insurance protection products (IPP) premiums. She obtained judgement in March this year. But Lloyds applied to set it aside and filed a Defence. The amount claimed is £1,274. We have drafted the Reply to Defence, which we have to submit on 17/08/15. But the Reply, (together with the Defence) need looking at or reviewed before we submit. Please, I should be very grateful if someone or the administrators or moderators can send me your email so I can forward a copy of the documents for your review and return by Friday 14/082015. Many thanks in advance. Good-doer
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