Brilliant thank you very very much Andy. I have trying been to find, amend and draft a defence for the past few hours

Hi - I have been unwell. Thanks for the above dx and Andyorch. When is day 33 please? I know it is in the next few days but i have dyslexia/dyscalculia and have have specific trouble working out dates. Is there a template on the forum for a defence? Thanks

Hi All, Received this letter dated xx/10/17 on the 26th from Kearns We write further to your correspondence dated xx/10/2017, received xx/10/2017 In order to provide the documents requested we require time to acquire, compile papers and forward them to you. We confirm that a hold has been placed on the account and no default Judgement shall be requested within fourteen days of the date the documents are provided. We do not consider it necessary to file an application seeking time to provide documents, though if you require such please confirm and we shall do so (though an order may be sought for costs for that) If you wish to discuss, please contact the address at the top of the page or alternatively speak to a Litigation Officer on 02920 XXXXXXX who will be happy to assist you Yours faithfully Kearns Solicitors

Thanks for deleting. It had something still on there that i should have blanked.

Yes all done yesterday. CPR 31:14 has been delivered to the solicitors. CCA still out for delivery to Link. Case also acknowledged online. Yes I do have a copy of the original agreement dated 6th November 1999 (not 22nd November as they state on the claim form) and the T&C's. Many thanks for asking dx and thanks for the assistance dx . Could you please delete the copy of the claim form? Please advice further when required.

Name of the Claimant- Asset Link Capital (no5) Date of issue –05 Oct 2017 What is the claim for – . Particulars of Claim: 1.The Claimant claims the whole of the outstanding balance due and payable under an agreement referenced .....and opened effective from 22/11/1999. The agreement is regulated by the Consumer Credit Act 1974, was signed by the Defendant and from which credit was extended to the Defendant. 2'The Defendant failed to make payment as required and by 26/03/2015 a default was recorded. 3.As at 30/09/2016 the Defendant owed Barclaycard plc the sum of £5288.34. By an agreement in writing the benefit of the debt has been legally assigned to the Claimant effective 30/09/2016 and made regular upon the Claimant serving a Notice of Assignment upon the Defendant shortly thereafter. 4.And the Claimant claims- 1. £5388.34 2. Interest pursuant to Section 69 county court Act (1984) at a rate of 8 % per Annum from 30/09/2016 to 04/10/2017 of £409.55 And thereafter at a daily rate of £1.12 to date of judgment or sooner payment. Date 04/10/2017 What is the value of the claim? £6207,89 Is the claim for a current account (Overdraft) or credit/loan account or mobile phone account? Credit card When did you enter into the original agreement before or after 2007? 6th November 1999 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- Asset Link Capital (no5) Were you aware the account had been assigned – did you receive a Notice of Assignment? Yes I still have it Did you receive a Default Notice from the original creditor? Yes I still have it Have you been receiving statutory notices headed “Notice of Default sums” – at least once a year ? Yes Why did you cease payments? I broke my ankle on or around the 18th March 2014 and was made redundant about two weeks later. I had a part time job then and was struggling financially. I now work in the gig economy being paid a fee for each job completed and things are even worse. What was the date of your last payment? 4th December 2014 £53.00 Was there a dispute with the original creditor that remains unresolved? No Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? Yes they reduced the interest and allowed minimum payment I then received various letters and statement of account from Link demanding payment. They also telephoned and I explained I had no means of paying them. On the 14th August, 2017 I received a letter from Link giving me 14 days notice that the account would be passed to Kearns Solicitors (which I have found is owned by Link). I thought it was time to do something about it. I then wrote to Link on the 18th August 2017 using the template on this forum offering them £2200 as full and final payment. I said my mother would lend me the money. I also explained my employment status and income . They did not reply or acknowledge the letter. On the 1st of September I received a Letter Before Action from Kearns demanding £5288.34 within 14 days. I wrote back to them on the 6th September enclosing the Link letter and my reply. I sent it signed for. It shows they received the letter on the 7th September on the Post Office track and trace. A few days or weeks later a Miss called from Kearns and I explained to her about my written offer and my letters. She then called me back saying Link had put in a counter offer of around £4300 and that I had so many days to accept it. I explained that £2200 was all I could offer. I asked her to reply to my letters and give the counter offer in writing. She declined . I had meant to write to them again but I received the Claim form on Monday 9th of October 2017. I have now drafted a letter to Link (using the template on the forum) asking for a copy of the original credit agreement and I intend to defend the case. I intend to send the letter to Link and the Defence and Counterclaim on Monday Can I put in a counter claim for the distress they have caused by not replying to my letters and for saying I owed Barclaycard £5288.34 and £409.55 interest on the particulars of Claim? If so how much? Barclaycard (but the original account was with Egg a division of Prudential Banking Plc. I have a card issued in 12/05 still in my possession number ...... I have another card with the same number which expired in 11/11. I have a copy of the original Egg Card Agreement dated 6th November 1999 but it does not have a number and I have not signed my copy. I think they sent me the card regardless. I think it was transferred to Barclaycard in May 2011 when Egg sold their business to Barclays. I have a copy of a letter from Egg in response to my complaint about PPI dated 21 July 2011 and it refers to account no ...... I was then issued with a Barclaycard .....in 10/11 Any help would be greatly appreciated.