This is where I am at with the witness statement. As requested, certain words have been removed though I still mean them, though I am completely understanding why the forum may not wish them to be used here. Sir / Madam, Further to my statement of case, dated 18th June 2018 I have now made some further highly important and relevant discoveries during my investigations into this claim and the evidence provided by the claimant’s solicitors. Whilst I have been examining in careful detail the two sets of paperwork provided by the claimant on two separate occasions I have found some serious and what appear to be deceptive and potentially criminal differences. Firstly, though not as important initially, there are serious fundamental errors with the values claimed. I set these out below for you; The claimant claims; £2463.43 plus interest totalling £2660.50 and additional solicitors’ fees and the court fee which totals £2845.50. I feel it relevant and important that the default balance on the Notice of Default is for £2239.13. The claimant is put to strict proof to prove their claim is accurate as it is £224.30 above the default balance! I have still not received a Default Notice from the claimant or indeed the original creditor. I wrote to the original creditor on the 19th September 2018 and requested a copy of the Default Notice and Notice of Assignment, this letter was sent recorded delivery and signed for on 20th September 2018 by “Name Removed” at (time removed) – nothing has been heard from the original creditor either. A copy of this letter is attached which shall be referenced as exhibit XX/7 in continuation of the previous exhibits. I have also included a print of the proof of delivery direct from Royal Mail which shall be exhibit XX/8. The statement of account that has been sent by the claimant showing an end balance of £2463.43 is incorrect as it should reflect the actual balance on the Notice of Default and the missing Default Notice. Further to this, I add and with serious concern that this document has been (word removed) created in order to mislead myself and the court. I set out my reasons for this below; The statement shows a card number ending 6817 which accurately reflects the claim form and indeed some of the other misleading paperwork provided by Lowell Solicitors. The document also has another 16 digit number which is referenced as the “account_number”. I respectfully point out that this 16 digit number is actually the number from a credit card I previously held and I have proof that the account number of the account that the claimant makes claim for ending 6817 is indeed the same as the card number ending 6817. I attach this old statement from Vanquis Bank on their letterheaded paper which clearly shows the customer account number of, 40XX X>XX > I put it to the claimant that this has been created and manipulated to mislead the court and myself. I further put the claimant to strict proof to show how it is possible for an account to have a 16 digit card number which is different to the account specified. This, as per below would render the system to receive payments and charges on other people’s cards and cause electronic mayhem for accounting and banking purposes. I made a telephone call to Vanquis Bank at 17:02 (approximately but my landline phone records are likely able to show the absolute time if necessary) on Wednesday 19th September 2018. I asked the advisor if a credit card with the details of 40XX X>XX XX 6817 would have a different account number. I was helpfully advised that this would not be the case as it would be almost impossible to have a card with a specific card number of 16 digits and to have it match a different number of 16 digits. The reason for this is that when a purchase is made it is a live purchase which is cross checked against the same number on the credit system in order for the purchase to be authorised or declined and for that to then be appropriately billed back to the right account holder. The card numbers which must match the account number actually have meanings. Each number is an identifier for the credit provider which allows the accounting to flow smoothly and be automated. For purposes of being clear and to avoid any discrepancy with the claimant, the stripe on the rear of the card holds the following primary information on tracks one and two but may contain a few other lender related details; There are three tracks which hold data about the card and the account holder, these are simply the card number, the expiry date and on some the card issuers details and the account holders details. The third track is generally encrypted on credit and debit cards. This is what is used to link back to the live system from the issuer in order to verify the purchase. It has to be the same format on both the card and the account system. The screen prints that the claimant has provided of the account details are (word removed) and intended to be deceptive, I state the reasons for this here; On the screen shots the account number is specified as; 40XX XXXX XXXX XX42 – this belongs to a different credit card which was previously held by myself! Having asked a friend who worked in the IT Industry for 20+ years with experience in Security and Accounting Systems on Electronic Point of Sale Systems she is very highly experienced and knowledgeable in this specialism. Further to this; The “Approval” is shown to be 15/01/2011 at 12:19 hours and the terms and conditions are referenced as “NP-TA-16” which match the terms sent by the claimant but there is a fundamental flaw with all the terms and conditions they have sent in that they are indeed dated 13/01/2011 at 12:48. There is also a random date on them which is 12/03/2012 – I am not sure what this date refers too but the claimant is put to strict proof to explain why it is there. I put it to the claimant that these are also indeed manipulated and (word removed). The claimant is put to strict proof to show how a Credit Card application can be approved two days after terms and conditions are dated but the application clearly could not have been made! In the professional experience and knowledge of my friend, it would be the other way round. Application approval and then terms and conditions on the same day in order for the applicant to know what they are agreeing too. When an application is made online, the applicant places a tick into a box to accept the terms and conditions at that point, with respect Sir / Madam, not two days before. The claimant alleges the agreement was later assigned to them on the 04/08/2013 on the claim form but the formal notice sent by Lowell is dated 11th April 2014 and the date of sale from Vanquis to them as “08th April 2013” – this is exhibit XX/3 The claimant is put to strict proof to show the original document that shows the actual date of sale from Vanquis to them. Exhibit XX/3 is dated more than a year after the sale, I find this extraordinary and another potential deceptive document provided by the claimant and or their solicitors. I further add to my defence that I am in possession of a document from Lewis Debt Recovery dated 28th December 2012 which is seeking payment of the account to them. I recall dealing with Lewis Debt Recovery at the time and disputing their claim of which I never heard anything back from them. The claimant is put to strict proof to show how they purchased the debt from Vanquis Bank Ltd whilst it appears to be with Lewis Debt Recovery. I set out in bullet form all the inconsistencies and errors; • Failed to comply with the CCA Request and CPR Request under the Consumer Credit Act 1974 on time and until Judge Anson ordered them to. • Provided misleading and incorrect documents on request of the CCA and CPR and was not in possession of the evidence and had to request it from the original creditor. It is my belief this could not be possible as my recent letter has been ignored and I suspect that is due to them not having the requested Notice of Default and Default Notice either. • Failed to provide an Original Default Notice. • Lowell sent a letter claiming it to be a “notice of assignment” which complies with the Consumer Credit Act but was actually just a letter “introducing Lowell”. • The Default Balance is £2239.13. • The Claimant claims - £2463.43 plus interest and Court / Solicitor fees. • The Claimant sends a document (exhibit XX/3) where they state the account was sold to them on the 08 April 2013 yet all their other documentation and claim form it is documented as 04/08/2013. This is an extremely important document as it is supplied as the “Notice of Assignment” yet is incorrectly dated and more to the point, appears to have the wrong date of sale on it. Therefore this document can not be genuine and is suspected to be (word removed). • The Claimant provides screen shots of the application with an incorrect account number assigned to it. • The Claimant has also provided a screen shot of the application which references the terms and conditions they have supplied with a date on that is dated two days prior to the application actually being made. • I have proof of the Card Number the claimant references in their claim to match the “account number” on a statement provided by Vanquis Bank, the original creditor. • Exhibit XX/1 – This is minor but I feel it must also be pointed out to show the lack of due care and attention and lack of professionalism the claimant and their solicitors have shown. It is clearly dated just short of a year prior to the claim. It is dated “28 March 2017”. Sir / Madam, with all these deceptive and what appears to be creative and poor manipulation of documents that have been produced as evidence in a Civil Claim through the judicial system I respectfully request that this case be struck out or dismissed unless the claimant can produce original supporting documentation that complies in full with their obligations under the Consumer Credit Act 1974 showing they have legal ownership and they have complied with all their obligations under the Act. Including statements and all notices they are obligated under the Act to comply with. I have had no documentation from Lowell Portfolio I Limited, including a Default Notice and as explained earlier in this Witness Statement, I have requested a copy of the Default Notice and Notice of Assignment from the original creditor which has also been ignored. I feel I have complied in every way to prove my defence against this claim which appears to be without cause and frivolous in its nature and has been brought by using documents that have clearly been manipulated. Sorry DX100 but I don't understand, the DN being blank? Upon very close examination there isn't one. I was mistaking it from the Notice of Default.

I ma back to writing my statement and I have a question which I hope someone can answer quickly which I think may be relevant, the digital signature on the terms and conditions are dated two days prior to the account application (i know - it just sums them up) but it shows something "NP-TA-16" - I am wondering if this is the year the terms were issued? It may be nothing but may be something and I am throwing everything I can at them.

I brought all my old paperwork with me today so we could go through and see if we could find an old statement from Vanquis that relates to the account they have references on the Court form. The statement I have does document one transaction which matches with the date on the statements sent by lowell so they may be genuine. Bingo, I have an old statement dated 25 Dec 2012 which references the "account number" as the same as the card number. I have also called Vanquis again today who are going to call me back as I have provided both the numbers to them to see if they relate to two separate accounts. The account had been passed to Lewis Debt Recovery in the first instance as I have the letter they sent with the statement attached. So, I'm sure you'll correct me if I am wrong but if the debt was "assigned" or bought by Lewis in the first instance then Lowell would have had to have bought it from them? Surely there must be a paper trail of transfers required? The one thing I don't have is a notice of assignment to Lewis from Vanquis. Sorry to post again but does this help me in any way at all or am I just wasting my time and let it be? I really want to fight and get through this but it is daunting when I have no real idea what to expect or what's going to happen. I've read loads and loads of success stories but can't find one where a case has been lost and what the outcome was. Sorry, that feeling sorry for myself again.

Thanks Dx100. I'll pop it up as a PDF (getting good at this now). I would like to ask you or someone to look at the differences in the card numbers / account numbers. It's clear that it has been reproduced but id like a second opinion, actually, probably a 5th. I don't want to put them up though as it is the full numbers (even though they are not mine!) Notes on Documentation Inconsistencies.pdf

As I've not heard anything we have just phoned the court handling centre who have confirmed that Lowell have paid the fee and the hearing is going ahead on the 26th. I'm a little worried now as I can't be there. Does any one have any suggestions? Also, I have a list of things that I have documented wrong with their paperwork and case and I don't want to put it online just in case they are monitoring this (been doing lots of research on them). Is there a way I can send it to someone who can advise on it?

Where I was going with the Notice of Assignment is that the date on the one Lowell have sent is a year after it was sold to them and I want to see one from Vanquis, hopefully with a date on it that reflects the sale, perhaps a week or two after, maybe even a month. Not a year as that stinks like they are fabricating it. If I have it then I can rely on it and disclose it that they have been found out to have produced a document that is false. They did eventually send a copy of the DN. The first time I asked for it with the CCA etc they didn't but the judge ordered it a little later and they sent it - a reconstituted one, the one I hope is with the wrong date and doesn't match one Vanquis hopefully send me. Vanquis have just told me on the phone that any card number is exactly the same as an account number. So, given that in mind... On the application document the fleecers have sent it shows a different account number than the account number they refer on their documentation (all of it) including the claim form. Vanquis have confirmed that when an application is approved the "account number" is the same as the card number. Lowell appear, or someone has, altered that document and also possibly the statements sent. I think I need to get it all scanned and sent up as a document so everyone can see what I mean. In short, the card number is the account number and vice versa and Lowell have produced a document with a different account number for a claim on a different card number. Isn't that deception or fraud?

They're not on headed paper or even have a logo. It's just plain white a4 paper like is in my friends printer to my right. I should have asked for a copy of statements in my letter to vanquis this morning asking for a copy of the default and noa. I'm hoping they show different things too from the one Lowell have produced / supplied.

OK. I'll wait until the last minute. I have just discovered something that I think may be relevant. The statement which they sent, it looks like a spreadsheet my friend says but the card number is right but it shows an account number which is as I have detailed above that ends differently. So just to be clear; It shows; Card_Number Account_Number xxxxxxxxxxxx6817 xxxxxxxxxxx6542 I may be wrong but it looks like they have put together this spreadsheet, used the card number and the number on the actual application that shows the account number as being different. Looking down the so called statement, they have duplicated it for about 1 page and then the account number changes to something completely different for the rest of the statement (around 6 pages). On all my previous credit cards the account number has always been the same as the card number, it's never been different. Would you concur that is the case, I don't understand why a card would be issued with 16 digits on and then it attached to another account with a different 16 digit set of numbers? I've also noticed that there is a difference in the closeness of the top of the numbers on the account number showing on the application document. One batch they sent shows the numbers almost perfectly lined up and in the center of the box, the other shows the numbers slightly higher and closer to the top of the box. Suspiciously like it has been pasted in. I'll check out witness statements too. Sorry, I would have added this to my last post but it crossed with your post. Skip my last question. I've just phoned Vanquis and asked if the account number matches the card number and it absolutely does. Another I honestly hope Vanquis read this as it is now looking as though someone has falsified a document to mislead a court and potentially a judge. I would imagine that would be quite serious.

Sorry Dx100 - I'm still learning all this techy stuff. I'll remember in future. I'm reading now and it does seem that Lowell have a habit of discontinuing claims but given that there may be a falsification of an account number here then it looks quite serious. Can I bring this to the attention of them and the court now or just wait until I need to submit the witness statement?

I'm looking now. Not found anything that is specific to incorrect account numbers but found one re dodgy evidence and what seems to be false accounting of some sort.

Struggling to find them. Any way you could point me in the right area. I'm searching Lowell but getting millions of results.

For them or me? Would you like a scan of two examples.

That is a very kind thing to do for me. Whilst you have had me go through the paperwork in more detail I have noticed something that may be important but may not be given I thought I was doing well with the figures being inaccurate! The Digital Signature page that has a Vanquis Logo on it which details my application says that the "Final Decision" is Approved on 15/01/2011 12:19. Then having gone through all the paperwork and the terms and conditions which they just bundled together and I've now sorted into order (they sent 4 copies and one is incomplete). On the last page of the terms and conditions it shows my name, the date it was signed on, being 13/01/2011. It also has another date slightly below which shows "12/03/2012". The box that shows the terms and conditions on the applications shows "NP-TA-16" and the terms also show that so I think they have provided the right terms but the dates are wrong on the paperwork. Is this what I am missing? The dates don't add up on any of their paperwork and now even on the actual application. How can I be approved on the terms two days before the application is even processed? One more thing I've just found. The account number on all their documentation is completely different to the one on the application document. The number on their claim relates to the original account number which ends 136817 (Credit Card Number - I'm not going to post it all up) but the one on the application document they have sent showing me being approved ends 086542. The first 4 digits of the account number is the same "4023" but the remaining numbers that make up the 16 digit card number is completely different. I'm certainly not an expert but surely that is not acceptable as evidence?

OK. I have sent the court a letter advising them of my absence on the date the hearing is scheduled to take place but I haven't heard anything back yet. I've not had a witness statement from Lowell if that is what you mean. Short of the discrepancies with the figures and one I have found stating that the account was originally taken out on the 15/01/11 but the documents (screen documents) show it as being accepted on the 13/01/11. I've not found anything else to help me. What am I missing? I don't know what else to look for to discredit their claim.

Thanks for coming back to me. Not sure what you mean by concentrating on the paperwork sent? Is there something I should specifically look for? Though, they did send a statement with the bundle which they claim is from Vanquis. The end balance on the statement is £2463.43 but wouldn't the end balance have to match the default amount of £2239.13?

The trial date is the 26th October 2018. The document that came from the court says that the claimant must, by the 28th September 2018 (4pm) pay the trial fee of £170 or file a completed application (i think that is for help with fees). If the claimant does not do this by the given timescale the case will be struck out "with effect from 28th September 2018 without further order and, unless the court orders otherwise, you will be liable for the costs which the defendant has incurred". The document further goes on to the directions which state; (1) - Each party shall deliver to every other party and to the court office copies of all documents (including experts report) on which he intends to rely at the hearing no later than 12 October 18. (2) - The original documents shall be brought to the hearing. (3) - Included in the copy documents shall be written statements of the witnesses (including the statements of the parties themselves) I noticed that the agreement was assigned to Lowell on 04/08/2013 yet their "reconstituted" notice of assignment is dated "08 April 2013 - however, the actual notice of assignment Lowell sent is dated "11 April 2014". I am in possession of a document that they firstly claimed was the notice of assignment but actually was just a letter "introducing lowell as a specialist debt purchaser" which is what was sent when the CPR and CCA was requested shows the figure they claim i owe to be £2463.43 yet on the claim form they try and claim £2660.50 before interest and solicitor fees. However, the actual default notice shows the balance to be £2239.13. I am not at all clever when it comes to matters such as these but surely they can't get away with claiming what appears to be random numbers and with dates that are incorrect, three different balances? What would be the general thoughts here about all these inconsistencies? My friend just suggested that maybe sending a Subject Access Request to Lowell and also the original creditor Vanquis? Sorry for another post, just want to run something by you kind people. It occurred to me that the discrepancy in the figures might be due to the default balance and an arrears. The default balance is £2239.13 and then there is an arrears on the account of £324.20 (this is what shows on the default notice Lowell sent) which if added up comes to £2563.33. Lowell claim is for £2660.50 (without additional costs and interest) which is still higher than the £2563.33 - I'm thinking someone just plucked a figure out of their tiny mind and decided to make a claim for it. On the Notice of Assignment that Lowell eventually sent as a reconstituted NoA it claims the balance outstanding from Vanquis to be £2463.43 which looks awfully similar to £2563.33 only either someone can't add up or mis-typed it. Am I right in my thought process that when I defaulted on the account it would be the £2239.13 + the arrears? In which case, this may suggest further that the NoA sent by Lowell is a forgery given that it is dated 11th april 2014 and the default date is 20th November 2012 and was sold to Lowell apparently on the 8th April 2013. I have sent a signed for letter to Vanquis for copies of the original default notice and notice of assignment they suggest they sent to me. I'm interested to see if there is any difference in dates and values. Again, I'm sorry for 3 posts, I'm thinking and should really put it on paper before posting. I hope someone can help answer my questions? I'm at my friends until this weekend so I'd be grateful if someone can do before then.

Ok. I'd appreciate an idea on what to send. I'm leaving my friends shortly and will be back possibly in the week so if you have any suggestions on what to say by then that would be great. Thanks

The date of the hearing is Friday 26th October 18. Thanks for the explanation re the twaddle.

Thank you.

With respect, perhaps I should have read the rules but my post was a spur of the moment post about whether or not that link was even accurate. I understand that the rules must be followed but I would have preferred an answer to my question rather than a rule book being thrown at me for what is a genuine honest mistake brought about by doing some research. Sorry to have bothered you.

I've just realised that the hearing date is whilst I am away with my children and grandchildren on a holiday. Would a letter to the court suffice to explain this with proof of it being pre-booked and should I send a copy to Lowell? Also, I'm getting a little nervous about this now, more so as I can't be there. I've just read this thread, is any of this remotely accurate and if so, can I use any of what is here, such as the "deed of assignment" / "novation of assignment".... I never knew any of those existed until now, is it too late to request the deed of assignment to get them to prove they own the debt fully and all the responsibilities they have to undertake as part of it? Or has that ship sailed and I need to rely on the judge to make them prove it? Thx, Ed

Hi, I’ve just received a letter that refers the case back to mediation. It didn’t go well last time. A hearing date has been set if it fails. I don’t think going to mediation is likely to help given I’m saying that I don’t owe Lowell a penny. Just after your thoughts on it?

Before I leave for home, is what I have put OK in the Witness statement (as in, does it make sense). I'll work on tidying it and keeping it simple at home as my friend has lent me a laptop. If you get a chance to reply and let me know before 3pm that would be amazing. Thankyou.

Sorry, I maybe misunderstood. I've just looked at the order and it said "statement of case" so I thought witness statement. I'll have a look again - keeping it simple Old Cogger....

Thank you. I am going to stick to my guns and stand firm, i've nothing to lose now. Please find below my first attempt at the statement requested. I have been looking around the site this morning and found a rough draft of one from a similar case live at present. I would be grateful if someone would look it over and see if i make any sense at all. I am the defendant in this case. Lowell Portfolio I Limited have issued a claim against me for an alleged credit card agreement between myself and Vanquis Bank. I also make this statement knowing that anything I believe to be false or misleading may lead to prosecution. It is my understanding that the ‘Claimant’ is an ‘Assignee’ of defunct or disputed debts which they purchase on mass at a hugely reduced figure. It is suggested after doing a little research into how Debt Management Companies work and also having spoken to a previous employee of a large national company that the debts purchased are at a figure of pennies in the pound, in a particular case I am privy too, 10 pence in the pound on a £3.5k debt. The debt has already been written off by the original creditor as a capitol loss and it is suspected that a taxable claim may have been made as taxable income. From a few minutes research I have discovered that the claimant then issues bulk claims through the Court against people to maximise profit. As an assignee or creditor as defined in section 189 of the Consumer Credit Act this applies to the new requirement on assignment of rights. This means that when an assignee purchases debt or otherwise acquires rights under a credit agreement it also acquires certain obligations to the borrower including the duty to comply with the Consumer Credit Agreement requirements, such as the rules on statements and notices and other post-contractual information. The assignee becomes the creditor under the agreement. This ensures that essential consumer protections under the Consumer Credit Agreement cannot be circumvented by assigning the debt to a third party. The claim made relates to an old Vanquis Credit Card Agreement between the defendant and Vanquis Bank. The defendant accepts that in the past he has had financial dealings with Vanquis Bank, however, the defendant does not recall any agreement with the Claimant and is unaware of what debt the claimant refers, having failed to adequately particularise its claim. As a result of this claim the defendant sent by way of recorded post to the Claimant on 31/01/18, a request for copies of the Consumer Credit Agreement, the Default Notice and original signed Notice of Assignment from the original creditor, Vanquis Bank. This was not complied with, instead a letter explaining they were “requesting” the documents from the original creditor was received with a further “request for payment”. I wish to express serious concern that the claimant has made a claim through the Legal system without actually having paperwork and proof of ownership to do so. I believe the claimant is misleading the court in the hope that the claim is not questioned, and it is won by default at the very start of the claim. As a result of not receiving the requested paperwork and proof of ownership, pursuant to the Law of Property Act 1925 s136 the defendant doubts the authenticity of the claim and the claimant. The claim form documents that the “agreement was later assigned to the claimant on 04/08/2013 and notice given to the defendant” yet the Notice of Assignment received, documents it as “08 April, 2013 your account was sold to Lowell Portfolio I Ltd”. The Notice of Assignment is dated “11 April 2014” which is a year after the debt was sold to the claimant, this raises serious doubt with regards to the authenticity of this document. I state the reason for this being that the original creditor is unlikely to have issued a Notice of Assignment a year after the debt was sold to the claimant, a genuine Notice of Assignment was requested which has not been produced. The claimant has documented in their own words on the claim form that “notice was given to the defendant” – however, that statement appears to be inaccurate given that the date on the notice is a year later and would therefore be impossible. The defendant believes this document is a poorly typed up forgery that is intended to mislead the court. The inconsistencies with the dates and the timescales of it being issued are suspect. On the 14 February 2018 the claimant sent a letter which documented it as “please find enclosed Notice of Assignment as requested”. This document is not a notice of assignment, it is a document that is “Introducing Lowell” as a “specialist debt purchaser who buys accounts”. The defendant believes this to be another attempt to mislead the defendant by misrepresenting it as a formal and legal Notice of Assignment (insert exhibit ref here). The defendant also believes that the Notice of Assignment date (11 April 2014) was used from the very letter the claimant suggested was the actual Notice of Assignment sent by them on the 14 February 2018 and is indeed a forgery. Further to the suspect notice of assignment, the claimants solicitors sent a letter dated “28 March 2017” in reference to this claim that states; “We have requested the documents in support of this claim from our Client and we will forward these onto you upon receipt. Whilst we endeavour to provide evidence of the debt as soon as possible, you will appreciate this is dependent upon receipt of the information from the original creditor”. Sir / Madam, with respect, for a claim being made in court that is for money, the claimant would be expected to have the “evidence” before such claim is made and this implies that they do not and never did have a genuine notice of assignment or indeed a right to make claim. This again is concerning and appears on the basis of it to be misleading the defendant into paying a debt to which he has not entered into with the claimant. Further, the fact the letter is also dated “28 March 2017” suggests, given the inaccuracies so far that this is a mass typed document sent as a standard response. It does not appear to be a professionally typed and sent document by a company of solicitors whereby a far higher standard of professionalism would be expected. The claimant, at the request and order of Judge Anson sent copies of the Notice of Assignment (insert here exhibit ref), copy of Default Notice and copy of the Consumer Credit Agreement. The Default Notice appears to be a reconstituted document and by the claimants solicitors own words in another letter sent as “without prejudice save as to costs” dated “19 April 2018” they clearly state “Please find enclosed a copy of the Credit Agreement, Statement and the Default Notice provided by Vanquis along with a copy of the reconstituted Notice of Assignment and letter of claim”. The claimant has admitted that the Notice of Assignment is not genuine and the discrepancies pointed out earlier in this statement show it to be fraudulent and intended to mislead the defendant and the court. In actual fact, what was received was the Notice of Default, not a Default Notice and a copy of statement of account from the original creditor. This statement clearly documents a “repayment option plan” which was never requested or known to have been applied to the account and has just made the defendant aware of charges that equate to £521.04 over the lifetime of the agreement with the original creditor to which are part of this claim”. This is to be reclaimed as it was never requested and is believed to be a form of Mis-Sold or indeed, Mis-Applied Payment Protection Insurance. The defendant wishes to point out that the default amount is “£2239.13”, yet the claimant has made claim for £2463.43 plus costs and interest totalling £2845.50. The defendant wishes to know how the claimant has made claim for additional monies on top of the actual default balance. This appears to be another inconsistency with their claim. The “copy of agreement” appears to be nothing more than a computer screen capture and until a true copy of the executed Credit Agreement that complies in full with the Consumer Credit Act 1974 is supplied the claimant has no grounds on which to enforce this alleged debt. I ask respectfully, that you strike out this claim and the Claimant be responsible for all costs incurred, given the errors and lack of evidence, respect and attention the claimant has shown towards the Court, Pre-Action Protocol the Civil Procedure Rules and also the Defendant.