Would this be ok or should it be worded better?
Particulars of claim for cross reference only
The claimant claims payment of the overdue balance due from the defendant (s) under a contract between the Defendant (s) and NEXT Directory dated on or about Aug 23 2008 and assigned to the claimant on Jun 09 2016.
PARTICULARS a/c no - *******
ITEM: Default Balance
Post Refrl NIL
1 The Defendant contends that the particulars of claim are vague and generic in nature.The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made.
2. Paragraph 1 is noted. I do not recollect any outstanding debt and have therefore requested clarification by way of a CPR 31.14.
3. Paragraph 2 is denied I have not been served with a Default Notice pursuant to the consumer credit Act 1974.
4. Paragraph 3 is denied. I am unaware of any legal assignment or Notice of Assignment pursuant to the Law and Property Act 1925 Section 136(1)
5. A request was made via CPR 31.14 to the claimant’s solicitor, requesting disclosure of documents on which the Claimant is basing their claim. The claimant has not complied and to date nothing has been received.
6. On MY DATE I made a CCA Request to the claimant, I received a response to this on MY DATE but it was just to falsely state that the claimant could not comply because of data protection.
7. It is therefore not accepted with regards to the Defendant owing any monies to the Claimant and the Claimant is put to strict proof to:
a) show how the Defendant has entered into an agreement and;
b) show how the Defendant has reached the amount claimed for and;
c) show the nature of the breach and evidence by way of a Default Notice pursuant to sec 88 CCA1974
d) show how the Claimant has the legal right, either under statute or equity to issue a claim
8. As per Civil Procedure 16.5 it is expected that the claimants prove the allegation that the money is owed
9. On the alternative, as the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of section 136 of the Law of Property Act and section 82A of the Consumer Credit Act 1974
10. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.