Thanks Andy, that makes sense.

Thank you, its all becoming clearer how this works. Not sure what you mean by ‘1 wit you’? When you say ‘you then state No’ - do you mean I state ‘no contract has been provided’ at the mediation call?

Ok so just to ensure I’m clear I should now complete the form and say yes to mediation - is that correct? May I please ask if that will then force the claimants hand to disclose the contract they are relying upon? To date its all felt like escalation for the purpose of intimidation without any evidence being produced.

May I please ask why you advise not to go to mediation? Is it just a waste of time? Would the courts not frown upon me not attempting mediation? Please feel free to DM me if you don't wish to answer this question publicly. I'm not sure I understand what you mean below: '3 copies etc etc as any pcn claimform thread already here' Could you please elaborate on this, apologies if I'm being slow?

sorry I thought I had replied but must have not clicked submit I checked the MCOL status and it says 'DQ sent to you on 06/12/2021' I can't see anything about N180 on the status.

It is correctly addressed to me with the correct address on page 1

Hello, Unfortunately Brachers made no attempt to contact me to try to resolve the matter during the 28 day period since they were served with my dispute of the claim. They have not provided any contracts/documentation as evidence of the amount being claimed. I have now received the attached. I would very much appreciate your advice as to how to respond. Many thanks FL CC Doc Dec 2021 goldsmiths no details.pdf

Thank you DX and Andy. I will submit it now.

Thanks again. Corrections made. Shall I submit now? The Defendant contends that the particulars of this claim vague and are 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. The Claimant has not complied with paragraph 3 of the PAPDC (Pre Action Protocol). The Claimant Failed to serve a letter of claim pre claim pursuant to PAPDC changes of the 1st October 2017. It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC. 1. It is denied that details of the tuition fees have been delivered to me. It is denied I entered into any form of credit agreement with Goldsmith’s University. 2. It is denied any sums are outstanding or due. 3. Further on 28th September 2021 I issued a CPR 31.14 Request to Brachers LLP Solicitors requesting the signed Contract or Agreement and any General Terms and Conditions relied upon for this claim. The CPR 31.14 request was delivered on 1st October 2021 by Royal Mail Signed for postal service tracking number GQ-redacted-GB To date I have not received a reply to this nor have I received any documentation evidencing the validity of the claim from Brachers LLP or any other party. On the basis that STA and Brachers LLP acting on behalf of Goldsmith’s University have not produced a signed agreement or contract as evidence that I owe this amount I dispute the claim in full. 4. It is denied the claimant is entitled to claim interest pursuant to sec69 of the County Court Act 1984. It is denied that there is any debt outstanding or due. 5. Notwithstanding the above the claimant is invited to disclose all relevant documents in connection to its claim and on which its claim is based. Pursuant to CPR 16 and PD 16 any claim for monies based on a contract/agreement must be disclosed and the original signed contract /agreement are available for any hearing. 6. 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.

Do I need to add the below red text to the top of my actual defence submission please? 1.The Claimant claims the sum of £1117.00 in respect of tuition fees, details of which have been delivered to the defendant. 2.Payment has not been made and the Claimant therefore claims - 1. The sum of £1117.00 being as the sum due. - 2. Costs 3.The claimant has complied with the Pre-Action Protocol for Debt Claims dated this 20/9/2021. 4.The Claimant claims interest under the section 69 of the County Court Act 1984 at the rate of 8.00% a year from 07/03/2017 to 20/09/2021 on £1117.00 and also interest at the same rate up to the date of judgment or earlier payment at a daily rate of £0.24

Thank you, here it is: The Defendant contends that the particulars of this claim vague and are 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. The Claimant has not complied with paragraph 3 of the PAPDC (Pre Action Protocol). The Claimant Failed to serve a letter of claim pre claim pursuant to PAPDC changes of the 1st October 2017. It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC. 1. It is denied that details of the tuition fees have been delivered to me. It is denied I entered into any form of credit agreement with Goldsmith’s University. 2. It is denied any sums are outstanding or due. 3. Further on 28th September 2021 I issued a CPR 31.14 Request to Claimant Michael Ronald Oatham of Brachers LLP Solicitors requesting the signed Contract or Agreement and any General Terms and Conditions relied upon for this claim. The CPR 31.14 request was delivered on 1st October 2021 by Royal Mail Signed for postal service tracking number GQ-redacted-GB To date I have not received a reply to this nor have I received any documentation evidencing the validity of the claim from Brachers LLP or any other party. On the basis that STA and Brachers LLP acting on behalf of Goldsmith’s University have not produced a signed agreement or contract as evidence that I owe this amount I dispute the claim in full. 4. It is denied the claimant is entitled to claim interest pursuant to sec69 of the County Court Act 1984. It is denied that there is any debt outstanding or due. Notwithstanding the above the claimant is invited to disclose all relevant documents in connection to its claim and on which its claim is based. Pursuant to CPR 16 and PD 16 any claim for monies based on a contract/agreement must be disclosed and the original signed contract /agreement are available for any hearing.

Thank you very much. Will do that now and submit.

Thank you, re-drafted: 1.The Claimant claims the sum of £1117.00 in respect of tuition fees, details of which have been delivered to the defendant. 2.Payment has not been made and the Claimant therefore claims - 1. The sum of £1117.00 being as the sum due. - 2. Costs 3.The claimant has complied with the Pre-Action Protocol for Debt Claims dated this 20/9/2021. 4.The Claimant claims interest under the section 69 of the County Court Act 1984 at the rate of 8.00% a year from 07/03/2017 to 20/09/2021 on £1117.00 and also interest at the same rate up to the date of judgment or earlier payment at a daily rate of £0.24 The Defendant contends that the particulars of claim vague and are 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. 1. It is denied that details of the tuition fees have been delivered to me. It is denied I entered into any form of credit agreement with Goldsmith’s University. 2. It is denied any sums are outstanding or due. 3. The Claimant has not complied with paragraph 3 of the PAPDC (Pre Action Protocol) Failed to serve a letter of claim pre claim pursuant to PAPDC changes of the 1st October 2017.It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC. 4. It is denied the claimant is entitled to claim interest pursuant to sec69 of the County Court Act 1984. It is denied that there is any debt outstanding or due. Notwithstanding the above the claimant is invited to disclose all relevant documents in connection to its claim and on which its claim is based. Pursuant to CPR 16 and PD 16 any claim for monies based on a contract/agreement must be disclosed and the original signed contract /agreement are available for any hearing.

I've also added this paragraph at the top. The Defendant contends that the particulars of claim vague and are 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.

Thank you, Just read that defence and this is what I have as my draft: I am concerned as I'm already potentially late - that I should just get something submitted asap? I have previously been contacted by STA Debt Collectors regarding this amount which they claim is owed to Goldsmith’s University. I have by phone and in writing by email on 19th November 2020 requested that STA provide evidence of the amount owed in the form of a signed contract or agreement and any terms and conditions incorporated which apply to this claim. I have to date not received such documentation to prove that I owe this amount. I have received notice of the County Court Claim without having received any Pre Action Protocol documentation such as a signed contract/agreement. Further on 28th September 2021 I issued a CPR 31.14 Request to Michael Ronald Oatham of Brachers LLP Solicitors requesting the same information. The CPR 31.14 request was delivered on 1st October 2021 by Royal Mail Signed for Post tracking number GQ-redacted-GB. To date I have not received a reply to this nor have I received any documentation evidencing the validity of the claim from Brachers LLP or any other party. On the basis that STA and Brachers LLP acting on behalf of Goldsmith’s University have not produced a signed agreement or contract to prove that I owe this amount I dispute the claim in full. Notwithstanding the above the claimant is invited to disclose all relevant documents in connection to its claim and on which its claim is based. Pursuant to CPR 16 and PD 16 any claim for monies based on a contract/agreement must be disclosed and the original signed contract /agreement are available for any hearing. I will be out of the country from 28th October 2021 until 13th November 2021 but can be reached by email and telephone. Contact details redacted