Just seen on MCOL that this has been transferred to my local court on Tuesday this week!!

Thank you so much. You are so valuable to us folk.

Yes delete the XXxX from the references in the claim that’s all.

Thanks Andy. This version is now ready to go when I add the references in yes? Thank you for all you do here.

Thanks DX. Over to the fabulous Andy now.

Sorry DX, where is this by in my defence as I can’t see it. thank you for all your help.

Paragraph 2 amended. 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. 1) The claim comprises the following agreements the defendant allegedly entered into: a. Shop Direct Financial Services with reference ########## and current balance of £481.84 b. Vanquis Bank with reference ############ and current balance of £2560.91 c. New Day Ltd with reference ###### and current balance of £1687.37 The defendant does not have an recollection of any of these agreements. 2. Paragraph 2 is denied. The Claimant has yet to supply the defendant with a copy of the any agreement or other such documents requested through the PAPDC reply form and CPR 31.14. The Defendant denies failing to maintain the required payments to Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. It is denied that the Defendant failed to respond to demands for payment sent by the claimant and/or its agents. The Claimant is put to strict proof that any such demands have been sent to the Defendant by the claimant 3. Therefore, the defendant denies owing any money to the Claimant and the claimant is put to strict proof: a. Show how the Defendant has entered into an Agreement. b. Show how the Defendant has reached the amount claimed for. c. That the Defendant failed to maintain the required payments and the service was terminated as claimed. d. Show how any breaches occurred and how valid Default Notices were issued. 4. As per Civil Procedure Rule 16.5(4) it is expected that the Claimant prove the allegation that the money is owed; having been provided with written requests for information under CPR 31.14 and to date have failed to provide any such documentation as detailed on the particulars of claim. 5. The Defendant has also provided the claimant directly with a written Section 78 request pursuant to the Consumer Credit Act 1974 for a true copy of the credit agreement relating to the alleged Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. To date the claimant has failed to provide the requested document copies." 6. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.

Is this any better? 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. 1) The claim comprises the following agreements the defendant allegedly entered into: a. Shop Direct Financial Services with reference ########## and current balance of £481.84 b. Vanquis Bank with reference ############ and current balance of £2560.91 c. New Day Ltd with reference ###### and current balance of £1687.37 The defendant does not have an recollection of any of these agreements. 2. Paragraph 2 is denied. The defendant does not recall any breach and again the Claimant has yet to supply me with a copy of the agreement requested through the PAPDC reply form and CPR 31.14. The Defendant denies failing to maintain the required payments to Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. It is denied that the Defendant failed to respond to demands for payment sent by the claimant and/or its agents. The Claimant is put to strict proof that any such demands have been sent to the Defendant by the claimant 3. Therefore, the defendant denies owing any money to the Claimant and the claimant is put to strict proof: a. Show how the Defendant has entered into an Agreement. b. Show how the Defendant has reached the amount claimed for. c. That the Defendant failed to maintain the required payments and the service was terminated as claimed. d. Show how any breaches occurred and how valid Default Notices were issued. 4. As per Civil Procedure Rule 16.5(4) it is expected that the Claimant prove the allegation that the money is owed; having been provided with written requests for information under CPR 31.14 and to date have failed to provide any such documentation as detailed on the particulars of claim. 5. The Defendant has also provided the claimant directly with a written Section 78 request pursuant to the Consumer Credit Act 1974 for a true copy of the credit agreement relating to the alleged Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. To date the claimant has failed to provide the requested document copies." 6. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.

Hi folks 1) The claim comprises the following agreements the defendant entered into: a. <Mail Order Company> with reference ########## and current balance of £####.## b. <Credit Card Company> with reference ############ and current balance of £###.## a < Credit Card Company > with reference ###### and current balance of £####.## 2.The agreements were terminated as payments were not maintained and subsequently assigned to the claimant. and the claimant claims: a) The total of the said sums being £####.## b) Interest persuant to s69 County Courts Act 1984 at the rate of 8% per annum from the date of assignment to the date of issue, but limited to one year, being £###.## c) costs Amount claimed £####.## Court fee £205.00 Legal Representatives costs £100 Total amount £55## What is the total value of the claim? G£55##.00 I have drawn up my defence to submit this week. Please see below, any advice greatly appreciated:- 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. 1. Paragraph a thru c is accepted insofar that relationships did exist between the Defendant and each of Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. However the Defendant cannot recall these accounts (Agreements) and the Claimant has yet to supply the Defendant with a copy of the Accounts/Agreements mentioned in particulars of Claim. 2. Paragraph 5 is denied, the defendant does not recall any breach and again the Claimant has yet to supply me with a copy of the agreement requested through the PAPDC reply form and CPR 31.14. The Defendant denies failing to maintain the required payments to Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. It is denied that the Defendant failed to respond to demands for payment sent by the claimant and/or its agents. The Claimant is put to strict proof that any such demands have been sent to the Defendant by the claimant 3. Therefore, the defendant denies owing any money to the Claimant and the claimant is put to strict proof: a. Show how the Defendant has entered into an Agreement. b. Show how the Defendant has reached the amount claimed for. c. That the Defendant failed to maintain the required payments and the service was terminated as claimed. d. Show how any breaches occurred and how valid Default Notices were issued. 4. As per Civil Procedure Rule 16.5(4) it is expected that the Claimant prove the allegation that the money is owed; having been provided with written requests for information under CPR 31.14 and to date have failed to provide any such documentation as detailed on the particulars of claim. 5. The Defendant has also provided the claimant directly with a written Section 78 request pursuant to the Consumer Credit Act 1974 for a true copy of the credit agreement relating to the alleged Shop Direct Financial Services, Vanquis Bank, and New Day Ltd. To date the claimant has failed to provide the requested document copies." 6. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief. Thank You again!!

Thanks DX. The only thing I wondered now is shall I send to DCBL last minute or doesn’t it matter.

DQ sent by court on 25th Jan but still not received it. I rang the Business Centre today and they emailed me a copy. I filled it in and emailed back. Its due by 11th Feb. shall I wait until about the 8th or 9th then send paper copy to DCBL?

Yep. They must hate you with a passion.

thanks DX, I have beaten them on 3 occasions so far with your advice. This is the first tripler I've had though.

MCOL shows they have sent me a DQ today. Im not ticking mediation. Do I email the court a copy and also email DCBL a copy? Im not putting contact details such a phone and email on there either. Thanks again.

OC 1 is Shop Direct OC 2 is Vanquis Bank OC 3 is New Day Ltd What do you mean by PB please? New dates noted thank you.

Thanks Andy.

Name of the Claimant ? Lowell Portfolio Ltd Date of issue – 18/1/2022 Date of issue To Acknowledge 04/02/20222 Days to submit defence = 18/02/2022 Particulars of Claim What is the claim for – the reason they have issued the claim? 1) The claim comprises the following agreements the defendant entered into: a. shop direct with reference ########## and current balance of £####.## b. vanquis with reference ############ and current balance of £###.## c. newday with reference ###### and current balance of £####.## The agreements were terminated as payments were not maintained and subsequently assigned to the claimant. and the claimant claims: a) The total of the said sums being £####.## b) Interest persuant to s69 County Courts Act 1984 at the rate of 8% per annum from the date of assignment to the date of issue, but limited to one year, being £###.## c) costs Amount claimed £####.## Court fee £205.00 Legal Representatives costs £100 Total amount £55## What is the total value of the claim? G£55##.00 Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) ?Yes Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? No Did you inform the claimant of your change of address? N/A Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? 2x Credit Card and One Catalogue When did you enter into the original agreement before or after April 2007 ? After Do you recall how you entered into the agreement...On line /In branch/By post ? I think Online Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? Not Sure 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. Assigned and issued by the purchaser Were you aware the account had been assigned – did you receive a Notice of Assignment? No Did you receive a Default Notice from the original creditor? Not Sure, I don’t think so Have you been receiving statutory notices headed “Notice of Sums in Arrears” or " Notice of Arrears "– at least once a year ? No What was the date of your last payment? Unsure but not statute barred 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? No Just to check, do I do a CCA for each one individually or do I do 3 separate ones and can I put them all in the same envelope. Also is it 3 postal orders for £1each, one for £3, or one for £1. I assume CPR to Overdales who are the acting solicitor. thanks

No last thing showing is my defence. No mention of anything else after that.

Here you go. Thanks for the software tip!! CP Plus N180 - Directions questionnaire (Small Claims Track) Redacted.pdf

What is the best way to redact personal info on the pdf Dave?

Morning all DCBL have sent me their questionnaire via email. I haven't been asked form the court for mine yet. They state they want it at the claimants home court and I will obviously state at mine. How do they normally decide the location on these thing? Thanks

Lovely. Thanks Dave.

Sorry, I meant SAR. I’m. It not that thick, honest lol. I know it’s due in 6bdays but I don’t want to get caught up in Xmas and miss it.

Thanks. Can anyone tell me if my defence is fine to submit please? Also, should I CCa the parking company for paperwork or not?

Morning all Im going to put my defence in this week as above. I have had a response from DCBL to the CPR which I have uploaded. They also sent a letter of authorisation from MOTO dated Dec last year. They also sent a load of photos for a completely different Service station lol. Can someone pleas have a look and advise me? Thanks DCBL Letter Reposnse to CPR Redacted.pdf DCBL Repsonse to Services Authority.pdf.pdf