What is the claim for – the reason they have issued the claim? 1 The claim is for the sum of £600 due by the Defendant under an agreement regulated by the Consumer Credit Act 1974 for a PayPal account with an account reference of —————

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 2 is denied. I am not aware of service of a Default Notice by the original creditor the Claimant refers to within its particulars of claim. 3. Paragraph 3 is noted. On the 5/06/2022 I requested information related to this claim by way of a Section 78 request, As of today, the Claimant has failed to respond to this request, and therefore remains in default of the section 78 request and therefore unable to enforce any alleged agreement until its compliance. 4. Therefore it is denied 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 the nature of the breach and evidence by way of a Default Notice Pursuant to s.87(1) of the Consumer Credit Act 1974. 5. As per Civil Procedure 16.5 it is expected that the Claimant prove the allegation that the money is owed. 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.

What was the outcome of you declining mediation? I ask as I have mine on the 12th and intend to follow the same path and decline whilst on the call.

From legal advise I’ve taken They will defend the invalid default notice with the case American Express vs Karl Robert Brandon 2010 where the precedent is that American Express did not register the default on the day on the letter and therefore 14 days was given. There isn’t a Brexit precedent, Section 16 of the agreement signed says the law courts of England will govern the agreement and have jurisdiction over disputes. Just what I’ve been told.

Which Court have you received the claim from ? Northampton Name of the Claimant ? Lowell Portfolio Ltd Date of issue – 25th May 22 Particulars of Claim What is the claim for – the reason they have issued the claim? Please type out their particulars of claim in full (verbatim) less any identifiable data and round the amounts up/down. PayPal Credit Default What is the total value of the claim? £1105 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? Yes Did you inform the claimant of your change of address? No Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? No 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 ? Online Is the debt showing on your credit reference files (Experian/Equifax/Etc...) ? Yes 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 to Lowell from Paypal 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? No Have you been receiving statutory notices headed “Notice of Sums in Arrears” or " Notice of Arrears "– at least once a year ? No Why did you cease payments? Couldn’t maintain payments due to unemployment What was the date of your last payment? Sept 2019 Was there a dispute with the original creditor that remains unresolved? Yes Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? No

So they are pressing ahead with it. Got a letter today. issue date 25th May, from Northampton County court Business centre. there’s a response pack, an admission form and a defense form. what’s my best course of action now?

Through the door today dated 11/4/22

Thankyou for the reply. PayPal have closed my account so I can’t actually log into it to view either the agreement or the balance or the transaction history. On the original email it does state Credit is offered by PayPal (Europe) S.à.r.l et Cie, S.C.A which is duly licensed as a Luxembourg credit institution and is under the prudential supervision of the Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier.

Overdales have sent me a "Letter of Claim" - 30 days to prevent legal action. Along with a Financial Status sheet and a Reply Form. The Debt is £600 with Paypal Credit. The letter states : on 01-05-2018 you entered into an agreement with Paypal Europe Sarl & Cie SCA to provide you with a Paypal Credit account. The Last payment I made was October 2019 They state that the agreement was terminated and assigned to our client (Lowells) on 15/9/21 The Paypal account was in dispute for a return on a faulty item that was lost by a courier and never recovered, They refused to refund it, which is why it remains unpaid. Is there anything i Can do to avoid court action or do I just finally have to take the hit? Thanks!