hopefully that had nothing to do with me!!!

and then they sent this letter - the one they refer to in the cpr 18 response received today attached above 1st Credit Limited The Omnibus Building Lesbourne Road Reigate Surrey RH2 7JP 21st April 2010 Tel: 01737228555 Fax: 0843 320 0070 • Dear Sir 1stCreditreference: xxxxx_ Thank you for your letter dated 8th March 2010. I have had the opportunity to look into your account and comment as follows. With respects to the letter enclosed with the copy of your agreement, we would clarify this being a computer generated letter, dispatched when an agreement IS issued. Clealiy this was an administrative error which we apologise for. We are aware that the copy agreement was not supplied within the specified time period however, on provision of this document, the debt has once again become en• forceable. Therefore your assertion that this debt is now 'irredeemably unenforceable' is incorrect. Please note that the request for a copy agreement was made to 1st Credit Ltd, not CitiFinancial therefore your comments that the account should not have been passed to 1s;Credit Ltd are incorrect. The copy agreement which was sent to you is a true copy of your agreement with CitiFinancial and from your comments it appears necessary to clarify the definition of a 'true copy' of an agreement. Where a creditor receives a request to supply a copy of the executed agreement, the Consumer Credit (Cancellation Notices and Copies of Documents) Regulations 1983apply. Regulation 3(1) sets out that 'every copy of an executed agreement ... shall be a true copy'. Regulation 3(2) goes on to state that there may be various information omitted from this true copy. Details which are not required to be in the agreement by law include the signature box, signature and date of signature. Therefore the effect of Regulation 3(2) is that the creditor is only obliged to send out a generic copy of the agreement the debtor has signed up to. The creditor is not obliged to make an actual photocopy of the agreement. Therefore 1st Credit Ltd has complied with the obligations of the law and has provided you with a true copy of the agreement. For your records ~and pursuant to your CCA Section 78 request, your statement of account is as follows» a) The state of the account = £6,727.12 outstanding. b) The amount, if any, currently payable under the agreement by the debtor to the creditor = £6,727.12. c) The amounts and due dates of any payments which, if the debtor does not draw further on the account, will later become payable under the agreement by the debtor total for credit or ==£6,727.12. As the Copy Agreement and Statement of Account has been supplied, our obligations regarding your request for information under Section 78 of the Consumer Credit Act 1974 have been fulfilled and the default no longer continues. We would decline your requests for a full refund of the payments made towards the account. We advise that your request for us to remove your data from either our records or the credit reference agencies is unjustified as you have a debt that is due and payable, with no clear substantiated dispute. Further, you have not specified upon which ground you rely for your notice under s10 of the Data Protection Act and therefore we do not consider this valid; additionally this is not a valid request as it falls under the exemption in Schedule 2 section 2(a) of the Act. Should we receive correspondence from any of the regulatory bodies we shall respond to them accordingly. We' would therefore respectfully request you to contact our office within 14 days from the date of this letter to discuss a payment arrangement for this account. We; look forward to hearing from you. Yours faithfully Humera Shamsuddin Compliance Officer Registered No. 3752940 in England and Wales Registered Office: Hill House, 1 Utile New Street, London EC4A 3TR

And mye response to all that was the following letter - 1st Credit, Administration Dept PO Box 278 Reigate Surrey RH2 7WB Monday, 08 March 2010 Dear Sir/Madam Your Ref xxxxxxxxx Citi Financial Acct No xxxxxxxxxxxxxxxx Before I continue I wish to establish that I am not seeking to avoid responsibility for any alleged debt or breach of any alleged agreement that I may have or have had. I am writing following receipt of an undated letter from your company and some documentation this week, purporting to be an edited copy of a credit agreement that existed between me and Citi Cards. Firstly your letter states that the documentation you enclosed was signed and you have asked me to confirm that my signature is the one on the paperwork. In the documentation you have sent to me there are no signatures whatsoever I am therefore obviously not in a position to comment any further on this matter. If you check your files you will see that I wrote to your company on 21-06-07 (Almost three years) by recorded delivery (ref No xxxxxxxx) asking for a signed true copy of the above agreement number with the with the relevant information under Section 77-79 of the Consumer Credit Act 1974, enclosing a £1.00 postal order as the fee payable. This letter was delivered and signed for on 23-06-07 The Consumer Credit Act allows 12 working days for this request to be carried out before your company enters into a default situation. This occurred on 6th July, 2007. Because the request was not satisfied after a further calendar month, your company committed an offence. Therefore on 6th August 2007 this time limit expired. In the 33 months that have elapsed since I first requested I have never received a copy of the agreement as required by S78 Consumer Credit Act 1974, nor any other information relating to same. As such, this account has become irredeemably unenforceable by law. As you are no doubt aware subsection (6) states: If the creditor under an agreement fails to comply with subsection (1)— (a) He is not entitled, while the default continues, to enforce the agreement; and (b) If the default continues for one month he commits an offence. As such, when the 12 working days expired (from your receipt of the request for the agreement and supporting documents) the account was in dispute, which your company was informed about and a complaint was lodged with the Financial Ombudsmen. As you are aware whilst an account is in dispute the agreement is unenforceable and no interest can be added to the account nor can any action be taken against me. No adverse credit references or defaults can be listed against me with Credit Reference Agencies. The account should not have been passed to a Debt Collection Agency such as yourselves. And lastly, I am not obliged to make any further payments to the account. Essentially, the account was ‘held’ as it was on the date of the CCA request expiring (6th July, 2007) I then wrote to you again on the 30-11-07 by recorded delivery (REF xxxxxxx) and this letter was delivered and signed for on the 03-12-07 by L Brazier. In this letter I stated then that because you had not complied with my original request in a letter dated 21-06-07 for an original signed copy of the executed agreement and statement of account that It was then and still is now my consideration that you have been unable to supply an agreement because no such agreement exists. Consequently, after 33 months of your company being unable to comply with my legal request, I still do not acknowledge any debt to your company. I confirmed in my letter of 29-11-07 that if I did not hear from you within the legal timescales that I would consider the matter closed, which is still my position. As 33 months have now passed since my original request for information, it is clear you are unable to provide me with the information I have requested and I must insist that you cease chasing this unsubstantiated debt with immediate effect. Furthermore, you are totally aware that a credit agreement that is not properly documented and signed by the customer is totally unenforceable under the Consumer Credit Act 1974 and is therefore a complete defence to any court claim that is issued. Please take note that any legal action you may contemplate will be vigorously defended and contested. Because you have not been able to provide me with the relevant documentation within the legal timeframes, any debt that you are attempting to recover is now irredeemably unenforceable. As you are unable to provide me a signed True Copy of my original Credit Agreement with Citi Cards and as the alleged debt is irredeemably unenforceable, I require the following action from 1st Credit : 1. All payments made to date to Citi Financial for this account (xxxxxxx) should be refunded in full, including interest at the rate of 8% per annum. 2. Removal of all defaults entered by Citi Financial or 1St Credit. Note this is to be a complete deletion and not merely an amendment. 3. I look forward to compensation under Section 13 of the Data Protection Act 1998 to be offered for the processing of my data in the manner it has been done over the past number of years. 4. After a full refund of all payments with interest and compensation are received by myself, you will be required under Section 10 and Section 12 of the Data Protection Act 1998 to cease and desist all manual and automatic processing of my data within your company and any other company within your group. If you do not respond positively to my request, court action may be taken under Section 14 of the Data Protection Act 1998 to force 1st Credit or any other company within the group to comply with the refund of all monies paid, removal of all defaults maintained and compensation for damage and distress as a result of unlawful data processing. I may also pass the matter to the relevant enforcement authorities including, but not limited to, the OFT, the Information Commissioners Office, Trading Standards, the CSA, the FOS and my local MP. I stated in my letter of 29-11-07 that any further action on your part or that of my alleged original creditor pursuant to your and/or their breaches of my statutory rights would be taken as a wilful act of harassment and each instance would be reported to the police. As you have now chosen to ignore my statement in my last letter I consider that your latest correspondence to be a wilful act of harassment and unless my requests are complied with within 14 days I will not hesitate to immediately report your company to the police for harassment. I will not hesitate to take this matter to court if you continue in this harassment. As you are aware, your non-compliance with my request meant that your company has committed an offence under Section 77 (4) of the Consumer Credit Act 1974, summarily punishable by a Level 4 fine on the standard scale. Yours faithfully, Mr W Sxxxxxx

OK so here is the text of the documentation in the order it came in - I have done a separate post for each one FIRST ONE Letter from 1st Credit with 2 copies of "my" CCA's Ist credit PO BOX 278 Reigate Surrey RH2 lWB Tel: 08433200000 - Dear Mr Wxxxxxxx Sxxxxx. Re: Copy agreement/Contract Ref: xxxxxx - THis was not my account No We attach an edited copy of the signed agreement in respect of the above account and would ask for your comments. a) If you confirm that this is your signature we will of course send you a complete copy of the relevant document. We would also invite your proposals for settling this outstanding debt. b) If this is not your signature we would ask you to provide our office with a copy of your signature from an official document, (such as a driving licence/passport), to substantiate your claim. Please be assured that the matter will be investigated immediately, this is not required but will of course assist us in resolving this matter. c) Where an address is detailed that you do not reside in we would ask you to comment on whether you ever resided at the address and, if so, the period of your occupation. d) If we believe that a fraud has taken place against you we will advise you. In these circumstances we would recommend that the matter is reported to the local Police and 1 st Credit Ltd will of course co-operate fully to ensure the matter is thoroughly investigated. Thank you for your assistance in this matter. Yours sincerely 1 st Credit Ltd Registered No. 3752940 in England and Wales Registered Office: Hill House, 1 Little New Street, London EC4A 3TR ===================================================================== THIS IS THE 1st AGREEMENT THAT WAS ENCLOSED THIS WAS SENT TO AN ADDRESS I MOVED OUT OF IN 2004 - 2 pages 0504 01 09 2002 Citibank VCS PL Credit Agreement regulated by the Consumer Credit Act 1974 243 376 This is a copy of your Agreement for you to keep. It includes a notice about your cancellation rights which you should read. Creditor: Citibank International plc, of 336 Strand, London, WC2R 1HB IMPORTANT - YOU SHOULD READ THIS CAREFULLY - YOUR RIGHTS The Consumer Credit Act 1974 covers this Agreement and lays down certain requirements for your protection which must be satisfied when the Agreement is made. If they are not, we cannot enforce the Agreement against you without a court order. The Act also gives you a number of rights. You have a right to settle this Agreement at any time by giving notice in writing and paying off all amounts payable under the Agreement. If you have obtained unsatisfactory goods or services under a transaction financed by the Agreement, apart from any purchased out of a cash loan, you may have a right to sue the supplier, us or both. Similarly, if the contract is not fulfilled, perhaps because the supplier has gone out of business, you may still be able to sue us. If you would like to know more about the protection and remedies provided under the Act, you should contact either your local Trading Standards Department or your nearest Citizens Advice Bureau. FINANCIAL AND RELATED PARTICULARS We will determine the credit limit and notify you direct. We may vary the limit at our discretion and will notify you of any change. Minimum monthly payment will be the larger of £5 or 3% of the outstanding balance (or the full balance outstanding if less than £5) shown on the periodic statement of account sent by LIS to you payable within 25 days from the date of each statement. The minimum amount or percentage or time within such monthly payment is payable to be variable at our discretion on seven days written notice to you. There is a minimum interest charge of 50p_ So if the interest we work out is less than SOp, 50p will appear on your statement as the amount you must pay. After any promotional period that we may choose to offer you relating to balance transfers has come to an end, the rate of interest to be charged on any balance transfer shall be the same as that charged upon purchases. The current debit rates for purchases, balance transfers and cash advances on Citibank VISA Cards are: PAGE A2 Debit Rates APR (variable) Monthly Purchases 18.9% 1.456% Cash Advances 19.1% 1.456% Balance Transfers 18.9% 1.456% A service charge of 3% will be made on the amount of any cash advance (apart from the initial cash advance) or cheque advance (subject to a minimum of £5). Debit rates and charges are variable at our discretion on seven days written notice to you. We do not usually charge for servicing your account. However, if at the end of each 12 month period after your account is opened and in any subsequent 12 month period either one of the following occurs: (i) the total value of transactions on your account is less than £1000 or (ii) if no interest has been charged on your account then we will charge you a low usage service charge of £10 in advance for the 'fpllowing 12 months. This charge does not count as a transaction or interest when we calculate whether the low usage service charge is payable and is not included in our ~APR or monthly interest calculations. NB •. 1. In calculating the APR, no account has been taken of any variation which may occur under this Agreement of the rate of interest or cash advance service charge payable in the circumstances set out above. 2. For further information including variation please see Terms and Conditions as follows: For Credit Limit - under Credit Limit Monthly Payment - under Monthly Payment Interest Rate and Service Charge for purchases, cash. balance transfers and cheque advances -under Charges and costs. RESPONSIBLE LENDING We appraise all applicants' financial circumstances carefully and make any credit reference or other enquiries we consider appropriate. LOSS OR MISUSE OF CARD If the card is lost, stolen or misused by someone who obtained it without your consent, you may be liable for up to £50 of any loss to us. If it is misused with your permission you will probably be liable for ALL losses. You will not be liable for losses to us which take place after you have told us of the theft. etc. provided you confirm any oral message in writing within seven days. CREDIT SCORING We will use a credit scoring or other automated decision making system when assessing your application. ========================================================================== OTHER 14 PAGE CCA DOC WITH CURRENT ADDRESS PAGE B1 Credit Card Agreement regulated by the Consumer Credit Act 1974 This is a copy of your agreement for you to keep. It includes a notice about your eaneellatien rightg, which you should rQad. This agreement is between us: CitiFinancial Europe plc of 87 Castle Street, Reading, Berkshire, RG17DX, and you: Mr wXXXXXX sXXXXX XXXXX XXXXX XXXX XXX KEY FINANCAL INFORMATION 1. We will set a credit limit for your Account and keep you informed what it is. We may change your Credit Limit at any time but will tell you when we do. 2. If you have a Balance on your Account. statements will be issued monthly and will show the payments credited and Transactions debited to your Account since the last statement. Your Account statements will show the minimum amount you must pay and the date by which you must make this payment. The Payment Due Date will be 25 days after the date of the statement. On making the relevant arrangement with us, the Payment Due Date can (in most cases) be amended. 3. Unless we tell you otherwise, the minimum monthly amount you must pay on your Account will be (where applicable): 3.1 the greater of £5 or 3% of the Non-Citi Flex Payments Balance; plus 3.2 the Citi Flex Payments Monthly Instalment. 4. The APR is 19.5% APR (variable). OTHER FINANCIAL INFORMATION 5. Your total charge for credit is £145.18. The total charge for credit is based on the assumptions that when you open your Account you make a purchase of £1 ,500 which you repay by 12 equal monthly repayments and interest is charged during that period at the standard rate for Purchases. When we send you a new Card, we will show your total charge for credit and this will reflect your standard interest rate for Purchases. 6. The standard rates of interest that we will charge you on Purchases, Balance Transfers and Cash Advances are: PAGE B2 243 376 Purchase Rate Balance Transfer Cash Advance I Monthly Per annum Monthly Per annum Monthly Per annum Rate (variable) Rate (variable) Rate (variable) 1.496% 17.9% 1.496% 17.9% 2.079% 24.9% 7. We may. at our discretion. at any time and for any period grant you a lower promotional interest rate for any of your Purchases, Balance Transfers and Cash Advances (including Credit Card Cheques and Purchases or Cash Advances converted to a Citi Rex Payments facility under clause 26) ("Promotional Balances") than the standard rates set out above. We will tell you at the time what any lower promotional rate is. If you: 7.1 do not make the minimum monthly payment required under clause 3 in cleared funds by the Payment Due Date; and/or 7.2 exceed your Credit Limit without our permission; and/or 7.3 at any time breach the terms of this agreement in any other way, we may, in addition to other action we may take, replace any lower promotional rate applicable to Promotional Balances with the applicable standard rate of interest set out in clause .6. The fees set out in clause 12 will also apply. Interest ctta"rges are calculated and applied as follows: 8.1 Purchases If you pay in full the Balance shown on your current statement by the Payment Due Date, you will not pay any interest on Purchases shown on your statement. If you pay in full the Balance shown on your current statement by the Payment Due Date but did not pay in full the Balance shown on your previous statement by the Payment Due Date, we will charge interest on each Purchase shown on your previous statement on a daily basis from the date of the relevant Purchase until you have paid the Balance in full. For the Balance to be cleared in full. this payment will need to include all interest accrued since the date of the statement until your payment clears onto your Account. 8.2 Cash Advances, Balance Transfers and Citi Flex Payments Interest is charged from the date of a Cash Advance until it has been repaid in full. Interest is cbarged from the date a Balance Transfer and/or Citi Flex Payments facility is charged to your Account, until it has been repaid in full. For these balances to be repaid in full. any payment will need to include all interest accrued since the date of the statement until your payment clears onto your Account. Interest will accrue to your Account on a daily basis and will form part of the interest Charged on your statement. 8.3 If we charge interest to your Account on any statement, this will be a minimum of 50p. Any billed Account Charges will immediately attract additional interest. As we charge interest on the daily outstanding balance, interest charges will increase the longer payment is delayed. 9. All payments we receive from you will (unless otherwise required by law) be applied to your Account in the following order: 9.1 Citi Flex Payments Monthly Instalment (to be applied to each Citi Flex Payment facility in the order of creation); 9.2 other interest and Account Charges; 9.3 existing Promotional Balances -lowest rates first; 9.4 new Promotional Balances - lowest rates first; 9.5 existing Purchase balances and non-promotional Balance Transfers - in the order in which they were debited to your Account as shown on the monthly statement; 9.6 new Purchase balances and non-promotional Balance Transfers - in the order in which they were debited to your Account but not yet shown on the monthly statement; 9.7 existing Cash balances shown on the last monthly and/or previous statements - in the order in which they were debited to your Account as shown on the monthly statement; PAGE B3 243 376 9.8 new Cash balances - in the order in which they were debited to your Account but not yet shown on the monthly statement; and 9.9 the balance of each Citi Flex Payments facility (to be applied to each facility in the order of creation). 10. In calculating the APR and the total charge for credit, we do not take into account any changes in our rate of interest that may occur. '11. We will regularly monitor your Account and the rates of interest charged. We may. at our sole discretion. vary the rates of interest charged at any time. In varying int~r~st rates we may consider factors such as our assessment of your creditworthiness (based on how you have maintained your Account and information provided by credit reference agencies) or general market conditions. We will always give you notice of any such changes to your rates of interest. KEY INFORMATION 12. In the instances stated below. your Account will be charged with the following service fees (unless otherwise specified, interest will be charged at the standard rate for Purchases): 12.1 Late fees: £12 each time we do not receive the minimum payment required on or before the Payment Due Date specified on each statement; 12.2 Overlimit fees: £12 if your Account Balance exceeds the Credit Limit on the statement date; 12.3 Returned payments: £12 each time a payment to your Account is not honoured when presented for payment: and 12.4 Insufficient funds: £12 each time you use a Credit Card Cheque issued from your Account when you do not have sufficient funds to cover this amount (for non-promotional Credit Card Cheques. interest on this service fee will be charged at the standard rate for Cash Advances; for promotional Credit Card Cheques, interest on this service fee will be charged at the promotional rate applicable to the relevant Credit Card Cheque). 13. The annual fee payable on your Account is £0. If an annual fee is payable. it will be charged on the anniversary of the Account opening date. No interest is charged on annual fees. 14. A service fee of 2% will be charged to your Account on the amount of any Cash Advance from a Banking Facility (subject to a minimum of £5). Interest will be charged on this fee at the standard rate for Cash Advances. If a Cash Advance from an ATM requires more than one withdrawal. each withdrawal will be treated as a separate Cash Advance. 15. We will charge a service fee to your Account in relation to other Cash Advances. Such service fee will be the higher of (i) £5 or (ii) 3% of the amount of each such Cash Advance. Interest will be charged on this fee at the standard rate for Cash Advances. 16. We will charge a service fee to your Account in relation to Balance Transfers. Such service fee will be 3% of the amount of each Balance Transfer (subject to a minimum service fee of £5). Interest will be charged on this fee at the standard or promotional rate applicable to the relevant Balance Transfer. 17. We will convert any Transactions that are made in a foreign currency into Sterling/Dollars (whichever is applicable to your account) at the exchange rate set by Visa or MasterCard on the date we process the Transaction. We will charge to your Account 2.75% of the value of each foreign currency transaction made and the Sterling/Dollar (whichever is applicable to your account) amount shown on your statement will include this fee. In the case of a Cash Advance, this charge will be in addition to the service fee in clause 15. 18. Should you request a copy, an administration fee will be charged for the documents listed below: 18. 1 £3 for each copy statement (this will be charged to your Account and interest on this fee will be charged at the standard Purchase rate); : 18.2 £10 for an authorised sales voucher (this will be charged to your Account and interest , will be charged on this fee at the standard Purchase rate); 18.3 £10 for the information we hold about you and your Account. in accordance with clause 39.12 and the Data Protection Act 1998 (we will ask for this payment separately); 18.4 £1 for a copy of your agreement (this will be charged to your Account and interest on this fee will be charged at the standard Purchase rate).

OK here are the copies of the CCA's they sent through as well as two letters one that came with the CCA's & one that was their reposne to my letter sent when they sent the CCA's. I will post the text of all the letters too in the next post. 100421 letter from 1st C response to my letter dated 08-03-10.pdf 1stC undated letter 2 CCA copies.pdf

Hi Brig - I have a note on the 1st letter I got from them that said they ceased to practice on 02-06-2010 but i havent made a note of where i got that info from - I assume it was off this forum. I will dig around in a bit and see what I can find. Scanning almost finished

Explorer 9

OK just scanning this stuff now - there will be 5 documents - 1 undated letter from them that arrived WC 01-03-10 with all of the copied stuff 2 1st lot of copies of CCA from Citi bank 14 pages long with 42 points from Citi & bmibaby cards on top 3 another CCA 11 pages long and with an address that I moved from in 2004! 4) my letter in response to the stuff they sent through 5) their response to that letter where they refer to the agreement/s I have no idea whay they sent through 2 lots of paperwork and there are no account numbers anywhere!

##UPDATE - COPY OF LCS LETTER## - Does anyone have any idea why the font colour icon isnt working?????? I have added my comments in bold underlined and in brackets as I cant change the folt colour LCS The Omnibus Building | Lesbourne Road | Reigate | Surrey | RH2 7JP Tel 0843 3200020 | Fax 0843 3200001 Email:[email protected] W xxxxxx Sxxxxxx Esq .. Please quote our reference in all Correspondence 19 July 2011 Dear Sirs. Claim No: _ 1stCredit (Finance) Limited-v- We enclose a Notice of Change of Solicitors by way of service upon you. We note that you consider that you have a CPR Part 18 request outstanding and that you require further time within which to serve a defence. ( Err well yes I do consider this is outstanding seeing as they didnt respond before today) As to your request under Part 18, . we refer to your letter dated 4 July 2011 addressed directly to our client at a time when you were well aware that Messrs. Judge & Priestly were on record as acting for the Claimant (and so do i get a slap on the wrists for being naughty and writing to 1st Crud). The format of the request is familiar to us being one freely available on the usual internet debt forums (And your point is what exactly? Without the stars on these forums you **** bags would get away with murder!. Rather than take the procedural point (what exactly do they mean by this), we will respond to the questions raised and will use your numbering to respond. 1. You have been provided with the Agreement upon which we intend to rely. You acknowledged receiving it within your letter dated 8 March 2010. Our further letter dated 21 April 2010 refers. 2. You were advised that you were sent the default notice in May 2007. (They did state this in a letter yet no proof of postage has been received and they have never sent a copy of it.) 3. We are not obliged to provide this to you – (Very interesting – need the CAG experts opinion on this ) 4(a) We are not obliged to provide copies of our recorded telephone conversations –( Is this true) 4(b) We do not possess any information from Citi as to any manual intervention on this account. Should any such information come to light we will provide it under the usual rules as to disclosure. 4© We have no information as to insurance as our client would not have been the insurer in any event. If such existed then you as the insured should be able to obtain information from any insurer involved. 4(d) We are unaware of any collection charges added to the account. We will provide any such information if it becomes available. 4( e) We are unaware of any other agency charges and whether such have been added to the account. We will provide any such information if it becomes available. 4(f) we would refer you to Part 1 of Schedule 1 and to Schedule 2. Paragraph 6 (1) of the Data Protection Act 1998. Schedule 1, Part 1, of the Data Protection Act 1998 (the "DPA") sets out the first data protection principle: - (End page 1) (1) "Personal data shall be processed fairly and lawfully,and, in particular, shall not be processed unless- (a) at least one of the conditions in Schedule 2 is met, and (b) in the case of sensitive personal data, at least one of the conditions in Schedule 3 is also met" Schedule 2, Paragraph 6 of the Data Protection Act 1998: - , (1) The processing is necessary for the purposes of . legitimate interests pursued by the data controller or by the third party or parties to whom the data are disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the rights and freedoms or legitimate interests of the data subject. We consider the interest of Debt Recovery a legitimate interest and 1st Credit Ltd being the third party to whom the data has been disclosed. (CAG Experts advice here Please – did they have lawful right to process my data?) 4(g) We supplied details of the account to Connaught Collections, Judge & Priestly, Experion, Callcredit and Equifax (So was it them I wonder that issued the default as it is them that shows on the credit file!) 4(h) We are not obliged to provide statements for the duration of the account. You have already been provided with the statements available for the period 11 April 2006 to 11 May 2007. Our Client's letter to you dated 30 July 2011 refers. Paragraph mis-numbered 3 again at page 2. :"We will comply with the rules as to disclosure during this matter. . As to your letter dated 12 July 2011 again sent directly to our client, we are instructed not to apply any credence to it by responding. –( Interesting comment now that they are in a Tacit Agreement with me.) As to your defence, we are instructed to consent to an extension of time. As the original limit was to expire on 21 July 2011, (This is for the compliance with CPR 18– but have they given full compliance?? we will agree to an extension to 4 p.m. on 18 August 2011. If you require further time you will be required to make an application. With regard to the defence, we will require a defence filed and served by Wxxxxxx Sxxxxx. If it is served and signed by any other person or entity we shall require the appropriate Notice of Acting to be served and filed at the same time. Yours faithfully, LCS~ SOLICITORS Principal solicitor R D Marr LCS Solicitors is the legal division of I" Credit Limited, registered in England and Waits number 375294(} Registered Office: Hill House, 1 Little New Street, London. EC4A 3TR

AH ok but they sent through two separate lots of papwer work - let me scan as two separate docs and see what you think - apologies in advance if I scan too much OK I have managed to get the PDF converted to word doc and have tidied it up. The letter is fine but the Notice of Change is garbage - too many boxes so I willl leave that as per the attached PDF.

OK try this one for size lets see if I can get the whole thing pasted up too 110720a letter from LCS RE CPR 18 & notice of change.pdf

Thanks guys - I cant seem to delete docs from the storage place - i am going to reboot and see if that sorts out things cos I just attached the newly scanned doc into my post above and it hasnt worked.

110720a letter from LCS RE CPR 18 & notice of change.pdf AAAgh - didnt see that - I will rescan in and repost it!!!!!!!! it must have been the loss of blood that left my head!!!! The agreement for 2010 - blimey thats a lot of pages - i need to scan those (after checking for my name that is!) how do i remove the PDF completely - or can the team do this for me? Any thoughts on how to just paste the details straight into the post Now you all know who I am OK its done again - now to see if I can paste the actual content!!

Ah well that worked very well thank you Count but what I wanted to have the actual letter copied into the actual post. - I still cant copy the text of all the PDF to the clipboard so not sure whats going on there - I will try to convert the PDF to word format and then see if I can paste the text that way. Anyway you can have a look at it now and by the time I get back to the office I will then have the rest of the day to sort this out. 110720 letter from LCS RE CPR 18 & Notice of Change Doc0001.pdf

Alf thanks very much for that - my scanner does scan it as a pdf so I copied all the pages and marked out the personal stuff before I scanned it. So I will give this a go and see how I get on. Elsa - Nothing is wasted and thank yoiu so much for your effort. It was a really good exercise and it focussed my mind as to what I would have said in the N244. We will use it all dont worry. Count Orlok - This is very interesting information and I have a note in my file that LCS went out of business on the xxxxxxx (sorry still at the blood donor session so will insert the date when I get back to the office. These fools do not intimidate me now and I want to utilise everything I possibly can to make them work. Ok lets see if I can get this PDF posted up. - Ideally both documents will be posted into the thread as it will be easier to compare whjat they have said in line with what I wrote in my CPR 18.

##UPDATE## 2 page Letter just arrived from LCS Solicitors and a Notice of Change of solicitor form signed by Colin Watts Paralegal with LCS. I have scanned all three pages and blacked out my personal details and I want to paste it up but I have absolutely no idea how to do that. If someone can help me I will either paste the text or the actiual letter. At the moment my PC wont let me copy the text from the PDF Doc to the clipboard so I will have to attend to this later as I have to go now and give blood. One other thing too - I the colour icon isnt working so I cant apply different colours to the text. They have responded to all the points - not satisfactorily imho and have also agreed to an extension of time. there are some things which are just incorrect so hopefully I can get this letter posted up as it is as it will take a while for me to type it out if I cant, which I am happy to do if all else fails. One funny bit in this letter is as follows - "We note you consider that you have a CPR PART 18 request outstanding and that you require further time within which to serve a defence. As to your request under Part 18, we refer to your letter dated 4 July 2011 addressed directly to our client at a time when you were well aware that Messrs. Judge and Priestly were on record as acting for the Claimant. The format of the request is familiar to us a being one freely available on the usual internet debt forums. Rather than take the procedural point, we will respond to the questions raised and will use your numbering to respond. As Arnie said - I will be back - less 1 pint of my blood - given to a good cause I hasten to add - not the blood suckers I am dealing with in this !

OFFICIAL COMPLAINT RE POSTED AS AMENDED WITH STATUTORY INTEREST BIT ADDED If someone can tell me how to attache a PDF I will do that to save space Wxxxxxx : Sxxxxx xxxxxxxx xxxxxxxxx xxxxx xxxxxxx Tel: 00000 000000 Mob: 0000000000 E mail: [email protected] Saturday 16-07-2011 OFFICIAL COMPLAINT AGAINST CITI FINANCIAL AND 1ST CREDIT Contents OFFICIAL COMPLAINT 2 BACKGROUND TO MY COMPLAINT 2 CITI FINANCIAL ACTED UNLAWFULLY BY NOT ISSUING ME WITH A DEFAULT NOTICE BEFORE SELLING THE BALANCE OF MY “DEBT” TO 1ST CREDIT. 4 DEFAULTED WITH NO NOTIFICATION WHILST ON AN AGREED PAYMENT PLAN 5 UNLAWFUL TELEPHONE & WRITTEN HARASSMENT 6 CONTRAVENTION OF OFT REQUIREMENTS FEBRUARY 2009 8 1ST CREDIT IS ACTING UNLAWFULLY BY PURSUING ME FOR AN ALLEGED DEBT THAT WAS SOLD TO THEM UNLAWFULLY AND ARE ATTEMPTING TO FRAUDULENTLY CLAIM INTEREST FOR A PERIOD WHEN THE ACCOUNT WAS IN DISPUTE. 9 CRIMINAL OFFENCE COMMITTED IN 2007 BY 1ST CREDIT: - 10 PROCESSING OF MY PERSONAL DATA WHILST MY ACCOUNT WAS IN DISPUTE. 11 OFFICIAL COMPLAINT This complaint relates to Citi Cards who are part of Citi Financial Europe Plc PO Box 49920, London, SE5 7ZF and a debt collection company, 1st Credit, 1st credit (Finance) Ltd, The Omnibus Building, Lesbourne Road, Reigate, Surrey, RH2 7JP, and their associated companies and the way they have acted in their dealings with me from October 2006 until the present day. I am making this complaint as it is my belief that both Citi Financial and 1st Credit and their associated companies have acted unreasonably, unlawfully, and have acted contrary to the Office of fair trading guidelines relating to the businesses practices of debt collection companies on a number of occasions since October 2006. It is also my belief that the rules as detailed in the Data Protection Act 1998 may have also been breached because of the on-going processing of my personal data by 1st Credit whilst they were in a default situation because of non-compliance with a request for an original contractual agreement under the CCA 1974. I have also experienced both verbal and written harassment from 1st Credit and Connaught Collections who are a “trading Style” of 1st Credit. Despite several written requests to 1st Credit not to contact me by telephone, Connaught Collections, telephoned me several times in May 2011. I have also received over 17 letters since 2010 from 1st Credit, LCS solicitors, Connaught Collections demanding full payment with threats of various actions if I did not respond. It is my belief that this verbal and written harassment and is contrary to Section 1 of the Protection from Harassment Act 1997 and Administration of Justice Act 1970 s40. It is also my belief that the failure of Citi Financial to send me a Default Notice or set out the Default Notice in accordance with the Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) did unduly prejudice me as it failed to allow me the required time to remedy the alleged default. BACKGROUND TO MY COMPLAINT In 2006 I had a credit card with Citi Cards and on the 23rd October 2006, I wrote advising them that I was experiencing financial difficulties and requested that they accept a reduced payment of £3 per month. I also sent them an income and expenditure statment. Citi Cards accepted this offer in a letter dated 28 October 2006. Having informed Citi that I was experiencing financial difficulties they sent me a letter dated 11-11-06 informing me that they had increased my credit limit to £15,000! This seemed somewhat irresponsible to me that a Creditor would increase a credit limit of a customer that had already informed them they were experiencing financial difficulties. I received another letter dated 14-11-06 from Mr Paul Campbell, Head of Collections at Citi, requesting that I complete and return an income and expenditure form that was enclosed, which I then completed and returned to Citi. On the 18-01-07, I wrote again to Mr Campbell and informed him that I was in a position to increase my payments to £5 per month and enclosed an up to date income and expenditure statement. I requested that Mr Campbell acknowledge receipt of my letter and also confirm that interest had been frozen on the account, however, I have never received a response to this request from Mr Campbell or anyone else at Citi Financial. I wrote again to Mr Campbell on the 23-03-07 to notify Citi that I was in a position to increase my monthly payments to £10 and that I had registered with the CCCS. I also enclosed the official CCCS statement of income and expenditure. Once again I requested an acknowledgement of my letter and again I have never received one. Citi accepted my offers of reduced payments as well as the money that I paid them. At no time did they give any indication that they were unhappy with this arrangement. I never missed any payments from the time that Citi had accepted my first offer of a reduced payment. I received a NOTICE OF ASSIGNMENT (NOA) dated 11-06-07 which appeared to be a photocopy as the Citi logo was in black and white, whereas all previous letters from them were on coloured headed paper. The NOA informed me that with effect from the 11-06-07 Citi had assigned my account to 1st Credit Finance Limited. Citi gave me no warning whatsoever that they were intending to assign my account to a debt collection company and when I subsequently contacted 1st Credit on Saturday 16-06-07 by telephone, I learned that Citi had in fact sold my account to them and a default had been placed on my credit file on the 31st May 2007 which was eleven days before the date on the NOA. Before selling my account to 1st Credit, Citi never gave me any indication of their intentions to sell my account to a third party debt collector, nor did they ever send me a Default Notice, which afforded me no opportunity whatsoever to rectify the situation that had led to a default being registered on my credit file. I spoke with Mr David Fell, a Citi Financial manager, on the 16-06-07 who admitted to me that he had no record on his file of any letters being sent to me from Citi Financial informing me that a default was going to be registered on my credit file. I contacted the Financial Ombudsmen Service on the 18-06-07 to make a formal complaint against Citi financial. I also made a formal complaint to Citi Financial and 1st Credit and informed Citi and 1st Credit that my account was then officially in dispute. I was advised to write to Ms Singh, Service Quality Director at Citi Financial. I wrote to Ms Singh, on the 18-06-07 after speaking to the FOS and confirmed that I had a written agreement with Citi to make reduced payments which I had been doing, without missing any payments since November 2006 and that I had not received any warning that my account was going to be sold or that Citi were unhappy with the payment arrangement. I enclosed a copy of the letter from Citi Financial which confirmed that they would accept my offer of a reduced payment. I received a letter dated 18-06-07 from 1st Credit informing me that my account had been assigned to them from Citi Financial and that the full amount outstanding was due immediately to 1st Credit. I wrote to 1st Credit on the 21-06-07 to a Mr Joe Simms informing him that as my account was officially in dispute I had sought further advice on this matter from the CCCS and that I had been advised that if 1st Credit were to attempt to recover an alleged debt whilst my account was in dispute, this would be a contravention of the OFT guidelines. I also informed Mr Simms that I would continue to make payments to Citi Financial. I stated to Mr Simms that I did not acknowledge any debt to 1st Credit and I requested that 1st Credit provide me with a true copy of the original Credit Card Agreement under the Consumer Credit Act 1978 that they had referred to in their letters. I also requested a true copy of the deed of assignment of the agreement they referred to. I also provided them with the reference number provided by the FOS in relation to my formal complaint against Citi Financial. The rest of my dealings with Citi Financial and 1st Credit are summarised in a separate document from 2007 to current date in Chronological order. Since I have started to deal with 1st Credit they have displayed an extremely arrogant attitude towards me and they seem to feel it perfectly acceptable to: • totally ignore numerous questions that I have asked without ever having the courtesy to provide an answer, • to commit criminal offences, • to act unlawfully by harassing me by making unlawful demands for an alleged debt that they have not proven they have the authority to collect. On the 21st June 2011 1st Credit instigated legal proceedings against me. I have stated on several occasion in previous letters to 1st Credit that if the instigated any legal proceedings against me, they would be defended vigorously and I would also not hesitate to report them to the OFT as well as other statutory bodies. It is my belief that 1st Credit has no lawful case against me which is why I am now making this formal complaint. 1st Credit are obviously intent on still harassing me by trying to recover an alleged debt whilst my account has been in dispute which is in contravention the Office of Fair Trading guidelines. This continued harassment has caused me much stress and I have informed 1st Credit a number of times that unless they stopped this harassment, I would take steps to report them relevant enforcement authorities as well as, Trading Standards, the police, the OFT, The Information commissioner’s office, the CSA, the FOS, local and national press and my local MP. A copy of this report is being provided to all of the aforementioned bodies. My specific points of complaint are detailed in the following pages. By bringing this complaint against Citi Financial and 1st Credit I am seeking the maximum financial compensation available for the way I have been treated. I also require that any default that is registered against my credit file be removed. I also require a full investigation into the way that both Citi Financial and 1st Credit have dealt with me. I also require that the legal proceedings that 1st Credit have instigated against me be struck out as it is my belief that they have no legal case upon which to take me to court.  CITI FINANCIAL ACTED UNLAWFULLY BY NOT ISSUING ME WITH A DEFAULT NOTICE BEFORE SELLING THE BALANCE OF MY “DEBT” TO 1ST CREDIT. Before Citi Financial sold my account to 1st Credit in June 2007 I never received a Default Notice from Citi Financial and as such I was never given the opportunity to rectify the situation under the statutory timescales that had led to them issuing a default on my credit file. Citi Financial never informed in writing or otherwise that they were unhappy with the reduced payments they had agreed to and they never informed me that they were going to register a default on my credit file or sell my account to a third party debt collector. I have written to 1st Credit on numerous occasions asking them to provide proof that a default notice had been issued, however, evidence of the default notice nor has proof of postage ever been provided. I received a letter from a Gemma Jackson; Compliance Officer at 1st Credit dated 18th May 2010 in response to a letter I had sent on 22nd April 2010 in which Ms Jackson stated; “Further to your allegation that the default notice was not issued, on examination of our file, I find a conversation with Citi Financial in June 2007 we were advised a notice had been sent to you the previous May. In addition we do not consider the matter of whether a default notice has been issued or not is relevant. Please can you explain why you believe it to be so? We note that the Consumer Credit Act States “Service of a notice on the debtor or hirer in accordance with Section 88 (a “default notice”) is necessary before the creditor or owner can become entitled, by reason of any breach by the debtor or hirer of a regulated agreement, - a) to terminate the agreement or b) to demand earlier payment of any sum. We consider there is no requirement to terminate your agreement as we are solely claiming accrued arrears. Nor are we demanding earlier payment” Ms Jackson seems to have totally missed the point in my reason for asking for proof that a default notice was issued and she has shown arrogance by stating that the matter of whether or not a default notice had been issued is relevant and also asking me to explain why I believed it was relevant. She then goes on to quote from the Consumer Credit Act to show the very reason why it is totally relevant. Despite Ms Jacksons statement that 1st Credit were told in a conversation by Citi Financial in June 2007 that a default notice had been issued to me in May 2007, neither 1st Credit nor Citi Financial have provided proof to corroborate this statement nor have they provided proof of postage of a default notice. It is therefore my belief that a Default Notice was never issued and as such as Citi have never issued me with a Default Notice they therefore acted unlawfully by terminating my agreement. As my agreement was terminated unlawfully by Citi Financial this then leads to the obvious conclusion that 1st Credit have no lawful right to try to collect on an alleged debt that that they bought unlawfully. It is my understanding that a creditor must under Section 87(1) of the Consumer Credit Act 1974 serve a valid Default Notice before they can demand early payment of sums not yet due under a Regulated Credit Agreement, which is exactly what 1st Credit have been doing. It is also my understanding that for a creditor to be entitled to terminate a regulated Credit Agreement where there is an alleged breach, demand repayment in full or take any legal action to recover any monies due under the Agreement, a creditor must serve a Default Notice under section 87(1) of the Consumer Credit Act 1974 which states: Section 87. Need for Default Notice (1) Service of a notice on the Debtor or hirer in accordance with section 88 (a "Default Notice ") is necessary before the creditor or owner can become entitled, by reason of any breach by the Debtor or hirer of a regulated Agreement – a) to terminate the Agreement, or b) to demand earlier payment of any sum, or c) to recover possession of any goods or land, or d) to treat any right conferred on the Debtor or hirer by the Agreement as terminated, restricted or deferred, or e) to enforce any security. The Act also sets out via Section 88(1), that the Default Notice must be in the prescribed form, as below: Section 88. Contents and effect of Default Notice (1) The Default Notice must be in the prescribed form… The wording must make it clear that no variation is acceptable. Therefore it cannot be dispensed with as a De Minimus issue. I note that the regulations do not allow any variation in the form of these statements and therefore it is suggested that where the statements are not as laid down in the regulations the Default Notice is rendered invalid as a consequence. In the case of Woodchester Lease Management Services Ltd v Swain & Co - [1998] All ER (D) 339 in the Court of Appeal, the Court addressed in some detail the issue of the contents of a Default Notice and should the notice fail to comply with the Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) it would render the Default Notice invalid. I quote the comment of KENNEDY LJ: "This statute was plainly enacted to protect consumers, most of whom are likely to be individuals" the judgment appears to confirm the consumer credit legislation made under the Consumer Credit Act 1974 as plainly enacted and set out to offer protection to the consumer. Therefore it is my belief that the failure of Citi Financial to send me a Default Notice or set out the Default Notice in accordance with the Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) did unduly prejudice me as it failed to allow me the required time to remedy the alleged default. Citi Financials failure to issue a valid Default Notice must surely prevent a right of action and would make any termination of the Agreement unlawful, as statute provides the procedure that must be followed. Since Citi Financial and 1st Credit have failed to adhere to statutory procedure it is averred that 1st Credit does not have a right of action against me and can never now have a right of action as Citi Financial terminated the Agreement unlawfully. If the agreement I had with Citi Financial was an Agreement Regulated by the Consumer Credit Act 1974 then there is no provision in the Act that allows a large financial institution to terminate an Agreement that is in alleged default or breach simply by giving notice to the Consumer, which is what they did to me. Section 98(6) makes that quite clear. The Creditor must follow the steps outlined in Section 87 and Section 88 if they are to lawfully Default and Terminate, and enjoy the benefits of Section 87. Furthermore it is my understanding that an invalid Default Notice cannot be remedied by simply issuing a new Default Notice. A creditor may not serve a second effective default notice in prescribed form post-termination of the agreement. Any such second default notice will necessarily state a date by when I would be required to comply after which in default the agreement would terminate. The second default notice would therefore contain the fiction that the agreement endured when that cannot be the case, as my agreement was defaulted and terminated on 31-05-2007. It is my contention that terminating an agreement on the back of a non-existent or defective Default Notice, simply confirms the undeniable truth that Termination of the agreement by Citi Financial was carried out in circumstances which then prohibited them or 1st Credit from enjoying the benefits of Section 87, namely the opportunity to seek early Payment of a sum that was, prior to Termination, only payable in the future. Not only have Citi Financial acted unlawfully by not issuing me with a default notice but 1st Credit have also been acting unlawfully since May 2007 by harassing me by trying to pursue me for a debt they have no lawful right to try to collect on when my account had been sold to them unlawfully in the first place. DEFAULTED WITH NO NOTIFICATION WHILST ON AN AGREED PAYMENT PLAN Citi Financial never gave me any indication that they were unhappy with the payment plan they had agreed to before they issued a default and sold my account to 1st Credit. I increased my payments twice since they first agreed to me making reduced payments. A default was registered on my credit file on the 31-05-07 and as I was never sent a default notice it is my belief that the failure of Citi Financial to send me a Default Notice or set out the Default Notice in accordance with the Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) did unduly prejudice me as it failed to allow me the required time to remedy the alleged default. UNLAWFUL TELEPHONE & WRITTEN HARASSMENT Since early 2010 I have been bombarded with numerous letters (17 in total) from 1st Credit and their associated representatives, solicitors and other companies that are “trading styles “ of 1st Credit, either threatening me with legal action or demanding immediate payment of the total alleged “debt” that they say I owe them. They have, I believe, acted unlawfully as they are demanding repayment for a debt that they have no legal right to try to collect on as my account was assigned to them by Citi Financial unlawfully in the first place due to the fact that Citi Financial never issued a Default Notice before they sold my account to 1st Credit. I wrote to 1st Credit on the 30-11-07 confirming the following: xxxxxxxx xxxxxxxxx xxxxxxxxx xxxxxx xxxxxx 1st Credit Administration Dept PO Box 278 Reigate Surrey RH2 7WB CC – Mr Ross Darbyshire, Citi Cards, Office of the Chief Executive. Friday 30th November 2007 Dear Sir/Madam Your Ref xxxxxxx Client Citi Financial Europe PLC Relating to Account Number xxxxxxxxxxxxxx Balance Outstanding £6,747.12 Before I continue I wish to establish that I am not seeking to avoid responsibility for any alleged debt or breach of any alleged agreement that I may have or have had. I wrote to Mr Joe Simms on the 21st June 2007 requesting a copy of the executed agreement under the Consumer Credit Act (1974). I also asked for a statement of account. A copy of that letter is attached for ease of reference. I also requested an executed deed of assignment documenting your involvement; this too has not been supplied. Accordingly, it is my consideration that you have been unable to supply an agreement because no such agreement exists. Also as you may be aware my account is in dispute and I have made an official complaint to the Financial Ombudsmen Service. Consequently I am unable to acknowledge any debt to your company Your non-compliance with my request means that your company has committed an offence under Section 77 (4) of the Consumer Credit Act 1974, summarily punishable by a Level 4 fine on the standard scale. I have also informed Citi Cards of the same information as detailed in my enclosed copy letter. A credit agreement that is not properly documented and signed by the customer is totally unenforceable under the Consumer Credit Act 1974 and is therefore a complete defence to any court claim that is issued. Please take note that any legal action you may contemplate will be vigorously defended and contested. Furthermore your actions arguably do not comply with the Office of Fair Trading (OFT) Debt Collection Guidelines of July 2003, in that you have ‘communicated with [me] in an inaccurate or misleading manner (section 2.1) by ‘presenting information in that it creates a false or misleading impression’ and ‘failing to provide [me] with information on the status of debts’. The fact that you have not provided me with a copy of the agreement negates any Notice of Default being served on me, as required by the conditions of the Consumer Credit Act 1974. Incidentally, if the documentation were to be produced, you will be aware that a default notice serves to cancel any original terms and conditions and as such cancels any right you or my creditor might have, implied or otherwise, to share my information without my consent. I would then be looking to receive substantial compensation from your firm for this breach of my rights. What I require I require you with immediate effect to ensure that all data held by you regarding the alleged agreement/debt is removed from any and all Credit Reference Agency database. Ensure that all data held by you regarding me is fully destroyed. I require written confirmation of the above together with a quarterly statement that no data has been processed by you regarding me. Failure to comply • Failure to comply with my request under the Data Protection Act 1998 will result in the matter being referred to the Information Commissioner. • Failure to comply with the requirements of the Consumer Credit Act 1974 will cause me to refer the matter to the Office of Fair Trading, and Trading Standards. • Failure to comply with the requirements Office of Fair Trading guidelines will lead to a report being submitted. • If you fail to comply with any or all of the above I reserve the right to take action against you without further contact. I expect to hear from you within 12 working days from the date of this letter. Failure to do so will be taken that you failed to comply with my request and I will consider the matter closed. Any further action on your part or that of my alleged original creditor pursuant to your and/or their breaches of my statutory rights will be taken as a wilful act of harassment and each instance will be reported to the police. Please note, I have also sent a copy of this letter to Citi Cards. Yours faithfully, xxxxxxxxx Despite never providing any of the requested information in the aforementioned letter 1st Credit has insisted on harassing me for full payment of the alleged debt that they say I owe them. After sending the above letter, I have written several times subsequently to 1st Credit stating categorically, that I wished to only be contacted in writing and also requesting that my number be removed from their database which they have refused to do. They have ignored my requests on numerous occasions and have harassed me by calling me numerous times to speak about this matter. The latest occurrences were in May 2011 when Connaught Collections, who are a “trading style” of 1st Credit phoned me several times to try to get me to reveal personal details and when I refused to do so the person on the other end of the phone stated that because I wouldn’t tell him who I was he wasn’t going to tell me who he was! Following 1st Credit’s initiation of legal proceedings, I wrote to Mr Gavin Flynn, Head of Collections at 1st Credit on the 27-06-2011 informing him that because of the continued harassment, I intended to take action under Section 1 of the protection from Harassment act 1997 and Administration of Justice Act 1970 s 40 which makes it a criminal offence for a creditor or a creditors agent to make demands for money which are aimed at causing alarm, distress or humiliation, because of their frequency or manner, which 1st Credit have succeeded in doing. This bombardment of written and verbal demands has caused me much stress, distress and alarm as well as humiliation within my family, due to the frequency and the manner in which 1st Credit have sought to make unreasonable demands on a debt that they have not proven they have a legal right to collect on and which was unlawfully sold to them originally. Since 1st Credit started this harassment I have not responded to any of these threats of legal action and unreasonable demands for payment because I had already stated in my letter of 30-11-07 that as 1st Credit have acted unlawfully and have been unable to provide proof that I have any lawful obligation to them, I considered the matter closed and I would not communicate any further with them in this matter. To date I have tried to be reasonable and have not reported the sustained harassment from 1st Credit to the police, however, as 1st Credit seem intent on continuing this harassment and have even instigated legal proceedings, it is now my intention to contact the police imminently and bring charges against them as well as contacting other organisations. I will also be seeking the maximum compensation available for the unlawful harassment I have been subjected to. The last letter I sent to 1st Credit prior to them instigating legal action was dated 18-06-2010 and then from that point they have harassed me with demands for full payment and with threats of County Court Proceedings that “may” be instigated and threatening that a statutory demand would be issued under the Insolvency Act 1986. In total I have received 17 separate items of written communication as well as several harassing phone calls. CONTRAVENTION OF OFT REQUIREMENTS FEBRUARY 2009 It is my contention that 1st Credit have contravened the requirements set out in a report dated 19-02-2009 by the OFT who imposed requirements on them over debt collection practices as they have now instigated legal action on the 21st June 2011 for a “debt” that they have no legal rights to collect upon. In the OFT report dated 19th February 2009 entitled:- REQUIREMENTS BY THE OFFICE OF FAIR TRADING (‘OFT’) PURSUANT TO SECTION 33A AND SECTION 33D(4) OF THE CONSUMER CREDIT ACT 1974 (‘the Act’) It states “THE OFT REQUIRES AS FOLLOWS 1) That as of 19 February 2009 1.2 1st Credit shall not discuss legal action or the implications of such action with debtors unless one of the following applies a) The debtor is unreasonably refusing to make payment; b) The debtor is refusing to provide suitable evidence to justify an offer of payment; c) The debtor is actively and unreasonably seeking to avoid the debt; d) The debtor is not prepared to make a firm arrangement to clear the debt or to take appropriate steps to deal with the matter e) The debtor has failed to adhere to a previously agreed arrangement; f) Ist credit is invited to do so by the debtor, or their representative g) A repayment offer is made which is unreasonable when the debtors financial circumstances are considered ; or h) 1st Credit limited reasonably doubts the debtor has a commitment to make payments; AND i) There is a realistic prospect of legal action being taken” It is my belief that by instigating legal proceedings 1st Credit have breached at least the following points a, c, d, (highlighted above) I have, on several occasions in letters I have written to 1st Credit made it clear that I was not seeking to avoid responsibility for any of my financial obligations and at no time have I ever refused to make payments nor have I ever actively and unreasonably sought to avoid any debt I might lawfully owe and I have never given any indication whatsoever that I was not prepared to make a firm arrangement to clear the alleged debt or to take appropriate steps to deal with the matter. I have actually written to Mr. Gavin Flynn, Head of Collections at 1st Credit on the 27-06-2011 and 05/07/2011 and categorically stated that I would be very happy to settle any financial obligation I might lawfully owe as soon as I received the following documentation from them: 1 Verification of their claim against me (a sworn affidavit or a hand signed invoice in accordance with the Bills of Exchange Act (1882) ); 2 A Copy of a lawful contract signed by both parties and therefore binding both parties. 3 Validation of the debt (the actual accounting) To date I have not received a response from Mr Flynn or anyone else at 1st Credit. Statutory Demands Connaught Collections (who are a trading style of 1st Credit and are located in the same building as 1st Credit) wrote to me on the 19-01-2010 and threatened that if I did not contact them within 7 days with a view to settling the account immediately or provide them with a good reason for non-payment, the matter would be passed to their Bankruptcy Department for the immediate issue of a Statutory notice under the Insolvency Act 1986. The threat that a Statutory Demand would immediately be issued contravenes the requirements set out in the above mentioned report in relation to the threat of Statutory Demands being issued. 1ST CREDIT IS ACTING UNLAWFULLY BY PURSUING ME FOR AN ALLEGED DEBT THAT WAS SOLD TO THEM UNLAWFULLY AND ARE ATTEMPTING TO FRAUDULENTLY CLAIM INTEREST FOR A PERIOD WHEN THE ACCOUNT WAS IN DISPUTE. 1st Credit instigated legal proceedings against me on the 21-06-07 following two letters I received from Judge and Priestly Solicitors dated 03-05-2011 & 13-05-2011. In both of the above mentioned letters, Judge and Priestly stated “We have been instructed by our client that you have failed to respond to all reasonable requests to settle the outstanding debt and have failed to identify any reason why the debt is not due or owing”. In the last paragraph of both letters, they also stated “If you believe that there is a good reason for your failure to settle our client’s account, please advise them immediately upon receipt of this letter. If you do not respond to this letter it will be taken that you have no good reason for your failure to pay the account and that such sum is properly due and payable. We will refer to this letter on the question of costs should proceedings subsequently be issued”. I wrote to 1st Credit on the 27-06-11 confirming that I had received the two letters from J&P and as stated above I have agreed to settle any financial obligation I might lawfully owe as soon as 1st Credit have provided the documentation I have requested. It is my understanding that as I have offered them a conditional settlement this has removed any contention upon which a case in a court of law could be adjudicated on. In the Particulars of Claim issued by 1st Credit from the Northampton County Court Bulk Centre they state that they are claiming statutory interest of £2,171.85 pursuant to Section 69 of the County Court Act 1984 at a rate of 8% per annum from the 08-06-07 to 20-06-2011 & thereafter at a daily rate of £1.47 until judgement or sooner payment. I have the following contentions with this statement; 1) The Notice of Assignment (NOA) I received from Citi Financial was dated 11-06-07 and it stated that “with effect from the date at the top of this letter (11-06-07) under a written assignment, we have assigned your contract to 1st Credit Finance Limited. Therefore as 1st Credit has stipulated a date of 08-06-07 as the date from which they are claiming interest, they are fraudulently and unlawfully trying to claim interest for a period before the date of the NOA. 2) As soon as I received the NOA in June 2007, I telephoned Citi Financial to try to ascertain why they had assigned my account to 1st Credit without issuing me with a formal default notice. I then registered a formal complaint with Citi Financial and the Financial Ombudsman on the 18-06-07. As my account has been in dispute from the 18-06-07 (and potentially still is), 1st Credit have acted unreasonably and unlawfully in trying to claim for interest for a period when the account was officially in dispute. 3) I wrote to 1st Credit on the 08-03-2010 and stated categorically; “In the 33 months that have elapsed since I first requested a true copy of a credit agreement, I have never received a copy of the agreement as required by S78 Consumer Credit Act 1974, nor any other information relating to same. As such, this account has become irredeemably unenforceable by law. As you are no doubt aware subsection (6) states: If the creditor under an agreement fails to comply with subsection (1)— (a) He is not entitled, while the default continues, to enforce the agreement; and (b) If the default continues for one month he commits an offence. As such, when the 12 working days expired (from your receipt of the request for the agreement and supporting documents) the account was in dispute, which your company was informed about and a complaint was lodged with the Financial Ombudsmen. As you are aware whilst an account is in dispute the agreement is unenforceable and no interest can be added to the account nor can any action be taken against me. No adverse credit references or defaults can be listed against me with Credit Reference Agencies. The account should not have been passed to a Debt Collection Agency such as yourselves. And lastly, I am not obliged to make any further payments to the account. Essentially, the account was ‘held’ as it was on the date of the CCA request expiring (6th July, 2007) 4) 1st Credit is trying to charge Statutory Interest and it is my understanding that Statutory interest cannot be charged on a Consumer Credit Act regulated debt. It is also my understanding that the only interest that can be claimed is that specified in the Terms &Conditions of the agreement. So not only are 1st Credit frauduletnyl trying to claim interest for a period when the account was in dispute but the actual amount they are claiming is wrong. It appears that as my account has been in dispute not only is the agreement that 1st Credit are seeking to recover payment on unenforceable, but 1st Credit are fraudulently trying to obtain interest unlawfully. 1st Credit has demanded payment when it has not been proven by a court of law that: a. They are acting lawfully and b. that my account is no longer in dispute (despite 1st Credit asserting that because I received a pile of photocopied papers from them they have complied with my previous requests for my original agreement and as such there was no longer a dispute!). 1st Credit has never provided me with: • Any evidence that they have proof of agency in this matter. • A true signed copy of the deed of assignment • Evidence of any Default Notice or proof of postage • A copy of a lawful contract signed by both parties • Validation of the actual debt (the actual accounting) • Verification of their claim against me (a sworn affidavit or a hand signed invoice in accordance with the bills of exchange act (1882)) CRIMINAL OFFENCE COMMITTED IN 2007 BY 1ST CREDIT: - Having requested a true copy of my original credit agreement on 21-06-07 from 1st Credit under the legislation contained within section 78 (1) of the Consumer Credit Act 1974 (s. 77 (1) for fixed sum credit), they did not respond within the statutory timescales which allowed 12 working days for my request to be carried out. It is my understanding that as 1st Credit were unable to provide me with the information I requested within the 12 days, that they entered into a default situation on the 06-07-07. It is also my belief that because 1st Credit was unable to satisfy my request after a further calendar month on the 06-08-07 that they then committed a criminal offence. It took 1st Credit over 33 months to send me what they claimed was a true copy of the agreement I had requested, although I have no evidence that this is the original credit agreement I had requested on the 21-06-07, as there were no signatures, either from myself or anyone at Citi Financial anywhere on paperwork they sent me. I received a letter dated 01-06-2010 from a 1st Credit Compliance officer called Gemma Jackson in which she confirmed that comments I had written in letters to them in 2007 relating to 1st Credit having committed a criminal offence in 2007 may have been correct in 2007 but that because the Consumer Protection from Unfair Trading Regulations 2008 section 3.12 states that this claim is “incompatible with the contract law” that my statement was now incorrect. I appreciate that the regulations have changed since 2007; however, under the law as it was in 2007, 1st Credit did commit an offence on the 06-08-07 (before the regulations were changed). As they have committed an offence then it is my contention that they are guilty of acting unlawfully and I feel they need to account for this criminal offence. PROCESSING OF MY PERSONAL DATA WHILST MY ACCOUNT WAS IN DISPUTE. I believe that as Citi Financial failed to issue a Default Notice and then unlawfully sold my account, that following this it was unlawful for them or 1st Credit to process my personal data and they have contravened the Data Protection Act 1998. I have requested that 1st Credit cease and desist all manual and automatic processing of my data within their company and any other company within their group which they have refused to do. As stated above, in a letter dated 30-11-2007 to 1st Credit Admin Department, because they had failed to provide a copy of an agreement under the CCA 1974, I stated: “What I require I require you with immediate effect to ensure that all data held by you regarding the alleged agreement/debt is removed from any and all Credit Reference Agency database. Ensure that all data held by you regarding me is fully destroyed. I require written confirmation of the above together with a quarterly statement that no data has been processed by you regarding me. Failure to comply • Failure to comply with my request under the Data Protection Act 1998 will result in the matter being referred to the Information Commissioner. • Failure to comply with the requirements of the Consumer Credit Act 1974 will cause me to refer the matter to the Office of Fair Trading, and Trading Standards. • Failure to comply with the requirements Office of Fair Trading guidelines will lead to a report being submitted. If you fail to comply with any or all of the above I reserve the right to take action against you without further contact.” These very specific requests were totally ignored by 1st Credit and it is my belief that they have continued to unlawfully process my data against my will and as such 1st Credit are guilty of breaching my statutory rights.

ANOTHER UPDATE - RE THE N244 PROCESS Well now that the Novacaine has finally worn off I called the NBCC and spoke with another very helpful lady called Sharon. The telephonists there are all so nice and helpful which is very refreshing:) I explained exactly what you told me to do Elsa re the wanting to put the "unless the Claimant complies" bit into the N244 and this is chapter and verse what she said. Firstly when I put in the N244 I have to put in that I want an extension as per CPR 15:5 and this is then given top priority and it means that the application will be dealt with there and then on the same day and there will be a bar on judgement applied immediately. They then send the N244 off to the District Judge who assess it and then sends it back with his directions on there - good or bad depending on how you look at it! When the court eventually receives the DJ's directions they then "draw up an order", which she qualified as meaning that the court will write a letter to both the Claimant and me informing us of the DJ's directions. The date that this letter is written is the date at which the 14 day clock for compliance with CPR 18 starts to tick. I did ask if anything goes to 1st Crappy but apparently they dont even get notified that the form has been submitted. Sharon did say that either LCS or 1st Crappy may contact the NBCC after the deadline of 16:00hrs Monday 25-01-11 but at that point they would be informed that the case has been refferred to the DJ. Sharon also said that they could try to force a judgement as there will not have been any defence submitted by the deadline but it would be at this point that they would be told there is a bar on judgement in force until the DJ has given his directions. I asked if I had to write to the Claimant and inform them of what is happening but this is not needed and so it looks like we will have a three to four week wait whilst the DJ looks at this. This is very useful information to know and definately one to add to the excellent PDF that Elsa drew up regarding the CPR advice compilation - or maybe thats not the right place but its very good to know what actually happens. So now that we know exactly what is going to happen my thoughts are that we need to take advantage of the fact that a DJ is going to review this and go for as much as we can on the N244. I did ask the question yesterday about there being multiple items in the N244 Application and there is no restriciton as to how many items can be put on there. What do you think guys about throwing in as much stuff as we can in the N244 particularly as I have total liberty in box 10 to have a lot of detail in there to support my application? For example - I enclose my 11 page report and state that I want an immediate strike out for the reasons contained in the report! It may be worth reading my official complaint again to see if we can actually go for an immediate strike out as 1st Crappy have acted in such a shocking way. I have slightly amended the report to add the bit about Statutory interest that you siuggested Elsa and from what I can ascertain this could be a pretty damning report for 1st Crappy. - it appears I cant edit that post now so I have reposted it next. what do you think guys? - I am paying good money to submit this report so the more muck i can sling at them in this the better - I ideally want a DJ to look at this and just strike it out immediately if at all possible but failing that then still sling as much mud as possible and make it as difficult as I possibly can for 1st Crud. Whats the general consensus guys - we have until Friday to put in an absolutely stonking N244. If it is easier to do this offline for the next couple of days I am very happy to give my number to genuine Caggers or deal with this by PM just in case there are any eyes from 1st Crappy looking at this thread! Just a thought! I dont want to give the game away too early. Waiting with baited breath guys :) Once again huge thanlks to all and sundry that are helping me to fight this battle - I will hopefully be able to do the same for others when all this is over!!!!!!!

Well its funny you should say that - I am sitting in my town office (AKA Starbucks!) having some liquid refreshement as I type - and I am actually managing not ot dribble!!!! I can just about feel my tongue now. :)

##ANother update## Just before I went to the dentist I spoke to a very nice chap at my local Trading Standards office and had a good 20 mins on the phone with him. It appears that TS can only act if a trader has committed a criminal offence as opposed to acting unlawfully - I didnt appreciate that criminal is different to unlawful - I do know the difference now. He told me that they also cant act when an offence is over 3 years old so the fact that back in 2007 when 1st Credit did commit an offence by not responding to my CCA request within the statutory 30 days there is nothing they can do about this now. I did ask him that if anyone committed an offence (I used murder as an example) then irrespective of when they did it - the fact is that they did it and no change in legislation can take away the fact that an offence was committed but he said that even though this argument is actually correct when it comes to contractual arguments and Consumer circumstances we are talking Civil not criminal. So I am kicking myself for being too nice back in 2007 - if I had acted then I dont think we would be having this hassle now - hey ho you live and learn! He did seem to think that 1st Credit may have acted in a criminal way in respect to harrasment and he also was interested in the possible breach of Data Protection act 1998 and he also said that he would look very closely at the fact that Citi sold my account to 1st Credit without issuing me with a Default Notice. So although it is going to take him about a week to look through things and come back to me, this is another body that are at least taking notice - whether or not it will do any good - well thats another question. My hope is that there is enough damning evidence for each individual item that this will make a pitcure that shows this bunch for what they are.

now that would be very funny - if they were prepared to work on a no win no fee basis then I would be very happy to get them to act for me! Now that has rasied an interesting point - do you or anyone else here know of a no win no fee firm that would represent me? I dont have the financial capacity to pay for this so if there was a NWNF solicitor then this would probably add extra clout than being a LIP! If no then theres no stress as I am actually beginning to enjoy this now.

Hi Elsa Sorry I didnt respomnd before now but I have been flat on my back for an hour in the dentist - both sides of my face are very numb!!! Tomorrow is absolutely fine thank you so much - hugely appreciated - The deadline for the the response is actually Monday at 16:00 hrs so no panic to have it finished by Friday - I just want to err on the side of caution if possible to allow time to re tweak and finalise. Sorry Elsa I am being a bit thick here - probably the novacaine but do I just eter the CPR 18 compliance request in box three and forget about the 31:14 until they have responded to the CPR 18? Again apologies OK I will now try to call the court if I can speak coherently!! I will repost when I have spoken to them.

Another update - Letter just arrived from J&P (they can move fast when they want to) When I was on the phone yesterday to MR Ridd I asked him if he could confirm what he told me in writing. Interestingly the letter states Connaught Collections as their client yet it is 1st Credit who are the Claimant!! As Connaught are only a trading style of 1st Credit I thiunk I will ignore this. Anyway the letter states Dear Sir RE: Our Client - Connaught Collections UK LTd As discussed in our telephone conversation, we write to confirm that LCS Solicitors have been instructed to act in this matter in our place. A Notice of Change will be filed with the Court - and a copy sent to you direct - by them shortly. Our client have confoirmed that LCS Solicitors will be dealing with your CPR 18 request and that you will be able to direct your request under CPR 15.5 to them once you have received the Notice of Change. As discussed, we are no longer instructed in this matter and this letter will be the last letter to you from our firm Yours faithfully Judge & Priestley LLP (computer generated "signature") I find it interesting that there is no word from 1st Credit at all - no response to my fax nothing - well I am hoping that all this silence will just be scoring me brownie points.

Hi Elsa - thank you so much for your help - its hugely reassuring to have people on this forum that cab guide those of us that are less knowledgable along the right road. I was going to answer in red in the body of your text but the colour icon isnt working so I have dont it in bold italics instead as that does seem to be working. So can you tell me if I have got this right from what I think you have said? First send the N244 only asking for compliance with the CPR 18 request and nothing else. secondly depending on whether or not they comply with this will depend on what happens - if they do comply then is that the time to ask for an extension under CPR15: 5 and also ask for the actual docs under 31:14? if no compliance with CPR 18 then go for a strike out? is that what you meant.

Good Morning Elsa Well that is a piece of information I wasnt aware of thank ypou very much for that - priceless - I will add that to my complaint report (oh BTE the trading standards called yesterday but I missed them so will speak to them today). ALso in relation to the interest - they are trying to charge interest for three days before thedate on the NOA I received from Citi on the NOA - the NOA was dated 11-06-07 and they have stated 08-06-07. And they are also trying to cliam interest for a period when the account was in dispute - remember from the first time I requested my CCA to the time they supplied a pile of what they claim is my agreement was over 33 months. - All of that is in my complaint report. As well as the CPR18 I have sent two other letters to Mr Flynn stating that I will pay in full any lawful obligation I may have (conditional agreement) - In the matter of the request for my payment of £6,727.12, I would be very happy to settle any financial obligation I might lawfully owe as soon as I have received the following documentation from you: 1 Verification of your claim against me (a sworn affidavit or a hand signed invoice in accordance Bills of Exchange Act (1882) ); 2 A Copy of a lawful contract signed by both parties and therefore binding both parties. 3 Validation of the debt (the actual accounting) I hereby give you ten (10) days from the above date to reply to this notice. Your said failure to provide the aforementioned documentation will constitute your agreement to the following terms: 1 That you are a third party interloper; 2 You have no legal standing; no first-hand knowledge of this matter; 3 Your claim is fraudulent; 4 Any damages I suffer you will be held culpable; 5 You agree to pay all fee schedules; 6 That any negative remarks made to a credit reference agency will be removed 7 That you will no longer pursue this matter any further Should you provide sufficient evidence that I owe your organisation or your client any outstanding amount and that you can provide proof that they have assigned you agency, I should be happy to pay any verified claim in full. This is if you like the second part of my strategy as I have condiditonally agreed to settle this matter in full I understand that this removes any controvesy on which a court could adjudicate. As they have now ignored both letters i wrote a third one and we are now in a tacit agreement situation so I want to use this at some point too if I need to put a defence together. These letter are in post #'s - 173 & 197. I have also written a thrid letter (post #214 ) informing him tjhat we now have a lawfully binding Tacit agreement, which means that Estoppel by Aquiesence is applicable and an official Estoppel notice will be sent this week to them. I want to use these other litle gems if I do have to enter a defence, although I feel it may not be necessary as I think they have done a good job of damning themselves without any help from me! OK the CPR 18 - Here it is in all its glory. Mr Gavin Flynn Head of Collections 1st credit (Finance) Ltd The Omnibus Building Lesbourne Road Reigate Surrey RH2 7JP In the Northampton county court Bulk Centre Claimant -v- (Wxxxxx Sxxxxx) Claim Number: xxxxxxxx 04th July 2011 Dear Mr Flynn REQUEST FOR INFORMATION CPR 18 I have received a recent court claim from your organisation dated 21st June 2011 out of the Northampton County Court Bulk Centre. I confirm I have completed an acknowledgement of service on line in which I have indicated that I intend to contest your entire claim. In order to file a defence I require some information. Given that this matter is now the subject of legal proceedings, your company is obliged to disclose the information and documents detailed below under the Civil Procedure Rules. The information must be furnished within fourteen days of the receipt of this letter. If you fail to comply, this will be reported to the Court, a copy of this letter will be provided as evidence to the same and an Order enforcing your compliance will be sought. I notice in the particulars of claim you mention that I was indebted to CitiFinancial Europe PLC, yet you give no particulars of any agreement/s on which you are relying on for this case, therefore, I request that you confirm the following. 1. Do you have a true copy of the original, signed, executed credit agreement and any terms and conditions that applied to the account at the time of default and at the time the account was opened? 1A. Was the agreement in written form and if so was this a regulated agreement under the Credit Consumer Act 1974. 2. Do you have true copies of any default notice or enforcement notice that you or the original creditor sent me and do you have copies of any proof of postage? 3. If copies of any of the above documents are to be relied on in court rather than originals, a copy of the Notice of proposal to adduce hearsay evidence required under s2(1) of the Civil Evidence Act 1995 together with proof of the authenticity of the document(s) as required under s8(1)(b) of the Act, including but not limited to: (a) a copy of the procedure(s) used for copying, storing and retrieving documents (b) a copy of the relevant log entry showing the time and date of the scan or copy, the name of the member of staff making the copy, the method used for copying, storage and retrieval and time and date of destruction of the original document(s) © copies of internal and external audit reports covering the entire period from the date of the copy to the present to demonstrate that the procedures have been complied with (d) copies of Quality Assurance accreditation certificates covering the entire period from the date of the copy to the present to demonstrate that the procedure(s) and audit process(es) comply with the appropriate quality standards 4. I require written confirmation of all records you hold on me relevant to this case, including but not limited to: a. Transcriptions of all telephone conversations recorded and any notes made in relation to telephone conversations by your company, or by any previous creditor b. Where there has been any event in my account history over this period which has required manual intervention by any person, I require disclosure of any indication or notes which have either caused or resulted in that manual intervention, or other evidence of that manual intervention in relation to my account formerly held with Citi Financial c. Documents relating to any insurance added to the account, including the insurance contract and terms and conditions, date it was added and deleted (if applicable). d. Details of any collection charge added to the account; specifically, the date it was levied, the amount of the charge, a detailed financial breakdown of how the charge was calculated, and what the charge covers. e. Specific details of the fees/charges levied by any other agency in respect of this account and a detailed breakdown of said fees/charges and what each charge relates to and on what date said fees/charges were levied. f. A genuine copy of any notice of fair use of my data as required by the Data Protection Act 1998 g. A list of third party agencies to whom you have disclosed my personal data and a summary of the nature of the information you have disclosed. h. Copies of statements for the entire duration of the credit agreement. 3. Any other documents you seek to rely on in court. I will require this information within the next fourteen days. I must advise you that if the information is not forthcoming, it will be reported to the Court that you are trying to frustrate proceedings and denying me the opportunity to file a defence and counter claim. Yours sincerely, Wxxxxx Sxxxxx