Hi Happy hippy. Well we did play letter ping pong last year after they had send me what they claim is a true copy of my CCA. we exchanged a few letters and I gave up writing back when they insisted that because the pile of photocopied stuff they sent was a true copy of my CCA I therefore owed them full payment. Well they have now had my letters and I will not go down without a fight!

I gave up being intimidated by these fools a long time ago, although I did panic a bit when the blue papers came in. However, having now spent days trawling this forum and others, I now have a two pronged strategy and 18 pages of letters and points for my defence. It is possible of course that 1st Crud do have my OCCA all signed and in place with the original T's & C's and if they do well then I will have to cross that bridge when I get to it but as has been said many times in this thread in the past if they did have the correct paperwork they would have had me in court a long time ago.

Hi Count Orlok If you look at the actual wording in the POC they are not claiming that it was them that sent the NoA just that I was sent one, which I was. In my case I did receive a NoA from Citi Financial dated 11-06-07, however, what they never sent me was a default notice. They registered a default notice on my credit file on the 31st May 2007 and from what I have gleaned from the many hours I have now spent on this forum, this is going to be a huge issue for them and one which I can use heavily when I come to put my defence together. THere is an abudance of info on this site you just have to look for it. I found a great defence for a dodgy DN and I am certainly going to use this. If you also read the POC they are claiming for interest for the period 08-06-07 (2 days before the actual assignment) - 20-06-2011. As I have said in a previous post from the date that I received the NOA I put the account into dispute, recorded a complaint with Citi, 1st Credit and the FOS so they are contravening the very act they state in the POC. Because the account was in dispute and the CCA had not been provided this means they are unable to claim for interest for that period - from what I understand. Even with the absoluty crap POC they have started this case with I think they have dug themselves a hole already.

Thanks Brigadier - you are right which is why I have sent this letter 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- (Wxxxxxx Sxxxxx) Claim Number: xxxxxxxxxx 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, Wxxxxxx Sxxxxx

Ok after a further read of a number of other threads I have drafted out this letter (CPR18) requesting further information from them as they have only actually mentioned the notice of assignment in their POC. When and if they respond to this letter I will then request the documents under CPR31:14 & 31:15. I will also request a CPR 15:5 at that time too. Any other thoughts from the site team if there is anything I have missed?

Hi Brigadier I posted up the POC in post #140 but here it is again word for word The claimant claims the sum of 8,898.97 for debt and interest. The defendant was indebted to Citifinancial Europe PLC for credit advanced. The debt was assigned to the claimant. Notice of assignement was given to the defendant. AND THE CLAIMANT CLAIMS 1 The sum of 6.727.12 2 Statutory interest pursuant to section 69 of the county Court Act 1984 at a rate of 8.00% per annum from 08/06/07 to 20/6/11 2,171.85 & thereafter at a daily rate of 1.47 until judgment or sooner payment IF YOU WISH TO SPEAK TO US REGARDING THIS CLAIM THEN PLEASE CALL 0208 7370 *schedule script I had originally drafted out a CPR 18 but on reflection as the CPR 18 is for information purposes only I feel it will be better to go straight for a CPR31:14 which only gives them 7 days to respond and also request an extension of time under CPR 15:5 at the same time. I do understand that the CPR 31:14 requests can be made when a claimant discloses a document by mention of it and as they have made mention of the assignement I cant see why I would be unable to as for all of the documents they are going to rely on in court. So to summarise - the claimiant is 1st Crud and their solicitors are J&P.

###### ADVICE PLEASE ####### Guys can you give me some further guidance please? Now that I have received the Claim from I need to write under CPR but I am not sure who to send the letters of request to - is it to the claimant or the solicitors? Firstly I want to ask for an extension of time under CPR 15:5 and I also need to request information under CPR 18 as they havent referred to any documentation in the POC.

So they havent received signed authority from me that I am giving myself permission to act on my behalf - thats circular logic in the extreme I think!! I am just going to ignore these muppets and carry on. I only wrote to Connaughts so that they had a copy of what I sent to Mr Flynn!! CPR 15: 5 here we come.

##### Update - Help required Please ##### Well this is an interesting turn of events. A letter has arrived from Connaught collections today (very quick response) and I would appreciate advice/help/suggestions as to how to respond to this / or if I should respond at all. It is very short so I will type it here word for word exactly as it has come in. I have also pasted my letter to them as i didnt put it above. I only copied Connaughts so that I had covered all bases as it was Gavin Flynn Head of Collections 1st Credit that my 1st letter was addressed to and I wrote in big CAPS in PEN; COPY on the letter that went to Connaiughts so that they could see what I had sent to 1st Crud (even though they are one and the same thing!). Your thoughts are most welcomed. -0-0-0-0-0-0-0-0-0-0-0-0-0-0-0-0-0- Connaught Collections Their address Soveriegn (thats their incorrect spelling) © Wxxxxxx : Sxxxx C/o Then my address as I put it on my letter Date 28 June 2011 Dear Sir / Madam, Thank you for your recent undated Letter (they are right - in my letter to them I forgot the date !!!) Please note that we have received no signed authority for you to act on behalf of Mr Wxxxxxx Sxxxxx and as such we disregard your letter in its entirety. Yours faithfully, Connaught Collections.. -0-0-0-0-0-0-0-0-0-0-0-0-0-0-00 What I sent to them was a very short letter and a copy of the original to 1st Credit which I posted above. My letter addressed to them was as follows - ©Wxxxxxx : Sxxxxx Authorised Representative for WXXXXXX SXXXXX (LEGAL FICTION NAME ™ and all derivatives thereof. My Address in full Connaught Collections, The Omnibus Building, Lesbourne Road, Reigate, RH2 7JP To Whom it may concern Connaught Collections Ref No 3637318 I am writing in response to two letters from your Judge & Priestly Solicitors dated 13/05.2011 & 03/05/201. I have, as requested in those letters, written directly to 1st Credit and have attached a copy of the letter I sent to them. Yours faithfully By: Sovereign © First name : Family Name Authorised Representative All Rights Reserved. Errors & Omissions Excepted WITHOUT PREJUDICE – WITHOUT RECOURSE – NON-ASSUMPSIT Without any admission of any liability whatsoever, and with all Natural, Inalienable, Rights reserved. Please address all future correspondence in the matter to a direct Human Self, namely First Name : of the family, as commonly called Sxxxxx.

#### Update ###### Well my letters have all arrived safely and have all been signed for. Interestingly the letter that arrived at the J&P office had an illegible signature and the name of the person that signed it was J+P!!! Also very interestingly both my letters to Connaughts and 1st Crud were signed at the same time on the same morning by the same person!!! Well they do make it clear on their letters that Connaughts are only a trading style of 1st Crud! So now they have arrived I am going to also put part two into action and request an extension under CPR15:5 Also just about to speak with OFT & trading standards about the way Connaughts have been harrasing me despite several very clear written requests that I do not wish to deal with this on the phone. Oh the joy of life dealing with low lifes!! Well come on Andy Murray thats all I can say today.

Hi debt4get When I received the claim form the very first thing I did was to go online and complete the AOS and absolutely ticked the " I intend to defend all of this claim" box. The next thing I did was prepare the letter I have pasted above and have sent that off yesterday RD to all & sundry. This is an approach a friend of mine has used with a lot of success and it involves, firstly accepting conditionally the amount stated and then if the DCA/Creditor dont come up with the information requested then by default the DCA/creditor is into a a tacit agreement with you. It takes about 30 days to get hem into a tacit agreement so with a CPR15:5 extension, I have plenty of time to prepare a defence if I need it. I am going to use this strategy in tandem with the CPR route too. I am going to request an extension under CPR 15:5 and then a N244 if they refuse. I am also going to CPR 31:14 and then also a CPR 18 if necessary Having now spent numerous hours on this forum and with 19 pages of information gleaned, i think I have an idea of the way forward. I really like some of the suggestions by silly girl1 and Pt2537 in http://www.consumeractiongroup.co.uk/forum/showthread.php?283443-Embarrassed-Defences-and-the-problems-with-them./page3 thread. I am not going to enter an ED but the advice there is priceless and I agree totally with Silly girl to keep it simple and direct. I am dealing with an absolute bunch of muppets at 1st Crud and I am now treating them as professionally as I can but with the contempt they absolutely deserve. I have had to put up with a lot of crap from this bunch and I feel it is time to fight back as they are now trying what I hope is their last ditch attempt to get me to roll over!! GRRRRRRR (Teeth showing)

DX - Thanks very much for your comment and it has taken me a good few hours to trawl through other threads on this site so no work done today, however, what I have found is pure gold and I hope will keep me pon the straight and narrow as things progress with this case. I have sent a letter off to 1st Credit, J&P & Connaiughts yesterday so that they all have a copy of it. I have pasted it here and I am hoping that by offering them conditional agreement they wont be so stupid as to keep this going on to court. If they do then I have as a back up all of the CPR letters, embarrassed defences, no / Incorrect DN statements and all of the other good stuff that is contained primarily in IJHP's post. Copy of my letter Non-Negotiable © xxxxxx: xxxx Authorised Representative for XXXXXXX™ and all derivatives thereof. C/o Address Mr Gavin Flynn, Head of Collections, 1st Credit, PO Box 278, Reigate, RH2, 7WB 27/06/2011 Dear Mr Flynn RE 1st Credit Limited Ref No xxxx; Connaught Collections &Judge & Priestly Ref No xxxxx I have received two letters recently from Judge and Priestly Solicitors dated: 13/05.2011 & 03/05/2011 I feel this matter is very serious and I wish to deal with it in writing. I have, on several occasions in the past requested that all correspondence relating to this matter be dealt with in writing, however, your company and those associated with you, namely Connaught Collections; seem to feel that it is acceptable to totally ignore this. Recently I have received several phone calls from Connaught Collections who are a trading style of your company and despite requesting that they cease calling me and remove my telephone number from their/your database, they have chosen to totally ignore my reasonable requests, and have continued to harass me by continuing to call me to discuss this matter. On the 24/06/2011 a representative from Connaught Collections called me twice and refused outright to remove my details from their records. He also refused to give me his name. I log the dates and times of all calls/messages and these calls now constitute ‘harassment’. Because of this harassment, I intend 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 creditor's agent to make demands (for money), which are aimed at causing 'alarm, distress or humiliation', because of their frequency or manner, which they have now succeeded in doing. To reiterate, I do not give you, Connaught Collections, Judge & Priestly Solicitors, LCS Solicitors or any other company you may trade as, or who are a trading style of your company, or whom you may request to assist you in relation to this matter, permission to contact me by telephone. Please read the following thoroughly and very carefully before responding. The reason why you need to read very carefully is simple. I am offering your company conditional agreement. This removes controversy, and means that you no longer have any ultimate recourse to a court of law in this matter, because there is no controversy upon which it could adjudicate. You always have the option of dragging these conditions into a court of law only to be told that they are, indeed, perfectly lawful. That is, of course, always your prerogative should you decide to waste your time. For this reason it is important that you carefully consider this notice and respond in substance, which means actually addressing the points raised herein. The 'nearest official form' will not suffice, and consequently is likely to be ignored by myself without any dishonour on my part. On the other hand there is a time-limit on the agreement being offered. It is reasonable, and if it runs out then you and all associated parties are in default, removing any and all lawful excuse on your part for proceeding in this matter. 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. NB This is not a complaint or a query or a request for a statement / agreement and is not to be treated as one. Do not refer to me as Mr or any Title, which is a legal fiction and is not me. You may only use my name when sending payment. Yours sincerely By: Sovereign © First name : Last Name Authorised Representative All Rights Reserved. Errors & Omissions Excepted CC: Judge & Priestly, Justin House, 6 West Street, Bromley, Kent, BR1 1JN Connaught Collections, The Omnibus Building, Lesbourne Road, Reigate, RH2 7JP WITHOUT PREJUDICE – WITHOUT RECOURSE – NON-ASSUMPSIT Without any admission of any liability whatsoever, and with all Natural, Inalienable, Rights reserved. Please address all future correspondence in the matter to a direct Human Self, namely First Name : of the family, as commonly called last name

Well I have to say that the old adage "seek and ye shall find" is certainly true when it comes to this site. I decided to spend the last few hours doing more research and I came across THIS thread which is almost a mirror image of mine. I have now got 19 pages on a word document for which to use for letters and to put together my defence if I ever need it - so huge thanks to the site team and to Enron & IJHP for their fantastic input, suggestions and letters. Huge thanks also to everyone who has helped me to date on this thread - the battle continues. I will post my letter sent yesterday in a separate post but I just wanted to say a huge thanks to all who make this site possible - when I have some spare cash I will make a donation that is a promise.

IHPJ I have just spent the last 3 hours reading all of this thread and I have to say it is pure gold - fantastic. I am in an unbelievably similar situation to you with 1st Credit having bought my "debt" from Citi and have now sent me a claim form from Northampton. Basically they have served me with a claim form with a laughable POC which sounds very similar to yours - This is what the notice says "The claimant claims the sum of 8,898.97 for debt and interest. The defendant was indebted to Citifinancial Europe PLC for credit advanced. The debt was assigned to the claimant. Notice of assignement was given to the defendant. AND THE CLAIMANT CLAIMS 1 The sum of 6.727.12 2 Statutory interest pursuant to section 69 of the county Court Act 1984 at a rate of 8.00% per annum from 08/06/07 to 20/6/11 2,171.85 & thereafter at a daily rate of 1.47 until judgment or sooner payment IF YOU WISH TO SPEAK TO US REGARDING THIS CLAIM THEN PLEASE CALL 0208 7370 *schedule script" Interestingly they make no mention of the fact that the account was in dispute for the 33 months (and still is IMHO due to the fact that they havent sent what I asked for) yet they are wanting to collect interest for it. They also don't make mention of the fact that Citi never told me they were defaulting my account and they certainly never sent me a DN. I was in a reduced payment plan with Citi which I actually doubled what I was paying them when I received a Notice of Assignment from them and then a welcome letter a week later from 1st Crud!!! If you want to have a laugh then the full sorry story which is great for a laugh is here Post #11 gives all the history and the rest is the story so far. You are a little way in front of me so if you dont mind I have copied all of your letters as they are excellent and I am about to write to 1st Crud again. I have already sent them one letter yesterday with a different approach which still gives me the option of employing the suggestions and proceses recommended here. I have 19 pages on a word doc of all the appropriate letters, tips hints laws etc etc as well as loads of other threads now stored in favoriotes, which I am sure is going to help me no end. In my case it took 1st crud 33 months to come up with what they claim is my CCA - basically a pile of photocopied paper with my name and account number stuck on the front. Having now studied this thread and all of the others that are refferred to within it I feel a lot more confident in being able to go ahead with my approach to what 1st Crud have done. I was scared at the start of this process but now I am just mad and I am am going to make it my business to report them to as many people as I can and make it as difficult as I can for them and their cohorts (connaughts). I have threatened in the past to reprt them but haven't but now enough is enough and my latest letter I said I am going to report them for harrasment which will be my next letter. OFT, Trading Standards & My MP here we come (not sure it will do any good but it will make me feel a lot better about it) I don't want to hijack your thread but I would love to stay in touch with you as you and I are both at very similar stages with the same bunch of lovely men & women!!

Thanks DX THe last payment I made to Citi was 05/11/07 even though they had sold the debt to 1st Crud we still made the payment to Citi. We did inform 1st Crud that as the account was in dispute we would not make payments to them but continue to make them to Citi.

It is also interesting to note that in all of the letters I wrote to Citi asking them to tell me why I was not informed that a default was going to be put on my file, I never received any answers to this qurestion. Another question Brigadier. In a letter I wrote to 1st Credit in Nov 2007 (which I gleaned the information from this forum) I wrote that because they had not provided me with a copy of the agreement that this negated any Notcie of Default being served on me as required by the CCA 1974 and that if documentation were to be produced, they would be aware that a default notice serves to cancel any original terms and conditions and as such cancelled any right that they or the original creditor miught have, implied or otherwise to share my information without my consent. DO you know if this is still true?

Thats a great start as you are quite right in that I had no opportunity to remedy the default. One of the 1st Cruds staff that I talked to actually admitted to me on the phone that he had no record on his system of any default notice being sent out to me. Citi actually wrote to me in 2008 and stated "we are under no obligation to comply with your request for a copy of your agreement under the Consumer Credit Act as we no longer have a contractual relationship with you, nor are we seeking to enforce any agreement against you. Your right ot be provided with this information from Citi Financial ended with the assignement of your debt to 1st Credit Limited" I am assuming that if this went to court the fact that the default was issued on the same day as they assigned the account means they would have to provide an answer for this - or would they jusyt pass the buck to 1st Credit. I ask because my credit file shows the default as being with 1st Credit. I intend to put them on strict proof of the delivery of the DN when and if it ever gets to court.

I have just checked the last credit report I had which shows that my account was in fact defaulted on the 31-05-07 and I wasnt informed by Citi that they had assigned my account to 1st Crud until 11/06/07. I was never informed by Citi or 1st Credit that a default was going to be registered on my account. - I am wondering if I can use this in any defence I put together 1ST CREDIT LIMITED Unsecured loan Default £6,727 Name: MR xxxxxxxxx xxxxxxxx Address: xxxxxxxxxxxxxxxxxxxxxxxxxx Date of birth: xx/xx/xx Company name: 1ST CREDIT LIMITED Account type: Unsecured loan (personal loans etc) Default Balance: £6,727 Current Balance: £6,727 Defaulted On: 31/05/2007 File Updated for the Period to: 23/12/2007 A defaulted account is removed from your report after six years whether or not you have paid the debt in full. If you have paid some of the debt off, the balance should show how much you still owe.

Well the original notice of assignment came from Citi Financial to which I immediately made a formal complaint and got the FOS involved. I then received a letter a week later from 1st Credit informing me that my account had been assigned to them. I havent checked my credit file for a while but I will have a look to see if there is a default on there and report back. I have just sent a letter to 1st Credit and have sent connaughts and J&P a copy too. I havent made reference to the claim form but have offered them a conditional agreement. My reasoning for this approach is that from what I understand, if I am not contending the fact that I owe them the money but am accepting full liability providing they can provide me with the proof, then this means there is no controvesy upon which a court could adjuicate. I will post my letter up in a while. I also intend to make formal complaints now to as many bodies as I can. - I am spitting feathers now as they say.

Thanks Brigadier Technically 1st Crud havent sold or assigned the debt as LCS & Connaughts are all one and the same thing. Citi financial are the only ones who sent a final response and I havent had one of thoise from 1st Crud. What was in dispute was thwe fact that Citi FInancial assigned my account to 1st Crud in the first place without even giving me a default notice. On one of the forums (I can remeber if it is this one as I have been looking at so much stuff) I recall someone posting that a customer needs to be warned that their account is going to be defaulted to give them time to rectify the situation. In my case this never happened and !st credit even stated that they thoiught this was irrelevant and asked me to state why I believed it was!

Haivng now calmed down and thought this through over the weekend, I feel I have a few options open to me As well as the issues I listed above, it occurred to me that in the past I have written to then and asked them to confirm if my original request for information was not responded to within the statutory legal limits. I also stated that because they had not responded within these timeframes that they had committed a criminal offence to which their response was:- 1) "Your claim that 1st Credit Ltd has committed a "criminal offence". This may have been correct when writing your earlier letters in 2007, however the Consumer Protection from Unfair Trading Regulations 2008 section 3.12 states that this claim is "incompatible with the contract law", thus your statement is now incorrect. 2) "Your "legal advisors" advised you thst it is necessary for a True Copy of the agreement to be signed. If they had indeed committed a criminal offence in 2007 by not responding to my request for information within the statutory legal timeframes I am woindering if they are correct that my statement is now incorrect? Surely they either did commit a criminal offence at the time or they did not commit a criminal offence? If they did commit a criminal offence can I report them to the police and take action against them now for this? Also they state that what they have sent me is a true copy of my credit agreement, however, how can they prove that this is the case unless there are signatures on the document? Anyone could have compiled the paperwork and inserted my details. With respect to the Particulars of Claim - my account was in dispute for the whole period they are claiming interest for and so am I correct in thinking that they cannot claim interest for this period?. I have stated to them in one letter that because they were trying to recover an alleged debt whilst the account was in dispute they were contravening the OFT guidelines and I did threaten to report them, however, due to the stress and anxiety that this has cause me I have never written to the OFT. Any thoughts on this would be most welcomed. Many thanks in advance.

Thanks for all your help Brigadier - I will await with anticipation.

Thanks again I am struggling with this because you have asked me to do something for which I am asking for help with. I understand I need to prepare a defence so is the type of thing I need - Having read other threads on the forum it seems that CPR letters (whether they be 18 or 31:14) should be requested from the solicitors acting on behalf of the Claimant. I did find this on one thread in terms of using this as a defence but I dont know how much (or little) to include 1. The particulars of claim are vague and do not provide sufficient detail to enable the defendant to plead effectivley or at all. By way of example the claimant has failed to confirm the date of agreement upon which the cause of action is based.[/i] 2. Prior to the issue of the action the claimant was requested to disclose documents relating to the alleged debt and/or agreement. The claimant failed and/or refused so to do. 3. The documents described above were the subject of a request pursuant to the Data Protection Act 1998 and/or the Consumer Credit Act 1974 4. In all the circumstances the defendant denies being indebted to the claimant as alleged or at all. Other things I think I could use are that I was in a repayment plan with the original creditor who for no apparent reason passed it to 1st Credit. I asked for proof of right to collect by means of a CCA which they have failed to provide. They sent me what they claim is my CCA but as I have said earlier in this thread it is only a bunch of photocopied paper. No signatures are present anywhere. I also never received a default notice from the OC only a notice of assignment. One of 1st Credits staff did admit on a phone call that they had no noitification of a default notice from the OC on my file. I have the date of this and the name of the person. I suppose that is my main defence that the OC sold my account and I never received a default notice and that I did not receive my CCA within the statutory guidelines (it took them 33 months to send me anything). Also are they able to claim interest for the 33 month period when I never heard from them. I also put the account into dispute and i was under the assumption that no DCA could chase for a debt when there was a dispute on the account. I am not sure of this is enough detail - Help please? I know you have said not to worry about thisd tonight or over the weekend but respectfully I am worried about it. I just need to know what to do and the right way to do it. Also can you explain at what point I write to J&P with the CPR letter and also which one is the right one to send.

Thanks Brigadier - if I forget J&P for now what is it that I need to do? I really am in the dark about this and would appreciate a step by step guide form someone.

I am going to spend this evening taking a very long look through the forum to see what others have done in the same situation. Having now gone on line and registered the acknowledgement of service can anyone please tell me whatI now need to do or which specific letter I need to write to J&P. I want to respond as soon as I can and would really appreciate someone guiding me in the right direction. Many thanks.