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About zhanzhibar

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  1. TQ for your advice PB. They are noted. Rather than talking about DN which we can only talk about if there is a validly executed agreement, I would appreciate it if you can comment on whether or not I do have an agreement/contract in the first place because all I know is my so-called agreement is made of these a) an intranet e-application form where even their 2 legal firms cannot agree as to when allegedly I applied for the card b) a blank T&Cs with none of my name nor address c) an IP address which as we all know is always changing d)and now suddenly in the disclosure of ev
  2. Am going to put a point number 3 for my case summary. 3. The Claimant disagree with the judgment in 2 above
  3. TQ Bazaar for your input. might have to rethink my case summary & schedule of issue. In the meantime would appreciate it if somebody could comment on my queries below re the listing Q itself Help! Comments please on the above Might have to rethink about the 2 schedule above after putting kids to bed. Would appreciate any pointers... and here's my estimate of costs.. is this ok do you guys think? Looks fair unlike theirs
  4. I've e-mailed them twice after their e-mail asking the wording to be more non-partisan: They don't like to change their "non-partisan view" of course & reply & This is Pishcon V3 So now what do I do?
  5. OK I think I am in trouible now... Mishcon replied.. So what if I disagree with their issue & case summary?
  6. Submitting these to Mishcon via e-mail this morning. Should I leave point 3 to be skeleton argument rather than issue..owh well.. I'll wait & see what they say 1st this morning.
  7. I am not sure whether to put it here now or to leave it as skeleton argument for later. What do you all think? I got till 10 this morn to decide becoz I told Pishcon I let them know whether I agree with the issue & sent them mine. I might just sent it to them & see whether they agree or not with that 3rd issue. I think I have to read up Carey v HSBC & Amex v Brandon case for next week STAY hearing.
  8. OK this is what I am going to send them tomorrw: Have I misssed anyhting? What do you all think?
  9. Hiya, I am going to put the WS of Fiona again here coz I think that's where I am going to raise my Schedule of issue: Para 2 from the above: can I include this as one of the issue? para 3 from below: another issue; I never received copy of ALL docs in FT1, para 7 ; pages 3-15 i never seen nor received before this. How can this be statement oftruth? para 10.10: The abridged terms is on page 47 to 51 ... I didn't notice until today.. Para 10.11: are they allowed to recon an agreemment as evidence? Page 52-56 Para 24:
  10. Just checking my other e-mail address & Mr Chik of Mishcon has been contacting me. Here are the attachments to the e-mail Have to say looking at the issues, it basically sums it up but my brain is a bit tired as it is now 3.30 am. I have e-mailed Edwin & told him I can't give any answer till Wed 13 b4 10. Would appreciate some comments on these please. I also noticed something when I went through Exhibit FT1 of Miss Fiona which consist of 100 pages of all sorts of documents tonight. Amongst these 100 pages, there are 3 sets of agreement wit
  11. TQ shadow. I am updating my case summary at the mo to include this. I am also preparing an estimate of costs and was going through what they sent me. The cost they estimating is c £12k. Here is my estimate of cost My £928 looks quite ridiculous next to their £12k, am I missing something here relating to fast track cost estimate? And what is that estimate costs re Defendant and his solicitor of £1000? Anybody familiar with these sort of thing? Furthermore, am wondering why is Bracher's costs in there too as we already settled that costs following
  12. TQ for that clarification, Shadow. I think I understand now. So So the result of the points above being only the court can determine whether the agreement is enforceable? So should I include this point in my case summary or shall I wait till I need to prepare skeletal argument?
  13. Hi all, can somebody explain to me why miss fiona said in para 31of Amex WS that the agreement "did not have a definite duration" hence s98 does not apply?
  14. Ok here is my case summary I need to do the listing questionnaire together with Summary of case & schedule of issues and submit yo court by 14th Oct; can anybody/somebody let me know whether a) the way I do my schedule of issues above is correct and perhaps give me a few pointers what else to write there b) whether my case summary above is the way to do it or whether case summary=skeleton argument hence I need to put all issues now c) whether I need to say sthg about the application to stay in the listing questionnaire part A?
  15. Hi all I am trying to get this argument re Clause 16(2) in my head in simple English. So am I right in thinking that a) in para 20 of their WS, Clause 16(2) of T&Cs give Claimant the power to end the agreement by giving notice to the defendant and vice versa. b) we are saying that Amex cannot do this because CCA is the regulation overriding here specifically s87/88 CCA 1974 so without a proper default under s87 they shouldnt be able to terminate the agreement early. c )so what we are saying is that the Clause 16(2) they relied upon from their T&C is void i.e inval
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