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I would love some help in the wording of Particulars of Claim against Orange

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I'm currently filing a claim against Orange (using MCOL), and would appreciate some input on what to put in the particulars of claim.


The claim is for two months service charges, during which time Orange had not provided me with a SIM card to use their service.


Some background:


The Ts & Cs in force at the time, section 12.2 states


what to do if your SIM Card is lost, stolen or damaged


You must inform us immediately if the SIM Card supplied to you is lost, stolen or damaged. You will remain liable for all Charges incurred until you do so. We will send you a replacement SIM Card as soon as reasonably practicable, but we reserve the right to charge you for doing so.


I did not receive a SIM card for 70 days, and only after phoning them a number of times.


A refund was refused when I called, leading me to terminate the contract and make a request for refund in writing.


On receiving no reply, I instead received a demand from their credit department, requesting payment of further service charges, occurring after the date of termination.


I have since sent a letter before action, to which I have received the standard "We are sorry that you're leaving us" sycophantic schtick, hence proceeding with the claim.


As this is would appear to be a purely contractual claim, how might I go about making sure that I include all of the relevant details, couched to appear that I have a reasonable case?

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I should also, perhaps, note that the letter from the credit department made vague threats about defaults and credit ratings.


I seems to me they are threatening me in order to enforce a contract that is no longer binding, and that they are initially in breach of - What steps, I any, do I need to take to prevent them from registering a default, no matter how inaccurate, as it would appear this would be very difficult to have removed.

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