Homelessness, Debt & Court Action after 14 days...

[pt2537]

ah i see where the confusion comes from and i will try and resolve it.

 

ok, when you write to a creditor and request a copy of your agreement and include the one pound fee. they do not need to send you an EXACT copy of your original credit agreement that is signed by you

 

the law allows them a loophole where they can send a copy of the agreement you would have signed providing the terms within are the same as the original that you signed

 

Ok, now that is for compliance with the CCA 1974.

 

however, when we come into the arena of court action then the rules change

 

they MUST HAVE A SIGNED COPY OF THE AGREEMENT containing all the required prescribed terms, if they dont then they cannot obtain an enforcement order

 

this is where the CPR or Civil Procedure Rules Request comes into play.

 

when they start litigation they must provide you a copy of the credit agreement not like the one they provided you but the copy of the signed one

 

so that is why you use the CPR request as well as the CCA request

 

i hope this clarifies a few things and answers you point

[lottery-loser]

Right! thanks for that! Does that mean the 12+30 day rule comes into play again? How long have they got to produce the proper agreement?

 

I will need to do my defence this week if you could have a look at the gibberish I wrote above as my 1st attempt please?

 

Thanks.

[lottery-loser]

Bump Bump Bump!

[lottery-loser]

Can Somebody Please Reply To My Posting Of 16th March!!!!!!

[pt2537]

Hey there LL

 

Right, i will go through the thread over the next hour or so and post up a suitable defence to use

 

off the top of my head i cant remember if they sent a credit agreement or if they sent a default notice or if they attached any documents to the claim form which they were looking to rely upon

 

so i will have to refresh myself on the thread

[lottery-loser]

THank you! I will check later and get back to you! Please note that they are also not going to be able to achieve anything by taking me to court as we have now sold our house (completion after Easter) have no income (except disability benefits) and have sold our possessions. Presumably they could still make me bankrupt but they still wouldn't get everything back as the £ simply isn't there.

 

I am also writing this week to HFC to offer a (partial) full & final settlement sum from the proceeds of the house sale, using the template on CAG.

[pt2537]

personally, i would be very very careful what you say to them, if you are writing, make sure the letter is headed clearly

 

WITHOUT PREJUDICE

 

if you dont they can use it against you in court

[lottery-loser]

can you be more specific (by pm if necessary!) about "being careful what I say to them" ?!

 

Please also note that they have not responded to the CPR (yet). Do they normally bother?

[pt2537]

well, i was being very general, but the Without prejudice cloak will protect you to a degree

 

what i really meant was dont say anything that they could use against you, like " i admit that i owe you the money" for instance

[lottery-loser]

Yes I took that bit (saying "all the money I owe you") out of the template letter as it occurred to me that that wasn't very sensible! I will post the letter up here for the benefit of others if successful, however at the moment the wording is obviously too personally attributable!

[lottery-loser]

Paul,

Did you manage to look at the thread for the necessary details? I must get this off on Wednesday!

Thanks.

[goorooji]

Removed

[pt2537]

Paul,

Did you manage to look at the thread for the necessary details? I must get this off on Wednesday!

Thanks.

i will post something up this evening to assist you, sorry for the delay but when you make plans to do things something comes along and mucks it up (in my case the outlaws arrived) so i have had to stay away from the PC

 

i will get on to it during this evening and see what i can get done

[pt2537]

Hi LL

 

can i just double check something,

 

the Credit Agreement and application form that you posted,

 

were they supplied in reply to a CCA request along with the one pound fee or were they supplied in response to the CPR request made under the Civil Procedure Rules?

 

also, can i just check that the LBA informing you they were taking legal action is dated 2 days before the court claim was issued, is htere any chance of a quick look at it please?

[lottery-loser]

That's ok Paul, I thought something like that might have happened (I know other people have a life outside here!!)

 

I'm just going through the letters now and will adumbrate the correspondence in a few mins.

[pt2537]

ok well ive just realised that you havent posted the POCs so i will struggle to build a defence to their claim without knowing what their POCs say

 

can you post them, ASAP and i will then be able to start on the defence

[lottery-loser]

28/07 request for CCA to JL Fin Services including updated financial statement;

10/11 1st letter from restons requesting reply by 24/10 demanding settlement or increased repayments if not forthcoming legal action would be taken;

15/11 JLFS letter saying unable to find CCA;

21/11 replied to R;

3/1/8 2nd letter from R: "We enclose copy of the legal agreement as requested" (this was the unsigned applicaiton form!!!!!!!!) "If we don't get realistic proposals by 15/1 we are instructed to commence legal proceedings without further notice";

10/1 emailed reply as they only gave me 4 days to get a repply to them. Offered 500% increase in monthly payment, whilst house sale ongoing;

25/2 reply from R rejecting payment offer, resending app form again. "received strict instructions to commence legal proceedings".

27/2 I RECEIVED court papers (issued 26/2).

 

I'll have a go at putting this last letter on photobucket. If you want any others please let me know.

[lottery-loser]

Paul I pm'd you POC on 2nd March (due to confidentiality). I've just re-sent it and will email it all too.

[pt2537]

Hi LL,

 

Thanks for that

 

much appreciated

[lottery-loser]

Last letter, Paul:

 

http://i270.photobucket.com/albums/jj85/toinyweeny/24032008079.jpg

[pt2537]

 

 

In the xxxxxxxx County Court

Claim number

 

 

 

 

 

Between

 

HFC- Claimant

 

and

 

 

LL - Defendant

 

 

 

Defence

 

 

1. I xxxxxxxxx of xxxxxxxxxxxxx am the defendant in this action and make the following statement as my defence to the claim made by xxxxxxxxxxxx

 

2. Except where otherwise mentioned in this defence, I neither admit nor deny any allegation made in the claimants Particulars of Claim and put the claimant to strict proof thereof.

 

3. The Defendant is embarrassed in pleading to the Particulars of Claim as it stands at present, inter alia: -

 

4. The claimant's statement of case is insufficiently particularised and does not comply or even attempt to comply with CPR part 16. In this regard I wish to draw the courts attention to the following matters;

 

 

a) The Particulars of Claim are vague and insufficient and do not disclose an adequate statement of facts relating to or proceeding the alleged cause of action. No particulars are offered in relation to the nature of the written agreement referred to, the method the claimant calculated any outstanding sums due, or any default notices issued or any Notice of Assignment required for the claimant to have a legitimate right of action for the purported debt or any other matters necessary to substantiate the claimant's claim.

 

b) A copy of the purported written agreement that the claimant cites in the Particulars of Claim, and which appears to form the basis upon which these proceedings have been brought, has not been served attached to the claim form.

 

c) A copy of any evidence of both the scope and nature of any default, and proof of any amount outstanding on the alleged accounts, has not been served attached to the claim form.

 

 

5. Prima facie the claimants particulars suggest that this is an open and shut case, however it is not and it is infact far from it. I will elucidate the main key issues in this defence and outline the reasons why the claimants case is seriously flawed as it stands

 

Statutory request made under section 78 Consumer Credit Act

 

6. On xx/xx/2007 I requested that the claimant provide a true copy of the executed credit agreement, which they claim exists between parties pursuant to section 78(1) Consumer Credit Act 1974. The Consumer Credit (Prescribed Periods for Giving Information) Regulations 1983 (SI 1983/1569) sets out that the claimant must comply with such request in 12 working days of receipt of such request. Copies of the letter and proof of delivery attached marked Exhibit LL X & X

 

7. For clarity, section 78(1) of the Consumer Credit Act 1974 states

 

78. Duty to give information to debtor under running-account credit agreement.-

 

(1) The creditor under a regulated agreement for running-account credit, within the prescribed period after receiving a request in writing to that effect from the debtor and payment of a fee of [F1 £1], shall give the debtor a copy of the executed agreement (if any) and of any other document referred to in it, together with a statement signed by or on behalf of the creditor showing, according to the information to which it is practicable for him to refer,-

 

(a)the state of the account, and

 

(b)the amount, if any currently payable under the agreement by the debtor to the creditor, and

 

©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 to the creditor.

 

 

8. Section 78 (6) consumer Credit Act 1974 sets out the consequences of failure to comply with such request and states

 

s78 (6) 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.

 

9. In response to the request made on xx/xx/2007 the claimant supplied a document annexed to this defence marked LL X, which it claimed to be the credit agreement. It was a single sheet of paper and the claimant has confirmed in writing that this document is indeed the credit agreement, which they hold on file.

 

10. In addition to the "priority Application form" the claimant supplied a blank credit agreement, which bears no obvious relationship to the application form. There is no apparent link between the two documents and therefore I do not believe that the second document is in anyway related to the application and accordingly put the claimant to strict proof that they are related

 

11. In addition I note the application form clearly states "Your Right To Cancel" above the Signature box. Therefore since the application confers a right of cancellation the claimant should have supplied notice of cancellation in response to the Statutory request made under section 78(1)

 

12. Further more the Application refers to "Terms and Conditions" but no terms and conditions were supplied in reply to my Statutory request made under section 78(1)

 

13. It is drawn to the courts attention that the documents supplied do not contain my signature and therefore are not executed ,the consequences of this are that if the claimant does not hold a signed credit agreement this claim cannot succeed as per section 127(3) CCA 1974

 

 

14. It is drawn to the courts attention that the claimant has failed to comply with my request and is in clear default of its obligations under s78 (1) Consumer Credit Act 1974 and it is averred that the claimant has no right of action until such time as the default is remedied and the claimant supplies the documents referred to in points 10,11 and 12

 

 

The Request for disclosure

 

 

 

15. Further to the case, in an attempt to ascertain what grounds the claimant is bringing this action and to allow me to prepare my defence I requested on xx/xx/2007 the disclosure of information pursuant to the Civil Procedure Rules, which is vital to this case from the claimant. The information requested amounted to copies of the Credit Agreement referred to in the particulars of claim and any default or termination notices, a transcript of all transactions, including charges, fees, interest, alleged repayments by myself and payments made by the original creditor. Also any other documents the Claimant seeks to rely on, including any default notices or termination notice. (Attached marked LL X)

 

16. To Date the claimant has failed to accede to my request under the CPR and I have not received any such documentation requested. As a result it has proven difficult to compose this defence without disclosure of the information requested. The claimant did acknowledge my letter but that is all

 

 

 

17. Notwithstanding point 14 that the claimant is not entitled as matters stand to this action. The courts attention is drawn to the fact that the without disclosure of the requested documentation pursuant to the Civil Procedure Rules I have not yet had the opportunity to asses if the documentation the claimant claims to be relying upon to bring this action even contains the prescribed terms required in Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) which was amended by Consumer Credit (Agreements) (Amendment) Regulations 2004 (SI2004/1482).

 

 

18. Under the Consumer Credit Act 1974 there are certain conditions laid down by parliament which must be complied with if such agreement is to be enforced by the courts

 

19. Firstly, the agreement must contain certain Prescribed terms under regulations made by the Secretary of State under section 60(1) CCA 1974, the regulations referred to are the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553)

 

 

20. The prescribed terms referred to are contained in schedule 6 column 2 of the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) and are inter alia: - A term stating the credit limit or the manner in which it will be determined or that there is no credit limit, A term stating the rate of any interest on the credit to be provided under the agreement and A term stating how the debtor is to discharge his obligations under the agreement to make the repayments, which may be expressed by reference to a combination of any of the following--

1. Number of repayments;

2. Amount of repayments;

3. Frequency and timing of repayments;

4. Dates of repayments;

5. The manner in which any of the above may be determined; or in any other way, and any power of the creditor to vary what is payable

 

 

 

21. It is submitted the "priority application form" purporting to be the credit agreement supplied falls foul of the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) in so far that the prescribed terms are not contained within the agreement. The prescribed terms must be with the agreement for it to be compliant with section 60(1) Consumer Credit Act 1974. In addition there is case law from the Court of Appeal which confirms the Prescribed terms must be contained within the body of the agreement and not in a separate document

 

22. I refer to the judgment of TUCKEY LJ in the case of Wilson and another v Hurstanger Ltd [2007] EWCA Civ 299

 

"[11] Schedule 1 to the 1983 Regulations sets out the "information to be contained in documents embodying regulated

consumer credit agreements". Some of this information mirrors the terms prescribed by Sch 6, but some does not. Contrasting

the provisions of the two schedules the Judge said:

 

 

"33 In my judgment the objective of Schedule 6 is to ensure that, as an inflexible condition of enforceability, certain basic minimum terms are included which the parties (with the benefit of legal advice if necessary) and/or the court can identify within the four corners of the agreement. Those minimum provisions combined with the requirement under s 61 that all the terms should be in a single document, and backed up by the provisions of section 127(3), ensure that these core terms are expressly set out in the agreement itself: they cannot be orally agreed; they cannot be found in another document; they cannot be implied; and above all they cannot be in the slightest mis-stated. As a matter of policy, the lender is denied any room for manoeuvre in respect of them. On the other hand, they are basic provisions, and the only question for the court is whether they are, on a true construction, included in the agreement. More detailed requirements, which

are designed to ensure that the debtor is made aware, so far as possible, of specified information (including information contained in the

minimum terms) are to be found in Schedule 1."

23. If the agreement does not contain these terms in the prescribed manner it does not comply with section 60(1) CCA 1974, the consequences of which means it is improperly executed and only enforceable by court order

 

 

24. I refer to LORD NICHOLLS OF BIRKENHEAD in the House of Lords Wilson v First County Trust Ltd - [2003] All ER (D) 187 (Jul)

 

 

28.........I should outline the salient provisions of the Consumer Credit Act 1974. Subject to exemptions, a regulated agreement is an agreement between an individual debtor and another person by which the latter provides the former with a cash loan or other financial accommodation not exceeding a specified amount. Currently the amount is £25,000. Section 61(1) sets out conditions which must be satisfied if a regulated agreement is to be treated as properly executed. One of these conditions, in paragraph (a), is that the agreement must be in a prescribed form containing all the prescribed terms. The prescribed terms are the amount of the credit or the credit limit, rate of interest (in some cases), how the borrower is to discharge his obligations, and any power the creditor may have to vary what is payable: Consumer Credit (Agreements) Regulations 1983, Schedule 6. The consequence of improper execution is that the agreement is not enforceable against the debtor save by an order of the court: section 65(1). Section 127(1) provides what is to happen on an application for an enforcement order under section 65. The court 'shall dismiss' the application if, but only if, the court considers it just to do so having regard to the prejudice caused to any person by the contravention in question and the degree of culpability for it. The court may reduce the amount payable by the debtor so as to compensate him for prejudice suffered as a result of the contravention, or impose conditions, or suspend the operation of any term of the order or make consequential changes in the agreement or security.

 

29. The court's powers under section 127(1) are subject to significant qualification in two types of cases. The first type is where section 61(1)(a), regarding signing of agreements, is not complied with. In such cases the court 'shall not make' an enforcement order unless a document, whether or not in the prescribed form, containing all the prescribed terms, was signed by the debtor: section 127(3). Thus, signature of a document containing all the prescribed terms is an essential prerequisite to the court's power to make an enforcement order. The second type of case concerns failure to comply with the duty to supply a copy of an executed or unexecuted agreement pursuant to sections 62 and 63, or failure to comply with the duty to give notice of cancellation rights in accordance with section 64(1). Here again, subject to one exception regarding sections 62 and 63, section 127(4) precludes the court from making an enforcement order.

 

30. These restrictions on enforcement of a regulated agreement cannot be sidestepped.....

 

And further more

 

36. In the present case the essence of the complaint is that section 127(3) of the Consumer Credit Act has the effect that a Regulated agreement is not enforceable unless a document containing all the prescribed terms is signed by the debtor

 

49. ".............The message to be gleaned from sections 65, 106, 113 and 127 of the Consumer Credit Act is that where a court dismisses an application for an enforcement order under section 65 the lender is intended by Parliament to be left without recourse against the borrower in respect of the loan. That being the consequence intended by Parliament, the lender cannot assert at common law that the borrower has been unjustly enriched.

 

 

50. This interpretation of the Consumer Credit Act accords with the approach adopted by the House in Orakpo v Manson Investments Ltd [1978] AC 95, regarding section 6 of the Moneylenders Act 1927 and, more recently, in Dimond v Lovell [2002] 1 AC 384, another case where section 127(3) precluded the making of an enforcement order. In Dimond's case the restitutionary remedy sought was payment of the hire charge for a replacement car used by Mrs Dimond. The House rejected a claim advanced on the basis of unjust enrichment. Lord Hoffmann observed that Parliament contemplated that a debtor might be enriched consequential upon non-enforcement of an agreement pursuant to the statutory provisions. It was not open to the court to say this consequence is unjust and should be reversed by a remedy at common law: [2002] 1 AC 384, 397-398.

25. Since the judgment of Lord Nicholls of Birkenhead clearly sets out that without a credit agreement the claimant's case cannot succeed

 

26. Should the claimant be unable to produce the original agreement signed by both debtor and creditor and containing the prescribed terms, I request that the court uses its powers under section 142 Consumer Credit Act 1974 and declare the agreement supplied by the claimant (marked Exhibit LL X) unenforceable

 

 

27. The claimant would be aware of the fact that they would need to be able to produce a copy of the original agreement should they ever need to take legal action to enforce the agreement. The claimant would also need to be able to produce a true copy of the Agreement upon request pursuant to section 78 (1) Consumer Credit Act 1974, therefore it stands to reason that the claimant must surely hold such document.

 

28. According to sections 221 and 222 of the Companies Act 1985, a public company is required to maintain records for a period of six years (section 222(5)(b).

 

29. As a credit agreement is active until the agreement is terminated, I would suggest that all the payment records (and other documents making up the file - including the agreement/application etc) would be "live" until the account is paid, or terminated - thus, the full file should be retained for at least six years after that.

 

30. This interpretation fits in with Inland Revenue legislation that requires prime documents to be retained for a period of six years - AFTER THE END OF THE RELEVANT ACCOUNTING PERIOD. That would mean some files need to be retained for up to seven years. The relevant legislation is found in Schedule 18 of the Finance Act 1998 (paragraph 21) - of particular significance is sub-paragraph (6) which states:

 

"The duty to preserve records under this paragraph includes a duty to preserve all supporting documents relating to the items mentioned in sub-paragraph (5)(a) and (b)."

 

31. Finally, key documents/application forms etc must be kept until 5 years after that business relationship has ended. This is a requirement of The Money Laundering Regulations 1993, 2003 and 2007.

 

32. Therefore since the original documents are required under the regulations stated in points 29- 32 and further more since the Civil Procedure Rules clearly set out that Original documents must be made available for inspection in practice direction 32 Para 13.1 I request that the claimant makes available the original agreement between parties for inspection and all other documents that are referred to within the agreement

 

33. If the claimant cannot supply a document signed by the creditor and debtor, easily legible and containing the prescribed terms per schedule 6 column 2 of SI 1983/1553 the agreement cannot be enforced. If the claimant asserts that it can provide proof that the monies have been used by the defendant and therefore even in the absence of the credit agreement the debt should be repaid then I quote the House of Lords in Wilson -v- FCT "lender is intended by Parliament to be left without recourse against the borrower in respect of the loan. That being the consequence intended by Parliament, the lender cannot assert at common law that the borrower has been unjustly enriched. That would be inconsistent with the parliamentary intention in rendering the entire agreement unenforceable" this clearly outlines that even if it is the case that the lender has loaned the monies ot the debtor, if he does not comply with the CCA 1974, he cannot seek and equitable remedy and stands to lose the monies loaned

 

34. Further more I refer to Sir Andrew Morritt's judgment in Wilson and FCT [2001] EWCA Civ 633 in the Court of Appeal at Para 26

 

In effect, the creditor--by failing to ensure that he obtained a document signed by the debtor which contained all the prescribed terms--must (in the light of the provisions in ss 65(1) and 127(3) of the 1974 Act) be taken to have made a voluntary disposition, or gift, of the loan moneys to the debtor. The creditor had chosen to part with the moneys in circumstances in which it was never entitled to have them repaid;

 

35. The claimant has in the defendants opinion failed to conduct themselves in accordance with the Civil Procedure Rules insofar that they failed to issue a letter before action compliant with the CPR preaction protocols which state

 

4.3

The claimant's letter should -

(a)

give sufficient concise details to enable the recipient to understand and investigate the claim without extensive further information;

 

(b)

enclose copies of the essential documents which the claimant relies on;

 

©

ask for a prompt acknowledgement of the letter, followed by a full written response within a reasonable stated period;

 

(For many claims, a normal reasonable period for a full response may be one month.)

 

(d)

state whether court proceedings will be issued if the full response is not received within the stated period;

 

(e)

identify and ask for copies of any essential documents, not in his possession, which the claimant wishes to see;

 

(f)

state (if this is so) that the claimant wishes to enter into mediation or another alternative method of dispute resolution; and

 

(g)

draw attention to the court's powers to impose sanctions for failure to comply with this practice direction and, if the recipient is likely to be unrepresented, enclose a copy of this practice direction.

 

36. the claimants letter purporting to be a letter before action is attached marked LL X

 

 

37. Without Disclosure of the relevant requested documentation I am unable to asses if I am indeed liable to the claimant, nor am I able to asses if the alleged agreement is properly executed, contain the required prescribed terms, or correct figures to make such an agreement enforceable by virtue of s127 Consumer Credit Act 1974

 

38. In view of the matters pleaded above, I respectfully request that the court gives consideration to whether the claimant's statement of case should be struck out as disclosing no reasonable grounds for bringing the claim, and/or that it fails to comply with CPR Part 16 and Practice Direction 16.

 

39. Additionally since the claimant has failed to discharge its obligations under Section 78(1) Consumer Credit Act 1974 as stated this defence, it is requested that the claimant case be struck out pursuant to section 78(6) Consumer Credit Act 1974

 

40. Alternatively if the court decides not to strike out the claimants case, it is requested that the court orders full disclosure of the requested documents pursuant to the Civil Procedure Rules

 

41. Having instigated these proceedings without any legal basis for doing so, having failed to provide sufficient information required under the pre-trial protocols in order to investigate this claim, or indeed to provide a reasonable time period to investigate this matter, and having failed to investigate a dispute as required by the OFT Debt collection Guidelines I believe the Claimant's conduct amounts to unlawful harassment under section 40 of The Administration of Justice Act1970. Furthermore, the Claimant's behaviour is entirely vexatious and wholly unreasonable.

 

 

42. I respectfully ask the permission of the court to amend this defence if / when the claimant provides full disclosure of the requested documents and allows inspection of the original documents

 

43. Should the issue of the repeal of section 127(3) be brought before the court, it is drawn to the courts attention that schedule 3 of Consumer credit Act 2006 prevents section 15 of the CCA 2006 from having effect on agreements made before 6th April 2007 such as this one

 

for the attention of the court I reproduce schedule 3 section 11

 

11

The repeal by this Act of-

(a) The words "(subject to subsections (3) and (4))" in subsection (1) of section 127 of the 1974 Act,

(b) Subsections (3) to (5) of that section, and

© The words "or 127(3)" in subsection (3) of section 185 of that Act, has no effect in relation to improperly-executed agreements made before the commencement of section 15 of this Act.

 

 

:

 

 

 

 

 

 

Statement of Truth

 

 

I XXXXXXXX, believe the above statement to be true and factual

 

 

Signed .....................

 

Date

 

 

 

 

have a browse over that and see what you think where i have mark LL X that requires you to sub your own initials and also number the documents accordingly

[lottery-loser]

Phew! That's a letter and a half! I've given a 1st reading but will re-do this. My initial question is:-

 

Re 15 & 16 If the CPR was that which i requested on 3rd March they have not acknowledged my letter. I've heard nothing since their last letter (day b4 court action).

 

 

Thank you very much so far! I'll respond further either later or tomorrow. Pity there aren't more decent solicitors-to-be out here!

[pt2537]

16. To Date the claimant has failed to accede to my request under the CPR and I have not received any such documentation requested. As a result it has proven difficult to compose this defence without disclosure of the information requested.

 

 

 

in that case sub it with this

 

simply if they didnt reply then remove the line that says

 

 

The claimant did acknowledge my letter but that is all

[lottery-loser]

Had a 2nd reading - it's starting to make more sense!

 

I assume the 1st line "I, LL of xxxxxxxx" = town where living?

 

The numbering seems a bit haywire. is this cos you've C&P from elsewhere and i should re-number appropriately? Sorry if this seems rhetorical - there might be method behind the madness for all I know!

 

point 6 Stat request

states "proof of delivery". Not available except that their eventual reply means they received it!

 

At point 10 I have added the date to make it clearer and point out that it took exactly FOUR MONTHS to send this useless piece of paper!

 

I think that's the lot! Let's hope it works and I can settle the blasted thing in a civil manner...

 

Thanks very much Paul. Sleep tight!!

[lottery-loser]

PS point 15 - is the blank date the October request (CCA?) or the March request (CPR?) or both?