1st credit and Lloyds TSB Platinum credit card

[hunterandthehunted]

right then, i will delete that post and have another crack at it.

coild be a late night again...

 

by the way i already listed all the documents i want to use in court on the AQ...

[citizenB]

You will still need to show them as exhibits attached to your witness statement.

[hunterandthehunted]

could someone have a look at this please and advise. i am beginning to get stressed out a bit as i dont seem to be making progress. i am thinking i could get away with submitting an embarressed defence again as the set aside hearing made by **** is not until february 2010.

it states this at the bottom of the notice of application hearing (n244) that

not less than 3 days before the telephone conferance the parties shall file with the court.

 

a) a case summary, a summary of issues and summary of issues to be dealt with at the hearing, agreed if possible.

b) a draft of any orders or direction sought, and

c) all other documents to be referred to including, where appropiate, any statements by expert witnesses, complying with CPR 35.12 (3) and any statement of costs complying with section 13.5 of the costs practice direction in FORM 260.

 

 

 

On behalf of: Defendant

Witness: [initials and surname]

Number: [1st]

Exhibits: H&H, HH1

Date:

 

IN THE XXXXXXXXXXXXXXX

COUNTY COURT Claim No:

 

 

BETWEEN

[________]

Claimant

and

[________]

Defendant

 

 

 

 

Witness Statement

 

I, Hunter and Hunted of.. CAG Forums will state as follows:

 

1. I make this witness statement in support of my application to have the case submitted by Lloyds TSB bank plc, struck out for failing to comply with the order made by District Judge NAME on DATE

 

2. The matters referred to in this witness statement are within my own knowledge, except where I have indicated otherwise. Where any matters contained in this witness statement are not within my own knowledge, I have stated the source of my information.

 

3. There is now produced and shown to me a bundle of documents marked "H&H" The exhibit H&H contains copies of the documents to which I will refer in this witness statement. Their related document number can be found at the bottom right hand of each page.

4. On the xxxxxxxxx I wrote to Lloyds tsb requesting a true copy of the Credit Agreement pursuant to section 78(1) of the Consumer Credit Act 1974. (Exhibit HH1)

Lloyds tsb replied to my request on the xxxxxxxxxx supplying an Application Form on what appears to be microfische. (Exhibit HH2)

5. The account was opened in june 2002 and closed in early 2003 and the cca provided by Lloyds tsb relates to the account being opened in june 2002.

6/ the account was re-opened in july 2003 and no cca has been provided for this.

 

7. On the 17th may 2009 I sent the claimant a subject access request for transactions and charges and on the 29th june 2009 received statements for the period covering july 2003 to july 2004. (Exhibit HH3)

8. On the 19th july 2009 I sent the claimant a second subject access request pointing out that statements were incomplete.(Exhibit HH4). I received a second set of statements exactly the same as the previous set.

9.on the 31st july 2009 I received a claim form from Lloyds for a debt totalling xxxxxxxxxx.(Exhibit HH5)

10. In the particular of claims, it is referred to as a Lloyds asset card which is incorrect, it referres to clause 7 8 and 9 of the agreement which on the agreement/application provided only goes up to clause 4 .(Exhibit HH6)

11. The particular of claims refers to a default notice which was allegedly issued in September 2006 but the claimant has admitted they do not keep copies and cannot provide one. (Exhibit HH7)

 

12. On the 13th august 2009 a 3rd subject access request was sent to Lloyds tsb asking for specific dates of copy statements, the statements requested were for the period June 2002 to July 2003.(Exhibit HH8 . I received a 3rd set of statements on the 15th September 2009 dated from September 2003 to October 2004 (Exhibit HH9).

13. On the 27th October 2009 district judge xxxxxxxxxx in the xxxxxxxxxx county court ordered that the claim be allocated to fast track and the parties give standard disclosure to all parties by serving copies with a disclosure statement by 4pm by the 13th November 2009 and in particular the claimant shall disclose:- (Exhibit HH10)

a) copies of the credit agreement and any documents referred to within it.

b) default notice

c) statements dated from June 2002 to November 2006

 

The defendant would like to draw to the courts attention to the following matter

 

13. The claimant failed to supply the defendant any documents which the applicant mentioned in their particulars of claim and which were central to the claimants case. The defendant asked for the documents, via a CPR 31.14 request (Exhibit HH11) which were pleaded in the claim on 31 July 2009 but the applicant has failed to supply these documents.

14.Despite repeated requests for key statements for the account the claimant has only provided statements for the period covering July 2003 to October 2004 and has failed to comply with a court order made on the 27th October by district judge xxxxxxxxxx to disclose statements covering the period from June 2002 to November 2006.

The applicant is fully aware that I am a litigant in person and therefore I have been placed at a disadvantage by their failings as I have been unable to compile a fully particularised defence and are deliberately merely trying to frustrate the defendant and hold up preceedings.

 

 

 

Edited November 23, 2009 by hunterandthehunted

[Tonka99]

Hi Hunter

 

Been following you , dont get stressed the morning posters will

check it out for you , sometimes it all gets to much as i know ,

when you have to get something done to a deadline and feel

the pressure to get it right .

 

Help with arrive your doing great

 

All the best

 

Tonks:)

[hunterandthehunted]

Hi Hunter

 

Been following you , dont get stressed the morning posters will

check it out for you , sometimes it all gets to much as i know ,

when you have to get something done to a deadline and feel

the pressure to get it right .

 

Help with arrive your doing great

 

All the best

 

Tonks:)

 

thanks tonks,

i am not sure whether or not the original deadline for witness statement applys because of ****s application to set aside and this is at the foot of the application notice which has confused me somewhat..

 

not less than 3 days before the telephone conferance the parties shall file with the court.

 

a) a case summary, a summary of issues and summary of issues to be dealt with at the hearing, agreed if possible.

b) a draft of any orders or direction sought, and

c) all other documents to be referred to including, where appropiate, any statements by expert witnesses, complying with CPR 35.12 (3) and any statement of costs complying with section 13.5 of the costs practice direction in FORM 260.

 

i have just had a lengthy chat with the court who has explained to me that an application to have the case struck out would cost £75 with or without a hearing because the other party involved have'nt consented.

 

i also asked if the directions from 27th october still applied in light of the claimants application to have part of the directions set aside.

i was told yes it would still apply and confirmed that the claimant has not filed any of the directions.

 

it was confirmed to me that witness statements have to be filed by 4pm this friday.

i explained that i am struggling to get a witness statement together because of the criteria the claimant has failed to file.

 

it was then explained to me that i dont have to apply for a strike out and that i could write a letter to the judge explaining my prediciment and it would save me £75.

 

thanks

could someone advise please as i think the letter could be the answer? or not? . i have posted some sort of WS in post 370

thanks in advance

[kel123]

H&H

 

I tried just writing in and the court wrote back saying It has been put before a DJ and he has said put it on the correct form and pay the fee and then it will be consideered - I never did, and I think I missed an opportunity

 

kel

[Craftygirl42]

My court did tell me to write in the first instance and then the DJ may ask me to put it on the proper form and pay the fee. So it may be an option. Its totally up to you, thats what the court lady said to me

[hunterandthehunted]

H&H

 

I tried just writing in and the court wrote back saying It has been put before a DJ and he has said put it on the correct form and pay the fee and then it will be consideered - I never did, and I think I missed an opportunity

 

kel

 

thanks kel,

i was thinking that i would have to use the form and pay the fee.

trouble is it wont make it in front of the judge before fridays deadline to

submit the WS and my WS needs looking at as i not happy with it as things stand

[vjohn82]

thanks kel,

i was thinking that i would have to use the form and pay the fee.

trouble is it wont make it in front of the judge before fridays deadline to

submit the WS and my WS needs looking at as i not happy with it as things stand

 

Hi,

 

We can help with the WS but you need to try and get thus order.

 

I will try and read as much of your thread as possible and then offer my tuppence worth.

 

I think writing a letter could be one way of doing it... but I believe this would be addressed to the case manager. If the Claimant is not following procedure then this will get up the DJ's nose.

 

That said the very least that could happen is you could write up your WS and request within it to revise if the Claimant complies with the Draft Order... you could also attach a letter to this WS stating that you are in detriment based upon the lack of co-operation on the part of the Claimant.

 

Let me have a look through... just before I start have you posted your WS/Defence etc here?

 

Right read through the WS...

 

In the PoC did they include any documents with it such as a credit agreement/default etc?

 

This is what I have come up with so far... others may also want to have an input... I cannot take credit for this really because it has been gathered from a wealth of knowledge gained from other members of this forum over time. I have simply put in comments which have been sucessful (for me) in grabbing a DJ's attention and for placing the burden of proof on the Claimant.

 

 

Witness Statement

 

1.I, hunterandthehunted of CAG Forums, am the defendant in this action and make the following statement in reference to the claim made by Lloyds TSB as required in the Court’s Order of [insert date].

 

2.I make this witness statement in support of my application to have the case submitted by Lloyds TSB bank plc, struck out for failing to comply with the order made by District Judge NAME on DATE.

 

3.Except where otherwise mentioned I neither admit nor deny any allegation made in the Claimant’s Particulars of Claim and put the Claimant to strict proof thereof.

 

4.The matters referred to in this witness statement are within my own knowledge, except where I have indicated otherwise. Where any matters contained in this witness statement are not within my own knowledge, I have stated the source of my information.

 

5.All of the exhibits referred to are from the bundle disclosed to me marked H&H and their related document numbers can be found at the bottom right hand of each page.

 

6.On the xxxxxxxxx I wrote to Lloyds TSB requesting a true copy of the Credit Agreement pursuant to section 78(1) of the Consumer Credit Act 1974 (Exhibit HH1). Lloyds TSB replied to my request on the xxxxxxxxxx supplying an Application Form on what appears to be microfiche. (Exhibit HH2).

 

7.The Defendant admits that they signed a document provided by Lloyds TSB. It is not admitted that the Defendant signed an agreement with Lloyds TSB.

 

8.It is admitted that, in the sense that the Defendant applied for and was given a credit card, that there was an agreement between the Defendant and Lloyds TSB. The Defendant does not admit that such agreement was reduced to writing.

 

9.The precise terms and date of any such agreement are not admitted. The Claimant is put to strict proof as to the date and terms of such agreement and is put to strict proof that a written agreement is in existence. If, which is not admitted, there is a written agreement in existence, it is admitted that such an agreement would be a regulated agreement within the terms of the Consumer Credit Act 1974 (The Act).

 

10.Any such regulated agreement regulated by the Consumer Credit Act 1974 must be signed in the prescribed manner both by the debtor and the creditor or owner, embody all the terms of the agreement, and be in such a state that all its terms are readily legible when presented for signature.

 

11.Under S61 of the Act, any agreement regulated by the Act, must contain certain Prescribed Terms under regulations made by the Secretary of State under S 60(1). These Prescribed Terms are contained in schedule 6 column 2 of the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) and are terms stating the credit limit, the rate of interest; and repayment terms.

 

12.The prescribed terms must be within the agreement and not in a separate document for it to be compliant with s60 (1). [Wilson and another v Hurstanger Ltd [2007] EWCA Civ 299]. Further, if the agreement does not contain these terms in the prescribed manner and does not comply with s60(1), it is improperly executed and only enforceable by court order [Wilson v First County Trust Ltd - [2003] All ER (D) 187 (Jul)].

 

13.Further, the Consumer Credit (Cancellation Notices and Copies of Documents) Regulations 1983 SI No. 1557 requires that the lettering in every copy of an executed agreement be easily legible. It is denied that the ‘Agreement’ Exhibit HH2 produced by the Claimant is an agreement within the terms of the Act.

 

14.The document states clearly that it is an Application Form. The Defendant asserts that most of the document is not easily legible and does not appear to contain the prescribed terms.

 

15.The Defendant would like to point out to the Court that the particular account the Claimant has produced an application for was opened in June 2002 and closed in early 2003. No credit agreement for any account has been supplied to the Defendant and the Claimant is put to strict proof that such a document exists.

 

16.On the 17 May 2009 I sent the Claimant a Subject Access Request, under the Data Protection Act 1998, for a list of transactions and charges. On the 29 June 2009 I received statements for the period covering July 2003 to July 2004 (Exhibit HH3).

 

17.On the 19 July 2009 I sent the Claimant a second Subject Access Request pointing out that statements were incomplete (Exhibit HH4). I received a second set of statements exactly the same as the previous set.

 

18.On the 13 August 2009 a third Subject Access Request was sent to Lloyds TSB asking for specific statements dated for the period June 2002 to July 2003 (Exhibit HH8) . I received a third set of statements on the 15 September 2009 dated from September 2003 to October 2004 (Exhibit HH9).

 

19.On the 31 July 2009 I received a Claim Form from Lloyds TSB for a debt totalling xxxxxxxxxx (Exhibit HH5). In the Particulars of Claim, it is referred to as a Lloyds Asset card and refers to clause 7, 8 and 9 of the agreement. However the document provided by the Claimant, Exhibit HH2, does not include clauses 7, 8 and 9 (Exhibit HH6) and therefore the Claimant is put to strict proof of how these documents are in anyway linked.

 

20.The Particulars of Claim refers to a Default Notice which was allegedly issued in September 2006 but the claimant has already admitted they do not keep copies and cannot provide one (Exhibit HH7).

 

21.A default notice is a required by S 87(1) of the Act before a creditor can become entitled to take any action in respect of a regulated credit agreement. Furthermore s 88(1) of the Act requires that a default notice must be in the prescribed form. The prescribed format for a default notice is laid down in Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) and Amendment regulations the Consumer Credit (Enforcement, Default and Termination Notices) (Amendment) Regulations 2004 (SI 2004/3237).

 

22.By Regulation 2(2) of these regulations, any Default Notice must include both a description of the agreement sufficient to identify it and the name and a postal address of the creditor or owner.

 

23.By s.7 of the Interpretation Act 1978, a posted document is deemed to have been served at the time when it would be delivered in the ordinary course of post.

 

24.The Claimant therefore is put to strict proof that the Default Notice was served properly under the requirements prescribed to lawfully terminate the account in question. It is respectfully asserted that if such a document was not served then the Claimant's actions could be considered vexatious.

 

25.On the 27th October 2009 district judge xxxxxxxxxx in the xxxxxxxxxx county court ordered that the claim be allocated to fast track and the parties give standard disclosure to all parties by serving copies with a disclosure statement by 4pm by the 13th November 2009 and in particular the claimant shall disclose (Exhibit HH10)

 

a) copies of the credit agreement and any documents referred to within it.

b) default notice

c) statements dated from June 2002 to November 2006

 

26.The Defendant would like to draw to the courts attention to the following matter. The Claimant has failed to supply the Defendant any documents mentioned in their Particulars of claim and which are of central importance to the Claimant’s case. The Defendant asked for the documents via a CPR 31.14 request (Exhibit HH11) which were pleaded in the claim on 31 July 2009 but the Claimant has failed to supply these documents.

27.Despite repeated requests for key statements for the account the Claimant has only provided statements for the period covering July 2003 to October 2004 and has failed to comply with a court order made on the 27th October by District Judge xxxxxxxxxx to disclose statements covering the period from June 2002 to November 2006.

 

28.The Claimant is fully aware that I am a litigant in person and therefore I have been placed at a disadvantage by their failings. I have been unable to compile a fully particularised defence to this action and therefore do not know what exact case I have to meet.

AND the Defendant

29.Seeks an order that the Claimant’s action is struck out or otherwise is dismissed on the grounds that any claim cannot succeed and that the Claimant do pay the Defendant’s costs.

 

 

 

[hunterandthehunted]

Right read through the WS...

 

In the PoC did they include any documents with it such as a credit agreement/default etc?

 

hello vjohn,

nice of you to drop in, as you can tell i am in a bit of a tiz with this.

 

what an idiot i am ..... back in a mo

Edited November 23, 2009 by hunterandthehunted

[vjohn82]

hello vjohn,

nice of you to drop in, as you can tell i am in a bit of a tiz with this

but to answer your question no they did not.

 

i sent a cpr 31.14 request which they sent me another copy of the application/agreement but iformed me that they not keep copys of

the default notice. the agreement is in post 1

 

see revised WS above

[hunterandthehunted]

thanks vjohn,

 

i will have a read of WS right away.

i think i misunderstood your other question regarding POC.

here is the POC...

 

1/ by agreement in writing and regulated by the consumer credit act 1974, the claiments issued to the defendant a credit-token, lloyds asset card, for the purpose of the defendant acquiring goods/services on credit.

2/ cluase 7 of the agreement provided that the claiments would furnish the defendant with a monthly statement showing the balance currently due, the minimum payment to be made and the the date for payment. if the balance was not paid, then provided the defendant made the minimum payment on or before such date, the remainder of the balance should remain outstanding and the defendant should pay interest upon it each month in accordance with clauses 8 and 9 of the agreement.

3/ in breach of the agreement, the defendant failed to make payment and on **/**/06 the claiments issued a default notice pursuant to section 87 (i) of the consumer credit act 1974.

4/ on the **/**/06 the claiments did issue a formal demand to the defendant.

5/ the claiments therfore claim the balance due under the agreement £****

signed or rather printed m f thomas

[vjohn82]

thanks vjohn,

 

i will have a read of WS right away.

i think i misunderstood your other question regarding POC.

here is the POC...

 

1/ by agreement in writing and regulated by the consumer credit act 1974, the claiments issued to the defendant a credit-token, lloyds asset card, for the purpose of the defendant acquiring goods/services on credit.

2/ cluase 7 of the agreement provided that the claiments would furnish the defendant with a monthly statement showing the balance currently due, the minimum payment to be made and the the date for payment. if the balance was not paid, then provided the defendant made the minimum payment on or before such date, the remainder of the balance should remain outstanding and the defendant should pay interest upon it each month in accordance with clauses 8 and 9 of the agreement.

3/ in breach of the agreement, the defendant failed to make payment and on **/**/06 the claiments issued a default notice pursuant to section 87 (i) of the consumer credit act 1974.

4/ on the **/**/06 the claiments did issue a formal demand to the defendant.

 

Ok... just add a part to the WS somewhere after the Default Notice part and put the Claimant to strict proof of this document

 

5/ the claiments therfore claim the balance due under the agreement £****

signed or rather printed m f thomas

 

We have covered the other points I think?

[hunterandthehunted]

a question regarding exhibits.

 

is H&H the file or bundle and HH1 HH2 etc... the documents refered to

within it?

[vjohn82]

a question regarding exhibits.

 

is H&H the file or bundle and HH1 HH2 etc... the documents refered to

within it?

 

Errr... well I tried to copy the bits in your WS...

 

But I was assuming that HH1 etc were the exhibits and the H&H was the actual bundle they appeared in???

[hunterandthehunted]

Errr... well I tried to copy the bits in your WS...

 

But I was assuming that HH1 etc were the exhibits and the H&H was the actual bundle they appeared in???

 

yeah thats what i meant citizen gave me the first 3 paragraghes as an example, obviously i new each documant had to be given a exhibit no:

 

just wondered what the bundle was but i think you just answered.

thanks

[the_shadow]

HH,

 

Letters to the court do sometimes work, its a judgment call I'm afraid... the fact the court has suggested it might mean something but there are no guarantees the judge will look at it save applying on an N244.

 

S.

[vjohn82]

HH,

 

Letters to the court do sometimes work, its a judgment call I'm afraid... the fact the court has suggested it might mean something but there are no guarantees the judge will look at it save applying on an N244.

 

S.

 

Exactly... that's why it's called a judge lottery hunter. Only you know the judge you had... BUT as I always say... they can always say no! At least you have asked

[hunterandthehunted]

Exactly... that's why it's called a judge lottery hunter. Only you know the judge you had... BUT as I always say... they can always say no! At least you have asked

 

what kind of thing would i be saying in the letter?

the same as the n244 application.

 

I WISH TO APPLY THAT THIS CASE BE STRUCK OUT AS THE CLAIMANT HAS FAILED TO COMPLY WITH THE DIRECTIONS MADE BY DISTRICT JUDGE ************ ON THE 26TH OCTOBER.

 

and is this ok for the evidence

 

1/ ON THE 26TH OCTOBER 2009 DISTRICT JUDGE ********* MADE AN ORDER ALLOCATING THIS CLAIM TO FAST TRACK.

2/ WITHIN THIS ORDER IT WAS ORDERED THAT THE PARTIES GIVE STANDARD DISCLOSURE TO ALL PARTIES BY SERVING COPIES WITH A DISCLOSURE STATEMENT BY 4PM ON 13 NOVEMBER 2009.

3/ WITHIN THIS ORDER AT 2 (A) IT IS ORDERED THAT THE CLAIMANT DISCLOSES COPIES OF THE CREDIT AGREEMENT ALONG WITH ANY DOCUMENTS REFERRED TO WITHIN IT.

4/ WITHIN THIS ORDER AT 2 © IT IS ORDERED THAT THE CLAIMANT DISCLOSES STATEMENTS DATED FROM JUNE 2002 TO NOVEMBER 2006.

5/ THE CLAIMANT HAS APPLIED FOR SET ASIDE ON SECTION 2 (B)

6/IT IS BELIEVED THAT THE CLAIMANT IS MERELY TRYING TO FRUSTRATE THE DEFENDANT AND TO HOLD UP PROCEEDINGS.

[vjohn82]

what kind of thing would i be saying in the letter?

the same as the n244 application.

 

I WISH TO APPLY THAT THIS CASE BE STRUCK OUT AS THE CLAIMANT HAS FAILED TO COMPLY WITH THE DIRECTIONS MADE BY DISTRICT JUDGE ************ ON THE 26TH OCTOBER.

 

and is this ok for the evidence

 

1/ ON THE 26TH OCTOBER 2009 DISTRICT JUDGE ********* MADE AN ORDER ALLOCATING THIS CLAIM TO FAST TRACK.

2/ WITHIN THIS ORDER IT WAS ORDERED THAT THE PARTIES GIVE STANDARD DISCLOSURE TO ALL PARTIES BY SERVING COPIES WITH A DISCLOSURE STATEMENT BY 4PM ON 13 NOVEMBER 2009.

3/ WITHIN THIS ORDER AT 2 (A) IT IS ORDERED THAT THE CLAIMANT DISCLOSES COPIES OF THE CREDIT AGREEMENT ALONG WITH ANY DOCUMENTS REFERRED TO WITHIN IT.

4/ WITHIN THIS ORDER AT 2 © IT IS ORDERED THAT THE CLAIMANT DISCLOSES STATEMENTS DATED FROM JUNE 2002 TO NOVEMBER 2006.

5/ THE CLAIMANT HAS APPLIED FOR SET ASIDE ON SECTION 2 (B)

6/IT IS AVERRED THAT THE CLAIMANT IS PLACING THE DEFENDANT AT A SIGNIFICANT DISADVANTAGE IN THESE PROCEEDINGS AND IT IS ARGUED THAT THE CLAIMANT HAS NOT PROVED SUFFICIENTLY THAT THE DEFENDANT HAS A CASE TO ANSWER

7/ I THEREFORE RESPECTFULLY REQUEST THE COURT TO EITHER MAKE AN "UNLESS" ORDER TO OFFER THE CLAIMANT ONE MORE OPPORTUNITY TO PROVIDE THE PAPERWORK AS DIRECTED OR STRIKE OUT THE CASE UNDER CIVIL PROCEDURE RULE 3.4 WHICH STATES:

(2)The court may strike out a statement of case if it appears to the court –

(a) that the statement of case discloses no reasonable grounds for bringing or defending the claim;

 

(b) that the statement of case is an abuse of the court’s process or is otherwise likely to obstruct the just disposal of the proceedings; or

 

© that there has been a failure to comply with a rule, practice direction or court order.

8/ I BELIEVE THE STATEMENT ABOVE TO BE TRUE AND FACTUAL AND TO THE BEST OF MY KNOWLEDGE.

 

 

Amendments in red... upto you if you include/amend your letter but I would be inclined to keep the judge sweet and show you are being reasonable

[hunterandthehunted]

thanks vjohn,

now i am tempted wait until next monday before i send the letter as i am

anticapating that **** dont bother submitting a WS by fridays deadline.

so i get 2 for the price of 1 (so to speak)

[vjohn82]

thanks vjohn,

now i am tempted wait until next monday before i send the letter as i am

anticapating that **** dont bother submitting a WS by fridays deadline.

so i get 2 for the price of 1 (so to speak)

 

I would say strike while the iron is hot... you can apply for a wasted costs order then.

 

The reason I say this is because they can still approach the judge, and disclose to you, the necessary documentation even if it is late. It's better to clarify it now with the judge that they are frustrating proceedings and this will mark their card so to speak.

 

IF they fail to provide the WS on Friday you can call up the Case Manager around 16:05 on the Friday and then request it over the phone or fax in the request to strike out.

[citizenB]

thanks vjohn,

now i am tempted wait until next monday before i send the letter as i am

anticapating that **** dont bother submitting a WS by fridays deadline.

so i get 2 for the price of 1 (so to speak)

 

 

Sadly, DJs are giving the likes of **** more time to produce their WS so dont assume that the case will be struck out if they dont submit on time:(

[Craftygirl42]

Keeping an eye in the hope your witness statement will help me when I come to do mine in a week or so.

 

Keep going Hunter, you are getting there

[hunterandthehunted]

Keeping an eye in the hope your witness statement will help me when I come to do mine in a week or so.

 

Keep going Hunter, you are getting there

 

 

thanks CG,

 

looking forward to printing all the docs:(

 

by the way all,

does "statements by all witnesses of fact shall be exchanged simultaneously by 4pm on 27/11/09"

mean i have to send **** a bundle??????????????

 

all so simultaneously means "at the same time doesnt it" so does this mean **** will be there

to greet me??????????????????