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Robinson Way And My Part 31.16

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I made a Part 31.16 to Robinson Way and all that they have sent is an application form.

The Application form is in relation to Capital One; totally unenforceable, I was sent this 18 months ago.


My Part 31.16 requested many documents and they just send One!




Next step?



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For the avoidance of doubt, this is the letter that was sent to Horwich Farrelly/Robinson Way:



"Horwich Farrelly Solicitors

London Scottish House

Quays Reach

Carolina Way


M50 2ZY



CPR Part 31.16


Dear Sirs,




On 28 August 2008, I wrote to your client’s organisation requesting that they supply me a copy of the alleged agreement for my account. My request extended to the full agreement which bore my signature and any other document referred to in it. I enclose a copy of the letter(s) which were sent for your information.


I note that to date, I have still not been provided with all the documents that I require. In view of the circumstances, I do not feel it unreasonable to ask for the documents again


Therefore, I request that you ask your client to provide me with a copy of the contract which bears my signature; I require the complete document with all its parts, including the inception Terms and Conditions and Payment Protection Insurance policy, together with the original Terms and Conditions of that insurance policy, at the time it was entered into.

Additionally I require:


• The underwriting sheet or other document showing any commissions paid by the broker.

• A transcript of ALL transactions, including charges, fees, interest, repayments and payments and both the original credit limit and any repayments made to it, the account.

• Transcriptions of ALL telephone conversations recorded and notes made in relation to telephone conversations.

• Where there has been any adverse event in the account’s history over the period from conception of the account which has required manual intervention by any person (whether they be permanent staff, or temporary staff), I require disclosure of any indication, or notes which would have caused, or resulted in that manual intervention, or other evidence of that manual intervention.

• True copies of any notice of assignment and/or default notice, or enforcement notice that your client or the original creditor sent me, with a copy of any proof of postage that is held.

• Documents relating to any insurance added to the account, including the insurance contract, policy and terms and conditions and the original signatory document.

• Specific details of the fees/charges levied and what each charge relates to and on what date the fees/charges were levied

• A genuine certified copy of the alleged deed of assignment, or documentary evidence proving that your client has the legal right to collect this alleged debt.

• Genuine copies of any notice of fair use of my data by yourself and/or your client, as required by the Data Protection Act 1998

• A list of all third parties to which you and your client have disclosed my personal data and a summary of the nature of the information you have disclosed.

• Bill of Sale and all relevant documents relating to the Sale’ rights and responsibilities.

• A copy of the terms and conditions of sale which were prevalent at the date of the alleged sale.

• Copies of the form of authorisation of the person who conducted the sale and his/her authorised signatory.

• A true and ‘notarised’ document proving that the account has not been securitised.

• A true copy of your client’s Consumer Credit Licence.

• A true copy of your Data Protection Licence and that of your client.

• A true copy of your complaints procedure and that of your client.

• A true copy of your client’s ACOPS.


Emphasis; this request is NOT made pursuant to Section 78 of the Consumer Credit Act 1974, but it is made pursuant to the Civil Procedure Rules (Pre-Action protocols and Part 31.16).


I do not view this as an unreasonable request given that by supplying the documents which I have asked for will allow me to assess the merit of my case and will help to resolve matters, possibly without the need to involve court and will undoubtedly save costs on both sides.


I look forward to your reply and would ask for a response by 4p.m. on 29 June 2009.


Yours faithfully



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