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Skeleton argument/Paginated bundle-2wks until trial to stop LL suing us for £10k

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Hi,

 

Have been on here before, but a rough outline of our case is...

- deposit wasn't protected as exceeds £25k threshold

- LL wants to keep our £3150 deposit and has requested an additional £7k in damages to replace the wood floor, rectify damp problem, repaint walls etc. Essentially refurbish his house

- there was no inventory when we moved in

- House left in excellent condition, extensive photographic evidence etc. We found adverts that the LL had posted advertising the house for immediate let, which proves he had no intention of using our deposit for anything (copies of this submitted as evidence)

- LL has consistently lied and witheld evidence throughout the process

-Case allocated to fast track and the trial is in two weeks :(

 

Sooooo, we're all getting very anxious about the upcoming trial. Does anyone have any advice/examples for forming a good skeleton argument. Also, can anyone clarify the paginated bundle??

We really deserve to win this case, but it's all very scary. Any advice/views would be great!

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See the final page on the document on the pdf link below. Although the particular example refers to the pagination of an Appeal Bundle, the same principle applies.

 

http://www.hmcourts-service.gov.uk/courtfinder/forms/204_0709_e.pdf

 

1) Basically you'll have an index at the front, with other documents throughout. Stick everything in an A4 Lever Arch File if you can, hole punch the pages, don't use plastic sleeves.

 

2)Once all your documents are in place, with a black pen start at the front and in the bottom right hand corner number each page in sequence from start to finish.. If you can afford an automatic number sequence / stamp then that makes life easier - unfortunately they cost about £40 - £60 I think.

 

3) Next update your index. Example index with instructions is here (Click on the Appeal Bundle Index link):-

 

http://www.consumeractiongroup.co.uk/forum/legal-issues/191784-shakespeare62-nastybank-10.html#post2571639

 

4) Example skeleton Argument structure is here :-

 

http://www.consumeractiongroup.co.uk/forum/legal-issues/191784-shakespeare62-nastybank-12.html#post2596735

The content you will need to change, but the principle is there. There may be better examples floating around - I'm just trying to help.

 

Good luck.

Edited by shakespeare62
edited to correct link to example Appeal Bundle index

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Note: you can also insert subject dividers (u know those multi-coloured cardboard with index tabs sticking out). This way you can split up a large bundle quickly for easy refererence. E.g label each tab e.g. p1 - 10, p 45 - 60 etc. as appropriate - make it tie in with your index.

 

So if you have a 200 page bundle for example, the judge doesn't through load of pages to get to page 142 ...he can go directly to the nearest divider section in the file .....

Edited by shakespeare62

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You're welcome. I've added an extra link in my post #2 above.

 

You'll see from the Appeal Bundle Index I linked to, that it lists all the documents I need ..including my Skeleton Argument starting at page 156.

 

Although my skeleton document has its own page numbers, It will also have numbers starting at 156 on the bottom right corner - because thats its location in the bundle.

 

Hope this makes sense. Remember to ask for help if you're not sure on anything.

Edited by shakespeare62

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fab, thanks. quick question, i've seen another example where you need to start from the beginning rather than start from the end/most recent doc. what do you suggest?

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fab, thanks. quick question, i've seen another example where you need to start from the beginning rather than start from the end/most recent doc. what do you suggest?

 

Sure - that's logical. For appeals, you're allowed to file the Skeleton argument 14 days after you file your Notice of Appeal,Grounds of Appeal & Appeal Bundle. For this reason I left room in my index at the end, for my Skeleton argument, as I didn't actually know how long it would be until it was completed. This way my skeleton could subsequently be inserted into the Appeal Bundle I had filed, without interfering with the index page numbers.

 

In general, I believe the documents in a bundle should be in chronological order.

Edited by shakespeare62

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How do you prepare a very good RCJ Bundle with skeletal argument, index , in a clear manner so that the Judge has no doubts

thak very much

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How do you prepare a very good RCJ Bundle with skeletal argument, index , in a clear manner so that the Judge has no doubts

thak very much

 

Read this thread??

 

By the way Lia - take an extra copy with you, just in case Judge does not have one....


Kentish Lass

Information given is based on my knowledge and experience and is not to be considered as legal advice

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