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    • I've inserted their poc re:your.. 1 ..they did send 2 paploc's  3. neither the agreement nor default is mentioned in their 2.        
    • Hi Guys, i read a fair few threads and saw a lot of similar templates being used. i liked this one below and although i could elaborate on certain things (they ignored my CCA and sent 2 PAPs etc etc) , am i right in that at this stage keep it short? If thats the case i cant see what i need to add/change about this one   1)   the defendant entered into a consumer credit act 1974 regulated agreements vanquis under account reference xxxxxxx 2)   The defendant failed to maintain the required payment, arrears began to accrue 3)   The agreement was later assigned to the claimant on 29 September 2017 and notice given to the defendant 4)   Despite repeated requests for payment, the sum of 2247.91 remains due outstanding And the claimant claims a)The said sum of £2247.91 b)The interest pursuant to S 69 county courts act 1984 at the rate of 8% per annum from the date of issue, accruing at a daily rate of £xxxx, but limited to one year,  being £xxxx c)Costs   Defence:   The Defendant contends that the particulars of claim vague and are generic in nature. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made.   1. The Claimant has not complied with paragraph 3 of the PAPDC ( Pre Action Protocol) Failed to serve a letter of claim pre claim pursuant to PAPDC changes of the 1st October 2017.It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC.   2. The Claimant claims £2247.91 is owed under a regulated consumer credit account under reference xxxxxxx. I do not recall the precise details or agreement and have sought verification from the claimant and the claimants solicitor by way of a CPR 31.14 and section 78 request who are yet to fully comply.   3. Paragraph 2 is denied. I am unable to recall the precise details of the alleged agreement or any default notice served in breach of any defaulted payments. 4. Paragraph 3 is denied.The Defendant contends that no notice of assignment pursuant to s.136 of the Law of Property Act & s.82 A of the CCA1974 has ever been served by the Claimant as alleged or at all.   5. It is therefore denied with regards to the Defendant owing any monies to the Claimant, the Claimant has failed to provide any evidence of assignment/balance/breach requested by CPR 31. 14, therefore the Claimant is put to strict proof to:   (a) show how the Defendant has entered into an agreement; and (b) show and evidence any cause of action and service of a Default Notice or termination notice; and © show how the Defendant has reached the amount claimed for; and (d) show how the Claimant has the legal right, either under statute or equity to issue a claim;   6. After receiving this claim I requested by way of a CPR 31.14 request and a section 78 request for copies of any documents referred to within the Claimants' particulars to establish what the claim is for. To date they have failed to comply to my CPR 31.14 request and also my section 78 request and remain in default with regards to this request.   7. As per Civil Procedure Rule 16.5(4), it is expected that the Claimant prove the allegation that the money is owed.   8. On the alternative, as the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974.   9. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.  
    • i understand. Just be aware I am prepared to take some risks 😉
    • Thanks Tnook,   Bear with us while we discuss this behind the scenes - we want you to win just as much as you do but we want to find the right balance between maximising your claim without risking too much in court fees, and in possible court costs awarded to the defendant bank.
    • Tell your son and think on this. He can pay the £160  and have no further worries from them. If he read POFA  Scedule 4 he would find out that if he went to Court and lost which is unlikely on two counts at least [1] they don't do Court and 2] they know they would lose in Court] the most he would be liable to pay them is £100 or whatever the amount on the sign says. He is not liable for the admin charges as that only applies to the driver-perhaps.If he kept his nerve, he would find out that he does not owe them a penny and that applies to the driver as well. But we do need to see the signage at the entrance to the car park and around the car park as well as any T&Cs on the payment meter if there is one. He alone has to work out whether it is worth taking a few photographs to help avoid paying a single penny to these crooks as well as receiving letters threatening him with Court , bailiffs  etc trying to scare him into paying money he does not owe. They know they cannot take him to Court. They know he does not owe them a penny. But they are hoping he does not know so he pays them. If he does decide to pay, tell him to wait as eventually as a last throw of the dice they play Mister Nice Guy and offer a reduction. Great. Whatever he pays them it will be far more than he owes as their original PCN is worthless. Read other threads where our members have been ticketed for not having a permit. [We know so little about the situation that we do not know if he has a permit and forgot to display it. ]
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hilaryfrances

Now official Im a celebrity is over, nominations please for replacements

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:D Let me start with my boss`s son, he is a very pompous little Pr*** and I hate him. I would love to be able to send him to the jungle to eat worms

 

:D:D

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Hmm. Lets see. I'd like to see the baby machine that liveth next door and the feral sprogs she keeps producing. They could keep the bug population down and actually be usefull to society.


Mungy Pup

 

I want to live in a world where chickens are free to cross the road without their intentions being questioned. :razz:

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I think the royal family will be a good choice. I can keep an eye on things at Bucky Palace while they are away.;)


 

 

If all else fails, kick them where it hurts and SOD'EM;)

 

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Katie Price yet again and let's get her to do all the trials but ban her from mentioning "the press" and/or Peter Andre :D

Now that would be torture :D


.

FSA Waiver on Bank Charges:http://www.fsa.gov.uk/pages/Doing/Regulated/Notify/Waiver/pdf/dir_quart_0709.pdf

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Jedward . . . . That'll make men of that pair. .


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5 posts an no Angela Knight? You caggers are slipping!


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5 posts an no Angela Knight? You caggers are slipping!

 

 

 

 

We don't think that is fair on the Australian environment:(.


 

 

If all else fails, kick them where it hurts and SOD'EM;)

 

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Ahh... I forgot about their strict rules on importing pond life


If in doubt, contact a qualified insured legal professional (or my wife... she knows EVERYTHING)

 

Or send a cheque or postal order payable to Reclaim the Right Ltd.

to

923 Finchley Road London NW11 7PE

 

 

Click here if you fancy an email address that shows you mean business! (only £6 and that will really help CAG)

 

If you can't donate, please use the Internet Search boxes on the CAG pages - these will generate a small but regular income for the site

 

Please also consider using the

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I don't follow it, so don't know how many people you need?

 

So, in the interest of having a varied choice:

 

DD's manager who has bullying her for months and when she got signed off with stress, pretended no to have received her sick note so she didn't get paid this month. :mad:

 

Angela Knight, of course.

 

DD's flatmate parents, who think that "discussion" means yelling, swearing and trying to force her into accepting bad terms.

 

Louis Walsh.

 

Nick Griffin.

 

My neighbour's 3 kids from hell, and might as well send her in there too so she can take responsability for their actions for once in her life.

 

Let me know if that's enough, if not don't you worry, I can think of plenty more.

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5 posts an no Angela Knight? You caggers are slipping!

 

That would be very cruel to the other contestants . . . I like it :D


Some useful links.

FAQ's

Making Posts

Letter Template Library

Bank Contact Details

AQ Guide to Completion

Court Fees

Data Protection non Compliance

Witness Statements for Court Bundle

Banking Code Website

Limitations Act

Fast Track Costs

A-Z Index

Mis-Claim Tutorial

Step By Step Instructions

 

Remember: The Ark was built by amateurs-The Titanic by professionals.

 

Please click my scales if you find my advice helpful !

 

If your claim is successful, please donate 5% so that it can continue to help others.

 

Your decisions and actions are your own, and should you be in any doubt, please seek qualified professional legal Help.

 

WARNING TO ALL

Please be aware of acting on advice given by PM .Anyone can make mistakes and if advice is given on the main forum people can see it to correct it ,if given privately then no one can see it to correct it. Please also be aware of giving your personal details to strangers

 

HAVE YOU BEEN TREATED UNFAIRLY BY CREDITORS OR DCA's?

 

YOU CAN NOW COMPLAIN TO THE OFT ABOUT THEIR CONDUCT UNDER THE CONSUMER PROTECTION FROM UNFAIR TRADING REGULATIONS 2008.

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All RBS bankers in line for a bonus...

 

Anyone who is above cashier level in Lloyds TSB...


[sIGPIC][/sIGPIC]

'Simples.' ;)

 

Any advice I offer is probably useless but there may be little nuggets of gold in there somewhere......If I have helped in any way, be it with knowledge or by giving your chuckle muscle some exercise please feel free to tip my scales....:-D

 

 

They say money talks......mine just keeps saying "Goodbye"

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OH or as he is affectionately know Grumpt old goat, he would make Kim look like a slob and i could live happily in my trough

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OH or as he is affectionately know Grumpt old goat, he would make Kim look like a slob and i could live happily in my trough

 

 

Hey I got one of those as well, but he does not clean! Just collects hobbies, maybe he could go there with his blessed model train! Dinning room table now full of model buildings he is making. Including coal shed with real coal, not what a want in my dinning room someone breaking coal into tiny pieces. Apperently it looks "authentic!"

 

 

:cool:

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